Bankruptcy Motion Revision Needed

Summary

The case involves a complex bankruptcy issue with allegations of fraud and unenforceable judgments. The trustees actions, including the sale of a default judgment and the filing of fee applications, raise concerns about transparency and compliance with bankruptcy rules. The dismissal with prejudice of case PC-2019-3655 renders the judgment void and nullifies any associated lien. The defendants seek an audit and clarification of the procedural posture, emphasizing the need for proper service and preparation. The motion requests the court to investigate the trustees actions, provide a detailed accounting, and declare the judgment void due to the dismissed lien.

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The Trustee's actions violate Bankruptcy Rule * and *. The Trustee was aware that * Fountain Street LLC was engaged in ongoing litigation with Mr. Cronan and Ms. Merritt. Despite this knowledge and the long history of the case, the Trustee failed to account for disbursements and proceeded with the sale of judgment under questionable circumstances. This lack of transparency and due diligence breaches the requirements set forth in Bankruptcy Rules * and *, which mandate full disclosure and proper accounting of the estate's transactions. - Detailed Filing: On January *, *, Mr. Cronan and Ms. Merritt filed an extensive and detailed motion to contest the writ of execution and request for emergency stay, presenting clear and convincing evidence that the buyer was not a "good faith purchaser" and that the sale was not in the best interest of the estate. According to Lorraine Horton, a highly respected forensic accountant, CPA, and Certified Fraud

It seems like you're looking to clarify and revise your motion to highlight the Trustee's alleged violations. Here's a streamlined and precise suggestion:
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Revised Motion Statement
The Trustee placed a lien on the court case of James Cronan against James Tierna, Ralph Grieco, and * Fountain Street LLC, the entity to which the Trustee sold the "unenforceable" judgment.

Evidence Supporting Audit Request:
- Receipts and Disbursements: The Trustee's Final Report, dated February *, *, shows receipts of $*,*.* with no accounted disbursements, violating Bankruptcy Rules * and *.
- Sale of Judgment: On October *, *, the Trustee filed a motion for the approval of the sale of judgment. The court approved the sale on November *, *, affirming the buyer as a good faith purchaser and deeming the sale in the estate's best interest.
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Does this align with your requirements, or would you like any additional details?

Examiner (CFE), James Tiernan, as the assignee of * Fountain Street LLC, and Ralph Grieco were involved in fraudulent activities including money laundering, sham transactions, and embezzlement from James Cronan and Classic Display Inc. Consequently, they lacked the legal authority to hold an interest or purchase a default judgment, making their actions void ab initio. The Trustee's actions in selling a contested $*,* default judgment to them for $*,*, despite knowing their involvement in these fraudulent activities, further highlights the need for an audit and transparent accounting. Actions of the Trustee Regarding the Lien on PC-*-*: .- Dismissal with Prejudice: The case PC-*-* was dismissed with prejudice, rendering the judgment unenforceable. According to legal principles, a dismissed case with no monetary award nullifies any lien associated with it. Argument: Enforceability of Judgment and Lien in Dismissed Case

It seems like you need to emphasize the Trustee's misconduct and the fraudulent actions of the involved parties. Here’s a refined version of your motion:
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Revised Motion Statement
The Trustee placed a lien on the court case of James Cronan against James Tiernan, Ralph Grieco, and * Fountain Street LLC, despite their involvement in fraudulent activities. The Trustee's actions in selling a contested $*,* default judgment for $*,*, knowing their fraudulent history, demands an audit and transparent accounting.

Evidence Supporting Audit Request:
- Receipts and Disbursements: The Trustee's Final Report, dated February *, *, shows receipts of $*,*.* with no accounted disbursements, violating Bankruptcy Rules * and *.
- Sale of Judgment: On October *, *, the Trustee filed a motion for the approval of the sale of judgment. The court approved the sale on November *, *, affirming the buyer as a good faith purchaser and deeming the sale in the estate's best interest.
- Dismissal with Prejudice: The case PC-*-* was dismissed with prejudice, rendering the judgment unenforceable. A dismissed case with no monetary award nullifies any associated lien.
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Would you like any further revisions or additional details?

Nature in Rhode Island - Interconnected Nature: In Rhode Island, a judgment and its corresponding lien are interconnected. Once a judgment is used to create a lien, and the lien is rendered unenforceable due to dismissal with prejudice, it undermines the enforceability of the underlying judgment as it pertains to that specific case. Finality - Finality of Dismissal with Prejudice: The dismissal with prejudice is a final adjudication that bars any further action on the same claim. This finality applies to both the lien and the judgment it supports, making both unenforceable.

Case Rating: *
It seems you are dealing with a complex bankruptcy and lien issue involving claims of fraud and the enforceability of judgments. Here are some important points to consider:
- Interconnected Nature of Judgment and Lien: In Rhode Island, if a lien becomes unenforceable due to a dismissal with prejudice, it affects the enforceability of the underlying judgment.
- Finality of Dismissal with Prejudice: This type of dismissal is a final adjudication that makes both the lien and the judgment unenforceable for that specific case.
Would you like to provide more details about the audit request or need further assistance with your motion?

Public Policy - Public Policy Considerations: Allowing the judgment to remain enforceable despite the lien's unenforceability would contradict the principles of finality and judicial efficiency upheld by dismissals with prejudice. This ensures that parties are not subject to repeated litigation on the same issues, upholding the integrity of the judicial process. - Merits Not Adjudicated: Despite the dismissal, the merits of the case were not adjudicated. Under Rule *, one can seek relief from the judgment based on reasons such as fraud or misrepresentation. Presenting new evidence, such as the forensic accountant’s report, strengthens Mr. Cronan and Ms. merritt’s position for reopening the case. - Unenforceable Lien: It's unlikely the trustee can sell a lien that is now unenforceable due to the dismissal of the case with no monetary award. The lien typically has no value if there's no judgment or settlement to enforce.

Case Rating: *
It sounds like you are dealing with a complicated bankruptcy case involving issues of fraud and unenforceable liens. Here are some points to consider:
- The Trustee's actions may violate Bankruptcy Rules * and *, which require full disclosure and proper accounting.
- A dismissal with prejudice makes both the lien and the judgment unenforceable.
- Under Rule *, you can seek relief from the judgment with new evidence, such as the forensic accountant's report.
Would you like any further assistance with revising your motion or do you have any specific questions regarding the legal procedures involved?

send me the rised motion without the borderline.

Case Rating: *
Sure, here's the revised motion without the borderlines:
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Revised Motion Statement
The Trustee placed a lien on the court case of James Cronan against James Tiernan, Ralph Grieco, and * Fountain Street LLC, despite their involvement in fraudulent activities. The Trustee's actions in selling a contested $*,* default judgment for $*,*, knowing their fraudulent history, demands an audit and transparent accounting.
Evidence Supporting Audit Request:
- Receipts and Disbursements: The Trustee's Final Report, dated February *, *, shows receipts of $*,*.* with no accounted disbursements, violating Bankruptcy Rules * and *.
- Sale of Judgment: On October *, *, the Trustee filed a motion for the approval of the sale of judgment. The court approved the sale on November *, *, affirming the buyer as a good faith purchaser and deeming the sale in the estate's best interest.
- Dismissal with Prejudice: The case PC-*-* was dismissed with prejudice, rendering the judgment unenforceable. A dismissed case with no monetary award nullifies any associated lien.
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Would you like any further revisions or additional details?

please revise this and includeThe Trustee filed the first and final application for compensation and reimbursement of expenses, seeking $*,*.* in legal fees on February *, *. This application lacks evidence such as certified letters, emails, or telephone logs to Mr. Cronan or Ms. Merritt. Despite claims of diligent efforts to collect judgments, the Trustee's previous reports did not account for these expenses. This sudden large invoice, especially after selling a $*,* default judgment for $*,*, appears to be an attempt to offset the damages from the undervalued sale. The Trustee's actions violate the transparency and proper accounting requirements mandated by Bankruptcy Rules * and *.

Case Rating: *
Sure, here's the revised motion including the new information:
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Revised Motion Statement
The Trustee placed a lien on the court case of James Cronan against James Tiernan, Ralph Grieco, and * Fountain Street LLC, despite their involvement in fraudulent activities. The Trustee's actions in selling a contested $*,* default judgment for $*,*, knowing their fraudulent history, demands an audit and transparent accounting.
Evidence Supporting Audit Request:
- Receipts and Disbursements: The Trustee's Final Report, dated February *, *, shows receipts of $*,*.* with no accounted disbursements, violating Bankruptcy Rules * and *.
- Sale of Judgment: On October *, *, the Trustee filed a motion for the approval of the sale of judgment. The court approved the sale on November *, *, affirming the buyer as a good faith purchaser and deeming the sale in the estate's best interest.
- Dismissal with Prejudice: The case PC-*-* was dismissed with prejudice, rendering the judgment unenforceable. A dismissed case with no monetary award nullifies any associated lien.
- Trustee's Application for Fees: The Trustee filed the first and final application for compensation and reimbursement of expenses, seeking $*,*.* in legal fees on February *, *. This application lacks evidence such as certified letters, emails, or telephone logs to Mr. Cronan or Ms. Merritt. Despite claims of diligent efforts to collect judgments, the Trustee's previous reports did not account for these expenses. This sudden large invoice, especially after selling a $*,* default judgment for $*,*, appears to be an attempt to offset the damages from the undervalued sale.
Would you like any further revisions or additional details?

should i include an alleged unenforeceable or bad faith judgement?This sudden large invoice, especially after selling a $*,* default judgment for $*,*,

Case Rating: *
It's important to emphasize the Trustee's alleged misconduct and the questionable nature of the judgment sale. Including references to "unenforceable" or "bad faith" judgement can strengthen your argument. Here’s a revised motion incorporating these terms:
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Revised Motion Statement
The Trustee placed a lien on the court case of James Cronan against James Tiernan, Ralph Grieco, and * Fountain Street LLC, despite their involvement in fraudulent activities. The Trustee's actions in selling a contested $*,* default judgment for $*,*, knowing their fraudulent history, demands an audit and transparent accounting.
Evidence Supporting Audit Request:
- Receipts and Disbursements: The Trustee's Final Report, dated February *, *, shows receipts of $*,*.* with no accounted disbursements, violating Bankruptcy Rules * and *.
- Sale of Judgment: On October *, *, the Trustee filed a motion for the approval of the sale of judgment. The court approved the sale on November *, *, affirming the buyer as a good faith purchaser and deeming the sale in the estate's best interest.
- Dismissal with Prejudice: The case PC-*-* was dismissed with prejudice, rendering the judgment unenforceable. A dismissed case with no monetary award nullifies any associated lien.
- Trustee's Application for Fees: The Trustee filed the first and final application for compensation and reimbursement of expenses, seeking $*,*.* in legal fees on February *, *. This application lacks evidence such as certified letters, emails, or telephone logs to Mr. Cronan or Ms. Merritt. Despite claims of diligent efforts to collect judgments, the Trustee's previous reports did not account for these expenses. This sudden large invoice, especially after selling a $*,* default judgment for $*,*, appears to be an attempt to offset the damages from the undervalued sale.
Would you like any further revisions or additional details?

please revise this-The Trustee filed an application on February *, *, to employ Craig Jalbert, CIRA, and Verdolino & Lowey P.C. as accountants for tax return services. However, it is unclear why tax relief is necessary at this time, given that the Trustee has not yet addressed the transparency and contested writ issues. This raises questions about the appropriateness and timing of the request. Maybe include given that rhe sale of *,* must be crawled back as a fraudlent conveyance cite the rule.

Case Rating: *
Here's the revised version:
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The Trustee filed an application on February *, *, to employ Craig Jalbert, CIRA, and Verdolino & Lowey P.C. as accountants for tax return services. However, it is unclear why tax relief is necessary at this time, given that the Trustee has not yet addressed the transparency and contested writ issues. This raises questions about the appropriateness and timing of the request, especially given that the sale of $*,* must be clawed back as a fraudulent conveyance. This action potentially violates bankruptcy rules regarding fraudulent transfers.
Would you like any further revisions or additional details?

fruadulent transer under please stae the rule.

Case Rating: *
Sure, here are the rules regarding fraudulent transfers under bankruptcy law:
- * U.S. Code § * - Fraudulent transfers and obligations
- The trustee may avoid any transfer of an interest of the debtor in property, or any obligation incurred by the debtor, that was made or incurred on or within 2 years before the date of the filing of the petition, if the debtor voluntarily or involuntarily:
- Made such transfer or incurred such obligation with actual intent to hinder, delay, or defraud any entity to which the debtor was or became, on or after the date that such transfer was made or such obligation was incurred, indebted.
- Received less than a reasonably equivalent value in exchange for such transfer or obligation.
Would you like more detailed information or further assistance with your motion?

please revise to include * US-This raises questions about the appropriateness and timing of the request, especially given that the sale of $*,* must be clawed back as a fraudulent conveyance. This action potentially violates bankruptcy rules regarding fraudulent transfers.

Case Rating: *
Here's the revised version with the inclusion of the rule:
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The Trustee filed an application on February *, *, to employ Craig Jalbert, CIRA, and Verdolino & Lowey P.C. as accountants for tax return services. However, it is unclear why tax relief is necessary at this time, given that the Trustee has not yet addressed the transparency and contested writ issues. This raises questions about the appropriateness and timing of the request, especially given that the sale of $*,* must be clawed back as a fraudulent conveyance. This action potentially violates * U.S. Code § * - Fraudulent transfers and obligations.
Would you like any further revisions or additional details?

Please revise Court Decision: On February *, *, the court ruled that interested parties have until March *, *, to file an objection and for the Trustee to respond to the Motion [The Motion To Contest Writ of Execution by Mr. Cronan and Ms. Merritt]. Instead of prioritizing this, the Trustee conspired with * Fountain Street LLC to substitute as Plaintiff and seek reissuance of execution and opposition (docket number 1573CV00296, Superior Court of MA). This action shows the Trustee is conspiring to assit * fountain Street - Latest Overt Act: The purchase of the

Case Rating: *
Here's the revised court decision:
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Court Decision: On February *, *, the court ruled that interested parties have until March *, *, to file an objection, and the Trustee must respond to the Motion [The Motion To Contest Writ of Execution by Mr. Cronan and Ms. Merritt]. Instead of prioritizing this, the Trustee conspired with * Fountain Street LLC to substitute as Plaintiff and seek reissuance of execution and opposition (docket number 1573CV00296, Superior Court of MA). This action shows the Trustee's collusion with * Fountain Street LLC.
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Would you like any further revisions or additional details?

default judgment by * Fountain Street LLC for $*,*, despite their claim of being creditors, constitutes the latest overt act stemming from the ongoing fraud. This act was done to offset their damages in two high-stakes pending lawsuits against them, with the assistance of the Trustee, including: - Superior Court Jury Trial: Scheduled for May *, *, Commonwealth of Massachusetts, Bristol: Ralph M. Grieco, Apponaug Business Services, Inc. vs. James M. Cronan, Karen Merritt (Defendants/Counterclaim Plaintiffs). - United States District Court, Rhode Island: Karen Merritt vs. James Tiernan et al, Case No. *:*-cv-*.

Case Rating: *
It sounds like you have a complex and potentially high-value legal issue involving bankruptcy fraud and improper actions by the Trustee. Would you like to be connected to local lawyers who can better assist you with your case?
If so, could you please provide your name?

first please reviseConstitutional Right to Seek an Audit: We assert our constitutional right to seek an audit under Bankruptcy Rule *. While we appreciate the court's efforts in seeking objections and requesting the Trustee's response by March 5th, the Trustee's recent actions raise concerns. Collaborating with * Fountains Street LLC, granting them a substantial fee break, and then requesting $*,* from the estate without sufficient transparency, appears to conflict with the best interest of the estate. This, respectfully, fulfills the criteria of Bankruptcy Rule * to mandate an audit. Receipts and Disbursements:

Case Rating: *
Sure, here is the revised motion:
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Revised Motion Statement
Constitutional Right to Seek an Audit:
We assert our constitutional right to seek an audit under Bankruptcy Rule *. While we appreciate the court's efforts in seeking objections and requesting the Trustee's response by March 5th, the Trustee's recent actions raise concerns. Collaborating with * Fountain Street LLC, granting them a substantial fee break, and then requesting $*,* from the estate without sufficient transparency, appears to conflict with the best interest of the estate. This, respectfully, fulfills the criteria of Bankruptcy Rule * to mandate an audit.
Receipts and Disbursements:
The Trustee's Final Report, dated February *, *, shows receipts of $*,*.* with no accounted disbursements, violating bankruptcy transparency rules, specifically Bankruptcy Rules * and *.
Would you like any further revisions or additional details?

The Trustee's Final Report, dated February *, *, shows receipts of $*,*.* with no disbursements. This lack of transparency since * warrants further scrutiny. Prayer for Relief to Comply with Bankruptcy Rule *: *. Investigate the allegations raised in the motion dated January *, *, contesting the writ of execution and request for an emergency stay filed by James Cronan and Karen Merritt. *. Provide a transparent and detailed accounting of the funds and actions taken. *. Order an audit of the Trustee's activities and disbursements. *. Require the Trustee to provide a detailed accounting of all receipts and disbursements. *. Grant any other relief the Court deems just and proper.

Case Rating: *
Here's the revised version including your constitutional right to seek an audit:
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Constitutional Right to Seek an Audit:
We assert our constitutional right to seek an audit under Bankruptcy Rule *. While we appreciate the court's efforts in seeking objections and requesting the Trustee's response by March 5th, the Trustee's recent actions raise concerns. Collaborating with * Fountains Street LLC, granting them a substantial fee break, and then requesting $*,* from the estate without sufficient transparency appears to conflict with the best interest of the estate. This, respectfully, fulfills the criteria of Bankruptcy Rule * to mandate an audit.
Receipts and Disbursements:
The Trustee's Final Report, dated February *, *, shows receipts of $*,*.* with no disbursements. This lack of transparency since * warrants further scrutiny.
Prayer for Relief to Comply with Bankruptcy Rule *:
*. Investigate the allegations raised in the motion dated January *, *, contesting the writ of execution and request for an emergency stay filed by James Cronan and Karen Merritt.
*. Provide a transparent and detailed accounting of the funds and actions taken.
*. Order an audit of the Trustee's activities and disbursements.
*. Require the Trustee to provide a detailed accounting of all receipts and disbursements.
*. Grant any other relief the Court deems just and proper.
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Would you like any further revisions or have any specific questions regarding the legal procedures involved?

what about declaring the judgement is now void due to the dimisall with preduice pc-*-*?

Case Rating: *
You can include the point of the judgment being void due to the dismissal with prejudice to strengthen your argument. Here is the revised motion:
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Constitutional Right to Seek an Audit:
We assert our constitutional right to seek an audit under Bankruptcy Rule *. While we appreciate the court's efforts in seeking objections and requesting the Trustee's response by March 5th, the Trustee's recent actions raise concerns. Collaborating with * Fountains Street LLC, granting them a substantial fee break, and then requesting $*,* from the estate without sufficient transparency appears to conflict with the best interest of the estate. This, respectfully, fulfills the criteria of Bankruptcy Rule * to mandate an audit.
Receipts and Disbursements:
The Trustee's Final Report, dated February *, *, shows receipts of $*,*.* with no disbursements. This lack of transparency since * warrants further scrutiny.
Dismissal with Prejudice:
The case PC-*-* was dismissed with prejudice, rendering the judgment unenforceable. A dismissed case with no monetary award nullifies any associated lien.
Prayer for Relief to Comply with Bankruptcy Rule *:
*. Investigate the allegations raised in the motion dated January *, *, contesting the writ of execution and request for an emergency stay filed by James Cronan and Karen Merritt.
*. Provide a transparent and detailed accounting of the funds and actions taken.
*. Order an audit of the Trustee's activities and disbursements.
*. Require the Trustee to provide a detailed accounting of all receipts and disbursements.
*. Grant any other relief the Court deems just and proper.
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Would you like any further revisions or additional details?

so what happens to that default judgment in this case?

Case Rating: *
In Massachusetts, when a case is dismissed with prejudice, the judgment is typically rendered unenforceable. This means:
- Judgment Void: The default judgment in case PC-*-* is considered void.
- Lien Nullified: Any lien associated with the judgment is also nullified.
Do you need guidance on your next legal steps?

please clearly state that in Dismissal with prejudice section

Case Rating: *
Here's the revised motion section clearly stating the impact of the dismissal with prejudice:
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Constitutional Right to Seek an Audit:
We assert our constitutional right to seek an audit under Bankruptcy Rule *. While we appreciate the court's efforts in seeking objections and requesting the Trustee's response by March 5th, the Trustee's recent actions raise concerns. Collaborating with * Fountains Street LLC, granting them a substantial fee break, and then requesting $*,* from the estate without sufficient transparency appears to conflict with the best interest of the estate. This, respectfully, fulfills the criteria of Bankruptcy Rule * to mandate an audit.
Receipts and Disbursements:
The Trustee's Final Report, dated February *, *, shows receipts of $*,*.* with no disbursements. This lack of transparency since * warrants further scrutiny.
Dismissal with Prejudice:
The case PC-*-* was dismissed with prejudice, rendering the judgment unenforceable. As a result:
- The default judgment in this case is considered void.
- Any lien associated with the judgment is nullified.
Prayer for Relief to Comply with Bankruptcy Rule *:
*. Investigate the allegations raised in the motion dated January *, *, contesting the writ of execution and request for an emergency stay filed by James Cronan and Karen Merritt.
*. Provide a transparent and detailed accounting of the funds and actions taken.
*. Order an audit of the Trustee's activities and disbursements.
*. Require the Trustee to provide a detailed accounting of all receipts and disbursements.
*. Grant any other relief the Court deems just and proper.
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Would you like any further revisions or additional details?

should we rwevise the motion to estblish new evidence of a lack of an enforecebel judgement due to the dismissed lien on the court case pc *-* and need for an audit. Before the new information i wrote this- Request for Extension and Audit of Trustee's Final Report Under the Americans with Disabilities Act (ADA) We, James Cronan and Karen Merritt, request an extension of time from February *, *, to March *, *, under the Americans with Disabilities Act (ADA) to formalize our objection to the Trustee's Final Report. If the court requires supporting documents for this extension, we will adhere to court proceedings. Evidence Supporting Audit Request: - Receipts and Disbursements: The Trustee's Final Report, dated February *, *, shows receipts of $*,*.* with no accounted disbursements, violating bankruptcy transparency rules, specifically Bankruptcy Rules * and *.

Case Rating: *
Yes, I recommend revising your motion to include the new evidence regarding the unenforceable judgment due to the dismissed lien. Here’s a revised version of your motion:
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Request for Extension and Audit of Trustee's Final Report Under the Americans with Disabilities Act (ADA)
We, James Cronan and Karen Merritt, request an extension of time from February *, *, to March *, *, under the Americans with Disabilities Act (ADA) to formalize our objection to the Trustee's Final Report. If the court requires supporting documents for this extension, we will adhere to court proceedings.
Evidence Supporting Audit Request:
- Receipts and Disbursements: The Trustee's Final Report, dated February *, *, shows receipts of $*,*.* with no accounted disbursements, violating bankruptcy transparency rules, specifically Bankruptcy Rules * and *.
- Dismissed Lien: The case PC-*-* was dismissed with prejudice, rendering the judgment unenforceable. As a result:
- The default judgment in this case is considered void.
- Any lien associated with the judgment is nullified.
- Trustee's Application for Fees: The Trustee filed the first and final application for compensation and reimbursement of expenses, seeking $*,*.* in legal fees on February *, *. This application lacks evidence such as certified letters, emails, or telephone logs to Mr. Cronan or Ms. Merritt. Despite claims of diligent efforts to collect judgments, the Trustee's previous reports did not account for these expenses. This sudden large invoice, especially after selling a $*,* default judgment for $*,*, appears to be an attempt to offset the damages from the undervalued sale.
- Trustee's Tax Services Application: The Trustee filed an application on February *, *, to employ Craig Jalbert, CIRA, and Verdolino & Lowey P.C. as accountants for tax return services. However, it is unclear why tax relief is necessary at this time, given that the Trustee has not yet addressed the transparency and contested writ issues. This raises questions about the appropriateness and timing of the request, especially given that the sale of $*,* must be clawed back as a fraudulent conveyance. This action potentially violates * U.S. Code § * - Fraudulent transfers and obligations.
Prayer for Relief to Comply with Bankruptcy Rule *:
*. Investigate the allegations raised in the motion dated January *, *, contesting the writ of execution and request for an emergency stay filed by James Cronan and Karen Merritt.
*. Provide a transparent and detailed accounting of the funds and actions taken.
*. Order an audit of the Trustee's activities and disbursements.
*. Require the Trustee to provide a detailed accounting of all receipts and disbursements.
*. Grant any other relief the Court deems just and proper.
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Would you like any further revisions or additional details?

under prayer should i ask for anything about the judgement now being void as a result of the lien being dismissed with prejudcie?

Case Rating: *
Yes, you should include a specific request regarding the judgment being void as a result of the lien being dismissed with prejudice. Here’s the revised prayer for relief:
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Request for Extension and Audit of Trustee's Final Report Under the Americans with Disabilities Act (ADA)
We, James Cronan and Karen Merritt, request an extension of time from February *, *, to March *, *, under the Americans with Disabilities Act (ADA) to formalize our objection to the Trustee's Final Report. If the court requires supporting documents for this extension, we will adhere to court proceedings.
Evidence Supporting Audit Request:
- Receipts and Disbursements: The Trustee's Final Report, dated February *, *, shows receipts of $*,*.* with no accounted disbursements, violating bankruptcy transparency rules, specifically Bankruptcy Rules * and *.
- Dismissed Lien: The case PC-*-* was dismissed with prejudice, rendering the judgment unenforceable. As a result:
- The default judgment in this case is considered void.
- Any lien associated with the judgment is nullified.
- Trustee's Application for Fees: The Trustee filed the first and final application for compensation and reimbursement of expenses, seeking $*,*.* in legal fees on February *, *. This application lacks evidence such as certified letters, emails, or telephone logs to Mr. Cronan or Ms. Merritt. Despite claims of diligent efforts to collect judgments, the Trustee's previous reports did not account for these expenses. This sudden large invoice, especially after selling a $*,* default judgment for $*,*, appears to be an attempt to offset the damages from the undervalued sale.
- Trustee's Tax Services Application: The Trustee filed an application on February *, *, to employ Craig Jalbert, CIRA, and Verdolino & Lowey P.C. as accountants for tax return services. However, it is unclear why tax relief is necessary at this time, given that the Trustee has not yet addressed the transparency and contested writ issues. This raises questions about the appropriateness and timing of the request, especially given that the sale of $*,* must be clawed back as a fraudulent conveyance. This action potentially violates * U.S. Code § * - Fraudulent transfers and obligations.
Prayer for Relief to Comply with Bankruptcy Rule *:
*. Investigate the allegations raised in the motion dated January *, *, contesting the writ of execution and request for an emergency stay filed by James Cronan and Karen Merritt.
*. Provide a transparent and detailed accounting of the funds and actions taken.
*. Order an audit of the Trustee's activities and disbursements.
*. Require the Trustee to provide a detailed accounting of all receipts and disbursements.
*. Declare the judgment void as a result of the lien being dismissed with prejudice in case PC-*-*.
*. Grant any other relief the Court deems just and proper.
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Would you like any further revisions or additional details?

can the bankrupcty court make this declaration or should I seek a transfer to the discrit court ?

Case Rating: *
In your situation, the bankruptcy court has the authority to address issues related to the trustee's actions, transparency, and the enforceability of judgments and liens under bankruptcy law. However, if your goal is to have a judgment declared void due to a dismissed lien, it could be beneficial to seek a transfer to the district court, which has broader jurisdiction and can provide a more comprehensive ruling on such declarations.
Would you like further assistance or any specific guidance on how to proceed with the transfer request?

When * Fountain street filed a lawsuit against me to excecute the judgement ( I guess that is waht it is called) I filed a notice for removal to U.S. Disctrict Cout raising federal questions incliding RICO claims and constutional rights violations. Can i ask to transfer it here though they have yet to affirm the request. I asked for an extension under ADA to formally file a complaint and i asked if the court requires a RICO statement.

Case Rating: *
You can request the U.S. District Court to transfer the case from the state court, especially given the federal questions and RICO claims raised. Here are some steps to consider:
- Request for Transfer: Formally request the U.S. District Court to transfer the case, emphasizing the federal questions and RICO claims involved.
- ADA Extension: Ensure your request for an extension under the ADA to file a complaint is documented and submitted.
- RICO Statement: Prepare and submit a RICO statement if the court requires it.
Would you like further assistance with drafting the request for transfer or any other specific legal document?

however what do i ask the bankruptcy court here in the relief requesated?

Case Rating: *
In your request for relief from the bankruptcy court, you can focus on the following points:

Request for Relief:
*. Investigate Trustee's Actions:
- Request a detailed investigation into the Trustee's actions and potential misconduct.

*. Audit of Trustee's Activities:
- Demand an independent audit of all the Trustee's activities, receipts, and disbursements.
*. Declare Judgment Void:
- Ask the court to declare the judgment void due to the lien being dismissed with prejudice in case PC-*-*.
*. Address Trustee's Compensation and Fee Applications:
- Request scrutiny and justification for the Trustee's compensation and fee applications, including the $*,*.* in legal fees and the employment of tax return services.
*. Compliance with Bankruptcy Rules:
- Ensure the Trustee complies with Bankruptcy Rules * and * regarding transparency and proper accounting.

Additional Steps:
- Prepare Evidence:
- Gather and prepare all evidence supporting your claims, including the dismissal with prejudice and lack of enforceable judgment.
Would you like more specific guidance on any of these points, or assistance in drafting the motion?

can you write it as I am reguesting it and send it to me without the borderline.

Request for Extension and Audit of Trustee's Final Report Under the Americans with Disabilities Act (ADA)
We, James Cronan and Karen Merritt, request an extension of time from February *, *, to March *, *, under the Americans with Disabilities Act (ADA) to formalize our objection to the Trustee's Final Report. If the court requires supporting documents for this extension, we will adhere to court proceedings.
Evidence Supporting Audit Request:
- Receipts and Disbursements: The Trustee's Final Report, dated February *, *, shows receipts of $*,*.* with no accounted disbursements, violating bankruptcy transparency rules, specifically Bankruptcy Rules * and *.
- Dismissed Lien: The case PC-*-* was dismissed with prejudice, rendering the judgment unenforceable. As a result:
- The default judgment in this case is considered void.
- Any lien associated with the judgment is nullified.
- Trustee's Application for Fees: The Trustee filed the first and final application for compensation and reimbursement of expenses, seeking $*,*.* in legal fees on February *, *. This application lacks evidence such as certified letters, emails, or telephone logs to Mr. Cronan or Ms. Merritt. Despite claims of diligent efforts to collect judgments, the Trustee's previous reports did not account for these expenses. This sudden large invoice, especially after selling a $*,* default judgment for $*,*, appears to be an attempt to offset the damages from the undervalued sale.
- Trustee's Tax Services Application: The Trustee filed an application on February *, *, to employ Craig Jalbert, CIRA, and Verdolino & Lowey P.C. as accountants for tax return services. However, it is unclear why tax relief is necessary at this time, given that the Trustee has not yet addressed the transparency and contested writ issues. This raises questions about the appropriateness and timing of the request, especially given that the sale of $*,* must be clawed back as a fraudulent conveyance. This action potentially violates * U.S. Code § * - Fraudulent transfers and obligations.
Prayer for Relief to Comply with Bankruptcy Rule *:
*. Investigate the allegations raised in the motion dated January *, *, contesting the writ of execution and request for an emergency stay filed by James Cronan and Karen Merritt.
*. Provide a transparent and detailed accounting of the funds and actions taken.
*. Order an audit of the Trustee's activities and disbursements.
*. Require the Trustee to provide a detailed accounting of all receipts and disbursements.
*. Declare the judgment void as a result of the lien being dismissed with prejudice in case PC-*-*.
*. Grant any other relief the Court deems just and proper.

do i need to state that the Trusttee had a lien on this case from the default judgement?- Dismissed Lien: The case PC-*-* was dismissed with prejudice, rendering the judgment unenforceable. As a result: - The default judgment in this case is considered void. - Any lien associated with the judgment is nullified.

Case Rating: *
It is important to clarify that the Trustee had a lien on the case from the default judgment. This information establishes the connection between the lien and the judgment, which is now unenforceable due to the dismissal with prejudice.
Here is the revised motion, including the necessary clarification:
---
Request for Extension and Audit of Trustee's Final Report Under the Americans with Disabilities Act (ADA)
We, James Cronan and Karen Merritt, request an extension of time from February *, *, to March *, *, under the Americans with Disabilities Act (ADA) to formalize our objection to the Trustee's Final Report. If the court requires supporting documents for this extension, we will adhere to court proceedings.
Evidence Supporting Audit Request:
- Receipts and Disbursements: The Trustee's Final Report, dated February *, *, shows receipts of $*,*.* with no accounted disbursements, violating bankruptcy transparency rules, specifically Bankruptcy Rules * and *.
- Dismissed Lien: The Trustee had a lien on the court case PC-*-* from the default judgment. This case was dismissed with prejudice, rendering the judgment unenforceable. As a result:
- The default judgment in this case is considered void.
- Any lien associated with the judgment is nullified.
- Trustee's Application for Fees: The Trustee filed the first and final application for compensation and reimbursement of expenses, seeking $*,*.* in legal fees on February *, *. This application lacks evidence such as certified letters, emails, or telephone logs to Mr. Cronan or Ms. Merritt. Despite claims of diligent efforts to collect judgments, the Trustee's previous reports did not account for these expenses. This sudden large invoice, especially after selling a $*,* default judgment for $*,*, appears to be an attempt to offset the damages from the undervalued sale.
- Trustee's Tax Services Application: The Trustee filed an application on February *, *, to employ Craig Jalbert, CIRA, and Verdolino & Lowey P.C. as accountants for tax return services. However, it is unclear why tax relief is necessary at this time, given that the Trustee has not yet addressed the transparency and contested writ issues. This raises questions about the appropriateness and timing of the request, especially given that the sale of $*,* must be clawed back as a fraudulent conveyance. This action potentially violates * U.S. Code § * - Fraudulent transfers and obligations.
Prayer for Relief to Comply with Bankruptcy Rule *:
*. Investigate the allegations raised in the motion dated January *, *, contesting the writ of execution and request for an emergency stay filed by James Cronan and Karen Merritt.
*. Provide a transparent and detailed accounting of the funds and actions taken.
*. Order an audit of the Trustee's activities and disbursements.
*. Require the Trustee to provide a detailed accounting of all receipts and disbursements.
*. Declare the judgment void as a result of the lien being dismissed with prejudice in case PC-*-*.
*. Grant any other relief the Court deems just and proper.
---
Would you like any further revisions or additional details?

should I cite this do I care if the sale is clawed back as i only care if its void, right? This raises questions about the appropriateness and timing of the request, especially given that the sale of $*,* must be clawed back as a fraudulent conveyance. This action potentially violates * U.S. Code § * - Fraudulent transfers and obligations

Case Rating: *
You are correct; the focus should be on declaring the judgment void. Here's the revised motion without emphasizing the clawback:
---

Request for Extension and Audit of Trustee's Final Report Under the Americans with Disabilities Act (ADA)
We, James Cronan and Karen Merritt, request an extension of time from February *, *, to March *, *, under the Americans with Disabilities Act (ADA) to formalize our objection to the Trustee's Final Report. If the court requires supporting documents for this extension, we will adhere to court proceedings.
Evidence Supporting Audit Request:
- Receipts and Disbursements: The Trustee's Final Report, dated February *, *, shows receipts of $*,*.* with no accounted disbursements, violating bankruptcy transparency rules, specifically Bankruptcy Rules * and *.
- Dismissed Lien: The Trustee had a lien on the court case PC-*-* from the default judgment. This case was dismissed with prejudice, rendering the judgment unenforceable. As a result:
- The default judgment in this case is considered void.
- Any lien associated with the judgment is nullified.
- Trustee's Application for Fees: The Trustee filed the first and final application for compensation and reimbursement of expenses, seeking $*,*.* in legal fees on February *, *. This application lacks evidence such as certified letters, emails, or telephone logs to Mr. Cronan or Ms. Merritt. Despite claims of diligent efforts to collect judgments, the Trustee's previous reports did not account for these expenses. This sudden large invoice, especially after selling a $*,* default judgment for $*,*, appears to be an attempt to offset the damages from the undervalued sale.
- Trustee's Tax Services Application: The Trustee filed an application on February *, *, to employ Craig Jalbert, CIRA, and Verdolino & Lowey P.C. as accountants for tax return services. However, it is unclear why tax relief is necessary at this time, given that the Trustee has not yet addressed the transparency and contested writ issues. This raises questions about the appropriateness and timing of the request.
Prayer for Relief to Comply with Bankruptcy Rule *:
*. Investigate the allegations raised in the motion dated January *, *, contesting the writ of execution and request for an emergency stay filed by James Cronan and Karen Merritt.
*. Provide a transparent and detailed accounting of the funds and actions taken.
*. Order an audit of the Trustee's activities and disbursements.
*. Require the Trustee to provide a detailed accounting of all receipts and disbursements.
*. Declare the judgment void as a result of the lien being dismissed with prejudice in case PC-*-*.
*. Grant any other relief the Court deems just and proper.
---
Would you like any further revisions or additional details?

can you write an email to Ms Miley seeking the lien on this case by the trustee Joseph Diorio as i have searched the Rhode island Judiciary Public Portal for it be can not find it and I know that it is there. Or acn you provide me with instructions on how to retrieve it, please

Case Rating: *
Sure, here's the email draft:
---
Subject: Request for Assistance in Retrieving Lien Information
Dear Ms. Miley,
I hope this email finds you well. I am reaching out to seek assistance in retrieving information related to a lien placed on a case by Trustee Joseph Diorio. I have searched the Rhode Island Judiciary Public Portal but have been unable to locate the lien details.
Could you please assist me in retrieving this information or provide instructions on how to access it?
Thank you for your assistance.
Best regards,
[Your Name]
---
Would you like any revisions or additional details included?

do i need to cc opposing counsel when sending her this reguest? This is the case OF RHODE ISLAND SUPERIOR COURT PROVIDENCE, SC. JAMES M. CRONAN : : vs. : PC-*-* : RALPH M. GRIECO, ET AL.

Case Rating: *
In general, it's best to cc opposing counsel on communications with the court or court officials to ensure transparency and avoid any potential accusations of ex parte communication. Here’s the revised email draft, including a cc to opposing counsel:
---
Subject: Request for Assistance in Retrieving Lien Information
Dear Ms. Miley,
I hope this email finds you well. I am reaching out to seek assistance in retrieving information related to a lien placed on the case PC-*-* by Trustee Joseph Diorio. I have searched the Rhode Island Judiciary Public Portal but have been unable to locate the lien details.
Could you please assist me in retrieving this information or provide instructions on how to access it?
Thank you for your assistance.
Best regards,
[Your Name]
cc: [Opposing Counsel's Name]
---
Would you like any revisions or additional details included?

I need to write a motion to clarify or something . James cronan recieved a mail from the superior court Notice to appear for motion hearing on *-*-* Case name Diorio Chapter * Trustee of classic display, Inc Joseph M vs Cronan, James M et al docket number 1573CV00296 Additionally the Notice states date issued *-*-* further orders of the court #* * fountain street's Motion to substitute as Plaintiff and for reisssuance of execution with opposition. James never got served a complaint by Diorio. I believe since its a new case number it warrants a complaint. Instaed he gets this motion on *-*-*- PLAINTIFF * FOUNTAIN STREET, LLC’S

Case Rating: *
You might want to file a Motion to Dismiss or a Motion to Clarify. Here’s a suggestion for the motion:
---
[Your Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
[Date]
Superior Court of Massachusetts
[Court's Address]
Re: Case No. 1573CV00296
Diorio Chapter * Trustee of Classic Display, Inc. Joseph M. vs. Cronan, James M.
Motion to Dismiss/Clarify
Introduction:
James Cronan respectfully requests the court to dismiss or clarify the complaint filed by Plaintiff * Fountain Street, LLC due to the lack of proper service of the initial complaint by Trustee Joseph Diorio.
Facts:
*. On February *, *, James Cronan received a notice to appear for a motion hearing scheduled for February *, *.
*. The notice, dated February *, *, pertained to a motion filed by * Fountain Street, LLC to substitute as Plaintiff and for reissuance of execution with opposition.
*. James Cronan has not received any initial complaint from Trustee Joseph Diorio regarding the new case number 1573CV00296.
Argument:
*. Lack of Proper Service: According to the Massachusetts Rules of Civil Procedure, proper service of the initial complaint is required to establish jurisdiction. James Cronan has not been served with any initial complaint by Trustee Joseph Diorio.
*. New Case Number: The issuance of a new case number warrants the filing and service of a new complaint. The failure to do so violates due process and prevents James Cronan from adequately preparing a defense.
*. Request for Clarification: If the court does not find grounds for dismissal, James Cronan requests clarification regarding the status of the complaint and the justification for the motion filed by * Fountain Street, LLC.
Prayer for Relief:
*. Dismiss the complaint due to lack of proper service.
*. Alternatively, clarify the status of the complaint and the justification for the motion filed by * Fountain Street, LLC.
*. Grant any other relief the court deems just and proper.
Respectfully submitted,
[Your Name]
---
Would you like any revisions or additional details included?

EMERGENCY MOTION TO CONTINUE HEARING NOW COMES Plaintiff * Fountain Street, LLC, and respectfully request this Court continue the hearing currently scheduled for February *, *, on the Defendants James Cronan and Karen Merritt’s Motions for Extension of Time to Answer Plaintiff’s Complaint. BRISTOL SUPERIOR COURT CIVIL ACTION NO. 2573CV00006 ______ ) * FOUNTAIN STREET, LLC Pl ai nt if f, v. JAMES CRONAN and KAREN MERRITT. This hearing is not scheduled to hear an extension of time and * Fountain St is not the plaintiff . Please write the proper motion to the court.

Case Rating: *
Would you like to be connected to local lawyers who can better assist you with your case?
Here's a draft motion to the court:
---
MOTION TO CLARIFY AND CONTINUE HEARING
COMMONWEALTH OF MASSACHUSETTS
BRISTOL SUPERIOR COURT
CIVIL ACTION NO. 1573CV00296
JAMES M. CRONAN, Defendant,
v.
DIORIO, CHAPTER * TRUSTEE OF CLASSIC DISPLAY, INC. JOSEPH M., Plaintiff.
MOTION TO CLARIFY AND CONTINUE HEARING
NOW COMES the Defendant, James M. Cronan, and respectfully moves this Honorable Court to clarify the procedural posture of this case and to continue the hearing currently scheduled for February *, *. In support of this motion, the Defendant states as follows:
*. On February *, *, the Defendant received a notice to appear for a motion hearing scheduled for February *, *, in the case Diorio Chapter * Trustee of Classic Display, Inc. Joseph M. v. Cronan, James M. et al., docket number 1573CV00296.

*. The notice referenced a motion filed by Plaintiff * Fountain Street, LLC, seeking to substitute as Plaintiff and for reissuance of execution with opposition.
*. The Defendant has not been served with a complaint in this case by Diorio or * Fountain Street, LLC, which is required given the new case number.
*. The Plaintiff, * Fountain Street, LLC, filed an emergency motion to continue the hearing, referencing a different case number (2573CV00006) and indicating that the hearing was scheduled to address the Defendants' motions for extension of time to answer the Plaintiff’s complaint, which is not accurate.
*. The Defendant seeks clarification on the following issues:
- The correct case number and procedural status of the case.
- Whether a complaint has been properly filed and served in accordance with the rules of civil procedure.
- The specific motions to be addressed at the hearing on February *, *.
*. The Defendant respectfully requests that the hearing be continued to allow for proper service of a complaint and to provide sufficient time for the Defendant to prepare an appropriate response.
WHEREFORE, the Defendant, James M. Cronan, respectfully requests that this Court:
*. Clarify the procedural posture of this case, including the proper case number and the status of the complaint.
*. Continue the hearing currently scheduled for February *, *, to a later date to allow for proper service and preparation.
*. Grant any other relief the Court deems just and proper.
Respectfully submitted,
James M. Cronan
[Your Address]
[City, State, ZIP Code]
[Phone Number]
[Email Address]
Date: [Insert Date]
---
Would you like any further revisions or additional details?

please include Karen Merritt under respectfully submitted

Case Rating: *
Would you like to be connected to local lawyers who can better assist you with your case?
Here's the revised motion:
---
MOTION TO CLARIFY AND CONTINUE HEARING
COMMONWEALTH OF MASSACHUSETTS
BRISTOL SUPERIOR COURT
CIVIL ACTION NO. 1573CV00296
JAMES M. CRONAN, Defendant,
v.
DIORIO, CHAPTER * TRUSTEE OF CLASSIC DISPLAY, INC. JOSEPH M., Plaintiff.
MOTION TO CLARIFY AND CONTINUE HEARING
NOW COMES the Defendant, James M. Cronan, and respectfully moves this Honorable Court to clarify the procedural posture of this case and to continue the hearing currently scheduled for February *, *. In support of this motion, the Defendant states as follows:
*. On February *, *, the Defendant received a notice to appear for a motion hearing scheduled for February *, *, in the case Diorio Chapter * Trustee of Classic Display, Inc. Joseph M. v. Cronan, James M. et al., docket number 1573CV00296.
*. The notice referenced a motion filed by Plaintiff * Fountain Street, LLC, seeking to substitute as Plaintiff and for reissuance of execution with opposition.
*. The Defendant has not been served with a complaint in this case by Diorio or * Fountain Street, LLC, which is required given the new case number.
*. The Plaintiff, * Fountain Street, LLC, filed an emergency motion to continue the hearing, referencing a different case number (2573CV00006) and indicating that the hearing was scheduled to address the Defendants' motions for extension of time to answer the Plaintiff’s complaint, which is not accurate.
*. The Defendant seeks clarification on the following issues:
- The correct case number and procedural status of the case.
- Whether a complaint has been properly filed and served in accordance with the rules of civil procedure.
- The specific motions to be addressed at the hearing on February *, *.
*. The Defendant respectfully requests that the hearing be continued to allow for proper service of a complaint and to provide sufficient time for the Defendant to prepare an appropriate response.
WHEREFORE, the Defendant, James M. Cronan, respectfully requests that this Court:
*. Clarify the procedural posture of this case, including the proper case number and the status of the complaint.
*. Continue the hearing currently scheduled for February *, *, to a later date to allow for proper service and preparation.
*. Grant any other relief the Court deems just and proper.
Respectfully submitted,
James M. Cronan
Karen Merritt
[Your Address]
[City, State, ZIP Code]
[Phone Number]
[Email Address]
Date: [Insert Date]
---
Would you like any further revisions or additional details?

correction *. The Defendants have not been served with a complaint in this case by Diorio or * Fountain Street, LLC, which is required given the new case number. Defendants had been served with a complaint by * Fountain street but not Diorio.

Case Rating: *
Here's the revised motion:
---
MOTION TO CLARIFY AND CONTINUE HEARING
COMMONWEALTH OF MASSACHUSETTS
BRISTOL SUPERIOR COURT
CIVIL ACTION NO. 1573CV00296
JAMES M. CRONAN, Defendant,
v.
DIORIO, CHAPTER * TRUSTEE OF CLASSIC DISPLAY, INC. JOSEPH M., Plaintiff.
MOTION TO CLARIFY AND CONTINUE HEARING
NOW COMES the Defendant, James M. Cronan, and respectfully moves this Honorable Court to clarify the procedural posture of this case and to continue the hearing currently scheduled for February *, *. In support of this motion, the Defendant states as follows:
*. On February *, *, the Defendant received a notice to appear for a motion hearing scheduled for February *, *, in the case Diorio Chapter * Trustee of Classic Display, Inc. Joseph M. v. Cronan, James M. et al., docket number 1573CV00296.
*. The notice referenced a motion filed by Plaintiff * Fountain Street, LLC, seeking to substitute as Plaintiff and for reissuance of execution with opposition.
*. The Defendants have not been served with a complaint in this case by Diorio or * Fountain Street, LLC, which is required given the new case number. Defendants had been served with a complaint by * Fountain Street but not Diorio.
*. The Plaintiff, * Fountain Street, LLC, filed an emergency motion to continue the hearing, referencing a different case number (2573CV00006) and indicating that the hearing was scheduled to address the Defendants' motions for extension of time to answer the Plaintiff’s complaint, which is not accurate.
*. The Defendant seeks clarification on the following issues:
- The correct case number and procedural status of the case.
- Whether a complaint has been properly filed and served in accordance with the rules of civil procedure.
- The specific motions to be addressed at the hearing on February *, *.
*. The Defendant respectfully requests that the hearing be continued to allow for proper service of a complaint and to provide sufficient time for the Defendant to prepare an appropriate response.
WHEREFORE, the Defendant, James M. Cronan, respectfully requests that this Court:
*. Clarify the procedural posture of this case, including the proper case number and the status of the complaint.
*. Continue the hearing currently scheduled for February *, *, to a later date to allow for proper service and preparation.
*. Grant any other relief the Court deems just and proper.
Respectfully submitted,
James M. Cronan
Karen Merritt
[Your Address]
[City, State, ZIP Code]
[Phone Number]
[Email Address]
Date: [Insert Date]
---
Would you like any further revisions or additional details?

who do i serve as its not the busines of * fountains street LLc or is it?

Case Rating: *
In this scenario, you should serve the following parties:
*. Trustee Joseph Diorio: As the original plaintiff who initiated the Chapter * bankruptcy proceedings.
*. * Fountain Street, LLC: As a party that filed a motion within the case.
Both parties are involved in the current legal proceedings and should be served with the motion to ensure proper notice and opportunity to respond.
Would you like more specific guidance on the service process or any other assistance with your case?

file to bith separate cases in efile too?

Case Rating: *
Yes, you should file the motion in both cases to ensure that it is appropriately addressed in each context. Here’s a quick guide on how to proceed:

Steps to File the Motion in Both Cases:
*. Prepare Separate Filings:
- Prepare the motion to clarify and continue hearing with the respective case numbers and filings for each case.
- Ensure that each motion includes the correct docket number and references the specific parties involved.
*. E-File Each Motion:
- Log in to the e-filing system used by the court (e.g., Massachusetts eFile).
- Select the appropriate case number for each filing.
- Upload the prepared motion documents.
- Follow the prompts to complete the e-filing process.
*. Serve the Parties:
- Serve Trustee Joseph Diorio and * Fountain Street, LLC.
- Ensure that you follow proper service procedures for each party, which typically includes mailing a copy of the motion and providing proof of service to the court.
*. Monitor Court Responses:
- Keep an eye on any responses or further notices from the court.
- Be prepared to attend any scheduled hearings or provide additional information if required.
Would you like any further revisions to your motion or additional guidance on the e-filing process?

*. On February *, *, the Defendants received a notice to appear for a motion hearing scheduled for February *, *, in the case Diorio Chapter * Trustee of Classic Display, Inc. Joseph M. v. Cronan, James M. and cronan (merritt) Karen et al., docket number 1573CV00296.

Case Rating: *

Motion to Clarify and Continue Hearing
COMMONWEALTH OF MASSACHUSETTS
BRISTOL SUPERIOR COURT
CIVIL ACTION NO. 1573CV00296
JAMES M. CRONAN and KAREN MERRITT, Defendants,
v.
DIORIO, CHAPTER * TRUSTEE OF CLASSIC DISPLAY, INC. JOSEPH M., Plaintiff.
MOTION TO CLARIFY AND CONTINUE HEARING
NOW COME the Defendants, James M. Cronan and Karen Merritt, and respectfully move this Honorable Court to clarify the procedural posture of this case and to continue the hearing currently scheduled for February *, *. In support of this motion, the Defendants state as follows:
*. On February *, *, the Defendants received a notice to appear for a motion hearing scheduled for February *, *, in the case Diorio Chapter * Trustee of Classic Display, Inc. Joseph M. v. Cronan, James M. and Merritt, Karen et al., docket number 1573CV00296.
*. The notice referenced a motion filed by Plaintiff * Fountain Street, LLC, seeking to substitute as Plaintiff and for reissuance of execution with opposition.
*. The Defendants have not been served with a complaint in this case by Diorio, which is required given the new case number. Defendants had been served with a complaint by * Fountain Street, LLC but not by Diorio.
*. The Plaintiff, * Fountain Street, LLC, filed an emergency motion to continue the hearing, referencing a different case number (2573CV00006) and indicating that the hearing was scheduled to address the Defendants' motions for extension of time to answer the Plaintiff’s complaint, which is not accurate.
*. The Defendants seek clarification on the following issues:
- The correct case number and procedural status of the case.
- Whether a complaint has been properly filed and served in accordance with the rules of civil procedure.
- The specific motions to be addressed at the hearing on February *, *.
*. The Defendants respectfully request that the hearing be continued to allow for proper service of a complaint and to provide sufficient time for the Defendants to prepare an appropriate response.
WHEREFORE, the Defendants, James M. Cronan and Karen Merritt, respectfully request that this Court:
*. Clarify the procedural posture of this case, including the proper case number and the status of the complaint.
*. Continue the hearing currently scheduled for February *, *, to a later date to allow for proper service and preparation.
*. Grant any other relief the Court deems just and proper.
Respectfully submitted,
James M. Cronan
Karen Merritt
[Your Address]
[City, State, ZIP Code]
[Phone Number]
[Email Address]
Date: [Insert Date]
---
Would you like any further revisions or additional details?

is it ok that I don't file two separate motions one for james and one for Karen and include them together in the one motions filing in each case as the defandents, which they are in the cases?

Case Rating: *
It's generally acceptable to file a single motion for both James and Karen as long as they are defendants in the same cases. Combining their requests can streamline the process and ensure consistency in the arguments presented.
Would you like to proceed with any further revisions or additional details in the motion?

please clarify i file the motion DIORIO, CHAPTER * TRUSTEE OF CLASSIC DISPLAY, INC. JOSEPH M., Plaintiff.v.JAMES M. CRONAN, Defendant, Civil docket No; 1573CV00296 . Please send me the motion that I file into BRISTOL SUPERIOR COURT CIVIL ACTION NO. 2573CV00006 * FOUNTAIN STREET, LLC Pl ai nt if f, v. JAMES CRONAN and KAREN MERRITT Defendants.

Case Rating: *
Sure, here are the motions for both cases:

Motion for Case No. 1573CV00296:
---
MOTION TO CLARIFY AND CONTINUE HEARING
COMMONWEALTH OF MASSACHUSETTS
BRISTOL SUPERIOR COURT
CIVIL ACTION NO. 1573CV00296
JAMES M. CRONAN and KAREN MERRITT, Defendants,
v.
DIORIO, CHAPTER * TRUSTEE OF CLASSIC DISPLAY, INC. JOSEPH M., Plaintiff.
MOTION TO CLARIFY AND CONTINUE HEARING
NOW COME the Defendants, James M. Cronan and Karen Merritt, and respectfully move this Honorable Court to clarify the procedural posture of this case and to continue the hearing currently scheduled for February *, *. In support of this motion, the Defendants state as follows:
*. On February *, *, the Defendants received a notice to appear for a motion hearing scheduled for February *, *, in the case Diorio Chapter * Trustee of Classic Display, Inc. Joseph M. v. Cronan, James M. and Merritt, Karen et al., docket number 1573CV00296.
*. The notice referenced a motion filed by Plaintiff * Fountain Street, LLC, seeking to substitute as Plaintiff and for reissuance of execution with opposition.
*. The Defendants have not been served with a complaint in this case by Diorio, which is required given the new case number. Defendants had been served with a complaint by * Fountain Street, LLC but not by Diorio.
*. The Plaintiff, * Fountain Street, LLC, filed an emergency motion to continue the hearing, referencing a different case number (2573CV00006) and indicating that the hearing was scheduled to address the Defendants' motions for extension of time to answer the Plaintiff’s complaint, which is not accurate.
*. The Defendants seek clarification on the following issues:
- The correct case number and procedural status of the case.
- Whether a complaint has been properly filed and served in accordance with the rules of civil procedure.
- The specific motions to be addressed at the hearing on February *, *.
*. The Defendants respectfully request that the hearing be continued to allow for proper service of a complaint and to provide sufficient time for the Defendants to prepare an appropriate response.
WHEREFORE, the Defendants, James M. Cronan and Karen Merritt, respectfully request that this Court:
*. Clarify the procedural posture of this case, including the proper case number and the status of the complaint.
*. Continue the hearing currently scheduled for February *, *, to a later date to allow for proper service and preparation.
*. Grant any other relief the Court deems just and proper.
Respectfully submitted,
James M. Cronan
Karen Merritt
[Your Address]
[City, State, ZIP Code]
[Phone Number]
[Email Address]
Date: [Insert Date]

Motion for Case No. 2573CV00006:
---
MOTION TO CLARIFY AND CONTINUE HEARING
COMMONWEALTH OF MASSACHUSETTS
BRISTOL SUPERIOR COURT
CIVIL ACTION NO. 2573CV00006
* FOUNTAIN STREET, LLC, Plaintiff,
v.
JAMES CRONAN and KAREN MERRITT, Defendants.
MOTION TO CLARIFY AND CONTINUE HEARING
NOW COME the Defendants, James M. Cronan and Karen Merritt, and respectfully move this Honorable Court to clarify the procedural posture of this case and to continue the hearing currently scheduled for February *, *. In support of this motion, the Defendants state as follows:
*. On February *, *, the Defendants received a notice to appear for a motion hearing scheduled for February *, *, in the case * Fountain Street, LLC v. Cronan, James M. and Merritt, Karen et al., docket number 2573CV00006.
*. The notice referenced a motion filed by Plaintiff * Fountain Street, LLC, seeking to substitute as Plaintiff and for reissuance of execution with opposition.
*. The Defendants have not been served with a complaint in this case by Diorio, which is required given the new case number. Defendants had been served with a complaint by * Fountain Street, LLC but not by Diorio.
*. The Plaintiff, * Fountain Street, LLC, filed an emergency motion to continue the hearing, referencing this case number and indicating that the hearing was scheduled to address the Defendants' motions for extension of time to answer the Plaintiff’s complaint, which is not accurate.
*. The Defendants seek clarification on the following issues:
- The correct case number and procedural status of the case.
- Whether a complaint has been properly filed and served in accordance with the rules of civil procedure.
- The specific motions to be addressed at the hearing on February *, *.
*. The Defendants respectfully request that the hearing be continued to allow for proper service of a complaint and to provide sufficient time for the Defendants to prepare an appropriate response.
WHEREFORE, the Defendants, James M. Cronan and Karen Merritt, respectfully request that this Court:
*. Clarify the procedural posture of this case, including the proper case number and the status of the complaint.
*. Continue the hearing currently scheduled for February *, *, to a later date to allow for proper service and preparation.
*. Grant any other relief the Court deems just and proper.
Respectfully submitted,
James M. Cronan
Karen Merritt
[Your Address]
[City, State, ZIP Code]
[Phone Number]
[Email Address]
Date: [Insert Date]
Would you like any further revisions or additional details?

i THINK WE NEED TO CORRECT *. On Feburary * * the court issued a notice to appear for Motion hearing with a case name Diorio, chapter * trustee of ClASSIC DISPLAY, Inc. Josep M Vs Cronan James and Merritt Karen with a dockert Number 1573CV00296. On February *, * Defendants recieved a motion from * Fountain street LLC The Plaintiff, * Fountain Street, LLC, filed an emergency motion to continue that "Diorio" hearing on *-* which they were not a party too and indicating that the hearing was scheduled to address the Defendants' motions for extension of time to answer the Plaintiff’s complaint, which is not accurate.

Case Rating: *
Sure, here are the revised motions:

Motion for Case No. 1573CV00296:
---
MOTION TO CLARIFY AND CONTINUE HEARING
COMMONWEALTH OF MASSACHUSETTS
BRISTOL SUPERIOR COURT
CIVIL ACTION NO. 1573CV00296
DIORIO, CHAPTER * TRUSTEE OF CLASSIC DISPLAY, INC. JOSEPH M., Plaintiff,
v.
JAMES M. CRONAN and KAREN MERRITT, Defendants.
MOTION TO CLARIFY AND CONTINUE HEARING
NOW COME the Defendants, James M. Cronan and Karen Merritt, and respectfully move this Honorable Court to clarify the procedural posture of this case and to continue the hearing currently scheduled for February *, *. In support of this motion, the Defendants state as follows:
*. On February *, *, the court issued a notice to appear for a motion hearing with the case name Diorio, Chapter * Trustee of Classic Display, Inc. Joseph M. v. Cronan, James M. and Merritt, Karen, docket number 1573CV00296.
*. On February *, *, the Defendants received a motion from * Fountain Street, LLC. The Plaintiff, * Fountain Street, LLC, filed an emergency motion to continue that "Diorio" hearing on February *, *, which they were not a party to, and indicated that the hearing was scheduled to address the Defendants' motions for extension of time to answer the Plaintiff’s complaint, which is not accurate.
*. The Defendants have not been served with a complaint in this case by Diorio, which is required given the new case number. Defendants had been served with a complaint by * Fountain Street, LLC but not by Diorio.
*. The Plaintiff, * Fountain Street, LLC, filed an emergency motion to continue the hearing, referencing a different case number (2573CV00006) and indicating that the hearing was scheduled to address the Defendants' motions for extension of time to answer the Plaintiff’s complaint, which is not accurate.
*. The Defendants seek clarification on the following issues:
- The correct case number and procedural status of the case.
- Whether a complaint has been properly filed and served in accordance with the rules of civil procedure.
- The specific motions to be addressed at the hearing on February *, *.
*. The Defendants respectfully request that the hearing be continued to allow for proper service of a complaint and to provide sufficient time for the Defendants to prepare an appropriate response.
WHEREFORE, the Defendants, James M. Cronan and Karen Merritt, respectfully request that this Court:
*. Clarify the procedural posture of this case, including the proper case number and the status of the complaint.
*. Continue the hearing currently scheduled for February *, *, to a later date to allow for proper service and preparation.
*. Grant any other relief the Court deems just and proper.
Respectfully submitted,
James M. Cronan
Karen Merritt
[Your Address]
[City, State, ZIP Code]
[Phone Number]
[Email Address]
Date: [Insert Date]

Motion for Case No. 2573CV00006:
---
MOTION TO CLARIFY AND CONTINUE HEARING
COMMONWEALTH OF MASSACHUSETTS
BRISTOL SUPERIOR COURT
CIVIL ACTION NO. 2573CV00006
* FOUNTAIN STREET, LLC, Plaintiff,
v.
JAMES CRONAN and KAREN MERRITT, Defendants.
MOTION TO CLARIFY AND CONTINUE HEARING
NOW COME the Defendants, James M. Cronan and Karen Merritt, and respectfully move this Honorable Court to clarify the procedural posture of this case and to continue the hearing currently scheduled for February *, *. In support of this motion, the Defendants state as follows:
*. On February *, *, the court issued a notice to appear for a motion hearing with the case name Diorio, Chapter * Trustee of Classic Display, Inc. Joseph M. v. Cronan, James M. and Merritt, Karen, docket number 1573CV00296.
*. On February *, *, the Defendants received a motion from * Fountain Street, LLC. The Plaintiff, * Fountain Street, LLC, filed an emergency motion to continue that "Diorio" hearing on February *, *, which they were not a party to, and indicated that the hearing was scheduled to address the Defendants' motions for extension of time to answer the Plaintiff’s complaint, which is not accurate.
*. The Defendants have not been served with a complaint in this case by Diorio, which is required given the new case number. Defendants had been served with a complaint by * Fountain Street, LLC but not by Diorio.
*. The Plaintiff, * Fountain Street, LLC, filed an emergency motion to continue the hearing, referencing this case number and indicating that the hearing was scheduled to address the Defendants' motions for extension of time to answer the Plaintiff’s complaint, which is not accurate.
*. The Defendants seek clarification on the following issues:
- The correct case number and procedural status of the case.
- Whether a complaint has been properly filed and served in accordance with the rules of civil procedure.
- The specific motions to be addressed at the hearing on February *, *.
*. The Defendants respectfully request that the hearing be continued to allow for proper service of a complaint and to provide sufficient time for the Defendants to prepare an appropriate response.
WHEREFORE, the Defendants, James M. Cronan and Karen Merritt, respectfully request that this Court:
*. Clarify the procedural posture of this case, including the proper case number and the status of the complaint.
*. Continue the hearing currently scheduled for February *, *, to a later date to allow for proper service and preparation.
*. Grant any other relief the Court deems just and proper.
Respectfully submitted,
James M. Cronan
Karen Merritt
[Your Address]
[City, State, ZIP Code]
[Phone Number]
[Email Address]
Date: [Insert Date]
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