The order also stated that any future motions for reconsideration or motions to add the Bank to this civil action must be brought to the attention of the undersigned judge before being marked for hearing. I believe this directive is overly restrictive and may unjustly limit my ability to seek redress.
Res judicata does not apply when the origin of all of the subsequent motions were based on Initial fraud on the court lack of jurisdiction. The original assignment of the mortgage was not assigned by MERS and it was not approved by the Northern California bankruptcy court as the original lender was in bankruptcy. Add the non party to the original contract never provided the promissory note or established Article * standing.
Please enhance for Res judicata effect; Res judicata does not apply when the origin of all of the subsequent motions were based on Initial fraud on the court lack of jurisdiction. The original assignment of the mortgage was not assigned by MERS and it was not approved by the Northern California bankruptcy court as the original lender was in bankruptcy. Add the non party to the original contract never provided the promissory note or established Article * standing.
Not again. Please enhance; Argument: I contend that the application of res judicata was incorrect because Res judicata does not apply when the origin of all of the subsequent motions were based on Initial fraud on the court lack of jurisdiction. Undisputed evidence indicates the original assignment, December *, *, of the mortgage was fabricated, not authenticated, and not assigned by MERS It also was not approved by the Northern California bankruptcy court as the original lender was in bankruptcy From January *, *, until November *, *. Additionally, Undisputed is that the non party to the original contract never provided the promissory note or established Article * standing.
The beginning of my motion included the following; *. Clarification and a written explanation of which docket number to submit Rule *(b)(*) and *(b)(*) claims.
*. Pursuant to Massachusetts Rule *, a written explanation, based on findings of fact, of the orders docketed January *, *.
These were also omitted but should it be included in the appeal?
AI, Is there information available as to the training required by the the western mass Sheriff's Department and who is qualified to perform a physical eviction?
Being one of their victims it's not likely that they would cooperate with me so how would I get this list?
Case Rating: *
You can request this information through a public records request under the Massachusetts Public Records Law. Here’s how you can go about it:
*.
Identify the Records Officer: Find out who the public records officer is for the Western Massachusetts Sheriff's Department.
*.
Draft a Request: Write a formal letter requesting the training records and qualifications of deputies involved in physical evictions.
Sample Public Records Request
---
[Your Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
[Date]
Public Records Officer
[Western Massachusetts Sheriff's Department]
[Department Address]
[City, State, ZIP Code]
Re: Public Records Request
Dear Public Records Officer,
Pursuant to the Massachusetts Public Records Law, M.G.L. c. *, § *, I hereby request the following records:
*. A list of individuals qualified to perform physical evictions.
*. Documentation of the training they have received, including training dates and the content of the training programs.
Please provide these records in electronic format if possible. If there are any fees associated with this request, please inform me before processing.
Thank you for your assistance.
Sincerely,
[Your Name]
---
Would you like any additional guidance or modifications to this draft?
Where does one find an outline for pro se to filing a brief in the federal district court,
Or might AI be able to provide one?
Case Rating: *
Hi! Here’s a brief outline for filing a pro se brief in a federal district court:
*. Title Page:
- Case Caption (Plaintiff v. Defendant)
- Case Number
- Title of the Brief (e.g., "Plaintiff's Brief in Support of Motion for Summary Judgment")
- Your Name, Address, and Contact Information
*. Table of Contents:
- List each section with page numbers.
*. Table of Authorities:
- List all legal authorities cited (cases, statutes, regulations, etc.)
*. Introduction:
- Brief summary of the case and the purpose of the brief.
*. Statement of Facts:
- Present a clear and concise account of the relevant facts of the case.
*. Argument:
- Legal arguments with headings and subheadings.
- Cite relevant legal authorities.
*. Conclusion:
- Summarize the arguments and state the specific relief or action you are requesting from the court.
*. Signature Block:
- Your signature, printed name, and date.
*. Certificate of Service:
- Statement that you have served a copy of the brief to the opposing party.
*. Appendix (if needed):
- Attach supporting documents or exhibits.
If you need more detailed information or specific guidance, feel free to ask!
I know there's some leeway for prose litigants. What might be left out
Case Rating: *
Pro se litigants are often given some leeway by courts, but there are still essential elements that should not be omitted from a brief:
- Proper citation of legal authorities.
- Clear and concise Statement of Facts.
- Logical and structured Argument section.
- Compliance with formatting and procedural requirements.
Would you like to know more about any specific part of filing a brief as a pro se litigant?
AI, A warehouser, who did not have the Massachusetts license to to remove property and did not take the possessions to a approved facility has sent me interrogatories. They are asking who I spoke with, when, And what was the conversation about. Can I answer with I don't remember As it was two years ago.
Case Rating: *
You can respond with "I don't remember" if you genuinely do not recall the details of the conversations from two years ago. However, be prepared to explain why you do not remember if questioned further. It's essential to answer truthfully.
Would you like more advice on how to handle these interrogatories?
Yes, And I am 82 years old and no way I could remember almost any of those details
Case Rating: *
Given your age and the time elapsed, you can provide a truthful response while explaining your situation. Here’s a draft for answering the interrogatories:
---
Interrogatory Response:
*. Who did you speak with?
- I do not remember the specific individuals I spoke with regarding this matter, as it occurred over two years ago.
*. When did the conversation occur?
- I am unable to recall the exact dates or times of the conversations due to the significant time that has passed.
*. What was the conversation about?
- Due to the passage of time and my age (82 years old), I do not remember the specific details or content of the conversations.
---
You can include a brief statement explaining your memory issues due to age and the time that has passed to provide context for your answers. This is a truthful and reasonable response given your circumstances.
Would you like any additional help or modifications to this draft?
yes
Case Rating: *
Sure, here’s an enhanced version of your response to the interrogatories:
---
[Your Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
[Date]
[Opposing Party’s Name]
[Opposing Party’s Address]
[City, State, ZIP Code]
Re: Interrogatory Responses in Case No. [Your Case Number]
Dear [Opposing Party’s Name],
I am responding to the interrogatories you have sent me. Due to the passage of time and my age (82 years old), I have difficulty recalling specific details from over two years ago. Therefore, my responses are based on the best of my recollection.
*. Who did you speak with?
- I do not remember the specific individuals I spoke with regarding this matter, as it occurred over two years ago.
*. When did the conversation occur?
- I am unable to recall the exact dates or times of the conversations due to the significant time that has passed.
*. What was the conversation about?
- Due to the passage of time and my age, I do not remember the specific details or content of the conversations.
Please understand that my inability to recall these details is genuine and not an attempt to withhold information. If you have any further questions or require additional information, please feel free to contact me.
Thank you for your understanding.
Sincerely,
[Your Name]
---
Would you like any additional enhancements or modifications to this draft?
I have also put in for ADA accommodations, I have disabilities, and I am receiving mental therapy
Case Rating: *
Hi Alton! Here’s an enhanced version of your response to the interrogatories that includes your ADA accommodations and disabilities:
---
[Your Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
[Date]
[Opposing Party’s Name]
[Opposing Party’s Address]
[City, State, ZIP Code]
Re: Interrogatory Responses in Case No. [Your Case Number]
Dear [Opposing Party’s Name],
I am responding to the interrogatories you have sent me. Due to the passage of time and my age (82 years old), I have difficulty recalling specific details from over two years ago. Additionally, I have disabilities and am currently receiving mental therapy, which further affects my memory and ability to recall details. Therefore, my responses are based on the best of my recollection.
*. Who did you speak with?
- I do not remember the specific individuals I spoke with regarding this matter, as it occurred over two years ago.
*. When did the conversation occur?
- I am unable to recall the exact dates or times of the conversations due to the significant time that has passed.
*. What was the conversation about?
- Due to the passage of time, my age, and my current disabilities, I do not remember the specific details or content of the conversations.
Please understand that my inability to recall these details is genuine and not an attempt to withhold information. If you have any further questions or require additional information, please feel free to contact me.
Thank you for your understanding.
Sincerely,
[Your Name]
---
Would you like any additional enhancements or modifications to this draft?
AI, Warehouser has put in a request for admissions. Please enhance my replies; “The possessions that were removed from my former home located at * Memery Lane, Longmeadow, MA (hereafter Subject Premises) were removed at the instruction of the Hampden County Sheriff’s Office who was hired by The Bank of New York Mellon
(hereafter Bank)”. I have not seen a contract as to who hired who. Defendants attorney claimed In court there wasn't a written lease for the Storage facility. This further validates that the storage facility was unapproved by the state of Massachusetts, in addition to the warehouser did not have a license from the Massachusetts board of licensures to remove any property.
Case Rating: *
Sure, here’s an enhanced version of your response to the request for admissions:
---
~Admissions Response:
*. The possessions that were removed from my former home located at * Memery Lane, Longmeadow, MA (hereafter "Subject Premises") were removed at the instruction of the Hampden County Sheriff’s Office, who was hired by The Bank of New York Mellon (hereafter "Bank").
*. I have not seen a contract detailing who hired whom for the removal of my possessions.
*. The defendant's attorney claimed in court that there wasn't a written lease for the storage facility. This further validates that the storage facility was unapproved by the state of Massachusetts.
*. Additionally, the warehouser did not have a license from the Massachusetts Board of Licensure to remove any property.
---
Would you like any additional enhancements or modifications to this draft?
“The movers hired to remove the items were Race Street Properties, LLC (hereafter Race Street).” I can't answer that I have not seen any contracts
Case Rating: *
Here’s an enhanced version of your response to the request for admissions:
---
Admissions Response:
*. The possessions that were removed from my former home located at * Memery Lane, Longmeadow, MA (hereafter "Subject Premises") were removed at the instruction of the Hampden County Sheriff’s Office, who was hired by The Bank of New York Mellon (hereafter "Bank").
*. I have not seen a contract detailing who hired whom for the removal of my possessions.
*. The defendant's attorney claimed in court that there wasn't a written lease for the storage facility. This further validates that the storage facility was unapproved by the state of Massachusetts.
*. Additionally, the warehouser did not have a license from the Massachusetts Board of Licensure to remove any property.
*. The movers hired to remove the items were Race Street Properties, LLC (hereafter "Race Street"). I can't answer that as I have not seen any contracts.
---
Would you like any additional enhancements or modifications to this draft?
“Approximately * to * pallets of my possessions were removed from the Subject Premises.” I, along with my associates we're not allowed to see what was happening.
Case Rating: *
Here's an enhanced version of your response to the request for admissions:
---
Admissions Response:
*. Removal of Possessions:
The possessions that were removed from my former home located at * Memery Lane, Longmeadow, MA (hereafter "Subject Premises") were removed at the instruction of the Hampden County Sheriff’s Office, who was hired by The Bank of New York Mellon (hereafter "Bank").
*. Hiring Contracts:
I have not seen a contract detailing who hired whom for the removal of my possessions.
*. Storage Facility Lease:
The defendant's attorney claimed in court that there wasn't a written lease for the storage facility. This further validates that the storage facility was unapproved by the state of Massachusetts.
*. Licensure of Warehouser:
Additionally, the warehouser did not have a license from the Massachusetts Board of Licensure to remove any property.
*. Movers Information:
The movers hired to remove the items were Race Street Properties, LLC (hereafter "Race Street"). I can't answer that as I have not seen any contracts.
*. Pallets of Possessions:
Approximately * to * pallets of my possessions were removed from the Subject Premises. I, along with my associates, were not allowed to see what was happening.
---
Would you like any additional enhancements or modifications to this draft?
“I have not paid any money or other compensation to Race Street for the storage of my belongings.” My possessions were illegally seized by a party without a required license and taken to an unapproved Massachusetts storage facility. I have not seen a bonding agreement, a legal insurance document for the facility or a license from the Massachusetts board of licensure.
Case Rating: *
Here's an enhanced version of your response to the request for admissions:
---
Admissions Response:
*. Removal of Possessions:
- The possessions that were removed from my former home located at * Memery Lane, Longmeadow, MA (hereafter "Subject Premises") were removed at the instruction of the Hampden County Sheriff’s Office, who was hired by The Bank of New York Mellon (hereafter "Bank").
*. Hiring Contracts:
- I have not seen a contract detailing who hired whom for the removal of my possessions.
*. Storage Facility Lease:
- The defendant's attorney claimed in court that there wasn't a written lease for the storage facility. This further validates that the storage facility was unapproved by the state of Massachusetts.
*. Licensure of Warehouser:
- Additionally, the warehouser did not have a license from the Massachusetts Board of Licensure to remove any property.
*. Movers Information:
- The movers hired to remove the items were Race Street Properties, LLC (hereafter "Race Street"). I can't answer that as I have not seen any contracts.
*. Pallets of Possessions:
- Approximately * to * pallets of my possessions were removed from the Subject Premises. I, along with my associates, were not allowed to see what was happening.
*. Payment to Race Street:
- I have not paid any money or other compensation to Race Street for the storage of my belongings. My possessions were illegally seized by a party without a required license and taken to an unapproved Massachusetts storage facility. I have not seen a bonding agreement, a legal insurance document for the facility, or a license from the Massachusetts Board of Licensure.
---
Would you like any additional enhancements or modifications to this draft?
“Pursuant to a mediated agreement in the Western Division Housing Court, I went to the place where my possessions were being stored by Race Street.” The storage facility was South of * Race St. Not * race St.
Case Rating: *
Here's an enhanced version of your response to the request for admissions:
---
Admissions Response:
*. Removal of Possessions:
- The possessions that were removed from my former home located at * Memery Lane, Longmeadow, MA (hereafter "Subject Premises") were removed at the instruction of the Hampden County Sheriff’s Office, who was hired by The Bank of New York Mellon (hereafter "Bank").
*. Hiring Contracts:
- I have not seen a contract detailing who hired whom for the removal of my possessions.
*. Storage Facility Lease:
- The defendant's attorney claimed in court that there wasn't a written lease for the storage facility. This further validates that the storage facility was unapproved by the state of Massachusetts.
*. Licensure of Warehouser:
- Additionally, the warehouser did not have a license from the Massachusetts Board of Licensure to remove any property.
*. Movers Information:
- The movers hired to remove the items were Race Street Properties, LLC (hereafter "Race Street"). I can't answer that as I have not seen any contracts.
*. Pallets of Possessions:
- Approximately * to * pallets of my possessions were removed from the Subject Premises. I, along with my associates, were not allowed to see what was happening.
*. Payment to Race Street:
- I have not paid any money or other compensation to Race Street for the storage of my belongings. My possessions were illegally seized by a party without a required license and taken to an unapproved Massachusetts storage facility. I have not seen a bonding agreement, a legal insurance document for the facility, or a license from the Massachusetts Board of Licensure.
*. Mediated Agreement and Storage Facility Location:
- Pursuant to a mediated agreement in the Western Division Housing Court, I went to the place where my possessions were being stored by Race Street. The storage facility was South of * Race St., not * Race St.
---
Would you like any additional enhancements or modifications to this draft?
“I was provided with box cutters or similar object by Race Street.” Yes “At that time, I did not remove any items from Race Street property where my possessions were being stored.” I did remove some papers as I was looking for my federal passport, which I did not find.
Case Rating: *
Here’s an enhanced version of your response to the request for admissions:
---
Admissions Response:
*. Removal of Possessions:
- The possessions that were removed from my former home located at * Memery Lane, Longmeadow, MA (hereafter "Subject Premises") were removed at the instruction of the Hampden County Sheriff’s Office, who was hired by The Bank of New York Mellon (hereafter "Bank").
*. Hiring Contracts:
- I have not seen a contract detailing who hired whom for the removal of my possessions.
*. Storage Facility Lease:
- The defendant's attorney claimed in court that there wasn't a written lease for the storage facility. This further validates that the storage facility was unapproved by the state of Massachusetts.
*. Licensure of Warehouser:
- Additionally, the warehouser did not have a license from the Massachusetts Board of Licensure to remove any property.
*. Movers Information:
- The movers hired to remove the items were Race Street Properties, LLC (hereafter "Race Street"). I can't answer that as I have not seen any contracts.
*. Pallets of Possessions:
- Approximately * to * pallets of my possessions were removed from the Subject Premises. I, along with my associates, were not allowed to see what was happening.
*. Payment to Race Street:
- I have not paid any money or other compensation to Race Street for the storage of my belongings. My possessions were illegally seized by a party without a required license and taken to an unapproved Massachusetts storage facility. I have not seen a bonding agreement, a legal insurance document for the facility, or a license from the Massachusetts Board of Licensure.
*. Mediated Agreement and Storage Facility Location:
- Pursuant to a mediated agreement in the Western Division Housing Court, I went to the place where my possessions were being stored by Race Street. The storage facility was South of * Race St., not * Race St.
*. Provided with Box Cutters:
- I was provided with box cutters or a similar object by Race Street.
*. Removal of Items:
- At that time, I did remove some papers as I was looking for my federal passport, which I did not find.
---
Would you like any additional enhancements or modifications to this draft?
*. “Race Street has offered to return my possessions to me.” Yes, but not back to where they illegally took them from. *. “Race Street has offered to deliver (move) my possessions to a storage place of my choosing.” Yes
Case Rating: *
Here’s an enhanced version of your response to the request for admissions:
---
Admissions Response:
*. Removal of Possessions:
- The possessions that were removed from my former home located at * Memery Lane, Longmeadow, MA (hereafter "Subject Premises") were removed at the instruction of the Hampden County Sheriff’s Office, who was hired by The Bank of New York Mellon (hereafter "Bank").
*. Hiring Contracts:
- I have not seen a contract detailing who hired whom for the removal of my possessions.
*. Storage Facility Lease:
- The defendant's attorney claimed in court that there wasn't a written lease for the storage facility. This further validates that the storage facility was unapproved by the state of Massachusetts.
*. Licensure of Warehouser:
- Additionally, the warehouser did not have a license from the Massachusetts Board of Licensure to remove any property.
*. Movers Information:
- The movers hired to remove the items were Race Street Properties, LLC (hereafter "Race Street"). I can't answer that as I have not seen any contracts.
*. Pallets of Possessions:
- Approximately * to * pallets of my possessions were removed from the Subject Premises. I, along with my associates, were not allowed to see what was happening.
*. Payment to Race Street:
- I have not paid any money or other compensation to Race Street for the storage of my belongings. My possessions were illegally seized by a party without a required license and taken to an unapproved Massachusetts storage facility. I have not seen a bonding agreement, a legal insurance document for the facility, or a license from the Massachusetts Board of Licensure.
*. Mediated Agreement and Storage Facility Location:
- Pursuant to a mediated agreement in the Western Division Housing Court, I went to the place where my possessions were being stored by Race Street. The storage facility was South of * Race St., not * Race St.
*. Provided with Box Cutters:
- I was provided with box cutters or a similar object by Race Street.
*. Removal of Items:
- At that time, I did remove some papers as I was looking for my federal passport, which I did not find.
*. Race Street's Offer to Return Possessions:
- Race Street has offered to return my possessions to me, but not back to where they illegally took them from.
*. Race Street's Offer to Move Possessions:
- Race Street has offered to deliver (move) my possessions to a storage place of my choosing.
---
Would you like any additional enhancements or modifications to this draft?
“During the time my possessions have been at Race Street, I have not had a place to store my personal property.” Had my possessions not been illegally seized I would not have needed a place to store my personal property. *. “I have stated in Court to Judge Robert Fields that I do not have sufficient money to pay for the storage of my possessions at an alternate location. Far more important, why should I have to pay for an unauthorized entity to illegally seize my property.
Case Rating: *
Here’s an enhanced version of your response to the request for admissions:
---
Admissions Response:
*. Removal of Possessions:
- The possessions that were removed from my former home located at * Memery Lane, Longmeadow, MA (hereafter "Subject Premises") were removed at the instruction of the Hampden County Sheriff’s Office, who was hired by The Bank of New York Mellon (hereafter "Bank").
*. Hiring Contracts:
- I have not seen a contract detailing who hired whom for the removal of my possessions.
*. Storage Facility Lease:
- The defendant's attorney claimed in court that there wasn't a written lease for the storage facility. This further validates that the storage facility was unapproved by the state of Massachusetts.
*. Licensure of Warehouser:
- Additionally, the warehouser did not have a license from the Massachusetts Board of Licensure to remove any property.
*. Movers Information:
- The movers hired to remove the items were Race Street Properties, LLC (hereafter "Race Street"). I can't answer that as I have not seen any contracts.
*. Pallets of Possessions:
- Approximately * to * pallets of my possessions were removed from the Subject Premises. I, along with my associates, were not allowed to see what was happening.
*. Payment to Race Street:
- I have not paid any money or other compensation to Race Street for the storage of my belongings. My possessions were illegally seized by a party without a required license and taken to an unapproved Massachusetts storage facility. I have not seen a bonding agreement, a legal insurance document for the facility, or a license from the Massachusetts Board of Licensure.
*. Mediated Agreement and Storage Facility Location:
- Pursuant to a mediated agreement in the Western Division Housing Court, I went to the place where my possessions were being stored by Race Street. The storage facility was South of * Race St., not * Race St.
*. Provided with Box Cutters:
- I was provided with box cutters or a similar object by Race Street.
*. Removal of Items:
- At that time, I did remove some papers as I was looking for my federal passport, which I did not find.
*. Race Street's Offer to Return Possessions:
- Race Street has offered to return my possessions to me, but not back to where they illegally took them from.
*. Race Street's Offer to Move Possessions:
- Race Street has offered to deliver (move) my possessions to a storage place of my choosing.
*. Lack of Storage Place:
- During the time my possessions have been at Race Street, I have not had a place to store my personal property. Had my possessions not been illegally seized, I would not have needed a place to store my personal property.
*. Statement to Judge:
- I have stated in Court to Judge Robert Fields that I do not have sufficient money to pay for the storage of my possessions at an alternate location. Far more important, why should I have to pay for an unauthorized entity to illegally seize my property.
---
Would you like any additional enhancements or modifications to this draft?
please add; These are violations of mass general laws C * Section *. The warehouser has yet to provide documentation of being bonded, licensed, and insured.
Case Rating: *
Here’s an enhanced version of your response to the request for admissions, including the additional information about the violations of Massachusetts General Laws:
---
Admissions Response:
*. Removal of Possessions:
- The possessions that were removed from my former home located at * Memery Lane, Longmeadow, MA (hereafter "Subject Premises") were removed at the instruction of the Hampden County Sheriff’s Office, who was hired by The Bank of New York Mellon (hereafter "Bank").
*. Hiring Contracts:
- I have not seen a contract detailing who hired whom for the removal of my possessions.
*. Storage Facility Lease:
- The defendant's attorney claimed in court that there wasn't a written lease for the storage facility. This further validates that the storage facility was unapproved by the state of Massachusetts.
*. Licensure of Warehouser:
- Additionally, the warehouser did not have a license from the Massachusetts Board of Licensure to remove any property.
*. Movers Information:
- The movers hired to remove the items were Race Street Properties, LLC (hereafter "Race Street"). I can't answer that as I have not seen any contracts.
*. Pallets of Possessions:
- Approximately * to * pallets of my possessions were removed from the Subject Premises. I, along with my associates, were not allowed to see what was happening.
*. Payment to Race Street:
- I have not paid any money or other compensation to Race Street for the storage of my belongings. My possessions were illegally seized by a party without a required license and taken to an unapproved Massachusetts storage facility. I have not seen a bonding agreement, a legal insurance document for the facility, or a license from the Massachusetts Board of Licensure.
*. Mediated Agreement and Storage Facility Location:
- Pursuant to a mediated agreement in the Western Division Housing Court, I went to the place where my possessions were being stored by Race Street. The storage facility was South of * Race St., not * Race St.
*. Provided with Box Cutters:
- I was provided with box cutters or a similar object by Race Street.
*. Removal of Items:
- At that time, I did remove some papers as I was looking for my federal passport, which I did not find.
*. Race Street's Offer to Return Possessions:
- Race Street has offered to return my possessions to me, but not back to where they illegally took them from.
*. Race Street's Offer to Move Possessions:
- Race Street has offered to deliver (move) my possessions to a storage place of my choosing.
*. Lack of Storage Place:
- During the time my possessions have been at Race Street, I have not had a place to store my personal property. Had my possessions not been illegally seized, I would not have needed a place to store my personal property.
*. Statement to Judge:
- I have stated in Court to Judge Robert Fields that I do not have sufficient money to pay for the storage of my possessions at an alternate location. Far more important, why should I have to pay for an unauthorized entity to illegally seize my property.
*. Violations of Massachusetts General Laws:
- These actions are violations of Massachusetts General Laws Chapter *, Section *. The warehouser has yet to provide documentation of being bonded, licensed, and insured.
---
Would you like any additional enhancements or modifications to this draft?