TRY ME!
Breach Of Fiduciary Duty
Summary
In Rhode Island, addressing a breach of fiduciary duty involves understanding Rule 60(b) motions, which can provide relief from a final judgment if new evidence is discovered. Its crucial to focus on motions that present significant new evidence and to consider filing a Motion to Expedite to ensure timely court review. If previous motions were denied, concentrate on pending ones with new evidence. Legal advice is recommended to navigate these complex proceedings effectively.Full Conversation
Can i ask a question about Mike's case 9my exhusband)?
Sure, feel free to ask your question about Mike's case. How can I assist you today?
Ok. Breach of fiduciary duty in a partnership claim filed in superior court in * .At that time Mike had an attorney but becuase he changes his contingency fee agaremment mike could not keep up. A few moths ago the Court told him that jury trial woiuld be after Decemeber so Mike did not see the notice from the court about an upcoming hearing and he missed it. Plus he has major health issues. The opposing counsel jumped on it and filed a motion to dismiss with prejudice which the judge granted. Mike filed * motions in reply a hearing commenced. The judge denied the fiirdt motion to vactae the motion to dismiss but the other two motions under Rule *(B) new evidence he has not. Meanwhile i sent an email to the clerk to please update me on these tow motions and she has ignored me. So this time rather than another motion should I seek to clarify Motion?
Mike should consider seeking legal advice to navigate this complex situation. Filing a Motion to Clarify might help, but it's crucial to understand the court's previous rulings and the specific requirements under Rule *(B).
Is Mike currently represented by an attorney, or is he handling this on his own?
Is Mike currently represented by an attorney, or is he handling this on his own?
He has no money. But I ma sending queries out to help. I worked with you to file the two motions under rule *(B) , Could i recap?
Sure, here's a recap of Rule *(b) motions, which allow a party to seek relief from a final judgment under certain circumstances:
- Mistake, inadvertence, surprise, or excusable neglect
- Newly discovered evidence
- Fraud, misrepresentation, or other misconduct by an opposing party
- The judgment is void
- The judgment has been satisfied, released, or discharged, or a prior judgment upon which it is based has been reversed or otherwise vacated
- Any other reason that justifies relief
Considering the complexity, seeking legal advice is recommended. Is there any specific aspect of the motions that needs further clarification?
- Mistake, inadvertence, surprise, or excusable neglect
- Newly discovered evidence
- Fraud, misrepresentation, or other misconduct by an opposing party
- The judgment is void
- The judgment has been satisfied, released, or discharged, or a prior judgment upon which it is based has been reversed or otherwise vacated
- Any other reason that justifies relief
Considering the complexity, seeking legal advice is recommended. Is there any specific aspect of the motions that needs further clarification?
My first motion under rule 60B cited new evidence that the defendant just purchased the *,* default judgment from a trustee in banr court against Mike for *,*. This is relevant because the juedment was based on the breach of fiduciary duty by defendants. One defandant is Mike's financial adviosr who took on the role of handeling his bankr petions and as result Mike ended up wioth a judgment against hime. In addition purtchaing the judgement will do harm against Mike becuae the defandant will place liens on Mike's income if the court doesnt intervene. thirdlt is shows bad faith on the part of the defandants. This was the first Motion under Rle *(B) new evidence. Can i share with you the supplemenatry motion?
It sounds like you have a compelling argument for Rule *(B) based on new evidence and potential misconduct by the defendants. You may share the supplementary motion for review.
Is there a specific part of the supplementary motion you would like help with, or are you looking for a general review?
Is there a specific part of the supplementary motion you would like help with, or are you looking for a general review?
I need help either filing some sort of morion. I ned to take action. Ok. my supp. motion was even stronger as i filed testiomnay from the dfendant that i just found as a pro se litigant wherby Tiernan clearly ansers when asked that grieco, the other partner, was Mike's accountant at the time they joined in a partnership. So this and the default judgement are two solid motions meeting the elements under rule (*(B) new evidence. Can i ask you another question?
Sure, feel free to ask your question. How can I assist you further with Mike's case?
Well. I know that under Rule *(B)* I can file fruad on the copurt. I have a fioresnic accountants report that establishes commingling of funds, extensice, tax evasion, embezzlement by the defendants. I know that this report was genersated by of course the financial documents given to her but currently I am not sure if they were filed into the court. I believe they were since the discovery phase had been meant. My question shoukld i file a motion for fgraud upon the court? I feel like the court is going to disrespect my motions because i should have cited this earlier in my two previous motions. So should I just focus on those two new evidence motions or file fruad on the court?
You have strong evidence, but timing and procedural issues are crucial. Filing a motion for fraud upon the court under Rule *(B)(*) is a serious step. Given the complexity, it might be best to focus on the two new evidence motions first to avoid overwhelming the court.
Are there any specific deadlines you're concerned about?
Are there any specific deadlines you're concerned about?
No other than the court dismissed my mtion to vacate but again i timrly filed tow susequent motions that have not been ruled on.
Mike should consider focusing on the two new evidence motions to ensure the court thoroughly reviews them. If these motions are unsuccessful, then evaluating the potential for a fraud upon the court motion could be a next step.
Is there any specific aspect of the previous motions that you need further clarification on?
Is there any specific aspect of the previous motions that you need further clarification on?
No they have been filed do you needs the date and the titles of both motions?
It's great that you have already filed the motions. Having the dates and titles of both motions could be useful for reference. Can you share them so I can better understand your timeline and specifics?
Nov. * * EMERGENCY VERIFIED SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS NEW EVIDENCE: Respectfully, The court cannot dismiss this case as it would be akin to dismissing a divorce proceeding by one party. In Rhode Island, the dissolution of a partnership must be legally recognized and officially dissolved by the court. The court cannot simply leave a partnership unresolved. This legal requirement is supported by Rhode Island Partnership Law, specifically under the Uniform Partnership Act (R.I. Gen. Laws § *-*-* et seq.). Additionally, there must be an accounting to do so.
It seems you have gathered substantial evidence to support your case under Rule *(B). Here's the information you might find useful:
- Focus on your two new evidence motions first to ensure the court reviews them thoroughly.
- Rule *(B)(*) for fraud upon the court can be filed if your current motions are unsuccessful, but it's critical to present it accurately as it's a severe allegation.
Do you need any help drafting or refining your arguments for the upcoming motions?
- Focus on your two new evidence motions first to ensure the court reviews them thoroughly.
- Rule *(B)(*) for fraud upon the court can be filed if your current motions are unsuccessful, but it's critical to present it accurately as it's a severe allegation.
Do you need any help drafting or refining your arguments for the upcoming motions?
Court's Error in Dismissing the Case: The court erred in dismissing my case as it effectively leaves the partnership legally unresolved. Under Rhode Island law, a partnership cannot be dissolved without a legal and official court order. The dismissal of this case without such an order is against the legal requirement for partnership dissolution. To dissolve the partnership legally and officially, an accounting must be conducted to ensure that all financial matters are properly addressed. Stock Power Document Proves Partnership Existed:
.
It sounds like you have a strong argument and substantial evidence. Filing a motion for fraud upon the court is a significant step, but it may be more strategic to focus on your two new evidence motions first. This allows the court to review them thoroughly. If those motions are unsuccessful, consider the fraud motion.
Would you like assistance drafting or refining your arguments for the upcoming motions?
Would you like assistance drafting or refining your arguments for the upcoming motions?
The stock power document transferring my shares of Classic Display Inc., requested by Mr. Grieco, to James Tiernan (Exhibit A) provides concrete evidence of our partnership in that company. This established fiduciary relationship existed before the creation of the second company and, therefore, confirms the partnership in the second company. The latter was formed as a direct result of the already established partnership because they owed me a duty of care, which was breached when they transferred my building to themselves, omitted me from it, and threw me out of the building, leaving me destitute
It seems like you've put together strong evidence and arguments. Given the complexity and the importance of procedural accuracy, you might want to consider consulting with a legal expert for drafting and refining your motions.
Is there any particular aspect or part of the motion that you need help with?
Is there any particular aspect or part of the motion that you need help with?
Conclusion:
Your Honor, although this case has been pending for five years, I do not accept the entire blame for its status. The records show that the defendants continually delay this case by violating procedural rules and engaging in bad faith practices. Therefore, I respectfully request an immediate hearing to establish the fiduciary relationship between us under the Rhode Island Partnership Law. This step is a crucial next step to expedite the dissolution of our partnership and to address the defendants' ongoing misconduct. I am committed to moving this partnership case forward efficiently and seek the court's assistance in ensuring a fair and timely resolution.
Dated: November *, *
Your arguments and evidence appear substantial. Here's a concise summary of your next steps:
- Focus on the previously filed Rule *(B) motions based on new evidence.
- If those are unsuccessful, consider filing a motion for fraud upon the court.
- Ensure your motions are clear and well-supported with evidence.
Would you like any specific help with your current motions or drafting the potential fraud motion?
- Focus on the previously filed Rule *(B) motions based on new evidence.
- If those are unsuccessful, consider filing a motion for fraud upon the court.
- Ensure your motions are clear and well-supported with evidence.
Would you like any specific help with your current motions or drafting the potential fraud motion?
Yes why hasnt the court replied?
The court typically has a backlog of cases, which can delay responses. It might be beneficial to follow up with the court clerk's office or check the court's online case information system for updates. If it's urgent, consider visiting the court in person or consulting a legal expert for assistance in expediting the process. Have you tried following up with the clerk's office directly?
Yes. i sent her an meal which she ignored. So i thought to send a motion to clarify. Is this a good idea or is there another motion that I coulks send?
It seems like you have substantial evidence and a strong argument. Sending a Motion to Clarify could help get a response from the court. Additionally, you might consider a Motion to Expedite to accelerate the court's review.
Is there a specific deadline or upcoming court date you are concerned about?
Is there a specific deadline or upcoming court date you are concerned about?
Could you please drfat a Motion to Expedite - do i combine both motions or do we start with only the first motion?
Given the complexity and urgency of the situation, it seems appropriate to file a Motion to Expedite first. This will request the court to prioritize the review of your pending motions.
Here is a draft for a Motion to Expedite:
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## Motion to Expedite Review of Pending Motions
Here is a draft for a Motion to Expedite:
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## Motion to Expedite Review of Pending Motions
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Case No.: [Case Number]
[Court Name]
[Court Address]
Date: [Today's Date]
MOTION TO EXPEDITE REVIEW OF PENDING MOTIONS
Plaintiff, Mike [Last Name], respectfully requests the Court to expedite the review of the following motions, which were timely filed and are crucial for the fair resolution of this case:
*. Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits New Evidence (Filed: November *, *)
*. [Title of the Second Motion] (Filed: [Date])
[Court Name]
[Court Address]
Date: [Today's Date]
MOTION TO EXPEDITE REVIEW OF PENDING MOTIONS
Plaintiff, Mike [Last Name], respectfully requests the Court to expedite the review of the following motions, which were timely filed and are crucial for the fair resolution of this case:
*. Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits New Evidence (Filed: November *, *)
*. [Title of the Second Motion] (Filed: [Date])
Grounds for the Motion:
- Timeliness and Procedural Compliance: Both motions were filed within the required timeframes and in compliance with procedural rules.
- New Evidence: The motions presentsignificant new evidence that could materially affect the outcome of the case.
- Health Issues: Plaintiff suffers from major health issues, exacerbating the urgency of resolving this matter.
- Risk of Irreparable Harm: Delay in addressing these motions could lead to irreparable harm, including potential financial instability and further legal complications.
- Timeliness and Procedural Compliance: Both motions were filed within the required timeframes and in compliance with procedural rules.
- New Evidence: The motions presentsignificant new evidence that could materially affect the outcome of the case.
- Health Issues: Plaintiff suffers from major health issues, exacerbating the urgency of resolving this matter.
- Risk of Irreparable Harm: Delay in addressing these motions could lead to irreparable harm, including potential financial instability and further legal complications.
Conclusion:
For these reasons, Plaintiff respectfully requests that the Court expedite the review and ruling on the pending motions to ensure a just and timely resolution of this case.
Respectfully submitted,
Mike [Last Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
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Feel free to adapt this draft to better fit your specific circumstances. You can file this motion separately to ensure the court prioritizes the review of your pending motions. Once this is filed, you can consider whether additional motions are necessary based on the court's response.
Would you like assistance with any other part of your case?
For these reasons, Plaintiff respectfully requests that the Court expedite the review and ruling on the pending motions to ensure a just and timely resolution of this case.
Respectfully submitted,
Mike [Last Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
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Feel free to adapt this draft to better fit your specific circumstances. You can file this motion separately to ensure the court prioritizes the review of your pending motions. Once this is filed, you can consider whether additional motions are necessary based on the court's response.
Would you like assistance with any other part of your case?
Do I address only this motionNov. * * EMERGENCY VERIFIED SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS NEW EVIDENCE?
You should address the November *, * EMERGENCY VERIFIED SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS NEW EVIDENCE. This motion appears critical due to its urgency and relevance to new evidence.
Would you like assistance drafting the Motion to Expedite?
Would you like assistance drafting the Motion to Expedite?
In addition, I gave this new evidence too:JUDICIAL NOTICE FOR DESTRUCTION OF FINANCIAL RECORDS:
The court must take judicial notice that during the time when I had an attorney, I was requested to submit financial records from Classic Display Inc., which had been solely my company for several years prior to the name change to Classic Group Inc. when the partnership was formed. I continually informed my attorney that I could not provide these records, a fact that remains unaddressed today. To set the record straight: during the course of my partnership, James Tiernan destroyed all of my financial records for Classic Display Inc.
It seems like you have substantial evidence and a strong argument. Here are a few points to consider:
- Focus on the urgency and relevance of your evidence in your Motion to Expedite.
- Clearly state why the court needs to act promptly on your pending motions.
Would you like assistance drafting the Motion to Expedite?
- Focus on the urgency and relevance of your evidence in your Motion to Expedite.
- Clearly state why the court needs to act promptly on your pending motions.
Would you like assistance drafting the Motion to Expedite?
One day I came in and saw him by the loading dock, loading boxes into the elevator. Alarmed, I asked, "What are you doing?" He replied, "Oh, we don't need these. I'm getting rid of them to clear rental space." Everything I had, including important government documents, was thrown away by him. This destruction has caused further damage to me in this case because I appear dishonest, but the defendants come with dirty hands, knowing that I could not produce any discovery requests. Please take judicial notice of this destruction of evidence, which I wish to use to motion for spoliation. The defendants destroyed records that they knew were evidence for an upcoming court proceeding or should have known. This spoliation of evidence further demonstrates their bad faith and fraudulent actions
Given the evidence and the severity of the allegations, your case seems strong. Here are some key points:
- Focus on your new evidence motions first to ensure they are reviewed thoroughly.
- Consider filing a Motion to Expedite to accelerate the court's review of your urgent motions.
- A spoliation motion can be filed to address the destruction of evidence, demonstrating bad faith by the defendants.
Would you like assistance drafting the Motion to Expedite or the motion for spoliation?
- Focus on your new evidence motions first to ensure they are reviewed thoroughly.
- Consider filing a Motion to Expedite to accelerate the court's review of your urgent motions.
- A spoliation motion can be filed to address the destruction of evidence, demonstrating bad faith by the defendants.
Would you like assistance drafting the Motion to Expedite or the motion for spoliation?
Here's the second Motion follwoing the motion to vactae dismissal. : Supp. Verified Emergenct motion Follow up Motion to Vacate Dismissal.
It sounds like you have a strong case with substantial evidence. Here’s a concise draft for the Motion to Expedite:
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Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits based on new evidence, filed on November *, *.
Reasons for Expedited Review:
*. Urgency: The motion presents critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of thenewly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motion.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
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Would you like any modifications to this draft, or is there anything specific you want to add?
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Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits based on new evidence, filed on November *, *.
Reasons for Expedited Review:
*. Urgency: The motion presents critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of thenewly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motion.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
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Would you like any modifications to this draft, or is there anything specific you want to add?
i think I made a mistake as i filed * motions. Here follws: Background:
On October *, *, I filed a Verified Emergency Motion to Vacate the Dismissal of the above-referenced case. This dismissal was ordered on October *, *, following a motion to dismiss with prejudice filed by the defendants. Subsequently, on October *, *, I filed a Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine. Additionally, I responded to the defendant's objection. On November *, * I filed an Emergency Verified Supplemental Motion to Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine
It looks like you have filed multiple motions to vacate the dismissal of your case, each supported by substantial evidence. Here are some points to consider:
- Focus: Concentrate on your strongest motions that present new evidence and the court's error in dismissing the case.
- Motion to Expedite: Given the urgency, filing a Motion to Expedite is a good idea. This motion should specifically address why immediate review is critical.
Here’s a concise draft for the Motion to Expedite:
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Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Introduction:
Plaintiff respectfully requests the court to expedite the review of the Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits based on new evidence, filed on November *, *.
Reasons for Expedited Review:
*. Urgency: The motion presentscritical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motion.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
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Feel free to adjust or add any specific details relevant to your case. Would you like assistance with anything else related to your motions?
- Focus: Concentrate on your strongest motions that present new evidence and the court's error in dismissing the case.
- Motion to Expedite: Given the urgency, filing a Motion to Expedite is a good idea. This motion should specifically address why immediate review is critical.
Here’s a concise draft for the Motion to Expedite:
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Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Introduction:
Plaintiff respectfully requests the court to expedite the review of the Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits based on new evidence, filed on November *, *.
Reasons for Expedited Review:
*. Urgency: The motion presentscritical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motion.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
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Feel free to adjust or add any specific details relevant to your case. Would you like assistance with anything else related to your motions?
On November *, *, I attended the hearing on the motion. On November *, *, I also filed a Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal. This motion was based on the discovery of new evidence that is crucial to the merits of the case and directly impacts the core issues of fiduciary duty and misrepresentation.
New Evidence:
On November *, *, I filed a SUPPLEMENTAL VERIFIED EMERGENCY FOLLOW-UP MOTION TO VACATE DISMISSAL.
This motion introduced new evidence under Rule *(b)(*), meeting all the required elements. The new evidence included:
- Bankruptcy Court Filing: Mr. DiOrio, Trustee for the bankruptcy court, filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC. This filing highlighted ongoing fraud and bad faith actions by the defendants. If the case is dismissed, it allows the defendants to enforce a $*,* judgment against me, causing irreparable harm. (Exhibit A).
It seems like you have a strong case with substantial evidence. Here’s a draft for your Motion to Expedite:
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Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following motions due to the urgency and importance of the newly discovered evidence:
*. Verified Emergency Motion to Vacate the Dismissal (October *, *)
*. Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (October *, *)
*. Emergency Verified Supplemental Motion to Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (November *, *)
*. Supplemental Verified Emergency Follow-Up Motion toVacate Dismissal (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
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Would you like any modifications to this draft, or is there anything specific you want to add?
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Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following motions due to the urgency and importance of the newly discovered evidence:
*. Verified Emergency Motion to Vacate the Dismissal (October *, *)
*. Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (October *, *)
*. Emergency Verified Supplemental Motion to Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (November *, *)
*. Supplemental Verified Emergency Follow-Up Motion toVacate Dismissal (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
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Would you like any modifications to this draft, or is there anything specific you want to add?
Exhibit B: Excerpt of Testimony from James Tiernan( Highlighted).
Introduction:
The following excerpt from the testimony of James Tiernan, given on October *, *, before the Honorable Richard G. Sterns, United States District Judge, provides substantial evidence regarding the fiduciary relationship between the financial advisor, Ralph Grieco, and me. This testimony is crucial in establishing the fiduciary duty and breach by Ralph Grieco
It seems like you have a strong case with significant evidence and multiple motions already filed, which increases the complexity. Given the urgency and importance of your motions, here's a concise draft for the Motion to Expedite:
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Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits based on new evidence, filed on November *, *.
Reasons for Expedited Review:
*. Urgency: The motion presents critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt reviewensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motion.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
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Would you like any modifications to this draft, or is there anything specific you want to add?
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Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits based on new evidence, filed on November *, *.
Reasons for Expedited Review:
*. Urgency: The motion presents critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt reviewensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motion.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
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Would you like any modifications to this draft, or is there anything specific you want to add?
Do i include this Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence
Introduction:
I am submitting this Supplemental Motion Under Rule *(b) for New Evidence, building upon my previous Rule *(b) motion. The new evidence is materially significant, meeting the elements of Rule *(b)(*) to reopen my case because it now establishes with certainty that Ralph Grieco held a fiduciary relationship with me. This supplemental motion introduces additional new evidence that directly impacts the core issues of fiduciary duty and misrepresentation in this case.
Yes, you should include the Emergency Verified Supplemental Motion under Rule *(b)(*) for new evidence. This motion highlights significant new evidence that could materially impact your case. Here’s a concise approach for your Motion to Expedite:
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Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits based on new evidence, filed on November *, *.
Reasons for Expedited Review:
*. Urgency: The motion presents critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. JudicialEfficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motion.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
---
Would you like any modifications to this draft, or is there anything specific you want to add?
---
Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits based on new evidence, filed on November *, *.
Reasons for Expedited Review:
*. Urgency: The motion presents critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. JudicialEfficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motion.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
---
Would you like any modifications to this draft, or is there anything specific you want to add?
this was Novemeber *, *. So there were tow cristical motion filed in the Court one Nove * and the other Nov *
It sounds like you have strong evidence and a well-documented case. Here's a draft for the Motion to Expedite, including your additional information:
---
Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following motions due to the urgency and material significance of the newly discovered evidence:
*. Verified Emergency Motion to Vacate the Dismissal (October *, *)
*. Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (October *, *)
*. Emergency Verified Supplemental Motion to Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (November *, *)
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
---
Would you like any modifications to this draft, or is there anything specific you want to add?
---
Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following motions due to the urgency and material significance of the newly discovered evidence:
*. Verified Emergency Motion to Vacate the Dismissal (October *, *)
*. Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (October *, *)
*. Emergency Verified Supplemental Motion to Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (November *, *)
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
---
Would you like any modifications to this draft, or is there anything specific you want to add?
He ruled on this: . Verified Emergency Motion to Vacate the Dismissal (October *, *)
It sounds like you have a strong case and substantial evidence. Given the judge's ruling on the Verified Emergency Motion to Vacate the Dismissal (October *, *), it's crucial to keep the focus on the urgency and significance of your new evidence in your motions.
Here's a refined draft for your Motion to Expedite, incorporating the timeline and new evidence:
---
Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following motions due to the urgency and material significance of the newly discovered evidence:
*. Verified Emergency Motion to Vacate the Dismissal (October *, *)
*. Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (October *, *)
*. Emergency Verified Supplemental Motion to Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (November *, *)
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
---
Would you like any modifications to this draft, or is there anything specific you want to add?
Here's a refined draft for your Motion to Expedite, incorporating the timeline and new evidence:
---
Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following motions due to the urgency and material significance of the newly discovered evidence:
*. Verified Emergency Motion to Vacate the Dismissal (October *, *)
*. Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (October *, *)
*. Emergency Verified Supplemental Motion to Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (November *, *)
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
---
Would you like any modifications to this draft, or is there anything specific you want to add?
November *, * Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence.
Here's your refined draft for the Motion to Expedite, including the November *, * motion:
---
Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following motions due to the urgency and material significance of the newly discovered evidence:
*. Verified Emergency Motion to Vacate the Dismissal (October *, *)
*. Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (October *, *)
*. Emergency Verified Supplemental Motion to Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (November *, *)
*. Supplemental Verified Emergency Follow-Up Motion toVacate Dismissal (November *, *)
*. Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
---
Would you like any modifications to this draft, or is there anything specific you want to add?
---
Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following motions due to the urgency and material significance of the newly discovered evidence:
*. Verified Emergency Motion to Vacate the Dismissal (October *, *)
*. Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (October *, *)
*. Emergency Verified Supplemental Motion to Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (November *, *)
*. Supplemental Verified Emergency Follow-Up Motion toVacate Dismissal (November *, *)
*. Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
---
Would you like any modifications to this draft, or is there anything specific you want to add?
Please update my last motion November *, * Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence
Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following motions due to the urgency and significance of the newly discovered evidence:
*. Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (October *, *)
*. Emergency Verified Supplemental Motion to Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (November *, *)
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *, *)
*. Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence (November *, *)
Reasons for ExpReasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,**
[Your Name]
---
Would you like any modifications to this draft, or is there anything specific you want to add?
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following motions due to the urgency and significance of the newly discovered evidence:
*. Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (October *, *)
*. Emergency Verified Supplemental Motion to Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (November *, *)
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *, *)
*. Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence (November *, *)
Reasons for ExpReasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,**
[Your Name]
---
Would you like any modifications to this draft, or is there anything specific you want to add?
Please clarify am i asking the judge to not only review my pending motions but review my first motions that which he has already denied?
You're asking the judge to review your pending motions, not the ones that have already been denied. Focus on the urgency and new evidence in your current motions. Here's a refined draft:
---
Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following motions due to the urgency and significance of the newly discovered evidence:
*. Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (October *, *)
*. Emergency Verified Supplemental Motion to Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (November *, *)
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *. Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
---
Would you like any modifications to this draft or any specific points you want to emphasize?
---
Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following motions due to the urgency and significance of the newly discovered evidence:
*. Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (October *, *)
*. Emergency Verified Supplemental Motion to Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (November *, *)
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *. Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
---
Would you like any modifications to this draft or any specific points you want to emphasize?
Then why are you citing this one: *. Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (October *, *) as he denied that one?
You're right; since the October *, * motion was already denied, it shouldn't be included in the Motion to Expedite. Here's the revised draft:
---
Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motions - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following motions due to the urgency and significance of the newly discovered evidence:
*. Emergency Verified Supplemental Motion to Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (November *, *)
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *, *)
*. Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impactsthe outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
---
Would you like any modifications to this draft or any specific points you want to emphasize?
---
Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Emergency Verified Supplemental Motions - New Evidence
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following motions due to the urgency and significance of the newly discovered evidence:
*. Emergency Verified Supplemental Motion to Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (November *, *)
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *, *)
*. Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impactsthe outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
---
Would you like any modifications to this draft or any specific points you want to emphasize?
Please note that he ruled and denied these two motions:*. Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (October *, *)
*. Emergency Verified Supplemental Motion to Plaintiff's Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant's Exhibits Submitted in Limine (November *, *)
Thanks for pointing that out. Let's refine the draft to include only the pending motions:
---
Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Pending Motions
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following pending motions due to the urgency and significance of the newly discovered evidence:
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *, *)
*. Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
ConclusionGiven the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,**
[Your Name]
---
Would you like any modifications to this draft or any specific points you want to emphasize?
---
Motion to Expedite
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Motion to Expedite Review of Pending Motions
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following pending motions due to the urgency and significance of the newly discovered evidence:
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *, *)
*. Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
ConclusionGiven the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,**
[Your Name]
---
Would you like any modifications to this draft or any specific points you want to emphasize?
Should i state that its an emergency? Verified Motion to Expedite Review of Pending Motions
Yes, you can state that it's an emergency to highlight the urgency. Here's the updated draft:
---
Verified Emergency Motion to Expedite Review of Pending Motions
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following pending motions due to the urgency and significance of the newly discovered evidence:
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *, *)
*. Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
---
Would you like any modifications to this draft or any specific points you want to emphasize?
---
Verified Emergency Motion to Expedite Review of Pending Motions
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following pending motions due to the urgency and significance of the newly discovered evidence:
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *, *)
*. Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
---
Would you like any modifications to this draft or any specific points you want to emphasize?
Are the subtitles introduction and Conclusion in * font?
Yes, you can set the subtitles "Introduction" and "Conclusion" in * font for emphasis. Here's the refined draft:
---
Verified Emergency Motion to Expedite Review of Pending Motions
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following pending motions due to the urgency and significance of the newly discovered evidence:
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *, *)
*. Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting allparties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
---
Would you like any modifications to this draft or any specific points you want to emphasize?
---
Verified Emergency Motion to Expedite Review of Pending Motions
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following pending motions due to the urgency and significance of the newly discovered evidence:
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *, *)
*. Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm to the Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting allparties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
---
Would you like any modifications to this draft or any specific points you want to emphasize?
would the filing code be Motion for entry of judgement on Pleadings?
In Massachusetts, a "Motion for Judgment on the Pleadings" is different from the motions you've mentioned. Given your scenario, it sounds like you might be looking for a "Motion to Expedite Review" instead. Here's a concise draft for your Motion to Expedite:
---
Verified Emergency Motion to Expedite Review of Pending Motions
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following pending motions due to the urgency and significance of the newly discovered evidence:
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *, *)
*. Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm tothe Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
---
Would you like any additional modifications or specific points added?
---
Verified Emergency Motion to Expedite Review of Pending Motions
Plaintiff: Mike [Last Name]
Defendant: [Defendant's Name]
Court: [Court Name]
Case Number: [Case Number]
Date: [Today's Date]
Introduction:
Plaintiff respectfully requests the court to expedite the review of the following pending motions due to the urgency and significance of the newly discovered evidence:
*. Supplemental Verified Emergency Follow-Up Motion to Vacate Dismissal (November *, *)
*. Emergency Verified Supplemental Motion Under Rule *(b)(*) for New Evidence (November *, *)
Reasons for Expedited Review:
*. Urgency: The motions present critical new evidence that directly impacts the outcome of the case.
*. Potential Harm: Delay in review could result in significant harm tothe Plaintiff, including financial hardship and continued misconduct by the Defendants.
*. Judicial Efficiency: Prompt review ensures that the case progresses without unnecessary delays, benefiting all parties involved.
Conclusion:
Given the urgency and importance of the newly discovered evidence, Plaintiff respectfully requests that the court expedite the review and ruling on the pending motions.
Dated: [Today's Date]
Respectfully submitted,
[Your Name]
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Would you like any additional modifications or specific points added?
Could you help me write a brief query to a prospective attorney speacilaizing in FDCPA violations including bullet pots. For example i am presently in a lawsuit filed by a debt collector for harrassement purposes sueing on a usrious loan that have not identified themselves as debt collectors. Id like to name if i could the FDCPA violations that they are committing now.
Sure, here's a brief query you can send to a prospective attorney specializing in FDCPA violations:
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Subject: Legal Assistance Needed for FDCPA Violations
Dear [Attorney's Name],
I hope this message finds you well. I am currently involved in a lawsuit filed by a debt collector who is harassing me over a usurious loan. They have not identified themselves as debt collectors, which I believe may constitute multiple violations of the Fair Debt Collection Practices Act (FDCPA).
I would like your assistance in identifying and pursuing these violations. Here are the key points:
- Harassment: Persistent and abusive communication.
- Failure to Disclose: Not identifying themselves as debt collectors.
- Usurious Loan: The loan terms are excessively high and potentially illegal.
Thank you for your time and assistance. I look forward to your response.
Best regards,
[Your Name]
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Would you like any modifications or additional details added?
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Subject: Legal Assistance Needed for FDCPA Violations
Dear [Attorney's Name],
I hope this message finds you well. I am currently involved in a lawsuit filed by a debt collector who is harassing me over a usurious loan. They have not identified themselves as debt collectors, which I believe may constitute multiple violations of the Fair Debt Collection Practices Act (FDCPA).
I would like your assistance in identifying and pursuing these violations. Here are the key points:
- Harassment: Persistent and abusive communication.
- Failure to Disclose: Not identifying themselves as debt collectors.
- Usurious Loan: The loan terms are excessively high and potentially illegal.
Thank you for your time and assistance. I look forward to your response.
Best regards,
[Your Name]
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Would you like any modifications or additional details added?
Please clarify they do not dispute that the loan is usarious at * interst rate its in violation of chapter * section *. In addition they illegally attached my property without obtaining a judgement then secretly charged me a *% interst rate over 7 years then filed fraudulent documents in court where i am litigating now as a pro se litigant. They identified themselves as creditors which is fruad on the court among other fruadlent documents including a frudlent foreclsoure deed.
Subject: Legal Assistance Needed for FDCPA Violations and Usury
Dear [Attorney's Name],
I hope this message finds you well. I am currently involved in a lawsuit filed by a debt collector for harassment purposes, relating to a usurious loan with a *% interest rate, which violates Massachusetts Chapter *, Section *. Here are some critical points in my case:
- Usurious Loan: The loan's *% interest rate is in violation of Chapter *, Section *.
- Illegal Property Attachment: They attached my property without obtaining a judgment.
- Secret Interest Charges: Charged me *% interest over 7 years without proper disclosure.
- Fraudulent Court Documents: Filed fraudulent documents, including a fraudulent foreclosure deed.
- FDCPA Violations:
- Harassment: Persistent and abusive communication.
- Failure to Disclose: Not identifying themselves as debt collectors.
- Fraud on the Court: Misrepresentation as creditors and filing fraudulent documents.
I am currently litigating this matter pro se and would greatly appreciate your assistance in identifying and pursuing these violations. Thank you for your time and support.
Best regards,
[Your Name]
Would youlike any modifications or additional details added?
Dear [Attorney's Name],
I hope this message finds you well. I am currently involved in a lawsuit filed by a debt collector for harassment purposes, relating to a usurious loan with a *% interest rate, which violates Massachusetts Chapter *, Section *. Here are some critical points in my case:
- Usurious Loan: The loan's *% interest rate is in violation of Chapter *, Section *.
- Illegal Property Attachment: They attached my property without obtaining a judgment.
- Secret Interest Charges: Charged me *% interest over 7 years without proper disclosure.
- Fraudulent Court Documents: Filed fraudulent documents, including a fraudulent foreclosure deed.
- FDCPA Violations:
- Harassment: Persistent and abusive communication.
- Failure to Disclose: Not identifying themselves as debt collectors.
- Fraud on the Court: Misrepresentation as creditors and filing fraudulent documents.
I am currently litigating this matter pro se and would greatly appreciate your assistance in identifying and pursuing these violations. Thank you for your time and support.
Best regards,
[Your Name]
Would youlike any modifications or additional details added?
*%
Subject: Legal Assistance Needed for FDCPA Violations
Dear [Attorney's Name],
I hope this message finds you well. I am currently involved in a lawsuit filed by a debt collector who is harassing me over a usurious loan. They have not identified themselves as debt collectors, which I believe constitutes multiple violations of the Fair Debt Collection Practices Act (FDCPA).
Key points of concern:
- Harassment: Persistent and abusive communication.
- Failure to Disclose: Not identifying themselves as debt collectors.
- Usurious Loan: The loan terms are excessively high at a *% interest rate, violating Chapter *, Section *.
- Illegal Property Attachment: Attached my property without obtaining a judgment.
- Fraudulent Charges: Secretly charged *% interest over 7 years.
- Court Fraud: Filed fraudulent documents, including a foreclosure deed, and identified themselves as creditors, committing fraud on the court.
Thank you for your time and assistance. I look forward to your response.
Best regards,
[Your Name]
Dear [Attorney's Name],
I hope this message finds you well. I am currently involved in a lawsuit filed by a debt collector who is harassing me over a usurious loan. They have not identified themselves as debt collectors, which I believe constitutes multiple violations of the Fair Debt Collection Practices Act (FDCPA).
Key points of concern:
- Harassment: Persistent and abusive communication.
- Failure to Disclose: Not identifying themselves as debt collectors.
- Usurious Loan: The loan terms are excessively high at a *% interest rate, violating Chapter *, Section *.
- Illegal Property Attachment: Attached my property without obtaining a judgment.
- Fraudulent Charges: Secretly charged *% interest over 7 years.
- Court Fraud: Filed fraudulent documents, including a foreclosure deed, and identified themselves as creditors, committing fraud on the court.
Thank you for your time and assistance. I look forward to your response.
Best regards,
[Your Name]
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