Legal Battle With Advisor

It sounds like you have a strong case with significant evidence to support your motion. Here’s how you can address the issue of supplementary financial records and the credibility of additional financial records in your supplemental motion:
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PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL
To the Honorable Judge Stern,
I, James Cronan, the plaintiff in the above-referenced case, respectfully submit this supplemental motion to support my original motion to vacate the dismissal of my case dated October *, *. This supplemental motion includes additional evidence and arguments as follows:
*. Forensic Accountant’s Report:
- Attached as Exhibit C is the report from a credible forensic accountant, which establishes serious allegations of tax evasion and commingling of funds by the defendant. These findings are critical to the integrity of this case.
*. Judicial Notice:
- I respectfully request that the court take judicial notice of the forensic accountant’s findings. The evidence provided is so authoritative and indisputable that it cannot reasonably be doubted.
*. Ethical Concerns:
- It is imperative to highlight that the opposing counsel, aware of these findings from the deposition of the forensic accountant, might beaiding and abetting criminal conduct. Representing the defendant with the aim of releasing them from liability and not reporting their illegal activities could constitute an act of aiding and abetting.
*. Lack of Notice:
- I did not receive proper notice of the hearing scheduled for October *, *. I discovered the notice was sent via email only after receiving the dismissal notice and conducting a search. [Reattach Exhibits A and B for proof of communication].
*. Health Issues:
- I am currently dealing with severe health issues, including Stage * kidney disease, which has significantly impacted my ability to keep up with court communications and proceedings. I respectfully request an extension of 30 days to submit further medical documentation if required.
*. New Email Address:
- To rectify any future communication issues, I have created a dedicated email address (jamescronan123@gmail.com) and have notified the clerk to use this for all court communications.
*. Consistent Attendance:
- I have never missed a hearing before, indicating my dedication to this case and my compliance with court procedures.
*. Supplementary Financial Records:
- Although I have requested supplementary forensic accounting to abide by court proceedings,

Sure, here's the continuation from point *:
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*. Supplementary Financial Records:
- Although I have requested supplementary forensic accounting to abide by court proceedings, I must emphasize that given the serious findings in the forensic accountant's report, any additional financial records submitted by the defendant may lack credibility. This highlights the necessity for thorough scrutiny and verification of all financial documentation provided.
Given the serious nature of the allegations and the evidence provided, dismissing this case would potentially enable further criminal conduct. I respectfully urge the court to vacate the dismissal and allow the case to proceed.
Respectfully submitted,
James Cronan
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Would you need any additional assistance with this?

It looks like you're on the right track. Here’s the continuation of the supplemental motion with the point on supplementary financial records included:
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PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL
To the Honorable Judge Stern,
I, James Cronan, the plaintiff in the above-referenced case, respectfully submit this supplemental motion to support my original motion to vacate the dismissal of my case dated October *, *. This supplemental motion includes additional evidence and arguments as follows:
*. Forensic Accountant’s Report:
- Attached as Exhibit C is the report from a credible forensic accountant, which establishes serious allegations of tax evasion and commingling of funds by the defendant. These findings are critical to the integrity of this case.
*. Judicial Notice:
- I respectfully request that the court take judicial notice of the forensic accountant’s findings. The evidence provided is so authoritative and indisputable that it cannot reasonably be doubted.
*. Ethical Concerns:
- It is imperative to highlight that the opposing counsel, aware of these findings from the deposition of the forensic accountant, might be aiding and abetting criminal conduct. Representing the defendant with the aimof releasing them from liability and not reporting their illegal activities could constitute an act of aiding and abetting.
*. Lack of Notice:
- I did not receive proper notice of the hearing scheduled for October *, *. I discovered the notice was sent via email only after receiving the dismissal notice and conducting a search. [Reattach Exhibits A and B for proof of communication].
*. Health Issues:
- I am currently dealing with severe health issues, including Stage * kidney disease, which has significantly impacted my ability to keep up with court communications and proceedings. I respectfully request an extension of 30 days to submit further medical documentation if required.
*. New Email Address:
- To rectify any future communication issues, I have created a dedicated email address (jamescronan123@gmail.com) and have notified the clerk to use this for all court communications.
*. Consistent Attendance:
- I have never missed a hearing before, indicating my dedication to this case and my compliance with court procedures.
*. Supplementary Financial Records:
- Although I have requested supplementary forensic accounting to abide by court proceedings, I must emphasize that given the serious findings in the forensic accountant's report,

It sounds like you have a strong basis for your case with significant evidence. Here’s the final draft of the supplemental motion with your specific request:
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PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL
To the Honorable Judge Stern,
I, James Cronan, the plaintiff in the above-referenced case, respectfully submit this supplemental motion to support my original motion to vacate the dismissal of my case dated October *, *. This supplemental motion includes additional evidence and arguments as follows:
*. Forensic Accountant’s Report:
- Attached as Exhibit C is the report from a credible forensic accountant, which establishes serious allegations of tax evasion and commingling of funds by the defendant. These findings are critical to the integrity of this case.
*. Judicial Notice:
- I respectfully request that the court take judicial notice of the forensic accountant’s findings. The evidence provided is so authoritative and indisputable that it cannot reasonably be doubted.
*. Ethical Concerns:
- It is imperative to highlight that the opposing counsel, aware of these findings from the deposition of the forensic accountant, might be aiding and abetting criminal conduct. Representing the defendantwith the aim of releasing them from liability and not reporting their illegal activities could constitute an act of aiding and abetting.
*. Lack of Notice:
- I did not receive proper notice of the hearing scheduled for October *, *. I discovered the notice was sent via email only after receiving the dismissal notice and conducting a search. [Reattach Exhibits A and B for proof of communication].
*. Health Issues:
- I am currently dealing with severe health issues, including Stage * kidney disease, which has significantly impacted my ability to keep up with court communications and proceedings. I respectfully request an extension of 30 days to submit further medical documentation if required.
*. New Email Address:
- To rectify any future communication issues, I have created a dedicated email address (jamescronan123@gmail.com) and have notified the clerk to use this for all court communications.
*. Consistent Attendance:
- I have never missed a hearing before, indicating my dedication to this case and my compliance with court procedures.
*. Supplementary Financial Records:
- Although I have requested supplementary forensic accounting to abide by court proceedings, I must emphasize that given the serious findings in the forensic accountant

Sure, here’s the continuation from point *:
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*. Supplementary Financial Records:
- Although I have requested supplementary forensic accounting to abide by court proceedings, I must emphasize that given the serious findings in the forensic accountant's report, any additional financial records submitted by the defendant may lack credibility. This highlights the necessity for thorough scrutiny and verification of all financial documentation provided before proceeding further.
Given the serious nature of the allegations and the evidence provided, dismissing this case would potentially enable further criminal conduct. I respectfully urge the court to vacate the dismissal and allow the case to proceed by first ordering the defendant to submit the supplementary financials before any trial date can be scheduled.
Respectfully submitted,
James Cronan
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Would you need any additional modifications or assistance with this?

Yes, you can request the appointment of a special master to review the financials. Here are some points to consider:
- Pre-Trial Request: You can argue that a special master is necessary now due to the severity of the tax evasion findings.
- Credibility of Documents: Emphasize that without a special master, the financial documentation may lack credibility.
- Judicial Efficiency: Argue that early involvement of a special master can streamline the process and ensure accurate financial records.
Would you like assistance drafting this specific request?

Given the complexity and seriousness of your case involving tax evasion allegations, it’s crucial to request thorough scrutiny of financial records. Here’s how you can incorporate your concerns and request for a special master:
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PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL
To the Honorable Judge Stern,
I, James Cronan, the plaintiff in the above-referenced case, respectfully submit this supplemental motion to support my original motion to vacate the dismissal of my case dated October *, *. This supplemental motion includes additional evidence and arguments as follows:
*. Forensic Accountant’s Report:
- Attached as Exhibit C is the report from a credible forensic accountant, which establishes serious allegations of tax evasion and commingling of funds by the defendant. These findings are critical to the integrity of this case.
*. Judicial Notice:
- I respectfully request that the court take judicial notice of the forensic accountant’s findings. The evidence provided is so authoritative and indisputable that it cannot reasonably be doubted.
*. Ethical Concerns:
- It is imperative to highlight that the opposing counsel, aware of these findings from the deposition of the forensic accountant, might be aiding and abetting criminal conduct. Representing the defendant with the aim of releasing them from liability and not reporting their illegal activities could constitute an act of aiding and abetting.
*. Lack of Notice:
- I did not receive proper notice of the hearing scheduled for October *, *. I discovered the notice was sent via email only after receiving the dismissal notice and conducting a search. [Reattach Exhibits A and B for proof of communication].
*. Health Issues:
- I am currently dealing with severe health issues, including Stage * kidney disease, which has significantly impacted my ability to keep up with court communications and proceedings. I respectfully request an extension of 30 days to submit further medical documentation if required.
*. New Email Address:
- To rectify any future communication issues, I have created a dedicated email address (jamescronan123@gmail.com) and have notified the clerk to use this for all court communications.
*. Consistent Attendance:
- I have never missed a hearing before, indicating my dedication to this case and my compliance with court procedures.
*. Supplementary Financial Records:
- Although I have requested supplementary forensic

Sure, here’s the continuation from point *:
---
*. Supplementary Financial Records:
- Although I have requested supplementary forensic accounting to abide by court proceedings, I must emphasize that given the serious findings in the forensic accountant's report, any additional financial records submitted by the defendant may lack credibility. This highlights the necessity for thorough scrutiny and verification of all financial documentation provided before proceeding further.
- I may request the court to appoint a special master to review the financials. While I understand that the court previously indicated this could be sought after a jury trial to determine damages, it seems prudent to address this now due to the serious allegations of tax evasion. A party reported in tax evasion by a forensic accountant may not have standing to proceed in a civil case.
Given the serious nature of the allegations and the evidence provided, dismissing this case would potentially enable further criminal conduct. I respectfully urge the court to vacate the dismissal and allow the case to proceed by first ordering the defendant to submit the supplementary financials before any trial date can be scheduled.
Respectfully submitted,
James Cronan
---
Would you need any additional modifications or assistance with this?

Sure, here’s the updated section from point * downward:
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*. Supplementary Financial Records:
- Although I have requested supplementary forensic accounting to abide by court proceedings, I must emphasize that given the serious findings in the forensic accountant's report, any additional financial records submitted by the defendant may lack credibility. This highlights the necessity for thorough scrutiny and verification of all financial documentation provided before proceeding further.
- I may request the court to appoint a special master to review the financials. While I understand that the court previously indicated this could be sought after a jury trial to determine damages, it seems prudent to address this now due to the serious allegations of tax evasion. A party reported in tax evasion by a forensic accountant may not have standing to proceed in a civil case.
Given the serious nature of the allegations and the evidence provided, dismissing this case would potentially enable further criminal conduct. I respectfully urge the court to vacate the dismissal and allow the case to proceed by first ordering the defendant to submit the supplementary financials before any trial date can be scheduled.
Respectfully submitted,
James Cronan
---
Would you need any additional modifications or assistance with this?

Sure, here’s the updated section from point * downward with your corrections:
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*. Supplementary Financial Records:
- Although I have requested supplementary forensic accounting to abide by court proceedings, I must emphasize that given the serious findings in the forensic accountant's report, any additional financial records submitted by the defendant may lack credibility. This highlights the necessity for thorough scrutiny and verification of all financial documentation provided before proceeding further.
- I may request the court to appoint a special master to review the financials. While I understand that the court previously indicated this could be sought after a jury trial to determine damages, it seems prudent to address this now due to the serious allegations of tax evasion. A party reported in tax evasion by a forensic accountant may not have standing to proceed in a civil case.
Given the serious nature of the allegations and the evidence provided, dismissing this case would potentially enable further criminal conduct. I respectfully urge the court to vacate the dismissal and allow the case to proceed by first ordering the defendant to submit the supplementary financials before any trial date can be scheduled.
Respectfully submitted,
James Cronan
---
Would you need any additional modifications or assistance with this?

Got it! Here's the updated section with your correction:
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*. Supplementary Financial Records:
- Although I have requested supplementary accounting from the defendant to abide by court proceedings, I must emphasize that given the serious findings in the forensic accountant's report, any additional financial records submitted by the defendant may lack credibility. This highlights the necessity for thorough scrutiny and verification of all financial documentation provided before proceeding further.
- I may request the court to appoint a special master to review the financials. While I understand that the court previously indicated this could be sought after a jury trial to determine damages, it seems prudent to address this now due to the serious allegations of tax evasion. A party reported in tax evasion by a forensic accountant may not have standing to proceed in a civil case.
Given the serious nature of the allegations and the evidence provided, dismissing this case would potentially enable further criminal conduct. I respectfully urge the court to vacate the dismissal and allow the case to proceed by first ordering the defendant to submit the supplementary financials before any trial date can be scheduled.
Respectfully submitted,
James Cronan
---
Would you need any additional modifications or assistance with this?

For clarity, you should use the date you filed the motion to vacate. Here's the complete section updated with the correct date reference:
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PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL
To the Honorable Judge Stern,
I, James Cronan, the plaintiff in the above-referenced case, respectfully submit this supplemental motion to support my original motion to vacate the dismissal of my case filed on [date you filed the motion]. This supplemental motion includes additional evidence and arguments as follows:
*. Forensic Accountant’s Report:
- Attached as Exhibit C is the report from a credible forensic accountant, which establishes serious allegations of tax evasion and commingling of funds by the defendant. These findings are critical to the integrity of this case.
*. Judicial Notice:
- I respectfully request that the court take judicial notice of the forensic accountant’s findings. The evidence provided is so authoritative and indisputable that it cannot reasonably be doubted.
*. Ethical Concerns:
- It is imperative to highlight that the opposing counsel, aware of these findings from the deposition of the forensic accountant, might be aiding and abetting criminal conduct. Representing thedefendant with the aim of releasing them from liability and not reporting their illegal activities could constitute an act of aiding and abetting.
*. Lack of Notice:
- I did not receive proper notice of the hearing scheduled for October *, *. I discovered the notice was sent via email only after receiving the dismissal notice and conducting a search. [Reattach Exhibits A and B for proof of communication].
*. Health Issues:
- I am currently dealing with severe health issues, including Stage * kidney disease, which has significantly impacted my ability to keep up with court communications and proceedings. I respectfully request an extension of 30 days to submit further medical documentation if required.
*. New Email Address:
- To rectify any future communication issues, I have created a dedicated email address (jamescronan123@gmail.com) and have notified the clerk to use this for all court communications.
*. Consistent Attendance:
- I have never missed a hearing before, indicating my dedication to this case and my compliance with court procedures.
*. Supplementary Financial Records:
- Although I have requested supplementary accounting from the defendant to abide by court proceedings, I must emphasize that given the serious findings

To the Honorable Judge Stern,
I, James Cronan, the plaintiff in the above-referenced case, respectfully submit this supplemental motion to support my original motion to vacate the dismissal of my case filed on October *, *. This supplemental motion includes additional evidence and arguments as follows:
*. Forensic Accountant’s Report:
- Attached as Exhibit C is the report from a credible forensic accountant, which establishes serious allegations of tax evasion and commingling of funds by the defendant. These findings are critical to the integrity of this case.
*. Judicial Notice:
- I respectfully request that the court take judicial notice of the forensic accountant’s findings. The evidence provided is so authoritative and indisputable that it cannot reasonably be doubted.
*. Ethical Concerns:
- It is imperative to highlight that the opposing counsel, aware of these findings from the deposition of the forensic accountant, might be aiding and abetting criminal conduct. Representing the defendant with the aim of releasing them from liability and not reporting their illegal activities could constitute an act of aiding and abetting.
*. Lack of Notice:
- I did not receive proper notice of the hearing scheduled forOctober *, *. I discovered the notice was sent via email only after receiving the dismissal notice and conducting a search. [Reattach Exhibits A and B for proof of communication].
*. Health Issues:
- I am currently dealing with severe health issues, including Stage * kidney disease, which has significantly impacted my ability to keep up with court communications and proceedings. I respectfully request an extension of 30 days to submit further medical documentation if required.
*. New Email Address:
- To rectify any future communication issues, I have created a dedicated email address (jamescronan123@gmail.com) and have notified the clerk to use this for all court communications.
*. Consistent Attendance:
- I have never missed a hearing before, indicating my dedication to this case and my compliance with court procedures.
*. Supplementary Financial Records:
- Although I have requested supplementary accounting from the defendant to abide by court proceedings, I must emphasize that given the serious findings in the forensic accountant's report, any additional financial records submitted by the defendant may lack credibility. This highlights the necessity for thorough scrutiny and verification of all financial documentation provided before proceeding further.
- I may request the court to appoint a special

It sounds like you have a very complex and serious case. Adding a statement about your financial and emotional situation as a pro se litigant could help the judge understand the challenges you face. Here’s how you might incorporate that into your supplemental motion:
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*. Supplementary Financial Records:
- Although I have requested supplementary accounting from the defendant to abide by court proceedings, I must emphasize that given the serious findings in the forensic accountant's report, any additional financial records submitted by the defendant may lack credibility. This highlights the necessity for thorough scrutiny and verification of all financial documentation provided before proceeding further.
- I may request the court to appoint a special master to review the financials. While I understand that the court previously indicated this could be sought after a jury trial to determine damages, it seems prudent to address this now due to the serious allegations of tax evasion. A party reported in tax evasion by a forensic accountant may not have standing to proceed in a civil case.
*. Challenges as a Pro Se Litigant:
- Although this court may find it more challenging to work with a pro se litigant, I come with great anxiety due to the grave financial crimes against me by my trusted financial advisor, whichhas left me insolvent and consequently enriched him. This is demonstrated by the fraudulent conversion of my shares in our partnered company, for which I received nothing (Exhibit D), and the fraudulent conversion of the commercial building at * Fountain St, R.I., leaving me with a Small Business Loan debt that I still pay monthly (Exhibit E). Therefore, I do not enjoy or relish being a pro se litigant in this honorable court, but I am forced to do so. This has left the defendant with an upper hand, having hired two attorneys to litigate this matter, paid for by his unjust enrichment.
Given the serious nature of the allegations and the evidence provided, dismissing this case would potentially enable further criminal conduct. I respectfully urge the court to vacate the dismissal and allow the case to proceed by first ordering the defendant to submit the supplementary financials before any trial date can be scheduled.
Respectfully submitted,
James Cronan
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Would you need any additional modifications or assistance with this?

Absolutely, I can help you with that. Here’s a concise way to present the key points from the forensic accountant's deposition:
*. Tax Evasion Allegations:
- Clearly state every instance the forensic accountant mentions tax evasion, including dates and specific transactions.
*. Commingling of Funds:
- Highlight instances where the forensic accountant identifies commingling of personal and business funds.
*. Supporting Documentation:
- Attach relevant exhibits referenced by the forensic accountant, such as financial records, emails, or transaction reports.
Would you like a template to organize these points effectively?

Sure, I can help you with that. Here’s how to incorporate the additional points into your supplemental motion:
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PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL
To the Honorable Judge Stern,
I, James Cronan, the plaintiff in the above-referenced case, respectfully submit this supplemental motion to support my original motion to vacate the dismissal of my case filed on October *, *. This supplemental motion includes additional evidence and arguments as follows:
*. Forensic Accountant’s Report:
- Attached as Exhibit C is the report from a credible forensic accountant, which establishes serious allegations of tax evasion and commingling of funds by the defendant. These findings are critical to the integrity of this case.
*. Judicial Notice:
- I respectfully request that the court take judicial notice of the forensic accountant’s findings. The evidence provided is so authoritative and indisputable that it cannot reasonably be doubted.
- Additionally, I request judicial notice that the defendant was my financial advisor for years and now has title to my company and commercial building. This in itself demonstrates a breach of fiduciary duty. The relationship and actions taken by the defendant are so clear that theyprove a breach of fiduciary duty, similar to how an X-ray showing a medical tool left in a patient’s abdomen clearly demonstrates medical malpractice.
*. Ethical Concerns:
- It is imperative to highlight that the opposing counsel, aware of these findings from the deposition of the forensic accountant, might be aiding and abetting criminal conduct. Representing the defendant with the aim of releasing them from liability and not reporting their illegal activities could constitute an act of aiding and abetting.
*. Lack of Notice:
- I did not receive proper notice of the hearing scheduled for October *, *. I discovered the notice was sent via email only after receiving the dismissal notice and conducting a search. [Reattach Exhibits A and B for proof of communication].
*. Health Issues:
- I am currently dealing with severe health issues, including Stage * kidney disease, which has significantly impacted my ability to keep up with court communications and proceedings. I respectfully request an extension of 30 days to submit further medical documentation if required.
*. New Email Address:
- To rectify any future communication issues, I have created a dedicated email address (jamescronan123@gmail.com) and have notified the clerk