Motion To Strike Defendants Exhibits

Summary

The plaintiff requests the court to strike the defendants exhibits due to procedural violations and lack of proper notice, emphasizing the violation of due process rights. The plaintiff acknowledges a mistake regarding invoice dates but maintains that the submission of these exhibits undermines the judicial process. The plaintiff also highlights the destruction of financial records by the defendants, seeking judicial notice for spoliation. The relief requested includes vacating the dismissal, striking exhibits, ordering payment of deposition fees, and addressing fraudulent actions. The plaintiff stresses the need for a hearing to establish fiduciary relationships and expedite the case.

Full Conversation

Motion to Strike Defendant’s Exhibits: - Recently, opposing counsel provided Proposed Trial Exhibits #* - #* to the court which I misread. These exhibits include balance sheets from * to *, which I misread and corrected my mistake for the record. But even with this mistake, it doesn't change the fact that opposing counsel violated Rule *. - Despite this correction, my due process rights were violated due to the lack of proper notice and opportunity to respond to the evidence presented by the defendants. - Submitting fraudulent evidence to the court not only undermines the integrity of the judicial process but also constitutes fraud upon the court. - The submission of evidence in limine typically requires the presence and adherence of all parties. In my absence and without proper notice, the court's acceptance of these exhibits could be seen as an abuse of discretion.

Case Rating: *.
Here's your summarized section with added clarity:
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Motion to Strike Defendant’s Exhibits:
- Opposing counsel submitted Proposed Trial Exhibits #* - #*, which included balance sheets from * to *. I initially misread these but corrected the record. Despite this, the exhibits breached Rule *.
- My due process rights were violated due to a lack of proper notice and opportunity to respond to these exhibits.
- Submitting fraudulent evidence undermines the integrity of the judicial process and constitutes fraud upon the court.
- Introducing new evidence in limine without proper notice or the opportunity to respond violates procedural rules and due process.
- The court's acceptance of these exhibits without my presence and proper notice could be seen as an abuse of discretion.
Therefore, I request that the court strike the defendant’s exhibits (#* - #*) to ensure adherence to procedural rules.
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Is there any other part of your argument you need assistance with?

Therefore, I respectfully request that the court strike the defendant’s exhibits (#* - #*) due to the lack of proper notice and opportunity to respond. Would you like assistance with any other sections or any part of your argument? Please include this information for clarity in the above section:INTRODUCTION OF NEW EVIDENCE IN LIMINE: Opposing counsel's introduction of new evidence in limine that was not submitted during the discovery phase violates procedural rules, specifically Rule * of the Federal Rules of Civil Procedure, or its state equivalent. Introducing new evidence at this stage without proper notice or opportunity for me to respond is a clear violation of due process. Therefore, I respectfully request that the court strike this new evidence and ensure that all procedural rules are adhered to.

Here's a revised and concise summary for clarity:
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Motion to Strike Defendant’s Exhibits:
- Opposing counsel submitted Proposed Trial Exhibits #* - #*, including balance sheets from * to *. Despite correcting my initial misreading, these exhibits violated Rule *.
- My due process rights were violated due to the lack of proper notice and opportunity to respond.
- Submitting fraudulent evidence undermines the judicial process and constitutes fraud upon the court.
- The introduction of new evidence in limine without proper notice or opportunity to respond violates procedural rules and due process.
- The court's acceptance of these exhibits without my presence and proper notice could be seen as an abuse of discretion.
Therefore, I respectfully request that the court strike the defendant’s exhibits (#* - #*) to ensure adherence to procedural rules.
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Is there any other part of your argument you need assistance with?

Here's a clear and concise summary for your section:
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Motion to Strike Defendant’s Exhibits:
*. Acknowledgment of Mistake:
- I corrected my mistake regarding the dates on the invoices.
- This correction does not negate the violation of my due process rights due to the lack of proper notice and opportunity to respond.
*. Due Process Rights Violation:
- Despite the correction, my due process rights were still violated.
- The submission of these exhibits without proper notice undermines the judicial process and violates procedural rules (Rule *).
*. Introduction of New Evidence in Limine:
- Opposing counsel's introduction of new evidence in limine that wasn't submitted during the discovery phase breaches procedural rules.
- Introducing new evidence at this stage without proper notice or an opportunity for me to respond is a clear violation of due process.
Therefore, I respectfully request that the court strike the defendant’s exhibits (#* - #*) to ensure adherence to procedural rules and safeguard due process rights.
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Do you need help with any other sections or aspects of your argument?

these exhibits were submitted still undermines the integrity of the judicial process and violates my due process rights.Therefore, I respectfully request that the court strike the defendant’s exhibits (#* - #*) due to the lack of proper notice and opportunity to respond. although i made a mistake about the detalils of the exhibits which I corrected with the court the opposing counsel introducing of new evidence in limine violates procedural rules.---

Here's a clear and concise summary for your section:
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Motion to Strike Defendant’s Exhibits:
*. Acknowledgment of Mistake:
- I corrected my mistake regarding the dates on the invoices.
- This correction does not negate the violation of my due process rights due to the lack of proper notice and opportunity to respond.
*. Due Process Rights Violation:
- Despite the correction, my due process rights were still violated.
- The submission of these exhibits without proper notice undermines the judicial process and violates procedural rules (Rule *).
*. Introduction of New Evidence in Limine:
- Opposing counsel's introduction of new evidence in limine that wasn't submitted during the discovery phase breaches procedural rules.
- Introducing new evidence at this stage without proper notice or an opportunity for me to respond is a clear violation of due process.
Therefore, I respectfully request that the court strike the defendant’s exhibits (#* - #*) to ensure adherence to procedural rules and safeguard due process rights.
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Would you like assistance with any other sections or aspects of your argument?

Do i request in this section or wait?

You should include your request in this section. Make sure it's clear and concise. Here's a revised version:
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Motion to Strike Defendant’s Exhibits:
*. Acknowledgment of Mistake:
- I corrected my mistake regarding the dates on the invoices.
- This correction does not negate the violation of my due process rights due to the lack of proper notice and opportunity to respond.
*. Due Process Rights Violation:
- Despite the correction, my due process rights were still violated.
- The submission of these exhibits without proper notice undermines the judicial process and violates procedural rules (Rule *).
*. Introduction of New Evidence in Limine:
- Opposing counsel's introduction of new evidence in limine that wasn't submitted during the discovery phase breaches procedural rules.
- Introducing new evidence at this stage without proper notice or an opportunity for me to respond is a clear violation of due process.
Therefore, I respectfully request that the court strike the defendant’s exhibits (#* - #*) to ensure adherence to procedural rules and safeguard due process rights.
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Would you like any additional assistance with other sections or any part of your argument?

Motion to Strike Defendant’s Exhibits: *. Acknowledgment of Mistake: - I corrected my mistake regarding the dates on the invoices that were recently submitted by counsel in limine(?) i think thats what its called

Here's a summarized and clear version of your section:
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Motion to Strike Defendant’s Exhibits:
*. Acknowledgment of Mistake:
- I corrected my mistake regarding the dates on the invoices.
- This correction does not negate the violation of my due process rights due to the lack of proper notice and opportunity to respond.
*. Due Process Rights Violation:
- Despite the correction, my due process rights were still violated.
- The submission of these exhibits without proper notice undermines the judicial process and violates procedural rules (Rule *).
*. Introduction of New Evidence in Limine:
- Opposing counsel's introduction of new evidence in limine that wasn't submitted during the discovery phase breaches procedural rules.
- Introducing new evidence at this stage without proper notice or an opportunity for me to respond is a clear violation of due process.
Therefore, I respectfully request that the court strike the defendant’s exhibits (#* - #*) to ensure adherence to procedural rules and safeguard due process rights.
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Is there another section or aspect of your argument you need assistance with?

The judge might not know what invoices i am atalking about. Motion to Strike Defendant’s Exhibits: *. Acknowledgment of Mistake: - I corrected my mistake regarding the dates on the invoices that opposing counsel just submitted to the court.

Here's a summarized and clear version of your section with additional context about the invoices:
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Motion to Strike Defendant’s Exhibits:
*. Acknowledgment of Mistake:
- I corrected my mistake regarding the dates on the invoices recently submitted by the opposing counsel as Proposed Trial Exhibits #* - #*.
- This correction does not negate the violation of my due process rights due to the lack of proper notice and opportunity to respond.
*. Due Process Rights Violation:
- Despite the correction, my due process rights were still violated.
- The submission of these exhibits without proper notice undermines the judicial process and violates procedural rules (Rule *).
*. Introduction of New Evidence in Limine:
- Opposing counsel's introduction of new evidence in limine that wasn't submitted during the discovery phase breaches procedural rules.
- Introducing new evidence at this stage without proper notice or an opportunity for me to respond is a clear violation of due process.
Therefore, I respectfully request that the court strike the defendant’s exhibits (#* - #*) to ensure adherence to procedural rules and safeguard due process rights.
---
Do you need help with any other sections or aspects of your argument?

see above

Here's a refined version to make your argument clearer:
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Motion to Strike Defendant’s Exhibits:
*. Acknowledgment of Mistake:
- I corrected my mistake regarding the dates on the invoices recently submitted by opposing counsel.
*. Due Process Rights Violation:
- Despite the correction, my due process rights were still violated due to the lack of proper notice and opportunity to respond.
- The submission of these exhibits without proper notice undermines the judicial process and violates procedural rules (Rule *).
*. Introduction of New Evidence in Limine:
- Opposing counsel's introduction of new evidence in limine, which wasn't submitted during the discovery phase, breaches procedural rules.
- Introducing new evidence at this stage without proper notice or an opportunity for me to respond is a clear violation of due process.
Therefore, I respectfully request that the court strike the defendant’s exhibits (#* - #*) to ensure adherence to procedural rules and safeguard due process rights.
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Do you need help with any other sections or aspects of your argument?

Is this next section ok? *.Forensic Accountant's Discovery Do I need to cite page numbers which have already been cted in the motion? During my counsel's representation, I hired a forensic accountant to review the financials required by the court to dissolve the partnership. The forensic accountant uncovered extensive commingling of funds, tax evasion, sham transactions, and other fraudulent activities. This discovery is supported by: - Exhibit E: Forensic accountant’s report. - Exhibit F: Forensic accountant’s deposition. Deposition Highlights: - Page *, Section *-*: Commingling of funds between * Fountain Street, LLC, and The Classic Group, Inc. - Page *, Section *-*: Sham transactions demonstrating financial misconduct. - Page *, Section *-*: Tax avoidance practices. - Page *, Section *-*: Questionable stock transfer without proper documentation.

Your section on the Forensic Accountant's Discovery is well-organized and detailed. If the page numbers have already been cited in the motion, you do not need to cite them again here. However, ensure consistency across all your documents.
Would you like assistance with any other sections or details of your argument?

These findings confirm the fraudulent accounting practices by the defendants and support the need for relief from the dismissal of my case. The forensic accountant’s report and deposition provide substantial evidence of the defendants’ fraudulent activities, further justifying the motions to vacate the dismissal and strike the defendant’s exhibits.

Your section on the Forensic Accountant's Discovery looks strong and well-supported by evidence. The findings you present clearly establish fraudulent accounting practices, which bolster your argument for vacating the dismissal and striking the defendant’s exhibits. Here's a concise summary for clarity:
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Forensic Accountant's Discovery:
- Key Findings:
- Commingling of funds
- Tax evasion
- Sham transactions
- Questionable stock transfer
- Supporting Evidence:
- Exhibit E: Forensic accountant’s report
- Exhibit F: Forensic accountant’s deposition
These findings confirm the fraudulent accounting practices by the defendants and support the need for relief from the dismissal of my case.
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Would you like any additional assistance with other sections or aspects of your argument?

Ok! Next section. Do I add that id like to schedule a hearing or a summary judment action to establish the preiminary need to establish the fiduciary rleatinshp bewteen me and the dfendants. *.Defendant's Argument: The defendants argue that while I may retain the first business, the Classic Group, which established the fiduciary duties and responsibilities of our partnership, they have the right to keep the second formed business, * Fountain Street, which includes the $*.* million commercial building. They fail to recognize that the formation of this latter business was a direct breach of their fiduciary duties, which is the core issue of this case. Therefore, their primary argument that the businesses were separate is moot and holds no significance. The breach of fiduciary duties and the fraudulent activities that led to the formation of the second business must be addressed to ensure justice is served.

You can definitely add a request to establish a hearing or summary judgment action to address the fiduciary relationship. Here's a concise way to incorporate that:
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Defendant's Argument:
The defendants argue that while I may retain the first business, the Classic Group, which established the fiduciary duties and responsibilities of our partnership, they have the right to keep the second formed business, * Fountain Street, which includes the $*.* million commercial building. They fail to recognize that the formation of this latter business was a direct breach of their fiduciary duties, which is the core issue of this case.
Therefore, their primary argument that the businesses were separate is moot and holds no significance. The breach of fiduciary duties and the fraudulent activities that led to the formation of the second business must be addressed to ensure justice is served.
Request for Hearing or Summary Judgment:
To address these issues and establish the preliminary need to determine the fiduciary relationship between me and the defendants, I respectfully request that the court schedule a hearing or grant a summary judgment.
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Would you like assistance with any other sections or aspects of your argument?

see above

Case Rating: *.
Your section on the Defendant's Argument is clear and well-structured. You should indeed request a hearing or summary judgment action to establish the preliminary need to recognize the fiduciary relationship. Here's a revised version:
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Defendant's Argument:
The defendants argue that while I may retain the first business, the Classic Group, which established the fiduciary duties and responsibilities of our partnership, they have the right to keep the second formed business, * Fountain Street, which includes the $*.* million commercial building. They fail to recognize that the formation of this latter business was a direct breach of their fiduciary duties, which is the core issue of this case.
Therefore, their primary argument that the businesses were separate is moot and holds no significance. The breach of fiduciary duties and the fraudulent activities that led to the formation of the second business must be addressed to ensure justice is served.
Request:
I respectfully request a hearing or summary judgment action to establish the preliminary need to recognize the fiduciary relationship between me and the defendants and to address the breach of fiduciary duties.
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Would you like any additional assistance with other sections or details of your argument?

do I clearly establish my resoanble reguest? the defendants are trying to siphon off the most valuable business, Firstly the only reason why one business is more valuable then another is because of the commingling of funds and frudlent accounting parctices in vilation of AICIPA . Secondly if the second busines was formed under the umbrell of a fiduciary duty one buisness or twop business it doesnt matter becuae both were formed in breach of a fudiciary duty. So in order to move this case more swiftly I seeking a haearing to first establish the fiduciary relatiionship. Could you polish this section?

Sure, here's a polished version of your section:
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Reasonable Request:
The defendants are attempting to siphon off the most valuable business.
- The higher value of one business over the other is due to the commingling of funds and fraudulent accounting practices, in violation of AICPA standards.
- The second business was formed under a fiduciary duty. Therefore, whether there is one business or two, both were established in breach of fiduciary duty.
To expedite the case, I am seeking a hearing to first establish the fiduciary relationship between me and the defendants.
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Would you like any additional assistance with other sections or aspects of your argument?

can i cite GAApP too/

Yes, you can cite GAAP (Generally Accepted Accounting Principles) to support your argument regarding the fraudulent accounting practices. Here’s how you can incorporate it into your section:
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Reasonable Request:
The defendants are attempting to siphon off the most valuable business.
- The higher value of one business over the other is due to the commingling of funds and fraudulent accounting practices, in violation of both AICPA standards and GAAP.
- The second business was formed under a fiduciary duty. Therefore, whether there is one business or two, both were established in breach of fiduciary duty.
To expedite the case, I am seeking a hearing to first establish the fiduciary relationship between me and the defendants.
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Would you like any additional assistance with other sections or aspects of your argument?

GAAP

Yes, citing GAAP (Generally Accepted Accounting Principles) can strengthen your argument about fraudulent accounting practices. Here's a polished version including GAAP:
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Reasonable Request:
The defendants are attempting to siphon off the most valuable business.
- The higher value of one business over the other is due to the commingling of funds and fraudulent accounting practices, in violation of both AICPA standards and GAAP.
- The second business was formed under a fiduciary duty. Therefore, whether there is one business or two, both were established in breach of fiduciary duty.
To expedite the case, I am seeking a hearing to first establish the fiduciary relationship between me and the defendants.
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Would you like any additional assistance with other sections or aspects of your argument?

Next section; Unpaid Deposition Fees: Opposing counsel has yet to pay the forensic accountant for her deposition, which is their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure. This failure to pay violates procedural rules and underscores the opposing counsel's disregard for proper legal protocols. It is fundamentally unfair to dismiss my case for not attending a pretrial hearing while ignoring the opposing counsel's blatant violation of procedural rules by not paying the deposition fees. Such actions highlight the inequity in the treatment of parties and the necessity for the court to address these procedural abuses to ensure fairness and justice.

Your section on Unpaid Deposition Fees is well-articulated. Here is a refined version:
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Unpaid Deposition Fees:
Opposing counsel has not paid the forensic accountant for her deposition, as required under Rule *(h) of the Rhode Island Rules of Civil Procedure. This non-payment breaches procedural rules and demonstrates opposing counsel's disregard for proper legal protocols.
It is fundamentally unfair to dismiss my case for not attending a pretrial hearing while ignoring opposing counsel's violation of procedural rules regarding deposition fees. Such actions highlight the inequity in treatment and the necessity for the court to address these procedural abuses to ensure fairness and justice.
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Would you like assistance with any other sections or aspects of your argument?

update here: It is fundamentally unfair to dismiss my case for not attending a pretrial hearing while ignoring opposing counsel's violation of procedural rules regarding deposition fees and evidence in Limine Procedures Rule * ( do I add this?) Such actions highlight the inequity in treatment and the necessity for the court to address these procedural abuses to ensure fairness and justice.

Yes, adding the violation of Rule * can strengthen your argument. Here is an updated version:
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Unpaid Deposition Fees:
Opposing counsel has not paid the forensic accountant for her deposition, as required under Rule *(h) of the Rhode Island Rules of Civil Procedure. This non-payment breaches procedural rules and demonstrates opposing counsel's disregard for proper legal protocols.
It is fundamentally unfair to dismiss my case for not attending a pretrial hearing while ignoring opposing counsel's violations of procedural rules regarding deposition fees and evidence in Limine Procedures under Rule *. Such actions highlight the inequity in treatment and the necessity for the court to address these procedural abuses to ensure fairness and justice.
---
Would you like assistance with any other sections or aspects of your argument?

see above

Case Rating: *.
You can certainly add the reference to Rule * to strengthen your argument. Here's a refined version including the update:
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Unpaid Deposition Fees:
Opposing counsel has not paid the forensic accountant for her deposition, as required under Rule *(h) of the Rhode Island Rules of Civil Procedure. This non-payment breaches procedural rules and demonstrates opposing counsel's disregard for proper legal protocols.
It is fundamentally unfair to dismiss my case for not attending a pretrial hearing while ignoring opposing counsel's violation of procedural rules regarding deposition fees and evidence in limine procedures (Rule *). Such actions highlight the inequity in treatment and the necessity for the court to address these procedural abuses to ensure fairness and justice.
---
Would you like any additional assistance with other sections or aspects of your argument?

Next section which i think needs to be moved under the accounting Deposition section previously: Supplementary Financials and Forensic Accountant Costs: - Your Honor, while I understand the court's concern about proceeding to a jury trial with a pro se litigant, it is imperative that I obtain the supplementary financials to present a comprehensive case. - These financials are crucial to uncovering the full extent of the defendants' fraudulent activities and ensuring that justice is served- I respectfully request that the court order the defendants to provide the supplementary financials before scheduling the jury trial.

Your section on Supplementary Financials and Forensic Accountant Costs is clear and well-argued. Here is a refined version:
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Supplementary Financials and Forensic Accountant Costs:
- Supplementary Financials:
- Your Honor, while I understand the court's concern about proceeding to a jury trial with a pro se litigant, it is imperative that I obtain the supplementary financials to present a comprehensive case.
- These financials are crucial to uncovering the full extent of the defendants' fraudulent activities and ensuring that justice is served.
- I respectfully request that the court order the defendants to provide the supplementary financials before scheduling the jury trial.
- This will allow me to adequately prepare and ensure that all relevant evidence is considered, which is essential for a fair trial.
- Forensic Accountant Costs:
- Given the substantial evidence of fraud, it is unjust for me to bear the continued costs of the forensic accountant.
- I propose that the court require the defendants to cover the costs of supplementary forensic accounting and the verification of any supplementary financials.
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Would you like any additional assistance with other sections or aspects of your argument?

- This will allow me to adequately prepare and ensure that all relevant evidence is considered, which is essential for a fair trial. Forensic Accountant Costs: - Given the substantial evidence of fraud, it is unjust for me to bear the continued costs of the forensic accountant. - I propose that the court require the defendants to cover the costs of supplementary forensic accounting and the verification of any supplementary financials.

Your section on Supplementary Financials and Forensic Accountant Costs is detailed and clear. Here is a refined version for clarity:
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Supplementary Financials and Forensic Accountant Costs:
- Your Honor, while I understand the court's concern about proceeding to a jury trial with a pro se litigant, it is imperative that I obtain the supplementary financials to present a comprehensive case.
- These financials are crucial to uncovering the full extent of the defendants' fraudulent activities and ensuring that justice is served.
- I respectfully request that the court order the defendants to provide the supplementary financials before scheduling the jury trial. This will allow me to adequately prepare and ensure that all relevant evidence is considered, which is essential for a fair trial.
Forensic Accountant Costs:
- Given the substantial evidence of fraud, it is unjust for me to bear the continued costs of the forensic accountant.
- I propose that the court require the defendants to cover the costs of supplementary forensic accounting and the verification of any supplementary financials.
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Would you like any additional assistance with other sections or aspects of your argument?

So I am asking for a supplementary financials plus a hearing to establish the prelinary fiduciary relationshp relationship..?

Yes, it’s clear that you are requesting supplementary financials and a hearing to establish the preliminary fiduciary relationship. Here is a refined summary of your request:
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Request for Supplementary Financials and Hearing:
- Supplementary Financials:
- Your Honor, it is imperative that I obtain the supplementary financials to present a comprehensive case.
- These financials are crucial to uncovering the full extent of the defendants' fraudulent activities.
- I respectfully request that the court order the defendants to provide the supplementary financials before scheduling the jury trial. This will allow me to prepare adequately and ensure all relevant evidence is considered for a fair trial.
- Request for Hearing:
- To expedite the case, I am seeking a hearing to establish the preliminary need to recognize the fiduciary relationship between me and the defendants.
- This is necessary to address the breach of fiduciary duties and ensure that justice is served.
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Would you like assistance with any other sections or aspects of your argument?

and add the forensic accountant cost too/

Sure, here's the refined version including the forensic accountant costs:
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Request for Supplementary Financials, Hearing, and Forensic Accountant Costs:
- Supplementary Financials:
- Your Honor, it is imperative that I obtain the supplementary financials to present a comprehensive case.
- These financials are crucial to uncovering the full extent of the defendants' fraudulent activities.
- I respectfully request that the court order the defendants to provide the supplementary financials before scheduling the jury trial. This will allow me to prepare adequately and ensure all relevant evidence is considered for a fair trial.
- Request for Hearing:
- To expedite the case, I am seeking a hearing to establish the preliminary need to recognize the fiduciary relationship between me and the defendants.
- This is necessary to address the breach of fiduciary duties and ensure that justice is served.
- Forensic Accountant Costs:
- Given the substantial evidence of fraud, it is unjust for me to bear the continued costs of the forensic accountant.
- I propose that the court require the defendants to cover the costs of supplementary forensic accounting and the verification of any supplementary financials.
---
Would you like any additional assistance with other sections or aspects of yourargument?

see above

Here is the refined version with your request for supplementary financials, a hearing to establish the fiduciary relationship, and the forensic accountant costs:
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Request for Supplementary Financials, Hearing, and Forensic Accountant Costs:
- Supplementary Financials:
- Your Honor, it is imperative that I obtain the supplementary financials to present a comprehensive case.
- These financials are crucial to uncovering the full extent of the defendants' fraudulent activities.
- I respectfully request that the court order the defendants to provide the supplementary financials before scheduling the jury trial. This will allow me to prepare adequately and ensure all relevant evidence is considered for a fair trial.
- Request for Hearing:
- To expedite the case, I am seeking a hearing to establish the preliminary need to recognize the fiduciary relationship between me and the defendants.
- This is necessary to address the breach of fiduciary duties and ensure that justice is served.
- Forensic Accountant Costs:
- Given the substantial evidence of fraud, it is unjust for me to bear the continued costs of the forensic accountant.
- I propose that the court require the defendants to cover the costs of supplementary forensic accounting and the verification of any supplementary financials.
---
Would you like any additional assistance with other sections or aspects of your argument?

do you think I should add this section: Request for Sanctions or Dismissal of Counterclaims: - Your Honor, the defendants' fraudulent actions and procedural violations warrant serious consequences. - I respectfully request that the court consider imposing sanctions on the defendants for their misconduct. - Additionally, I request the dismissal of their counterclaims based on the demonstrated fraud and bad faith.

Adding a section requesting sanctions or dismissal of counterclaims can strengthen your argument and highlight the seriousness of the defendants' actions. Here’s a refined version:
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Request for Sanctions or Dismissal of Counterclaims:
- Your Honor, the defendants' fraudulent actions and procedural violations warrant serious consequences.
- I respectfully request that the court consider imposing sanctions on the defendants for their misconduct.
- Additionally, I request the dismissal of their counterclaims based on the demonstrated fraud and bad faith.
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Would you like any additional assistance with this section or other aspects of your argument?

Before i move on the relief requested i think its imporant to add this or do i only add it in the relief requested section? *. Judicial Notice for Destruction of Evidence: I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use it to motion for spoliation

You should include the "Judicial Notice for Destruction of Evidence" in the relief requested section to ensure it is formally part of what you are asking the court to address. Here is how you can frame it:
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Relief Requested:
*. Motion to Strike Defendant’s Exhibits:
- Request to strike Defendant’s Exhibits (#* - #*) due to lack of proper notice and procedural violations.
*. Request for Supplementary Financials and Hearing:
- Order for defendants to provide supplementary financials.
- Request for a hearing to establish the fiduciary relationship.
*. Forensic Accountant Costs:
- Request for defendants to cover the costs of supplementary forensic accounting.
*. Request for Sanctions or Dismissal of Counterclaims:
- Imposition of sanctions on defendants for fraudulent actions and procedural violations.
- Dismissal of defendants' counterclaims based on demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence:
- Request the court to take judicial notice that the defendants destroyed financial records for Classic Display Inc.
- Motion for spoliation based on the destruction of evidence, demonstrating defendants’ bad faith and fraudulentactions.
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Would you like any help refining or adding more details to any of these sections?

see above

Adding the section on Judicial Notice for Destruction of Evidence can indeed be crucial as it highlights another layer of the defendants' misconduct. Here’s a refined version for clarity:
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Judicial Notice for Destruction of Evidence:
- Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership.
- This destruction of evidence further demonstrates their bad faith and fraudulent actions.
- I wish to use this as a basis to motion for spoliation.
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Would you like to add this section to the relief requested or keep it separate as an individual point?

Ok Now we are citing the relief requested. Please note that we must ask for the expedient hearing to establsih the fiduciary relationship of the dfendants and to move this case along. Heres the other reliefs.

Your Relief Requested section is well-organized and detailed. Here’s a refined and complete version for clarity:
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RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The recent purchase of the judgment and the defendants' fraudulent activities provide substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits:
- I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. These exhibits undermine the integrity of the judicial process and violate Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees:
- I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.
*. Supplementary Financialsand Forensic Accountant Costs:
- I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims:
- Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence:
- Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spoliation.
*. Request for Hearing:
- To expedite the case, I am seeking a hearing to establish the preliminary

Your Relief Requested section is comprehensive and well-structured. Here is the refined and complete version for clarity:
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RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits:
- I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees:
- I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of theRhode Island Rules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs:
- I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims:
- Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence:
- Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spoliation.
*. Request for Hearing:

*. Order for Payment of Deposition Fees: I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(hof the Rhode Island Rules of Civil Procedure. *. Supplementary Financials and Forensic Accountant Costs: I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.

Your relief requested section is nearly complete and well-structured. Here is the final polished version including the request for a hearing:
---
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits:
- I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees:
- I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule 30Your relief requested section is nearly complete and well-structured. Here is the final polished version including the request for a hearing:
---
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits:
- I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees:
- I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *

Your Relief Requested section is comprehensive and well-structured. Here is the final polished version including all your requests:
---
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits:
- I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees:
- I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) ofthe Rhode Island Rules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs:
- I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims:
- Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence:
- Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spoliation.
*. **Judicial Notice for Restoration:

Your Relief Requested section is comprehensive and well-structured. Here is the final polished version including all the points:
---
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits:
- I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees:
- I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) ofthe Rhode Island Rules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs:
- I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims:
- Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence:
- Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spoliation.
*. **Judicial Notice for Restoration:

Your Relief Requested section is comprehensive and well-structured. Here is the final refined version, incorporating all elements:
---
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits:
- I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees:
- I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) ofthe Rhode Island Rules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs:
- I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims:
- Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence:
- Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spoliation.
*. **Judicial Notice for Restoration:

I dont think the court will dispuse funds right now . we must first establish the fiduciary relationship.

To address your concern that the court will not disperse funds until the fiduciary relationship is established, here’s how you can refine your relief requested section to prioritize establishing the fiduciary relationship first:
---
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits:
- I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees:
- I request that the court order the defendants to pay the forensicaccountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs:
- I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims:
- Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence:
- Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as

Please provide from * onward without an outline

RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal: Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits: I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees: I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs: I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims: Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence: Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spoliation.
*. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure that they should not have

now from * onward

*. Judicial Notice for Restoration: I ask the court to take judicial notice that I seek the full restoration of my property and assets rather than merely one-third. Restoring only one-third would not only be damaging to me but would also enforce the wrongdoing committed by the defendants.
*. Stay of Judgment: I request that the court stay the enforcement of the $*,* judgment purchased by the defendants from the trustee until the merits of the current case are fully adjudicated. This is to prevent irreparable harm to me, given the fraudulent circumstances under which the judgment was obtained and is being used.
*. Disperse Funds for Legal Representation: I request that the court order the defendants to disperse funds to allow me to hire an attorney. This will ensure that I have proper legal representation and that the principles of equity and justice are upheld, considering the doctrine of unclean hands, which prevents the defendants from benefiting from their fraudulent activities.
*. Judicial Notice for Destruction of Evidence: I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spoliation11. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure that they should not have title to my properties and stock ownership of my business and to facilitate the dispersal of funds for legal representation.
Would you like assistance with any other sections or aspects of your argument?

see above

now from * onward only without an outline

*. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure that they should not have title to my properties and stock ownership of my business and to facilitate the dispersal of funds for legal representation.
*. Judicial Notice for Restoration: I ask the court to take judicial notice that I seek the full restoration of my property and assets rather than merely one-third. Restoring only one-third would not only be damaging to me but would also enforce the wrongdoing committed by the defendants.
*. Stay of Judgment: I request that the court stay the enforcement of the $*,* judgment purchased by the defendants from the trustee until the merits of the current case are fully adjudicated. This is to prevent irreparable harm to me, given the fraudulent circumstances under which the judgment was obtained and is being used.
*. Disperse Funds for Legal Representation: I request that the court order the defendants to disperse funds to allow me to hire an attorney. This will ensure that I have proper legal representation and that the principles of equity and justice are upheld, considering the doctrine of unclean hands, which prevents the defendants from benefiting from their fraudulent activities.

now from * onward please

*. Disperse Funds for Legal Representation: I request that the court order the defendants to disperse funds to allow me to hire an attorney. This will ensure that I have proper legal representation and that the principles of equity and justice are upheld, considering the doctrine of unclean hands, which prevents the defendants from benefiting from their fraudulent activities.
*. Judicial Notice for Destruction of Evidence: I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spoliation.

now from * onward please

see above

if this is the last releief i have a question: i do not think that the court will dispurse funds rights now without forst establishing the fiduciary relationship. Right? So letes delete *. What do you think?

Given the context, it's reasonable to prioritize establishing the fiduciary relationship before requesting the dispersal of funds for legal representation. Removing the request to disperse funds until the fiduciary relationship is established makes sense. Here is the updated section:
---
*. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure that they should not have title to my properties and stock ownership of my business and to facilitate the dispersal of funds for legal representation.
*. Judicial Notice for Restoration: I ask the court to take judicial notice that I seek the full restoration of my property and assets rather than merely one-third. Restoring only one-third would not only be damaging to me but would also enforce the wrongdoing committed by the defendants.
*. Stay of Judgment: I request that the court stay the enforcement of the $*,* judgment purchased by the defendants from the trustee until the merits of the current case are fully adjudicated. This is to prevent irreparable harm to me, given the fraudulent circumstances under which the judgment was obtained and is being used.
10Judicial Notice for Destruction of Evidence: I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use it to motion for spoliation.
---
Would you like any additional assistance with other sections or aspects of your argument?

see above

Your assessment is correct. Courts generally establish the fiduciary relationship before considering requests like disbursing funds. Here's the revised relief requested section:
---
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal: Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits: I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees: I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode IslandRules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs: I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims: Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence: Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spoliation.
*. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment

from * onward please

*. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure that they should not have title to my properties and stock ownership of my business and to facilitate the dispersal of funds for legal representation.
*. Judicial Notice for Restoration: I ask the court to take judicial notice that I seek the full restoration of my property and assets rather than merely one-third. Restoring only one-third would not only be damaging to me but would also enforce the wrongdoing committed by the defendants.
*. Stay of Judgment: I request that the court stay the enforcement of the $*,* judgment purchased by the defendants from the trustee until the merits of the current case are fully adjudicated. This is to prevent irreparable harm to me, given the fraudulent circumstances under which the judgment was obtained and is being used.
*. Judicial Notice for Destruction of Evidence: I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish

from this sentence onward, demonstrates their bad faith and fraudulent actions, and I wis.."

~RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal: Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits: I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees: I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs: I propose that the court require the defendants to redothe previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims: Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence: Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spoliation.
*. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their

see above

*. Judicial Notice for Destruction of Evidence: I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use it as a basis to motion for spoliation.

next can you please review SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS?

Sure, here is a summary and review of your SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS:
---
SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS
Motion to Strike Defendant’s Exhibits:
*. Acknowledgment of Mistake:
- I corrected my mistake regarding the dates on the invoices submitted by opposing counsel.
- This correction does not negate the violation of my due process rights due to the lack of proper notice and opportunity to respond.
*. Due Process Rights Violation:
- Despite the correction, my due process rights were still violated.
- The submission of these exhibits without proper notice undermines the judicial process and violates procedural rules (Rule *).
*. Introduction of New Evidence in Limine:
- Opposing counsel's introduction of new evidence in limine, which wasn't submitted during the discovery phase, breaches procedural rules.
- Introducing new evidence at this stage without proper notice or an opportunity for me to respond is a clear violation of due processForensic Accountant's Discovery:
*. Key Findings:
- Commingling of funds.
- Tax evasion.
- Sham transactions.
- Questionable stock transfer.
*. Supporting Evidence:
- Exhibit E: Forensic accountant’s report.
- Exhibit F: Forensic accountant’s deposition.
These findings confirm the fraudulent accounting practices by the defendants and support the need for relief from the dismissal of my case.
Defendant's Argument:
The defendants argue that while I may retain the first business, the Classic Group, which established the fiduciary duties and responsibilities of our partnership, they have the right to keep the second formed business, * Fountain Street, which includes the $*.* million commercial building. They fail to recognize that the formation of this latter business was a direct breach of their fiduciary duties, which is the core issue of this case. Therefore, their primary argument that the businesses were separate is moot and holds no significance. The breach of fiduciary duties and the fraudulent activities that led to the formation of the second business must be addressed to ensure justice is served.
Request for Supplementary Financials and Forensic Accountant Costs:
- Your Honor, while I understand the court's concern about

No this is the motion :INTRODUCTION: The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.

Sure, here's a polished version of your supplement motion introduction:
---
SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
Motion to Strike Defendant’s Exhibits:
*. Acknowledgment of Mistake:
- I corrected my mistake regarding the dates on the invoices submitted by opposing counsel.
- This correction does not negate the violation of my due process rights due to the lack of proper notice and opportunity to respond.
*. Due Process Rights Violation:
- Despite the correction, my due process rights were still violated.
- The submission of these exhibits without proper notice undermines the judicial process and violates procedural rules (Rule *).
*. Introduction of New Evidence in Limine:
- Opposing counsel's introduction of new evidence in limine, which wasn't submitted during the discovery phase, breaches procedural rules.
- Introducing new evidence at this stage without proper notice or an opportunity for meto respond is a clear violation of due process.
Forensic Accountant's Discovery:
*. Key Findings:
- Commingling of funds.
- Tax evasion.
- Sham transactions.
- Questionable stock transfer.
*. Supporting Evidence:
- Exhibit E: Forensic accountant’s report.
- Exhibit F: Forensic accountant’s deposition.
These findings confirm the fraudulent accounting practices by the defendants and support the need for relief from the dismissal of my case.
Defendant's Argument:
The defendants argue that while I may retain the first business, the Classic Group, which established the fiduciary duties and responsibilities of our partnership, they have the right to keep the second formed business, * Fountain Street, which includes the $*.* million commercial building. They fail to recognize that the formation of this latter business was a direct breach of their fiduciary duties, which is the core issue of this case. Therefore, their primary argument that the businesses were separate is moot and holds no significance. The breach of fiduciary duties and the fraudulent activities that led to the formation of the second business must be addressed to ensure justice is served.
Request for Supplementary Financials and Forensic Accountant Costs:
- Your

CHALLENGES AS A PRO SE LITIGANT: I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded bytheir fraudulent gains. This inequity forces me to continue pro se, worsening my damages. Therefore, I request the court order the defendants to disperse funds allowing me to hire an attorney.

SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS

INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.

CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by their fraudulent gains. This inequity forces me to continue pro se, worsening my damages. Therefore, I request the court order the defendants to disperse funds allowing me to hire an attorney.

RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable courtGiven the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal: Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits: I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees: I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs: I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AIC

PROCEDURAL CHALLENGES: Opposing counsel is introducing invoices as exhibits in limine, which were from a period before I hired my financial advisor for the bankruptcy court proceedings. Despite the error in the dates of the invoices, my due process rights were violated as I did not have the opportunity to oversee this evidence or have a voice in the matter. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process.

Your supplemental motion is thorough and well-structured. However, here are some minor refinements for clarity and coherence:
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SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by their fraudulent gains. This inequity forces me to continue pro se, worsening my damages. Therefore, I request the court order the defendants to disperse funds allowing me to hire an attorney.
PROCEDURAL CHALLENGYour supplemental motion is thorough and well-structured. However, here are some refinements for clarity and coherence:
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SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by their fraudulent gains. This inequity forces me to continue pro se, worsening my damages.
PROCEDURAL CHALLENGES:**
Opposing counsel is introducing invoices as exhibits in limine, which were from a period before

DISCOVERY NOT OFFICIALLY CLOSED: Given the substantial evidence of fraudulent documents submitted by the defendants, the discovery phase cannot be considered officially closed. The fraudulent nature of the documents undermines the validity of the discovery process. Under Rule * of the Federal Rules of Civil Procedure, or its state equivalent, discovery should be comprehensive and transparent. I respectfully request that the court reopen the discovery phase to allow for the proper examination and authentication of financial records. The integrity of the judicial process and my right to a fair trial depend on the ability to present and challenge all relevant evidence.

Your supplemental motion is well-structured and detailed. Here is the refined version for clarity and coherence:
---
SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by their fraudulent gains. This inequity forces me to continue pro se, worsening my damages. Therefore, I request the court order the defendants to disperse funds allowing me to hire an attorney.
PROCEDURAL CHALLENGES:
Opposing counsel is introducing invoices as exhibits in limine, which were from a period before I hired my financial advisor for the bankruptcy court proceedings. Despite the error in the dates of the invoices, my due process rights were violated as I did not have the opportunity to oversee this evidence or have a voice in the matter. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process.
DISCOVERY NOT OFFICIALLY CLOSED:
Given the substantial evidence of fraudulent documents submitted by the defendants, the discovery phase cannot be considered officially closed. The fraudulent nature of the documents undermines the validity of the discovery process. Under Rule * of the Federal Rules of Civil Procedure, or its state equivalent, discovery should be comprehensive and transparent. I respectfully request that the court reopen the discovery phase to allow for the proper examination and authentication of financial records. The integrity of the judicial process and my right to a fair trial depend on the ability to present and challenge all relevant evidence.
INTRODUCTION OF NEW EVIDENCE IN LIMINE:
Opposing counsel's introduction of new evidence in limine that was not submitted during the discovery phase violates procedural rules, specifically Rule * of the Federal Rules of Civil Procedure, or its state equivalent. Introducing new evidence

INTRODUCTION OF NEW EVIDENCE IN LIMINE: Opposing counsel's introduction of new evidence in limine that was not submitted during the discovery phase violates procedural rules, specifically Rule * of the Federal Rules of Civil Procedure, or its state equivalent. Introducing new evidence at this stage without proper notice or opportunity for me to respond is a clear violation of due process. Therefore, I respectfully request that the court strike this new evidence and ensure that all procedural rules are adhered to.

SUPPLEMENTAL EXPLANATION:
*. Acknowledgment of Mistake:
- I acknowledge the mistake in reading the dates on the invoices and correct the record with this motion. This acknowledgment does not diminish the fact that my due process rights were violated due to the lack of proper notice and opportunity to respond to the evidence presented by the defendants.
*. Due Process Rights Violation:
- Despite the error regarding the dates, my due process rights were violated because I did not receive an opportunity to oversee this evidence or have a voice in the matter.
- The manner in which these exhibits were submitted still undermines the integrity of the judicial process and violates my due process rights. Therefore, I respectfully request that the court strike the defendant’s exhibits (#* - #*) due to the lack of proper notice and opportunity to respond.
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 unaddressedtoday. To set the record straight: during the course of my partnership, James Tiernan destroyed all of my financial records for Classic Display Inc. 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.
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal: Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice

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. 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 proceedingor should have known. This spoliation of evidence further demonstrates their bad faith and fraudulent actions.

Classic Display Inc. 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.
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal: Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities,provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits: I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees: I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs: I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims: Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants

RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal: Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits: I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees: I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs: I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims: Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence: I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spoliation.
*. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure that they should not have title to my properties and stock ownership of my

then it cited the same relief requested as in our oral argument.

Your supplemental motion is comprehensive and well-structured. Here are some key points for clarity and conciseness:
---
SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by their fraudulent gains. This inequity forces me to continue pro se, worsening my damages.
PROCEDURAL CHALLENGES:
Opposing counsel is introducing invoices as exhibits in limine, which were from a period beforeI hired my financial advisor for the bankruptcy court proceedings. Despite the error in the dates of the invoices, my due process rights were violated as I did not have the opportunity to oversee this evidence or have a voice in the matter. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process.
DISCOVERY NOT OFFICIALLY CLOSED:
Given the substantial evidence of fraudulent documents submitted by the defendants, the discovery phase cannot be considered officially closed. The fraudulent nature of the documents undermines the validity of the discovery process. Under Rule * of the Federal Rules of Civil Procedure, or its state equivalent, discovery should be comprehensive and transparent. I respectfully request that the court reopen the discovery phase to allow for the proper examination and authentication of financial records. The integrity of the judicial process and my right to a fair trial depend on the ability to present and challenge all relevant evidence.
INTRODUCTION OF NEW EVIDENCE IN LIMINE:
Opposing counsel's introduction of new evidence in limine that was not submitted during the discovery phase violates procedural rules, specifically Rule * of the Federal Rules of Civil Procedure, or its state equivalent. Introducing new evidence at this stage without proper notice or opportunity for me to respond is a clear violation of due

Despite MY error in the dates of the invoices believing that they were from the partnership and therfore fruadlent ,they were the invoices made during our patnership and they were not.

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SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by their fraudulent gains. This inequity forces me to continue pro se, worsening my damages.
PROCEDURAL CHALLENGES:
Opposing counsel is introducing invoices as exhibits in limine, which were from a period before I hired my financial advisor for the bankruptcy court proceedings. Despite the error in the dates of the invoices, mydue process rights were violated as I did not have the opportunity to oversee this evidence or have a voice in the matter. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process.
DISCOVERY NOT OFFICIALLY CLOSED:
Given the substantial evidence of fraudulent documents submitted by the defendants, the discovery phase cannot be considered officially closed. The fraudulent nature of the documents undermines the validity of the discovery process. Under Rule * of the Federal Rules of Civil Procedure, or its state equivalent, discovery should be comprehensive and transparent. I respectfully request that the court reopen the discovery phase to allow for the proper examination and authentication of financial records. The integrity of the judicial process and my right to a fair trial depend on the ability to present and challenge all relevant evidence.
INTRODUCTION OF NEW EVIDENCE IN LIMINE:
Opposing counsel's introduction of new evidence in limine that was not submitted during the discovery phase violates procedural rules, specifically Rule * of the Federal Rules of Civil Procedure, or its state equivalent. Introducing new evidence at this stage without proper notice or opportunity for me to respond is a clear violation of due process. Therefore, I respectfully request that the court strike this new evidence and ensure that all procedural rules are adhered

I think that i want to acknowledge my mistake to ensure my credabity because I made the misstament that opposing counsel recently filed exhibits of invoices and they are fraudlent given the forensic acciountants report but i was mistaken because the invoices were prepartnership. Then conintue, " Despite the error..."

Sure, here’s a revised section acknowledging your mistake for credibility and continuing your argument:
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SUPPLEMENTAL EXPLANATION:
*. Acknowledgment of Mistake:
- I acknowledge my mistake in stating that the invoices recently filed as exhibits by opposing counsel were fraudulent based on the forensic accountant’s report. Upon further review, I realize that these invoices were from a period before the partnership.
- Despite this error, the fact remains that my due process rights were violated due to the lack of proper notice and opportunity to respond to the evidence presented by the defendants.
*. Due Process Rights Violation:
- Even with the correction regarding the dates of the invoices, my due process rights were still violated because I did not receive an opportunity to oversee this evidence or have a voice in the matter.
- The manner in which these exhibits were submitted still undermines the integrity of the judicial process and violates procedural rules (Rule *).
Therefore, I respectfully request that the court strike the defendant’s exhibits (#* - #*) due to the lack of proper notice and opportunity to respond.
---
Would you like any additional assistance with other sections or aspects of your argument?

see above

Here's the refined section acknowledging your mistake while maintaining credibility:
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SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by their fraudulent gains. This inequity forces me to continue pro se, worsening my damages.
PROCEDURAL CHALLENGES:
Opposing counsel is introducing invoices as exhibits in limine, which were from a period before I hired my financial advisor for the bankruptcy court proceedings.I initially made a misstatement, believing that the invoices were fraudulent based on the forensic accountant's report. However, I was mistaken as the invoices were from a period prior to the partnership. Despite this error, my due process rights were violated as I did not have the opportunity to oversee this evidence or have a voice in the matter. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process.
DISCOVERY NOT OFFICIALLY CLOSED:
Given the substantial evidence of fraudulent documents submitted by the defendants, the discovery phase cannot be considered officially closed. The fraudulent nature of the documents undermines the validity of the discovery process. Under Rule * of the Federal Rules of Civil Procedure, or its state equivalent, discovery should be comprehensive and transparent. I respectfully request that the court reopen the discovery phase to allow for the proper examination and authentication of financial records. The integrity of the judicial process and my right to a fair trial depend on the ability to present and challenge all relevant evidence.
INTRODUCTION OF NEW EVIDENCE IN LIMINE:
Opposing counsel's introduction of new evidence in limine that was not submitted during the discovery phase violates procedural rules, specifically Rule * of the Federal Rules of Civil Procedure, or its state equivalent.

Now from Intro of new evidence onward.

Sure, here’s the continued section from "Introduction of New Evidence in Limine" onward:
---
INTRODUCTION OF NEW EVIDENCE IN LIMINE:
Opposing counsel's introduction of new evidence in limine that was not submitted during the discovery phase violates procedural rules, specifically Rule * of the Federal Rules of Civil Procedure, or its state equivalent. Introducing new evidence at this stage without proper notice or opportunity for me to respond is a clear violation of due process. Therefore, I respectfully request that the court strike this new evidence and ensure that all procedural rules are adhered to.
SUPPLEMENTAL EXPLANATION:
*. Acknowledgment of Mistake:
- I acknowledge the mistake in reading the dates on the invoices and correct the record with this motion. This acknowledgment does not diminish the fact that my due process rights were violated due to the lack of proper notice and opportunity to respond to the evidence presented by the defendants.
*. Due Process Rights Violation:
- Despite the error regarding the dates, my due process rights were violated because I did not receive an opportunity to oversee this evidence or have a voice in the matter.
- The manner in which these exhibits were submitted still undermines the integrity of the judicial process and violatesmy due process rights. Therefore, I respectfully request that the court strike the defendant’s exhibits (#* - #*) due to the lack of proper notice and opportunity to respond.
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. 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

From, "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.." onward.

---
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.
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal: Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits: I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity ofthe judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees: I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs: I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims: Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence: Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my

see above

Sure, here’s the continued section from "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..." onward:
---
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.
---
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal: Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.

*. Motionto Strike Defendant’s Exhibits: I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees: I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs: I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims:** Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing

From * onward

*. Request for Sanctions or Dismissal of Counterclaims: Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Restoration: I ask the court to take judicial notice that I seek the full restoration of my property and assets rather than merely one-third. Restoring only one-third would not only be damaging to me but would also enforce the wrongdoing committed by the defendants.
*. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure that they cannot claim title to my properties and stock ownership of my business and to facilitate the dispersal of funds for legal representation.
*. Stay of Judgment: I request that the court stay the enforcement of the $*,* judgment purchased by the defendants from the trustee until the merits of the current case are fully adjudicated. This is to prevent irreparable harm to me, given the fraudulent circumstances under which the judgmentwas obtained and is being used.
*. Judicial Notice for Destruction of Evidence: I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spoliation.
Would you like any further assistance with your motion or any other aspect of your case?

see above

*. Request for Sanctions or Dismissal of Counterclaims: Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Restoration: I ask the court to take judicial notice that I seek the full restoration of my property and assets rather than merely one-third. Restoring only one-third would not only be damaging to me but would also enforce the wrongdoing committed by the defendants.
*. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure that they should not have title to my properties and stock ownership of my business and to facilitate the dispersal of funds for legal representation.
*. Stay of Judgment: I request that the court stay the enforcement of the $*,* judgment purchased by the defendants from the trustee until the merits of the current case are fully adjudicated. This is to prevent irreparable harm to me, giventhe fraudulent circumstances under which the judgment was obtained and is being used.
*. Judicial Notice for Destruction of Evidence: I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spoliation.
Would you like any additional assistance with other sections or aspects of your argument?

Please send me from * onward.

Sure, here’s the continued section from "*. Request for Sanctions or Dismissal of Counterclaims" onward:
---
*. Request for Sanctions or Dismissal of Counterclaims: Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Restoration: I ask the court to take judicial notice that I seek the full restoration of my property and assets rather than merely one-third. Restoring only one-third would not only be damaging to me but would also enforce the wrongdoing committed by the defendants.
*. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure that they should not have title to my properties and stock ownership of my business and to facilitate the dispersal of funds for legal representation.
*. Stay of Judgment: I request that the court stay the enforcement of the $*,* judgment purchased by the defendantsfrom the trustee until the merits of the current case are fully adjudicated. This is to prevent irreparable harm to me, given the fraudulent circumstances under which the judgment was obtained and is being used.
*. Judicial Notice for Destruction of Evidence: I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use it as a basis to motion for spoliation.
Would you like any additional assistance with other sections or aspects of your argument?

Can we edit this relief? *. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure that they should not have title to my properties and stock ownership of my business and to facilitate the dispersal of funds for legal representation. This is critical to expedite this case .

Sure, here's a refined version of your relief request for a hearing or summary judgment for fiduciary relationship:
---
*. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners and fiduciaries, owing me a duty of care, loyalty, and priority of my needs. This is essential to ensure they should not have title to my properties or stock ownership of my business and to expedite the dispersal of funds for legal representation. This expedited process is crucial to advancing the case efficiently.
---
Would you like any further assistance with other sections or aspects of your argument?

see above

Sure, here’s the refined version of the relief requested for the fiduciary relationship:
---
*. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure that they should not have title to my properties and stock ownership of my business and to facilitate the dispersal of funds for legal representation. This is essential to expedite this case.
---
Would you like any additional assistance with other sections or aspects of your argument?

see above

Sure, here’s the edited relief request for clarity and emphasis on expediting the case:
*. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure they should not have title to my properties and stock ownership of my business and to facilitate the dispersal of funds for legal representation. This step is essential to expedite this case.
Would you like any additional assistance with other sections or aspects of your argument?

Please send me from * onward. conclusion. I want the couyrt to take judicial notice that althiough this case has been pending for 5 years I do not accept the entire blame for this status. Let the records show that the defenadants continue delay this case like curerently on proceduarl matters where once again they come wityh dirty hands as they violated procedural rules . Rather I wish to highlite that i seek to expedite this case to ask the court for an immiediet hearing to establish the fiduciary relatiohsip between us in addition to the above relief requests. can you polish the conclusion?

Sure, here’s a polished version of your conclusion:
---
*. Judicial Notice for Destruction of Evidence: I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use it as a basis to motion for spoliation.
---
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. This step is crucial to expedite the resolution of this case and to address the defendants' ongoing misconduct.
---
Would you like any additional assistance?

Do you think its a good idea to have a hearing or summary judgement action before the jury trail?

Yes, requesting a hearing or summary judgment action before the jury trial can be beneficial. Here are a few reasons why:
- Clarifies Issues: It can help to clearly establish key issues, such as the fiduciary relationship, before going to trial.
- Efficiency: Resolving some matters before the trial can streamline the trial process and potentially shorten its duration.
- Strengthens Case: Establishing a fiduciary duty through a hearing or summary judgment can strengthen your case and lay a strong foundation for the jury trial.
Would you like assistance with any specific preparations for the hearing or summary judgment action?

or will the court rather wait to a jury trial to prove the fidicuary relationship?

It is often a good idea to request a hearing or summary judgment action to establish the fiduciary relationship before proceeding to a jury trial. Summary judgment can expedite the case by resolving key legal issues early, potentially simplifying the matters to be decided at trial. However, whether the court will grant such a request depends on the specific circumstances of your case and the court's discretion. Establishing the fiduciary relationship early could strengthen your position and clarify the legal duties owed by the defendants.
Would you like assistance drafting the specific request for a hearing or summary judgment action?

is this not enough or do you think I need to word it differently that i will be filing a motion : *. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure that they should not have title to my properties and stock ownership of my business and to facilitate the dispersal of funds for legal representation.

Your wording is clear and well-structured. Here’s a slightly refined version to ensure clarity and emphasis on the importance of establishing the fiduciary relationship:
---
*. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure that they should not have title to my properties and stock ownership of my business. Establishing this relationship is also necessary to facilitate the dispersal of funds for legal representation and to expedite the resolution of this case.
---
Would you like any further assistance or refinements?

I am more concerned that the judge is going to dismiss the case becuase its been in his court too long. Your thoughts?

Your concern about the judge dismissing the case due to its prolonged duration in court is valid. However, by presenting a well-substantiated argument and demonstrating ongoing procedural violations and bad faith actions by the defendants, you strengthen your position. Here are a few steps to reinforce your request and prevent potential dismissal:
*. Highlight Efforts to Expedite: Emphasize your continuous efforts to expedite the proceedings and resolve the case, such as requesting hearings and addressing procedural violations.
*. Document Delays: Clearly document and present instances where the defendants have caused delays, showing that the protracted duration is not solely due to your actions.
*. Request for Immediate Hearing: Stress the urgency and necessity of an immediate hearing to establish the fiduciary relationship, which is a critical step in advancing the case.
Your existing request for a hearing or summary judgment is well-worded. However, you can further strengthen it by explicitly stating your intention to file a formal motion if necessary:

~*. Hearing or Summary Judgment for Fiduciary Relationship:
I request an immediate hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own.This is critical to ensure they should not have title to my properties and stock ownership of my business and to facilitate the dispersal of funds for legal representation. If the court deems it necessary, I am prepared to file a formal motion to this effect. This step is essential to expedite this case.

~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 and to address the defendants' ongoing misconduct. This step is crucial to expedite the resolution of this case and to ensure justice is served.
Would you like assistance with any other sections or aspects of your argument?

see above

I understand your concern. It's important to clearly communicate that the delays are not solely your fault and emphasize your proactive steps to expedite the case. Here’s a refined version of your request and conclusion to address these concerns:
---
*. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure they should not have title to my properties and stock ownership of my business and to facilitate the dispersal of funds for legal representation. This step is essential to expedite this case and prevent further undue delays.
---
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. This step is crucial to expedite the resolution of this case and to address the defendants' ongoing misconduct. I am committed to moving this case forward efficiently and seek the court's assistance in ensuring a fair and timely resolution.
---
Would you like any additional assistance ormodifications?

Could you please outline the relief request section from prority to least priority?

Sure! Here’s your relief request section outlined from priority to least priority:
---
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits:
- I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees:
- I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.
*. SupplementaryFinancials and Forensic Accountant Costs:
- I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims:
- Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence:
- Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spoliation.
*. Hearing or Summary Judgment for Fiduciary Relationship:
- I request a hearing or

from * onward please with closing for verfied motion.

Sure, here’s the continued section from "*. Hearing or Summary Judgment for Fiduciary Relationship" onward, with the closing for the verified motion:
*. Hearing or Summary Judgment for Fiduciary Relationship: I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure they should not have title to my properties and stock ownership of my business and to facilitate the dispersal of funds for legal representation. This step is essential to expedite this case and prevent further undue delays.
*. Stay of Judgment: I request that the court stay the enforcement of the $*,* judgment purchased by the defendants from the trustee until the merits of the current case are fully adjudicated. This is to prevent irreparable harm to me, given the fraudulent circumstances under which the judgment was obtained and is being used.
*. Judicial Notice for Destruction of Evidence: I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spolilation.

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. This step is crucial to expedite the resolution of this case and to address the defendants' ongoing misconduct. I am committed to moving this case forward efficiently and seek the court's assistance in ensuring a fair and timely resolution.
---
Would you like any additional assistance or modifications?

i just thought of something. The court dimiss this case as its like dismissing a divorce proceeding by one party. It takes both, right. In rhode Island in order to dissolve a partnership the court must dissole it legally and officially . right? The court can not just leave a partnership undisolved.

Yes, you are correct. In Rhode Island, just like in divorce proceedings, 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 can aid in your argument to prevent the dismissal of your case.
Here’s the refined relief request section from priority to least priority, including the closing for a verified motion:
---
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits:
- I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule 26of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees:
- I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.

*. Supplementary Financials and Forensic Accountant Costs:
- I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims:
- Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence:
- Your Honor, I ask the court to take judicial notice that the

I want to HIGHLITE this in a separate section. Please cite rhode island law. In addition please cite that the court erred by dimsiisng my case and opposing showed misconduct.

Sure, here’s the highlighted section addressing Rhode Island law, the court's error in dismissing your case, and opposing counsel's misconduct:
---
Legal Requirement for Partnership Dissolution in Rhode Island:
In Rhode Island, the dissolution of a partnership must be legally recognized and officially dissolved by the court. The court cannot leave a partnership unresolved, similar to a divorce proceeding where both parties must be involved for a resolution. This requirement is supported by Rhode Island Partnership Law, specifically under the Uniform Partnership Act (R.I. Gen. Laws § *-*-* et seq.).
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.
Opposing Counsel's Misconduct:
Opposing counsel has shown misconduct by:
- Introducing new evidence in limine that was not submitted during the discovery phase, violating Rule * of the Federal Rules of Civil Procedure.
- Submitting fraudulent documents and failing to pay the forensic accountant's deposition fees, as required under Rule *(h) of the Rhode IslandRules of Civil Procedure.
- Destroying critical financial records of Classic Display Inc., demonstrating bad faith and spoliation of evidence.
Given these points, I request the court to reconsider the dismissal of my case and address the procedural violations and misconduct by the opposing counsel.
---
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits:
- I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees:
- I request that the

from * onward please

Sure, here’s the continued section from "*. Order for Payment of Deposition Fees" onward:
*. Order for Payment of Deposition Fees:
- I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.

*. Supplementary Financials and Forensic Accountant Costs:
- I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims:
- Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence:
- Your Honor, I ask the court to take judicial notice that thedefendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spoliation.
*. Hearing or Summary Judgment for Fiduciary Relationship:
- I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure they should not have title to my properties and stock ownership of my business and to facilitate the dispersal of funds for legal representation. This step is essential to expedite this case.
*. Stay of Judgment:
- I request that the court stay the enforcement of the $*,* judgment purchased by the defendants from the trustee until the merits of the current case are fully adjudicated. This is to prevent irreparable harm to me, given the fraudulent circumstances under which the judgment was obtained and is being used.
*. Judicial Notice for Destruction of Evidence:
- I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad

Id like to add that at the very least the stock power ducument establishing the transfer of my shares of the classic display to James tiernan established concret evidence of the partnership to one of the companies . And again by establishing the fiduciaryy relatinship in this company which was formed before the birth of the second confirms the partnership relationship of the second company. the latter was formed as a result of the already established partnership . Please say this differently.

Sure! Here's a refined version of your statement:
---
The stock power document transferring my shares of Classic Display to James Tiernan provides concrete evidence of our partnership in that company. Establishing the fiduciary relationship in this company, which existed before the creation of the second company, further confirms the partnership in the second company. The latter was formed as a result of the already established partnership.
---
Would you like any additional assistance with other sections or aspects of your argument?

can you say it better than me? And add the exhibit A the tarnsfer of shares ? The stock power document transferring my shares of Classic Display to James Tiernan provides concrete evidence of our partnership in that company. Establishing the fiduciary relationship in this company, which existed before the creation of the second company, further confirms the partnership in the second company. The latter was formed as a result of the already established partnership

Certainly! Here’s a refined version with the addition of Exhibit A:
---
The stock power document transferring my shares of Classic Display 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.
---
Would you like any additional assistance with other sections or aspects of your argument?

. The latter was formed as a direct result of the already established partnership becuase they owed me a duty of care which was breahed as they transfeerd my building to themslves ommitting me from it and throwing me out of the building, leaving me destitude.

Sure, here’s the further refined version incorporating that part:
---
The stock power document transferring my shares of Classic Display 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. They owed me a duty of care, which was breached when they transferred my building to themselves, omitted me from it, and ultimately left me destitute by throwing me out of the building.
---
Would you like any additional assistance with other sections or aspects of your argument?

see above

Sure! Here’s a refined version including your additional points:
---
The stock power document transferring my shares of Classic Display 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.
---
Would you like any additional assistance with other sections or aspects of your argument?

please start again incorpoarting the new verbage Legal Requirement for Partnership Dissolution in Rhode Island:

Sure, here’s a refined and comprehensive version of your supplemental motion incorporating the new verbiage about the legal requirement for partnership dissolution in Rhode Island:
---

SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS

CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by their fraudulent gains. This inequity forces me to continue pro se, worsening my damages.

PROCEDURAL CHALLENGES:
Opposing counsel is introducing invoices as exhibits in limine, which were from a period before I hiredmy financial advisor for the bankruptcy court proceedings. I initially made a misstatement, believing that the invoices were fraudulent based on the forensic accountant's report. However, I was mistaken as the invoices were from a period prior to the partnership. Despite this error, my due process rights were violated as I did not have the opportunity to oversee this evidence or have a voice in the matter. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process.

DISCOVERY NOT OFFICIALLY CLOSED:
Given the substantial evidence of fraudulent documents submitted by the defendants, the discovery phase cannot be considered officially closed. The fraudulent nature of the documents undermines the validity of the discovery process. Under Rule * of the Federal Rules of Civil Procedure, or its state equivalent, discovery should be comprehensive and transparent. I respectfully request that the court reopen the discovery phase to allow for the proper examination and authentication of financial records. The integrity of the judicial process and my right to a fair trial depend on the ability to present and challenge all relevant evidence.

I want to state New evidence that the court can not dismiss this ccase given ....Right at the top. Is this new evidence as i jut thought of it.

Certainly! Here’s the refined and comprehensive version of your supplemental motion, incorporating the new verbiage about the legal requirement for partnership dissolution in Rhode Island and emphasizing the new evidence at the top:
---
SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS
NEW EVIDENCE:
The court cannot dismiss this case given the newly discovered evidence which includes:
*. The stock power document transferring my shares of Classic Display to James Tiernan (Exhibit A), providing concrete evidence of our partnership.
*. The defendants’ destruction of financial records, further demonstrating their bad faith and fraudulent actions.
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by their fraudulent gains. This inequity forces me to continue pro se, worsening my damages.
PROCEDURAL CHALLENGES:
Opposing counsel is introducing invoices as exhibits in limine, which were from a period before I hired my financial advisor for the bankruptcy court proceedings. I initially made a misstatement, believing that the invoices were fraudulent based on the forensic accountant's report. However, I was mistaken as the invoices were from a period prior to the partnership. Despite this error, my due process rights were violated as I did not have the opportunity to oversee this evidence or have a voice in the matter. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process.
DISCOVERY NOT OFFICIALLY CLOSED:
Given the substantial evidence of fraudulent documents submitted by the defendants, the discovery phase cannot be considered officially closed. The fraudulent nature of the documents undermines the validity of the discovery process. Under Rule * of the Federal Rules of Civil Procedure, or its state equivalent, discovery should be comprehensive and transparent. I respectfully request that the court reopen the discovery phase

see above

Sure! Here’s the refined version with the new evidence statement at the top:
---

SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS

NEW EVIDENCE:
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.).
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by their fraudulent gains. This inequity forces me to continue pro se, worsening my damages.
PROCEDURAL CHALLENGES:
Opposing counsel is introducing invoices as exhibits in limine, which were from a period before I hired my financial advisor for the bankruptcy court proceedings. I initially made a misstatement, believing that the invoices were fraudulent based on the forensic accountant's report. However, I was mistaken as the invoices were from a period prior to the partnership. Despite this error, my due process rights were violated as I did not have the opportunity to oversee this evidence or have a voice in the matter. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process.
DISCOVERY NOT OFFICIALLY CLOSED:
Given the substantial evidence of fraudulent documents submitted by the defendants, the discovery phase cannot be considered officially closed. The fraudulent nature of the documents undermines the validity of the discovery process. Under Rule * of the Federal Rules of Civil Procedure, or its state equivalent, discovery should be comprehensive and transparent. I respectfully request that

in addition there must be an accounting to do so.

Sure, here’s the refined and comprehensive version of your supplemental motion, incorporating the new evidence statement at the top and including the necessity for an accounting:
---

SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS

NEW EVIDENCE:
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.
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions.These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by their fraudulent gains. This inequity forces me to continue pro se, worsening my damages.
PROCEDURAL CHALLENGES:
Opposing counsel is introducing invoices as exhibits in limine, which were from a period before I hired my financial advisor for the bankruptcy court proceedings. I initially made a misstatement, believing that the invoices were fraudulent based on the forensic accountant's report. However, I was mistaken as the invoices were from a period prior to the partnership. Despite this error, my due process rights were violated as I did not have the opportunity to oversee this evidence or have a voice in the matter. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process.
DISCOVERY NOT OFFICIALLY CLOSED:
Given the substantial evidence of fraudulent documents submitted by the defendants, the discovery phase cannot be considered officially closed. The fraudulent nature of the documents undermines the validity of the discovery process. Under Rule

do we add: 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.

Certainly! Here’s the revised and comprehensive version of your supplemental motion, incorporating the new evidence statement, the necessity for an accounting, and highlighting the court's error in dismissing the case:
---

SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS

NEW EVIDENCE:
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.
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financialcrimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by their fraudulent gains. This inequity forces me to continue pro se, worsening my damages.
PROCEDURAL CHALLENGES:
Opposing counsel is introducing invoices as exhibits in limine, which were from a period before I hired my financial advisor for the bankruptcy court proceedings. I initially made a misstatement, believing that the invoices were fraudulent based on the forensic accountant's report. However, I was mistaken as the invoices were from a period prior to the partnership. Despite this error, my due process rights were violated as I did not have the opportunity to oversee this evidence or have a voice in the matter. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process.
DISCOVERY NOT OFFICIALLY CLOSED:
Given the substantial evidence of fraudulent documents submitted by the

see above

Sure, here’s the refined and comprehensive version of your supplemental motion, incorporating the new evidence statement at the top, the necessity for an accounting, and the court’s error in dismissing the case:
---
SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS
NEW EVIDENCE:
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.
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.
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submitsthis Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by their fraudulent gains. This inequity forces me to continue pro se, worsening my damages.
PROCEDURAL CHALLENGES:
Opposing counsel is introducing invoices as exhibits in limine, which were from a period before I hired my financial advisor for the bankruptcy court proceedings. I initially made a misstatement, believing that the invoices were fraudulent based on the forensic accountant's report. However, I was mistaken as the invoices were from a period prior to the partnership. Despite this error, my due process rights were violated as I did not have the opportunity to oversee this evidence or have a voice in the

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 and to do so at a minimum there must be an accounting to do so. ( maybe state the accounting in this section. Please update

Sure, here’s the refined and comprehensive version of your supplemental motion, incorporating the new evidence statement at the top, the necessity for an accounting, and the court’s error in dismissing the case:
---
SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS
NEW EVIDENCE:
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.
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 toensure that all financial matters are properly addressed.
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by their fraudulent gains. This inequity forces me to continue pro se, worsening my damages.
PROCEDURAL CHALLENGES:
Opposing counsel is introducing invoices as exhibits in limine, which were from a period before I hired my financial advisor for the bankruptcy court proceedings. I initially made a misstatement, believing that the invoices were fraudulent based on the forensic accountant's report. However, I was mistaken as the invoices were from a period prior to the partnership. Despite this error,

follwing" legally and officially, an accounting must be conducted toensure that all financial matters are properly addressed.' Should the next section be the Stock Power Proves a Partnership existed? Or another great titel?

Sure, here's the refined and comprehensive version of your supplemental motion, incorporating the new evidence statement at the top, the necessity for an accounting, and the court’s error in dismissing the case:
---
SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS
NEW EVIDENCE:
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.
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 ensurethat all financial matters are properly addressed.
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by their fraudulent gains. This inequity forces me to continue pro se, worsening my damages.
PROCEDURAL CHALLENGES:
Opposing counsel is introducing invoices as exhibits in limine, which were from a period before I hired my financial advisor for the bankruptcy court proceedings. I initially made a misstatement, believing that the invoices were fraudulent based on the forensic accountant's report. However, I was mistaken as the invoices were from a period prior to the partnership. Despite this error, my

see above

Sure! Here’s the refined and comprehensive version of your supplemental motion, incorporating the new evidence statement at the top, the necessity for an accounting, the court’s error in dismissing the case, and a new section highlighting the Stock Power document:
---
SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS
NEW EVIDENCE:
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.
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 legallyand officially, an accounting must be conducted to ensure that all financial matters are properly addressed.
Stock Power Document Proves Partnership Existed:
The stock power document transferring my shares of Classic Display 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.
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused

Now from, "The bankruptcy court was abused...'

Sure! Continuing from "The bankruptcy court was abused...":
---
The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by their fraudulent gains. This inequity forces me to continue pro se, worsening my damages.
PROCEDURAL CHALLENGES:
Opposing counsel is introducing invoices as exhibits in limine, which were from a period before I hired my financial advisor for the bankruptcy court proceedings. I initially made a misstatement, believing that the invoices were fraudulent based on the forensic accountant's report. However, I was mistaken as the invoices were from a period prior to the partnership. Despite this error, my due process rights were violated as I did not have the opportunity to oversee this evidence or have a voice in the matter. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process.
DISCOVERY NOT OFFICIALLY CLOSED:
Given the substantial evidence of fraudulent documents submitted by the defendants, the discovery phase cannot be considered officially closed. The fraudulent nature of the documents undermines the validity of the discovery process. Under Rule * of the Federal Rules of Civil Procedure, or its state equivalent, discovery should be comprehensive andtransparent. I respectfully request that the court reopen the discovery phase to allow for the proper examination and authentication of financial records. The integrity of the judicial process and my right to a fair trial depend on the ability to present and challenge all relevant evidence.
INTRODUCTION OF NEW EVIDENCE IN LIMINE:
Opposing counsel's introduction of new evidence in limine that was not submitted during the discovery phase violates procedural rules, specifically Rule * of the Federal Rules of Civil Procedure, or its state equivalent. Introducing new evidence at this stage without proper notice or opportunity for me to respond is a clear violation of due process. Therefore, I respectfully request that the court strike this new evidence and ensure that all procedural rules are adhered to.
SUPPLEMENTAL EXPLANATION:
*. Acknowledgment of Mistake:
- I acknowledge the mistake in reading the dates on the invoices and correct the record with this motion. This acknowledgment does not diminish the fact that my due process rights were violated due to the lack of proper notice and opportunity to respond to the evidence presented by the defendants.
*. Due Process Rights Violation:
- Despite the error regarding the dates, my due process rights were violated because I did not receive an opportunity to oversee this evidence

Now from, "Despite the error regarding the dates, my due process rights were violated because I did not receive an opportunity to oversee this evidence..."

Sure! Continuing from "Despite the error regarding the dates, my due process rights were violated because I did not receive an opportunity to oversee this evidence...":
---
Despite the error regarding the dates, my due process rights were violated because I did not receive an opportunity to oversee this evidence or have a voice in the matter. The manner in which these exhibits were submitted still undermines the integrity of the judicial process and violates my due process rights. Therefore, I respectfully request that the court strike the defendant’s exhibits (#* - #*) due to the lack of proper notice and opportunity to respond.
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. One day I came in and saw him by the loading dock, loading boxes into theelevator. 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.
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available

see above

Sure, continuing from "Despite the error regarding the dates, my due process rights were violated because I did not receive an opportunity to oversee this evidence...":
---
SUPPLEMENTAL EXPLANATION:
*. Acknowledgment of Mistake:
- I acknowledge the mistake in reading the dates on the invoices and correct the record with this motion. This acknowledgment does not diminish the fact that my due process rights were violated due to the lack of proper notice and opportunity to respond to the evidence presented by the defendants.
*. Due Process Rights Violation:
- Despite the error regarding the dates, my due process rights were violated because I did not receive an opportunity to oversee this evidence or have a voice in the matter.
- The manner in which these exhibits were submitted still undermines the integrity of the judicial process and violates my due process rights. Therefore, I respectfully request that the court strike the defendant’s exhibits (#* - #*) due to the lack of proper notice and opportunity to respond.
JUDICIAL NOTICE FOR DESTRUCTION OF FINANCIAL RECORDS:
The court must take judicial notice that during the timewhen 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. 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.
RELIEF REQUEST

Please start from relief requested onward

Sure, here’s the continued section from "RELIEF REQUESTED" onward:
---
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits:
- I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees:
- I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.
*. SupplementSupplementary Financials and Forensic Accountant Costs:
- I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims:
- Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence:
- Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spoliation.
*. Hearing or Summary Judgment for Fiduciary Relationship:**
- I request

please start from * onward.

Sure, here’s the continued section from "*. Hearing or Summary Judgment for Fiduciary Relationship" onward:
---
*. Hearing or Summary Judgment for Fiduciary Relationship:
- I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure they should not have title to my properties and stock ownership of my business and to facilitate the dispersal of funds for legal representation. This step is essential to expedite this case and prevent further undue delays.
*. Judicial Notice for Restoration:
- I ask the court to take judicial notice that I seek the full restoration of my property and assets rather than merely one-third. Restoring only one-third would not only be damaging to me but would also enforce the wrongdoing committed by the defendants.
*. Stay of Judgment:
- I request that the court stay the enforcement of the $*,* judgment purchased by the defendants from the trustee until the merits of the current case are fully adjudicated. This is to prevent irreparable harm to me, given the fraudulent circumstances under which the judgment was obtained and is being used.
*. Judicial Notice for Destruction of Evidence:
- I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use it as a basis to motion for spoliation.
---
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. This step is crucial to expedite the resolution of this case and to address the defendants' ongoing misconduct. I am committed to moving this case forward efficiently and seek the court's assistance in ensuring a fair and timely resolution.
Would you like any additional assistance with other sections or aspects of your argument?

see above

Sure, here’s the continued section from "*. Hearing or Summary Judgment for Fiduciary Relationship" onward:
*. Hearing or Summary Judgment for Fiduciary Relationship:
- I request a hearing or summary judgment to establish that the defendants were my partners, fiduciaries, and owed me a duty of care, loyalty, and putting my needs above their own. This is critical to ensure they should not have title to my properties and stock ownership of my business and to facilitate the dispersal of funds for legal representation. This step is essential to expedite this case.
*. Judicial Notice for Restoration:
- I ask the court to take judicial notice that I seek the full restoration of my property and assets rather than merely one-third. Restoring only one-third would not only be damaging to me but would also enforce the wrongdoing committed by the defendants.
*. Stay of Judgment:
- I request that the court stay the enforcement of the $*,* judgment purchased by the defendants from the trustee until the merits of the current case are fully adjudicated. This is to prevent irreparable harm to me, given the fraudulent circumstances under which the judgment was obtained and is being used.
*. Judicial Notice for Destruction ofEvidence:
- I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for spoliation.
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. This step is crucial to expedite the resolution of this case and to address the defendants' ongoing misconduct. I am committed to moving this case forward efficiently and seek the court's assistance in ensuring a fair and timely resolution.
Would you like any additional assistance or modifications?

Lets include the r.I. Partnership law ..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 Partnership fiduciary relationship between us. This step is crucial next step to expedite the dissolutuin of our Partnership case 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.

Sure! Here’s the refined and comprehensive version of your supplemental motion, incorporating all the relevant details and the Rhode Island Partnership Law:
---
SUPPLEMENTAL MOTION TO PLAINTIFF’S SUPPLEMENTAL MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS
NEW EVIDENCE:
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.
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 ProStock Power Document Proves Partnership Existed:
The stock power document transferring my shares of Classic Display 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.
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
CHALLENGES AS A PRO SE LITIGANT:**
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I

I have everything but can you update the Conclusion to include somethin like this . Please polish:.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 Partnership fiduciary relationship between us. This step is crucial next step to expedite the dissolutuin of our Partnership case 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.

Sure! Here’s a polished and comprehensive version of your conclusion:
---
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 partnership fiduciary relationship between us. This step is crucial 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.
---
Would you like any additional assistance or modifications?

Please just send me the conclusion.

Sure! Here’s the polished conclusion:
---
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.
---

see above

Would you like any additional assistance with other sections or aspects of your argument?

cAN YOU PLEASE PROVIDE THE SIGNATIRE SECTION AS A VERIFIED MOTION?

Sure! Here’s a template for the signature section as a verified motion:
---
DECLARATION OF VERIFICATION
I, [Your Name], declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct to the best of my knowledge and belief.
Executed this [Day] day of [Month], [Year], at [City, State].
---
Respectfully submitted,
[Your Name]
[Your Address]
[City, State, ZIP Code]
[Your Email Address]
[Your Phone Number]
---
Signature:
_______________________________
[Your Name]
---
Would you like any additional modifications or assistance?

CAN YOU PLEASE PROVIDE THE SIGNATIRE SECTION AS A VERIFIED MOTION?

Sure! Here’s the signature section formatted as a verified motion:
---
Dated: [Date]
Respectfully submitted,
[Your Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
Verification
I, [Your Name], verify that I have read the foregoing Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits and that the facts stated therein are true and correct to the best of my knowledge, information, and belief.
Signed under the pains and penalties of perjury this [Day] of [Month], [Year].
___________________________
[Your Name]
Notary Public
___________________________
My commission expires:
[Date]
---
Would you like any additional assistance or modifications?

Please provide withou the notary as i must file it immiedietly and wont have time for a notary stamp.

Sure! Here’s the signature section formatted as a verified motion without the notary:
---
Dated: [Date]
Respectfully submitted,
[Your Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
Verification
I, [Your Name], verify that I have read the foregoing Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits and that the facts stated therein are true and correct to the best of my knowledge, information, and belief.
Signed under the pains and penalties of perjury this [Day] of [Month], [Year].
___________________________
[Your Name]
---
Would you like any additional assistance or modifications?

and with the s signature please

Sure! Here’s the signature section formatted as a verified motion with the s signature:
---
Dated: [Date]
Respectfully submitted,
[Your Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
Verification
I, [Your Name], verify that I have read the foregoing Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits and that the facts stated therein are true and correct to the best of my knowledge, information, and belief.
Signed under the pains and penalties of perjury this [Day] of [Month], [Year].
s/[Your Name]
---
Would you like any additional assistance or modifications?

see above

Sure! Here’s the signature section formatted as a verified motion with the signature line:
---
Dated: [Date]
Respectfully submitted,
[Your Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
Verification
I, [Your Name], verify that I have read the foregoing Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits and that the facts stated therein are true and correct to the best of my knowledge, information, and belief.
Signed under the pains and penalties of perjury this [Day] of [Month], [Year].
___________________________
[Your Name]
---
Would you like any additional assistance or modifications?

How do you sign it with /s/?

Sure, here’s the signature section formatted with the /s/ for electronic filing:
---
Dated: [Date]
Respectfully submitted,
/s/ [Your Name]
[Your Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
Verification
I, [Your Name], verify that I have read the foregoing Supplemental Motion to Plaintiff’s Supplemental Motion to Vacate Dismissal and Strike Defendant’s Exhibits and that the facts stated therein are true and correct to the best of my knowledge, information, and belief.
Signed under the pains and penalties of perjury this [Day] of [Month], [Year].
/s/ [Your Name]
[Your Name]
---
Would you like any additional assistance or modifications?

lets change this *. Motion to Vacate Dismissal: - Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.

Here’s the refined section for your Motion to Vacate Dismissal:
---
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
---
Would you like any additional assistance or modifications?

Under rhode siland Partnership law the dissolutuion of a partnership must be granted by the court to dtermine many factor but primarilty that there is a afir distribution of assets.

Sure! Here’s the revised relief request section with the updated point *:
---
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. According to Rhode Island Partnership Law, the dissolution of a partnership must be granted by the court to determine many factors, primarily to ensure a fair distribution of assets. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits:
- I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees:
- I request that the court order the defendants topay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs:
- I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims:
- Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence:
- Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use

Lastly can we no update our Oral argument to include New Evidence partnership Law here:LaGood [morning/afternoon], Your Honor. My name is James Cronan, and I am the plaintiff in this case. I am here to present my Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant’s Exhibits Submitted In Limine. *. Introduction: - Request relief from the dismissal under Rule *(b)(*) and (*) due to excusable neglect, lack of notice, and newly discovered evidence.

Sure! Here’s the updated oral argument including the new evidence regarding partnership law:
---
Good [morning/afternoon], Your Honor. My name is James Cronan, and I am the plaintiff in this case. I am here to present my Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant’s Exhibits Submitted In Limine.
*. Introduction:
- Request relief from the dismissal under Rule *(b)(*) and (*) due to excusable neglect, lack of notice, and newly discovered evidence. According to Rhode Island Partnership Law, the dissolution of a partnership must be legally recognized and officially dissolved by the court to determine many factors, primarily to ensure a fair distribution of assets.
*. New Evidence:
- The court cannot dismiss this case as it would be akin to dismissing a divorce proceeding by one party. Rhode Island Partnership Law, specifically under the Uniform Partnership Act (R.I. Gen. Laws § *-*-* et seq.), mandates that a partnership dissolution must be granted by the court. Additionally, an accounting must be conducted to ensure all financial matters are properly addressed.
*. Procedural Challenges:
- Opposing counsel is introducing invoices as exhibits in limine, which were from a period before Ihired my financial advisor for the bankruptcy court proceedings. I initially made a misstatement, believing that the invoices were fraudulent based on the forensic accountant's report. However, I was mistaken as the invoices were from a period prior to the partnership. Despite this error, my due process rights were violated as I did not have the opportunity to oversee this evidence or have a voice in the matter. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process.
*. Discovery Not Officially Closed:
- Given the substantial evidence of fraudulent documents submitted by the defendants, the discovery phase cannot be considered officially closed. The fraudulent nature of the documents undermines the validity of the discovery process. Under Rule * of the Federal Rules of Civil Procedure, or its state equivalent, discovery should be comprehensive and transparent. I respectfully request that the court reopen the discovery phase to allow for the proper examination and authentication of financial records. The integrity of the judicial process and my right to a fair trial depend on the ability to present and challenge all relevant evidence.
*. Introduction of New Evidence in Limine:
- Opposing counsel's introduction of new evidence in limine that was not submitted during the discovery phase violates procedural rules, specifically Rule * of the Federal

Do you think its still imporatnt to also stse the following:*. Lack of Notice: - Misunderstanding regarding the jury trial date set for after December. - Discovered the October * notice post-dismissal. - Court proceeded without confirmation of my notice. *. Health Condition: - Stage * kidney disease impacted my ability to manage court communications. *. Proactive Measures: - Created a dedicated email for court notifications. - Notified the court clerk promptly about my situation. *. Merits of the Case: - Pioneer Investment Services Co.v. Brunswick Associates Ltd. Partnership emphasizes judging cases on their merits rather than procedural grounds. *. Opposing Counsel’s Actions: - Opposing counsel filed a motion to dismiss with prejudice during my absence, undermining fair adjudication.

Yes, including the following points can further strengthen your argument and provide additional context to the court. Here’s the updated oral argument including those points:
---
Good [morning/afternoon], Your Honor. My name is James Cronan, and I am the plaintiff in this case. I am here to present my Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant’s Exhibits Submitted In Limine.
*. Introduction:
- Request relief from the dismissal under Rule *(b)(*) and (*) due to excusable neglect, lack of notice, and newly discovered evidence. According to Rhode Island Partnership Law, the dissolution of a partnership must be legally recognized and officially dissolved by the court to determine many factors, primarily to ensure a fair distribution of assets.
*. New Evidence:
- The court cannot dismiss this case as it would be akin to dismissing a divorce proceeding by one party. Rhode Island Partnership Law, specifically under the Uniform Partnership Act (R.I. Gen. Laws § *-*-* et seq.), mandates that a partnership dissolution must be granted by the court. Additionally, an accounting must be conducted to ensure all financial matters are properly addressed.
*. Procedural Challenges:
-Opposing counsel is introducing invoices as exhibits in limine, which were from a period before I hired my financial advisor for the bankruptcy court proceedings. I initially made a misstatement, believing that the invoices were fraudulent based on the forensic accountant's report. However, I was mistaken as the invoices were from a period prior to the partnership. Despite this error, my due process rights were violated as I did not have the opportunity to oversee this evidence or have a voice in the matter. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process.
*. Discovery Not Officially Closed:
- Given the substantial evidence of fraudulent documents submitted by the defendants, the discovery phase cannot be considered officially closed. The fraudulent nature of the documents undermines the validity of the discovery process. Under Rule * of the Federal Rules of Civil Procedure, or its state equivalent, discovery should be comprehensive and transparent. I respectfully request that the court reopen the discovery phase to allow for the proper examination and authentication of financial records. The integrity of the judicial process and my right to a fair trial depend on the ability to present and challenge all relevant evidence.
*. Introduction of New Evidence in Limine:
- Opposing counsel's introduction of new evidence

see above

Yes, it would be important to include those points to provide a comprehensive argument. Here’s the updated oral argument including all relevant details:
---
Good [morning/afternoon], Your Honor. My name is James Cronan, and I am the plaintiff in this case. I am here to present my Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant’s Exhibits Submitted In Limine.
*. Introduction:
- Request relief from the dismissal under Rule *(b)(*) and (*) due to excusable neglect, lack of notice, and newly discovered evidence. According to Rhode Island Partnership Law, the dissolution of a partnership must be legally recognized and officially dissolved by the court to determine many factors, primarily to ensure a fair distribution of assets.
*. New Evidence:
- The court cannot dismiss this case as it would be akin to dismissing a divorce proceeding by one party. Rhode Island Partnership Law, specifically under the Uniform Partnership Act (R.I. Gen. Laws § *-*-* et seq.), mandates that a partnership dissolution must be granted by the court. Additionally, an accounting must be conducted to ensure all financial matters are properly addressed.
*. Lack of Notice:
- There was a misunderstanding regarding the jury trialdate set for after December. I discovered the October * notice post-dismissal, and the court proceeded without confirmation of my notice.
*. Health Condition:
- I have Stage * kidney disease, which impacted my ability to manage court communications effectively.
*. Proactive Measures:
- I created a dedicated email for court notifications and promptly notified the court clerk about my health situation.
*. Merits of the Case:
- Pioneer Investment Services Co. v. Brunswick Associates Ltd. Partnership emphasizes judging cases on their merits rather than procedural grounds. My case has substantial merits that deserve a fair hearing.
*. Opposing Counsel’s Actions:
- Opposing counsel filed a motion to dismiss with prejudice during my absence, undermining fair adjudication. Their actions demonstrate bad faith and procedural violations, further justifying the need for relief.
*. Procedural Challenges:
- Opposing counsel is introducing invoices as exhibits in limine, which were from a period before I hired my financial advisor for the bankruptcy court proceedings. I initially made a misstatement, believing that the invoices were fraudulent based on the forensic accountant's report. However, I was mistaken as the invoices were from a period prior to the partnership. Despite this error, my due process rights were violated as

Oral arugument please uodate relief request section here to include the partnership *. Motion to Vacate Dismissal: - Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.

Good [morning/afternoon], Your Honor. My name is James Cronan, and I am the plaintiff in this case. I am here to present my Supplemental Verified Emergency Motion to Vacate Dismissal and Strike Defendant’s Exhibits Submitted In Limine.
*. Introduction:
- I request relief from the dismissal under Rule *(b)(*) and (*) due to excusable neglect, lack of notice, and newly discovered evidence. According to Rhode Island Partnership Law, the dissolution of a partnership must be legally recognized and officially dissolved by the court to determine many factors, primarily to ensure a fair distribution of assets.
*. New Evidence:
- The court cannot dismiss this case as it would be akin to dismissing a divorce proceeding by one party. Rhode Island Partnership Law, specifically under the Uniform Partnership Act (R.I. Gen. Laws § *-*-* et seq.), mandates that a partnership dissolution must be granted by the court. Additionally, an accounting must be conducted to ensure all financial matters are properly addressed.
*. Lack of Notice:
- There was a misunderstanding regarding the jury trial date set for after December. I discovered the October * notice post-dismissal, and the court proceeded without confirmation of my notice.
*. Health Condition:
- I have Stage * kidney disease, which impacted my ability to manage court communications effectively.
*. Proactive Measures:
- I created a dedicated email for court notifications and promptly notified the court clerk about my health situation.
*. Merits of the Case:
- Pioneer Investment Services Co. v. Brunswick Associates Ltd. Partnership emphasizes judging cases on their merits rather than procedural grounds. My case has substantial merits that deserve a fair hearing.
*. Opposing Counsel’s Actions:
- Opposing counsel filed a motion to dismiss with prejudice during my absence, undermining fair adjudication. Their actions demonstrate bad faith and procedural violations, further justifying the need for relief.
*. Procedural Challenges:
- Opposing counsel is introducing invoices as exhibits in limine, which were from a period before I hired my financial advisor for the bankruptcy court proceedings. I initially made a misstatement, believing that the invoices were fraudulent based on the forensic accountant's report. However, I was mistaken as the invoices were from a period prior to the partnership. Despite this error, my due process rights were violated as I did not have the opportunity to oversee this evidence or have a voice in the matter. Additionally, the manner in which these exhibits were

Relief requested section please and not the Introduction section please

Sure! Here’s the updated relief requested section:
---
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. According to Rhode Island Partnership Law, the dissolution of a partnership must be legally recognized and officially dissolved by the court to ensure a fair distribution of assets. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits:
- I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees:
- I request that the court order the defendants to pay the forensic accountant's deposition fees,as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs:
- I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims:
- Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence:
- Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this as a basis to motion for sp

see above

Sure! Here’s the updated relief requested section for your oral argument:
---
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. According to Rhode Island Partnership Law, the dissolution of a partnership must be granted by the court to determine many factors, primarily to ensure a fair distribution of assets. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits:
- I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees:
- I request that the court order the defendants to pay theforensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs:
- I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims:
- Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence:
- Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I wish to use this

- Immediate judicial intervention is necessary to ensure justice and prevent further abuse of the legal system. - If my case is dismissed, the defendants would be able to enforce the $*,* judgment against me, potentially attaching liens to my other cases, which would cause me irreparable harm. In addition the Partnership would still be in violation of Rhode Island Partnership Laws. - This underscores the importance of addressing the fraudulent activities and procedural violations before moving forward with any enforcement actions.

Sure! Here’s the updated relief requested section for your oral argument, incorporating your additional points:
---
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. According to Rhode Island Partnership Law, the dissolution of a partnership must be granted by the court to determine many factors, primarily to ensure a fair distribution of assets. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits:
- I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees:
- I request that the court orderthe defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs:
- I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims:
- Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence:
- Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their bad faith and fraudulent actions, and I

Im referring to: Newly Discovered Evidence - Recently, Mr. DiOrio, Trustee for the bankruptcy court, filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC, to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. - This judgment stems from my financial advisor's fraudulent actions in the bankruptcy court. If my case is dismissed, the defendants would be able to enforce the $*,* judgment against me, potentially attaching liens to my other cases, which would cause me irreparable harm. In adddition the partnership would bre in violatopn of Partnerships laws. Right or dont add it here?

Given the context, it is indeed pertinent to include the newly discovered evidence and its implications to your relief requested section. Here's the updated version:
---
RELIEF REQUESTED:
Given the substantial evidence of fraud, bad faith, and procedural violations by the defendants, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Dismissal:
- Under Rule *(b), I request that the court vacate the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence. According to Rhode Island Partnership Law, the dissolution of a partnership must be granted by the court to determine many factors, primarily to ensure a fair distribution of assets. The newly discovered evidence, including the recent purchase of the judgment and the defendants' fraudulent activities, provides substantial grounds for relief that were not available during the initial proceedings.
*. Motion to Strike Defendant’s Exhibits:
- I request that the court strike the defendant’s exhibits (#* - #*) submitted to the court. The manner in which these exhibits were submitted undermines the integrity of the judicial process and violates Rule * of the Federal Rules of Civil Procedure and my due process rights.
*. Order for Payment of Deposition Fees: - I request that the court order the defendants to pay the forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.
*. Supplementary Financials and Forensic Accountant Costs:
- I propose that the court require the defendants to redo the previous fraudulent financials under GAAP principles governed by the AICPA and then provide supplementary financials. The defendants should bear the cost of supplementary forensic accounting to verify the credibility of these financials. Given their fraudulent behavior, it is unjust for me to bear these costs. I have already paid for the initial report, which was a hardship.
*. Request for Sanctions or Dismissal of Counterclaims:
- Due to the defendants' fraudulent actions and procedural violations, I respectfully request that the court consider imposing sanctions on the defendants under Rule * of the Federal Rules of Civil Procedure and dismissing their counterclaims based on the demonstrated fraud and bad faith.
*. Judicial Notice for Destruction of Evidence:**
- Your Honor, I ask the court to take judicial notice that the defendants destroyed all of my financial records for Classic Display Inc. during the course of our partnership. This destruction of evidence further demonstrates their

please provide me only that section if you choose to update it.

Sure! Here’s the updated section incorporating the newly discovered evidence and the potential impact if your case is dismissed:
---
Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC, to purchase a $*,* judgment for $*,*. This raises serious concerns about ongoing fraud and bad faith.
- This judgment stems from my financial advisor's fraudulent actions in the bankruptcy court.
- If my case is dismissed, the defendants would be able to enforce the $*,* judgment against me, potentially attaching liens to my other cases, which would cause me irreparable harm. Additionally, the partnership would be in violation of Rhode Island Partnership Laws.
---
Would you like any additional assistance or modifications?

Question: in Bankr court. If a judge lifts an automatic stay based on the belief that the so-called creditor has a "colorable" claim and thus a party of interest do i have a right as the part who was damages as a result of the order to ask the judge what finder of facts vlaidated the existance of a clorable claim?

In general, if a judge lifts an automatic stay in bankruptcy court based on the belief that a creditor has a "colorable" claim, it means the judge has determined that the creditor's claim is plausible enough to warrant relief from the stay. While you may not have a direct right to demand the judge explain what specific finder of fact validated the claim, you do have options to challenge the decision:
*. Motion for Reconsideration: You can file a motion for reconsideration, asking the judge to review and reconsider the decision to lift the stay. In this motion, you can argue why the claim is not colorable and provide evidence to support your position.
*. Appeal: If your motion for reconsideration is denied, you have the right to appeal the decision to a higher court. An appeal allows you to argue that the judge made an error in lifting the stay.
*. Discovery: During the bankruptcy proceedings, you can engage in discovery to obtain evidence and information related to the creditor's claim. This can help you build your case against the validity of the claim.
*. Objection to Claim: You can file an objection to the creditor's claim in the bankruptcy court, challenging its validity and presenting evidence tosupport your position.
Here's a concise summary of your options:
- Motion for Reconsideration: Request the judge to review the decision.
- Appeal: Challenge the decision in a higher court if reconsideration is denied.
- Discovery: Obtain information related to the creditor's claim.
- Objection to Claim: Formally object to the creditor's claim in bankruptcy court.
Would you like any additional assistance or guidance on any of these options?

Discovery - I objected to the so called creditors claim but I did not ask for dicovery. So how and when can I ask for discovery, am I too late because i did not ask for dicvvery when i contested the claim?

You can still request discovery even if you did not initially ask for it when objecting to the creditor's claim. Here's what you can do:
*. File a Motion for Discovery:
- Submit a motion to the bankruptcy court requesting permission to conduct discovery related to the creditor's claim. Explain why discovery is necessary and relevant to your objection.
*. Amend Your Objection:
- If the court allows, you can amend your initial objection to include a request for discovery. This can strengthen your objection by incorporating new evidence obtained through discovery.
*. Follow Local Rules:
- Make sure to follow the local rules of the bankruptcy court regarding discovery procedures and timelines.
Would you like guidance on how to draft a motion for discovery?

see above

You can still request discovery even if you did not initially request it when you contested the claim. Here’s what you can do:
*. File a Motion for Discovery: You can file a motion for discovery in the bankruptcy court, explaining why you need additional information to challenge the creditor's claim effectively. Specify the documents and information you are seeking.
*. Request a Hearing: Along with your motion, you can request a hearing to present your reasons for needing discovery and to argue why it is necessary for a fair adjudication of the claim.
*. Amend Your Objection: If new information comes to light during discovery, you may be able to amend your initial objection to the creditor's claim.
*. Consult the Court’s Rules: Ensure you are following the specific rules and deadlines of the bankruptcy court for filing motions and requesting discovery.
Here’s a concise summary of your next steps:
- Motion for Discovery: File a motion requesting the court to allow discovery.
- Request a Hearing: Ask for a hearing to present your reasons for needing discovery.
- Amend Your Objection: Amend your initial objection if new information is discovered.
Would you like assistance with drafting a motion for discovery or any additional guidance?

Question: they dismissed my case october *, *. I am writing amotion uner *(b) * and * citing fraud upon the court. So in this motion can i request discovery ?

Yes, you can request discovery in your motion under Rule *(b)(*) and (*) citing fraud upon the court. When drafting your motion, you should:
- Clearly state your request for discovery.
- Explain the relevance and necessity of the discovery to your claims of fraud upon the court.
- Specify the documents and information you are seeking.
Would you like assistance with drafting this specific request in your motion?

In my motion if i provided exhibits showing and estblishing fraud would this support my request for discover asking for how the so clalled creditor met the definition of providing a colrable claim to lift my stay?

Providing exhibits that establish fraud can indeed support your request for discovery. Here’s a concise way to present this in your motion:
---
Motion for Discovery:
Given the substantial evidence of fraud presented in the attached exhibits, I request the court to grant discovery to determine how the so-called creditor met the definition of providing a "colorable claim" to lift the automatic stay. Specific documents and information sought include:
*. Any and all documentation supporting the creditor’s claim.
*. Communications related to the validation of the creditor’s claim.
*. Evidence used by the court to determine the claim as "colorable."
---
Would you like any additional assistance with drafting or refining your motion?

see above

Yes, providing exhibits that establish fraud would support your request for discovery by demonstrating the need for further investigation into how the so-called creditor met the definition of a colorable claim to lift your stay. When drafting your motion, you should:
*. State the Request for Discovery:
- Clearly request discovery to obtain information and documents related to the creditor's claim.

*. Explain Relevance and Necessity:
- Detail why the discovery is necessary to challenge the validity of the creditor’s claim and to support your allegations of fraud upon the court.

*. Provide Supporting Exhibits:
- Include exhibits that demonstrate the fraudulent actions, emphasizing how these exhibits necessitate further discovery to uncover the full extent of the fraud and the legitimacy of the creditor’s claim.
Here’s how you might structure this section of your motion:
---
Request for Discovery:
Given the substantial evidence of fraud, I respectfully request that the court allow discovery to obtain critical information and documents related to the creditor's claim, specifically:
*. Relevance and Necessity of Discovery:
- The exhibits provided herein establish prima facie evidence of fraud upon the court by the creditor. These exhibits necessitate further discovery to uncover the full extent of the fraudulent actions andto determine how the creditor’s claim was deemed colorable, justifying the lifting of the automatic stay.
*. Specific Documents and Information Sought:
- All communications between the creditor and any parties involved in the bankruptcy proceedings.
- Documents evidencing the creditor's claim, including any contracts, agreements, or other relevant paperwork.
- Records of any court proceedings or decisions that validated the creditor’s claim as colorable.
*. Supporting Exhibits:
- Exhibit A: [Describe Exhibit A briefly]
- Exhibit B: [Describe Exhibit B briefly]
- Exhibit C: [Describe Exhibit C briefly]
These exhibits demonstrate the fraudulent nature of the creditor’s actions and the need for discovery to ensure a fair adjudication of my claims.
---
Would you like further assistance with drafting this section or any other part of your motion?

see above

Yes, providing exhibits that establish fraud would strengthen your request for discovery. Here’s how you can structure your request in the motion:
*. Introduction: State that you are filing the motion under Rule *(b)(*) and (*) due to fraud upon the court.
*. Background: Provide a brief history of the case, including the dismissal date and the basis of your fraud claims.
*. Exhibits: Mention and attach the exhibits that establish the fraud you are alleging.
*. Request for Discovery:
- Specific Request: Clearly state that you are requesting discovery to obtain information on how the so-called creditor met the definition of providing a colorable claim, which led to the lifting of the automatic stay.
- Relevance: Explain how the discovery will help uncover the truth about the creditor's claim and support your allegations of fraud upon the court.
- Details: Specify the type of documents and information you are seeking through discovery.
Here’s a concise example of how you might word this section:
---
Request for Discovery:
Given the provided exhibits that establish fraud upon the court, I respectfully request discovery to obtain information and documents showing how the so-called creditor met the definition ofproviding a colorable claim, which led to the lifting of the automatic stay. The requested discovery is critical to uncovering the truth about the creditor's claim and supporting my allegations of fraud upon the court.
Exhibits:
Attached are exhibits [list exhibit numbers] that demonstrate the fraudulent actions taken by the creditor.
Specific Discovery Request:
- All documents and communications related to the creditor’s claim that were submitted to the court.
- Documentation showing the basis for the creditor’s claim and the validation process used to determine it was colorable.
- Any internal communications within the creditor’s organization regarding the claim.
---
Would you like further assistance with any specific part of your motion?

see above

Yes, providing exhibits that establish fraud would support your request for discovery by demonstrating the need to investigate further into how the so-called creditor met the definition of providing a colorable claim to lift the stay. Including this evidence strengthens your argument that there is a valid reason to question the creditor's claim and the process that led to the stay being lifted.
Here’s a concise way to include this in your motion:
---
Dated: [Date]
Respectfully submitted,
/s/ [Your Name]
[Your Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
Verification
I, [Your Name], verify that I have read the foregoing Motion under Rule *(b)(*) and (*) citing fraud upon the court and that the facts stated therein are true and correct to the best of my knowledge, information, and belief.
Signed under the pains and penalties of perjury this [Day] of [Month], [Year].
/s/ [Your Name]
[Your Name]
---
Request for Discovery:
In support of my motion, I have provided exhibits that establish fraud upon the court. These exhibits raise serious concerns about the validity of the creditor's claim and the process that led to the lifting of theautomatic stay. Therefore, I respectfully request the court to permit discovery to investigate how the so-called creditor met the definition of providing a colorable claim. Specifically, I seek the following documents and information:
- All communications between the creditor and the court regarding the claim.
- Documentation supporting the creditor's claim as a valid party of interest.
- Evidence used by the court or the creditor to establish the colorable claim.
These documents are necessary to ensure a fair adjudication of the creditor's claim and to address the fraud upon the court.
Would you like any additional assistance or modifications for your motion?

In my motion if i provided exhibits showing fraud would this support my request for discovery asking for cewrtain documents?

Yes, providing exhibits that establish fraud would support your request for discovery to obtain documents related to how the so-called creditor met the definition of providing a colorable claim to lift your stay. Here's how you can draft this specific request in your motion under Rule *(b)(*) and (*):
---
MOTION TO VACATE DISMISSAL UNDER RULE *(b)(*) AND (*)
Introduction:
The Plaintiff, [Your Name], respectfully submits this motion under Rule *(b)(*) and (*) to vacate the dismissal of my case due to fraud upon the court and other reasons as outlined below.
Fraud Upon the Court:
*. I have provided exhibits (Exhibits A, B, C, etc.) that clearly establish instances of fraud committed by the so-called creditor. These exhibits include evidence of [briefly describe the nature of the fraud].
Request for Discovery:
*. To further substantiate my claims of fraud and to understand how the so-called creditor met the definition of providing a colorable claim to lift the automatic stay, I request discovery of the following documents and information:
- All communications between the creditor and the bankruptcy court.
- Any documentssubmitted by the creditor to substantiate their claim.
- Records of any investigations or validations performed regarding the creditor's claim.
- Any other relevant documents that were used to establish the creditor's colorable claim.
Relevance and Necessity:
*. The requested discovery is essential to demonstrate that the creditor's claim was not colorable and was instead based on fraudulent information. This discovery will provide the necessary evidence to support my motion to vacate the dismissal of my case and to prevent further injustices.
Conclusion:
Given the evidence of fraud provided in my exhibits and the necessity for the requested discovery, I respectfully request that the court:
- Vacate the dismissal of my case under Rule *(b)(*) and (*).
- Grant my request for discovery to obtain the specified documents and information.
Verification:
I, [Your Name], verify that I have read the foregoing motion and that the facts stated therein are true and correct to the best of my knowledge, information, and belief.
Dated: [Date]
Respectfully submitted,
/s/ [Your Name]
[Your Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
---
Would you like any additional assistance or modifications

What documents must the so called creditor submit into bankr court to establish a plausible and or colorable claim to lift an atomatic stay?

To establish a plausible or colorable claim to lift an automatic stay in bankruptcy court, a creditor typically needs to submit the following documents:
*. Proof of Claim: A detailed statement of the amount owed, the basis for the claim, and any supporting documentation, such as invoices, contracts, or promissory notes.
*. Motion to Lift Automatic Stay: A formal request outlining the reasons for lifting the stay, such as lack of adequate protection, debtor's default, or the creditor's interest in the property.
*. Affidavit or Declaration: A sworn statement by the creditor or an authorized representative attesting to the facts and circumstances supporting the motion.
*. Supporting Evidence: Any documents that substantiate the creditor's claim, such as loan agreements, security agreements, mortgage documents, or evidence of non-payment.
*. Notice of Motion: A document notifying the debtor and other interested parties of the motion to lift the stay, including the date, time, and location of the hearing.
*. Certificate of Service: Proof that the creditor has properly served the debtor and other interested parties with the motion and supporting documents.
Would you need help drafting any specific document or understanding more about the process?

I know that the so called creditor did not file a proof of claim, affidavit, but they did file a fraudulent foreclsoure deed and stated clims in their motion that stae court judgement was issed against me. But the judgement was based on fraud up on the court. The problem that I am having is that the judge staes that all she need was a plausible claim. But a plausible claim was not supported. What Do i do?

To address the issue of the judge stating that all she needs is a plausible claim, but you believe the claim is not supported, here’s what you can do:
*. Motion for Reconsideration: File a motion for reconsideration, providing detailed arguments and evidence that the claim is not plausible and was based on fraud. Clearly outline how the lack of a proof of claim, affidavit, and the fraudulent foreclosure deed undermine the credibility of the creditor's claim.
*. Request for Discovery: Along with your motion for reconsideration, request discovery to obtain documentation and information that can further demonstrate the fraudulent nature of the creditor's claim.
*. Amend Your Objection: If you have new evidence or arguments, consider amending your initial objection to the creditor's claim to include this information.
Here’s a concise draft of what your motion for reconsideration and request for discovery might look like:
---
MOTION FOR RECONSIDERATION AND REQUEST FOR DISCOVERY
Introduction:
The Plaintiff, [Your Name], respectfully submits this Motion for Reconsideration under Rule *(b)(*) and (*) to vacate the previous order lifting the automatic stay, due to the creditor's fraudulent actions and lack of plausible claims.
Argument:
*. Fraudulent Foreclosure Deed and Unsupported Judgement:
- The so-called creditor did not file a proof of claim or affidavit, instead relying on a fraudulent foreclosure deed and a state court judgment, which was based on fraud upon the court.
- The judgment should not be considered plausible as it was issued under fraudulent circumstances.
*. Lack of Plausible Claim:
- The creditor failed to submit essential documents such as a proof of claim and an affidavit, which are necessary to establish a plausible claim.
- The fraudulent foreclosure deed and unsupported claims do not meet the standard of a plausible claim required to lift the automatic stay.
Request for Discovery:
To substantiate my claims of fraud and to demonstrate that the creditor did not meet the definition of providing a plausible claim, I request discovery of the following documents and information:
- All communications between the creditor and the bankruptcy court.
- Any documents submitted by the creditor to substantiate their claim.
- Records of any investigations or validations performed regarding the creditor's claim.
- Any other relevant documents that were used to establish the creditor's colorable claim.
Relevance and Necessity:
The requested discovery is essential to demonstrate that the creditor's claim

see above

Given the situation, you have several options to address the issue. Here’s a step-by-step approach:
*. File a Motion for Reconsideration:
- Explain that the so-called creditor did not file essential documents like a proof of claim or an affidavit.
- Argue that the foreclosure deed and state court judgment were based on fraud.
- Request the court to reconsider the decision to lift the stay, emphasizing that the claim was not plausible due to the lack of supporting documentation and the fraudulent nature of the evidence provided.
*. Request Discovery:
- Along with your motion for reconsideration, request discovery to obtain all documents and communications that the so-called creditor used to establish their claim.
- Highlight the necessity of this discovery to demonstrate the fraudulent nature of the creditor's claim.
*. Gather Additional Evidence:
- Collect as much evidence as possible that shows the fraudulent nature of the creditor's actions and the state court judgment.
- This could include affidavits, expert reports, or any other documentation that supports your position.
*. Consult with a Bankruptcy Attorney:
- Given the complexity of your case, it might be beneficial to consult with a bankruptcy attorney who can provide specialized guidance and represent you in courtHere’s a refined draft for your motion, incorporating these points:
---
MOTION FOR RECONSIDERATION OF ORDER LIFTING AUTOMATIC STAY
Introduction:
The Plaintiff, [Your Name], respectfully submits this motion for reconsideration of the order lifting the automatic stay, based on the lack of essential documentation by the so-called creditor and the fraudulent nature of their claim.
Lack of Supporting Documentation:
*. The so-called creditor did not file a proof of claim or an affidavit, which are essential to establish a plausible claim.
*. The only documents submitted were a fraudulent foreclosure deed and a motion stating a state court judgment against me. This judgment was based on fraud upon the court.
Request for Discovery:
*. I request discovery to obtain:
- All communications between the creditor and the bankruptcy court.
- Any documents submitted by the creditor to substantiate their claim.
- Records of any investigations or validations performed regarding the creditor's claim.
- Any other relevant documents used to establish the creditor's claim.
Relevance and Necessity:
*. The requested discovery is crucial to demonstrate that the creditor's claim is not plausible and is based on fraudulent information.
*. This discovery will provide the necessary evidence to support

Can I submit the Motion for reconsidertaion even though they denied my omnibus motion on October *, * or am I too late?

You can still submit a Motion for Reconsideration even though your omnibus motion was denied on October *, *. Generally, motions for reconsideration should be filed within a reasonable time after the original decision, often within 14 days. However, the specific timing may vary depending on the court's local rules. Here’s a concise draft for your Motion for Reconsideration:
---
MOTION FOR RECONSIDERATION OF ORDER LIFTING AUTOMATIC STAY
Introduction:
The Plaintiff, [Your Name], respectfully submits this motion for reconsideration of the order lifting the automatic stay, based on the lack of essential documentation by the so-called creditor and the fraudulent nature of their claim.
Lack of Supporting Documentation:
*. The so-called creditor did not file a proof of claim or an affidavit, which are essential to establish a plausible claim.
*. The only documents submitted were a fraudulent foreclosure deed and a motion stating a state court judgment against me. This judgment was based on fraud upon the court.
Request for Discovery:
*. I request discovery to obtain:
- All communications between the creditor and the bankruptcy court.
- Any documents submitted by the creditor to substantiate their claim.
- Records of any investigations or validations performed regarding the creditor's claim.
- Any other relevant documents used to establish the creditor's claim.
Relevance and Necessity:
*. The requested discovery is crucial to demonstrate that the creditor's claim is not plausible and is based on fraudulent information.
*. This discovery will provide the necessary evidence to support my motion to vacate the dismissal and prevent further injustices.
Conclusion:
Given the evidence of fraud and the lack of supporting documentation provided by the so-called creditor, I respectfully request that the court:
- Reconsider the order lifting the automatic stay.
- Grant my request for discovery to obtain the specified documents and information.
Verification:
I, [Your Name], verify that I have read the foregoing motion and that the facts stated therein are true and correct to the best of my knowledge, information, and belief.
Dated: [Date]
Respectfully submitted,
/s/ [Your Name]
[Your Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
---
Would you like any additional assistance or modifications?

see above

You can still file a Motion for Reconsideration even if your omnibus motion was denied on October *, *. However, it is crucial to act promptly as courts generally have specific deadlines for filing such motions. Typically, a motion for reconsideration must be filed within a reasonable time, often within * or 28 days after the order you are challenging, depending on the local rules of the court.
Here’s a concise guide on what steps to take:
*. Review Local Rules: Verify the specific deadline for filing a motion for reconsideration in your jurisdiction.
*. Draft the Motion for Reconsideration: Include the following key points:
- State the date of the original order and the reasons for seeking reconsideration.
- Clearly explain the lack of essential documentation by the so-called creditor.
- Emphasize the fraudulent nature of the creditor’s claim.
- Request discovery to obtain all relevant documents and communications.
- Argue the necessity of this discovery to demonstrate the fraudulent nature of the creditor's claim.
*. File the Motion Promptly: Ensure that you file the motion within the timeframe allowed by the court rules.
Here’s a refined draft to help you get started:
---
MOTION FORRECONSIDERATION OF ORDER LIFTING AUTOMATIC STAY
Introduction:
The Plaintiff, [Your Name], respectfully submits this motion for reconsideration of the order lifting the automatic stay, based on the lack of essential documentation by the so-called creditor and the fraudulent nature of their claim.
Lack of Supporting Documentation:
*. The so-called creditor did not file a proof of claim or an affidavit, which are essential to establish a plausible claim.
*. The only documents submitted were a fraudulent foreclosure deed and a motion citing a state court judgment against me. This judgment was based on fraud upon the court.
Request for Discovery:
*. I request discovery to obtain:
- All communications between the creditor and the bankruptcy court.
- Any documents submitted by the creditor to substantiate their claim.
- Records of any investigations or validations performed regarding the creditor's claim.
- Any other relevant documents used to establish the creditor's claim.
Relevance and Necessity:
*. The requested discovery is crucial to demonstrate that the creditor's claim is not plausible and is based on fraudulent information.
*. This discovery will provide the necessary evidence to support my motion to vacate the dismissal of my case and prevent further injustices.
**Conclusion

see above please

You can still file a motion for reconsideration, but it's important to do so promptly. Generally, a motion for reconsideration should be filed within a short period after the court's decision, often within * to 28 days, depending on local court rules. Given the urgency and the denial of your omnibus motion on October *, *, you should act quickly.
Here’s a draft for your motion for reconsideration:
---
MOTION FOR RECONSIDERATION OF ORDER LIFTING AUTOMATIC STAY
Introduction:
The Plaintiff, [Your Name], respectfully submits this motion for reconsideration of the order lifting the automatic stay, based on the lack of essential documentation by the so-called creditor and the fraudulent nature of their claim.
Lack of Supporting Documentation:
*. The so-called creditor did not file a proof of claim or an affidavit, which are essential to establish a plausible claim.
*. The only documents submitted were a fraudulent foreclosure deed and a motion stating a state court judgment against me. This judgment was based on fraud upon the court.
Request for Discovery:
*. I request discovery to obtain:
- All communications between the creditor and the bankruptcy court.
- Any documents submitted by the creditor to substantiatetheir claim.
- Records of any investigations or validations performed regarding the creditor's claim.
- Any other relevant documents used to establish the creditor's claim.
Relevance and Necessity:
*. The requested discovery is crucial to demonstrate that the creditor's claim is not plausible and is based on fraudulent information.
*. This discovery will provide the necessary evidence to support my motion to vacate the dismissal of my case and prevent further injustices.
Conclusion:
Given the evidence of fraud provided in my exhibits and the necessity for the requested discovery, I respectfully request that the court:
- Reconsider the order lifting the automatic stay.
- Grant my request for discovery to obtain the specified documents and information.
Verification:
I, [Your Name], verify that I have read the foregoing motion and that the facts stated therein are true and correct to the best of my knowledge, information, and belief.
Dated: [Date]
Respectfully submitted,
/s/ [Your Name]
[Your Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
---
Would you like any additional assistance or modifications?

Question: In my other case opposing counsel asking the court to dismiss my partnership case with prejudice because i missed a hearing was legally wrong because prejudice means that I can never seek to disolve the abisuve partnership again. Right? I have a right to dissove the partnership and to do so reguires a state action.

In Massachusetts, dismissing a case "with prejudice" means that you would indeed be barred from bringing the same claim again. You have the right to dissolve a partnership, and typically, such dissolution requires legal action.
Here are some points to consider for your argument:
- Right to Dissolve Partnership: You have a legal right to seek dissolution of the partnership under Massachusetts law.
- Dismissal with Prejudice: Arguing that dismissal with prejudice is overly harsh, especially if you missed only one hearing.
- Due Process: Emphasize your right to due process and fair adjudication.
Would you like assistance drafting a motion to oppose the dismissal with prejudice, or any other specific section of your argument?

I have filed my emergency motions . I have an upcoming hearing that you have written. Opoosing counsel wants the case dimissed because I have a forensic accountants' report citing commingling of funds, tax evasion and sham transaction that were performed in the partnership but then they claim that there was no partnership. My partner was my CPA for several years so although I dont have a contract specifying the nature of our oartnership agreement as i trusated him to have the stock power documents transferring my shaes to the other partner which was executed and signed by that CPA.

It sounds like you have substantial evidence of fraud and misconduct. Here are some critical points to include in your argument:
*. Existence of Partnership:
- Highlight the stock power document transferring your shares, executed and signed by your CPA, as evidence of the partnership.
- Emphasize the fiduciary relationship established by your CPA’s role and actions.
*. Forensic Accountant’s Report:
- Detail the findings of commingling of funds, tax evasion, and sham transactions.
- Argue that these findings support the existence of the partnership and demonstrate misconduct.
*. Opposing Counsel’s Motion to Dismiss:
- Argue that dismissing the case with prejudice is inappropriate and denies your right to dissolve the partnership.
- Emphasize that under Massachusetts law, dissolving a partnership requires a legal action and due process.
*. Request for Hearing:
- Request an immediate hearing to establish the fiduciary relationship and partnership, which is essential for the case’s resolution.
Here’s a draft for your argument at the upcoming hearing:
---
Your Honor,
*. Introduction:
- My name is [Your Name], and I am the plaintiff in thiscase. I am here to address the motion to dismiss filed by the opposing counsel and to present evidence supporting the existence and dissolution of the partnership.
*. Existence of Partnership:
- The stock power document transferring my shares to my partner, executed and signed by my CPA, provides concrete evidence of our partnership.
- My CPA’s role and actions establish a fiduciary relationship, further confirming the partnership’s existence.
*. Forensic Accountant’s Report:
- The forensic accountant's report reveals commingling of funds, tax evasion, and sham transactions within our partnership.
- These findings substantiate the existence of the partnership and highlight the defendants' fraudulent activities.
*. Opposing Counsel’s Motion to Dismiss:
- Dismissing this case with prejudice would unjustly prevent me from seeking the dissolution of the abusive partnership.
- Under Massachusetts law, a partnership cannot be dissolved without a legal action, which requires due process and fair adjudication.
*. Request for Hearing:
- I respectfully request an immediate hearing to establish the fiduciary relationship and partnership. This step is crucial to expedite the case and address the defendants' ongoing misconduct.
Conclusion:
- Your Honor, although this case has been

shares

Given the circumstances, you have a strong case for arguing against dismissal. Here are some key points to emphasize during your upcoming hearing:
*. Right to Dissolve Partnership:
- According to Massachusetts law, you have the right to dissolve a partnership. This process typically requires legal action and cannot be dismissed with prejudice simply because of a missed hearing.
*. Partnership Evidence:
- The forensic accountant’s report provides substantial evidence of commingling of funds, tax evasion, and sham transactions, indicating partnership activities.
- The stock power documents transferring your shares to the other partner, executed and signed by your CPA, serve as concrete evidence of the partnership.
*. Opposing Counsel’s Contradictory Claims:
- Highlight that opposing counsel's argument that there was no partnership contradicts the documented evidence and the financial activities reported by the forensic accountant.
*. Lack of Written Agreement:
- While you may not have a formal written partnership agreement, the longstanding professional relationship and actions taken by your CPA, including the signed stock power documents, demonstrate an implied partnership.
*. Due Process and Fairness:
- Emphasize your right to due process and fair adjudication. Dismissing the case withprejudice would unjustly prevent you from seeking legal resolution for the dissolution of the partnership and addressing the financial misconduct.
Here’s a concise outline for your oral argument:
Good [morning/afternoon], Your Honor. My name is [Your Name], and I am the plaintiff in this case. I am here to oppose the motion to dismiss my partnership case with prejudice.
*. Right to Dissolve Partnership:
- Under Massachusetts law, I have the right to seek the dissolution of the partnership. This requires legal action and cannot be dismissed with prejudice due to a missed hearing.
*. Partnership Evidence:
- The forensic accountant’s report provides substantial evidence of commingling of funds, tax evasion, and sham transactions, indicating partnership activities.
- The stock power documents transferring my shares to the other partner, executed and signed by my CPA, serve as concrete evidence of the partnership.
*. Opposing Counsel’s Contradictory Claims:
- Opposing counsel's argument that there was no partnership contradicts the documented evidence and the financial activities reported by the forensic accountant.
*. Lack of Written Agreement:
- While there is no formal written partnership agreement, the longstanding professional relationship and actions taken

In bankr court can you provide the case law wherby a claimant does not have to file a Proof Of claim and the court still can granted a release of automatic stay.

In bankruptcy court, it is generally expected that a creditor file a proof of claim to establish their right to payment from the debtor’s estate. However, there are circumstances where a creditor may be granted relief from the automatic stay without filing a proof of claim. The court will consider whether the creditor has a "colorable" claim, meaning the claim appears plausible on its face based on the evidence presented.
One case that addresses this issue is In re Veal, * B.R. * (B.A.P. 9th Cir. *). The court in Veal indicated that a party seeking relief from the automatic stay must demonstrate that it has a colorable claim to the property at issue. The court does not require a full adjudication of the validity of the claim at the stay relief stage, but rather a showing of a colorable claim is sufficient.
Key Points from In re Veal:
- Colorable Claim Requirement: The claimant must show a plausible basis for their claim.
- Proof of Claim Not Mandatory: The court may grant relief from the automatic stay without a formal proof of claim if the claimant demonstrates a colorable claim.
- Minimal Scrutiny: The court's scrutiny atthe stay relief stage is less rigorous than that used for final adjudication of claims.
Steps to Take in Your Case:
*. File a Motion for Reconsideration: Argue that the so-called creditor did not meet the standards for a colorable claim.
*. Request Discovery: Seek documents that the creditor used to support their claim.
*. Provide Evidence of Fraud: Submit exhibits that establish the fraudulent nature of the creditor’s claim.
Would you like assistance drafting the motion for reconsideration or any additional guidance?
Today I was in oral argment in front of a judge in superior court R.I you helped me to draft * motions and a outline to read from for oral argument. The hearing was to address my motion to vacate dismissal with prejudice for missing a pretrial hearing . My motions were under rule * b(*) and *. I made a mistake as i was not paying attention to my emails because at my last hearing the judge told me my jurytrial would be scheduled for some time after december so I wasent looking for emails fro the court in October. Rather than discussing my * reliefs requested in my well supported motion the judge only wanted to ask questions about why I missed the emails. Do you have any ideas as to why?
It sounds like the judge focused on why you missed the emails to determine whether there was excusable neglect or another valid reason for not attending the pretrial hearing. Judges often prioritize procedural issues first to establish the legitimacy of addressing the substantive matters of the case. Here are a few possible reasons why the judge concentrated on this aspect:
- Procedural Compliance: Judges need to ensure that procedural rules are followed. Missing a hearing can be seen as a serious procedural lapse, and the judge may have wanted to understand if there was a justifiable reason.
- Excusable Neglect: Under Rule *(b)(*), the court can grant relief for excusable neglect. The judge may have been assessing whether your reasons for missing the emails constituted excusable neglect.
- Fair Process: The judge might have been trying to ensure that the process is fair to all parties. Understanding why you missed the emails helps in evaluating if any party was disadvantaged or if there were genuine reasons for your absence.
To strengthen your position, you can provide detailed explanations and evidence of your circumstances, such as the judge's indication about the jury trial scheduling and any health or personal issues that affected your ability to monitor emails.
Would you like assistance drafting a follow-upmotion to address the judge's concerns, or help with any other part of your case?
see above
It seems that the judge focused on why you missed the emails because the court is likely trying to determine whether your failure to attend the pretrial hearing was due to excusable neglect. This is a critical factor under Rule *(b)(*) for vacating a dismissal. The judge might be assessing whether your reasons for missing the emails are sufficient to justify reopening the case.
Here are some possible reasons why the judge focused on this aspect:
*. Excusable Neglect: The judge needs to be convinced that your absence was due to excusable neglect. This includes understanding the specific reasons why you missed the emails and whether those reasons are reasonable and justifiable.
*. Procedural Fairness: Courts often prioritize procedural fairness. The judge may be ensuring that there was no procedural misconduct or negligence on your part that would undermine the integrity of the judicial process.
*. Burden of Proof: You have the burden to demonstrate that your failure to appear was excusable. The judge's questions are likely aimed at gathering sufficient information to make this determination.
*. Judicial Discretion: Judges have a significant amount of discretion in deciding whether to grant a Rule *(b) motion. They may focus on specific aspects they find most pertinent to thedecision-making process.
Here’s what you can do moving forward:
*. Clarify Your Reasons: Ensure that you clearly and thoroughly explain why you missed the emails. Emphasize any factors beyond your control, such as health issues or misunderstandings regarding the trial schedule.
*. Highlight Your Proactive Measures: Stress the steps you took to rectify the situation once you realized the mistake, such as creating a dedicated email for court notifications and promptly notifying the court clerk.
*. Reiterate the Merits of Your Case: While explaining the reasons for your absence, also reiterate the substantive merits of your case and the importance of addressing the fraudulent activities and procedural violations.
*. Request Consideration of All Reliefs: Politely request the judge to consider all the reliefs requested in your motion, not just the reason for your absence.
Would you like assistance in drafting a follow-up motion or any other specific guidance?
Please note: In R.I. in order to dissolve a partnership case like mine oarties must get the state to do so. So to dismiss my case with prejudice is illegal. i must ask the court to dissolve my partnership which i clearly highlighted as new evidence.. Right?
Yes, you're correct. In Rhode Island, dissolving a partnership requires legal action and a court order. Dismissing your case with prejudice would prevent you from seeking the legal dissolution of your partnership, which is a right you have under Rhode Island law. Here’s how you can incorporate this point into your argument:
---
Follow-Up Motion or Argument:
Introduction:
Good [morning/afternoon], Your Honor. My name is [Your Name], and I am the plaintiff in this case. I am here to provide further clarification and request the court's consideration of my motion to vacate the dismissal with prejudice.
*. Legal Requirement for Partnership Dissolution:
- In Rhode Island, the dissolution of a partnership must be legally recognized and officially dissolved by the court. This requirement is supported by Rhode Island Partnership Law, specifically under the Uniform Partnership Act (R.I. Gen. Laws § *-*-* et seq.).
- Dismissing my case with prejudice would prevent me from seeking the legal dissolution of my partnership, which is a right that cannot be forfeited simply due to missing a pretrial hearing.
*. Excusable Neglect:
- I missed the pretrial hearing because I was not paying attention to my emails,believing that the jury trial would be scheduled after December as informed by the judge at the previous hearing.
- Once I realized the mistake, I took proactive measures such as creating a dedicated email for court notifications and promptly notified the court clerk about my situation.
*. Merits of the Case:
- The forensic accountant’s report provides substantial evidence of commingling of funds, tax evasion, and sham transactions, indicating partnership activities.
- The stock power documents transferring my shares to the other partner, executed and signed by my CPA, serve as concrete evidence of the partnership.
*. Opposing Counsel’s Contradictory Claims:
- Opposing counsel argues there was no partnership, yet the documented evidence and financial activities reported by the forensic accountant contradict this claim.
*. Procedural Fairness and Due Process:
- Emphasize my right to due process and fair adjudication. Dismissing the case with prejudice would unjustly prevent me from seeking legal resolution for the dissolution of the partnership and addressing the financial misconduct.
*. Request for Consideration of All Reliefs:
- While understanding the importance of addressing why I missed the emails, I respectfully request the court to consider all the reliefs requested in my motion, particularly the necessity
In addition if my case is dimissed with prejudice the judgement which my partners are in the process of purchasing would allow them to sue me for a quarter of a million dollars , the value of the judgement and file bogus liens against me. This would cause me irreparable harm since they come with dirty hands having been a direct cause of the procurement of the judgement.
Got it! Here’s the revised follow-up motion or argument incorporating all your points:
---
Follow-Up Motion or Argument:
Introduction:
Good [morning/afternoon], Your Honor. My name is [Your Name], and I am the plaintiff in this case. I am here to provide further clarification and request the court's consideration of my motion to vacate the dismissal with prejudice.
*. Legal Requirement for Partnership Dissolution:
- In Rhode Island, the dissolution of a partnership must be legally recognized and officially dissolved by the court. This requirement is supported by Rhode Island Partnership Law, specifically under the Uniform Partnership Act (R.I. Gen. Laws § *-*-* et seq.).
- Dismissing my case with prejudice would prevent me from seeking the legal dissolution of my partnership, which is a right that cannot be forfeited simply due to missing a pretrial hearing.
*. Excusable Neglect:
- I missed the pretrial hearing because I was not paying attention to my emails, believing that the jury trial would be scheduled after December as informed by the judge at the previous hearing.
- Once I realized the mistake, I took proactive measures such as creating a dedicated email for court notifications and promptly notified the court clerkabout my situation.
*. Merits of the Case:
- The forensic accountant’s report provides substantial evidence of commingling of funds, tax evasion, and sham transactions, indicating partnership activities.
- The stock power documents transferring my shares to the other partner, executed and signed by my CPA, serve as concrete evidence of the partnership.
*. Opposing Counsel’s Contradictory Claims:
- Opposing counsel argues there was no partnership, yet the documented evidence and financial activities reported by the forensic accountant contradict this claim.
*. Procedural Fairness and Due Process:
- Emphasize my right to due process and fair adjudication. Dismissing the case with prejudice would unjustly prevent me from seeking legal resolution for the dissolution of the partnership and addressing the financial misconduct.
*. Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC, to purchase a $*,* judgment for $*,*. This raises serious concerns about ongoing fraud and bad faith.
- This judgment stems from my financial advisor's fraudulent actions in the bankruptcy court.
- If my case is dismissed, the defendants
In addition the defenants are in violation of Rule * not paying the forensic accountas invoice for a deposition that they ordered and in violation Rule xxx submitting new evidence in limine without following the correct procedure. It appears unfair to me o dismiss my breach of fiduciary partnership claim for unknowingly and mistakenly missing a pretrial hearing while their willful conduct goes unchecked.
Sure, here’s the refined and comprehensive version of your argument, incorporating all the relevant points:
---
Follow-Up Motion or Argument:
Introduction:
Good [morning/afternoon], Your Honor. My name is [Your Name], and I am the plaintiff in this case. I am here to provide further clarification and request the court's consideration of my motion to vacate the dismissal with prejudice.
*. Legal Requirement for Partnership Dissolution:
- In Rhode Island, the dissolution of a partnership must be legally recognized and officially dissolved by the court. This requirement is supported by Rhode Island Partnership Law, specifically under the Uniform Partnership Act (R.I. Gen. Laws § *-*-* et seq.).
- Dismissing my case with prejudice would prevent me from seeking the legal dissolution of my partnership, which is a right that cannot be forfeited simply due to missing a pretrial hearing.
*. Excusable Neglect:
- I missed the pretrial hearing because I was not paying attention to my emails, believing that the jury trial would be scheduled after December as informed by the judge at the previous hearing.
- Once I realized the mistake, I took proactive measures such as creating a dedicated email for court notifications and promptly notified thecourt clerk about my situation.
*. Merits of the Case:
- The forensic accountant’s report provides substantial evidence of commingling of funds, tax evasion, and sham transactions, indicating partnership activities.
- The stock power documents transferring my shares to the other partner, executed and signed by my CPA, serve as concrete evidence of the partnership.
*. Opposing Counsel’s Contradictory Claims:
- Opposing counsel argues there was no partnership, yet the documented evidence and financial activities reported by the forensic accountant contradict this claim.
*. Procedural Fairness and Due Process:
- Emphasize my right to due process and fair adjudication. Dismissing the case with prejudice would unjustly prevent me from seeking legal resolution for the dissolution of the partnership and addressing the financial misconduct.
*. Request for Consideration of All Reliefs:
- While understanding the importance of addressing why I missed the emails, I respectfully request the court to consider all the reliefs requested in my motion, particularly the necessity of dissolving the partnership.
*. Potential Irreparable Harm:
- If my case is dismissed with prejudice, the defendants, who are in the process of purchasing a quarter of a million dollar judgment against me,
please send from * onward
Sure, here’s the continued section from "*. Potential Irreparable Harm" onward:
---
*. Potential Irreparable Harm:
- If my case is dismissed with prejudice, the defendants, who are in the process of purchasing a quarter of a million dollar judgment against me, would be able to enforce this judgment and file bogus liens against me. This would cause me irreparable harm, especially since they come with dirty hands, having been a direct cause of the procurement of the judgment.
- Additionally, the defendants are in violation of Rule * by not paying the forensic accountant’s invoice for a deposition that they ordered, and in violation of Rule [XXX] by submitting new evidence in limine without following the correct procedure. It appears unfair to dismiss my breach of fiduciary partnership claim for unknowingly and mistakenly missing a pretrial hearing while their willful conduct goes unchecked.
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 acrucial 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.
---
Would you like any further assistance or modifications?
see above
Sure, here’s the continued section from "*. Potential Irreparable Harm" onward:
---
*. Potential Irreparable Harm:
- If my case is dismissed with prejudice, the defendants, who are in the process of purchasing a quarter of a million dollar judgment against me, would be able to enforce this judgment. This could lead to them filing bogus liens against me, causing me irreparable harm. Their actions are particularly egregious given that they are the direct cause of the procurement of this judgment through fraudulent means.
*. Defendants’ Procedural Violations:
- The defendants are in violation of Rule * for not paying the forensic accountant's invoice for a deposition they ordered.
- They are also in violation of procedural rules by submitting new evidence in limine without following the correct procedure.
- It appears unfair to dismiss my breach of fiduciary partnership claim for unknowingly and mistakenly missing a pretrial hearing while their willful conduct goes unchecked.
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 animmediate 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.
Verification:
I, [Your Name], verify that I have read the foregoing motion and that the facts stated therein are true and correct to the best of my knowledge, information, and belief.
Dated: [Date]
Respectfully submitted,
/s/ [Your Name]
[Your Name]
[Your Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
---
Would you like any additional assistance or modifications?
I honestly apologize for missing the hearing and becuase I have taken appropriate measures from that happening again would you please allow my case to move forward .Like everyone in this case we all want resolution but a resolution that is just and fair is the only resolution that I believe you would stand by in your court as your reputation for being fair precedes you.
Certainly! Here’s the continued section from point * onward, incorporating your apology and additional points:
---
*. Potential Irreparable Harm:
- If my case is dismissed with prejudice, the defendants, who are in the process of purchasing a quarter of a million dollar judgment against me, would be able to sue me and file bogus liens against me. This would cause me irreparable harm, especially since they have acted with fraudulent intent and come with unclean hands, having been a direct cause of the procurement of the judgment.
*. Procedural Violations by Defendants:
- The defendants are in violation of Rule * for not paying the forensic accountant's invoice for a deposition that they ordered.
- They also violated procedural rules by submitting new evidence in limine without following the correct procedure.
- It appears unfair to dismiss my breach of fiduciary partnership claim for unknowingly and mistakenly missing a pretrial hearing while their willful conduct goes unchecked.
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 thepartnership 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.
- I honestly apologize for missing the hearing and because I have taken appropriate measures to prevent that from happening again, I respectfully request that you allow my case to move forward. Like everyone in this case, we all want a resolution, but a resolution that is just and fair is the only resolution that I believe you would stand by in your court as your reputation for being fair precedes you.
Would you like any additional assistance or modifications?
I am a bit concerned that the judge will get irritated by rpeating lengthy argu,emts that he already read. But I want to sent the motion. Can you please revise to make it short and compelling?
Sure, here is a concise and compelling version of your motion:
---
MOTION TO VACATE DISMISSAL UNDER RULE *(b)(*) AND (*)
Introduction:
The Plaintiff, [Your Name], respectfully submits this motion to vacate the dismissal of my case due to fraud upon the court and other justifying reasons.
Legal Requirement for Partnership Dissolution:
- In Rhode Island, the dissolution of a partnership must be legally recognized and officially dissolved by the court (R.I. Gen. Laws § *-*-* et seq.). Dismissing my case with prejudice prevents me from seeking the legal dissolution of my partnership, which is a right that cannot be forfeited.
Excusable Neglect:
- I missed the pretrial hearing due to a misunderstanding about the jury trial date and not paying attention to emails. I have since created a dedicated email for court notifications and notified the court clerk.
Newly Discovered Evidence:
- Mr. DiOrio, Trustee for the bankruptcy court, filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC, raising concerns about ongoing fraud and bad faith. If my case is dismissed, the defendants could enforce a$*,* judgment against me, causing irreparable harm.
Merits of the Case:
- The forensic accountant’s report evidences commingling of funds, tax evasion, and sham transactions, indicating partnership activities.
- The stock power documents transferring my shares to the other partner, executed and signed by my CPA, serve as concrete evidence of the partnership.
Opposing Counsel’s Misconduct:
- Opposing counsel argues there was no partnership, yet the evidence contradicts this claim.
- They violated Rule * by not paying the forensic accountant's deposition fees and submitting new evidence in limine without following proper procedures.
Request for Discovery:
- I request discovery of all communications between the creditor and the bankruptcy court, any documents submitted by the creditor, and records of any investigations or validations performed regarding the creditor's claim.
Conclusion:
- Your Honor, although this case has been pending for five years, I do not accept the entire blame for its status. The defendants continually delay this case by violating procedural rules and engaging in bad faith practices. I respectfully request an immediate hearing to establish the fiduciary relationship between us under Rhode Island Partnership Law, essential for the fair dissolution of our partnership.
- I apologize for missing the hearing and have taken
Request for discovery is not part of this case: But you bring up a valid point what am I requesting the judge to do in this motion?
Sure, here's a revised and concise version of your motion, focusing on the key points:
---
MOTION TO VACATE DISMISSAL UNDER RULE *(b)(*) AND (*)
Introduction:
The Plaintiff, [Your Name], respectfully submits this motion to vacate the dismissal of my case due to fraud upon the court and other justifying reasons.
Legal Requirement for Partnership Dissolution:
- In Rhode Island, the dissolution of a partnership must be legally recognized and officially dissolved by the court (R.I. Gen. Laws § *-*-* et seq.). Dismissing my case with prejudice prevents me from seeking the legal dissolution of my partnership, a right that cannot be forfeited.
Excusable Neglect:
- I missed the pretrial hearing due to a misunderstanding about the jury trial date and not paying attention to emails. I have since created a dedicated email for court notifications and notified the court clerk.
Newly Discovered Evidence:
- Mr. DiOrio, Trustee for the bankruptcy court, filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC, raising concerns about ongoing fraud and bad faith. If my case is dismissed, the defendants could enforce a $*,* judgment against me, causing irreparable harm.
Merits of the Case:
- The forensic accountant’s report evidences commingling of funds, tax evasion, and sham transactions, indicating partnership activities.
- The stock power documents transferring my shares to the other partner, executed and signed by my CPA, serve as concrete evidence of the partnership.
Opposing Counsel’s Misconduct:
- Opposing counsel argues there was no partnership, yet the evidence contradicts this claim.
- They violated Rule * by not paying the forensic accountant's deposition fees and submitting new evidence in limine without following proper procedures.
Conclusion:
- Your Honor, although this case has been pending for five years, I do not accept the entire blame for its status. The defendants continually delay this case by violating procedural rules and engaging in bad faith practices. I respectfully request an immediate hearing to establish the fiduciary relationship between us under Rhode Island Partnership Law, essential for the fair dissolution of our partnership.
- I apologize for missing the hearing and have taken appropriate measures to prevent it from happening again. I respectfully request that you allow my case to move forward for a just and fair resolution.
Dated: [Date]
Respectfully submitted,
/s/ [Your Name]
Can i reguest an evidentiary hearing or a summary judgement hearing, a declataroy hearing? What type of hearing to declare that there was a partnership ?
To determine the existence of a partnership, you can request a declaratory judgment hearing. This type of hearing can help establish the legal recognition of the partnership, which is crucial for moving forward with your case. Here's a revised and concise version of your motion with a request for a declaratory judgment hearing:
---
MOTION TO VACATE DISMISSAL UNDER RULE *(b)(*) AND (*)
Introduction:
The Plaintiff, [Your Name], respectfully submits this motion to vacate the dismissal of my case due to fraud upon the court and other justifying reasons.
Legal Requirement for Partnership Dissolution:
- In Rhode Island, the dissolution of a partnership must be legally recognized and officially dissolved by the court (R.I. Gen. Laws § *-*-* et seq.). Dismissing my case with prejudice prevents me from seeking the legal dissolution of my partnership, which is a right that cannot be forfeited.
Excusable Neglect:
- I missed the pretrial hearing due to a misunderstanding about the jury trial date and not paying attention to emails. I have since created a dedicated email for court notifications and notified the court clerk.
Newly Discovered Evidence:
- Mr. DiOrio, Trustee for thebankruptcy court, filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC, raising concerns about ongoing fraud and bad faith. If my case is dismissed, the defendants could enforce a $*,* judgment against me, causing irreparable harm.
Merits of the Case:
- The forensic accountant’s report evidences commingling of funds, tax evasion, and sham transactions, indicating partnership activities.
- The stock power documents transferring my shares to the other partner, executed and signed by my CPA, serve as concrete evidence of the partnership.
Opposing Counsel’s Misconduct:
- Opposing counsel argues there was no partnership, yet the evidence contradicts this claim.
- They violated Rule * by not paying the forensic accountant's deposition fees and submitting new evidence in limine without following proper procedures.
Request for Declaratory Judgment Hearing:
- To establish the legal recognition of the partnership, I request a declaratory judgment hearing. This hearing is essential to determine that the defendants were my partners, owed me fiduciary duties, and to facilitate the fair dissolution of our partnership.
Conclusion:
- Your Honor, although this case has been pending for five years, I do not accept the entire blame for its status.
conclusion, I believe that my proposed remedy for taking the resposiabilty for mistakenly missing the hearing icluding setting up an official court email address and seekin an immiede motion for a declaratory judgement hearing is addressing bothe your assumed concerns that Im not taling my case seriously enough and that theres been too may delays.
Sure, here’s a concise and compelling version of your motion with the requested declaratory judgment hearing and conclusion:
---
MOTION TO VACATE DISMISSAL UNDER RULE *(b)(*) AND (*)
Introduction:
The Plaintiff, [Your Name], respectfully submits this motion to vacate the dismissal of my case due to fraud upon the court and other justifying reasons.
Legal Requirement for Partnership Dissolution:
- In Rhode Island, the dissolution of a partnership must be legally recognized and officially dissolved by the court (R.I. Gen. Laws § *-*-* et seq.). Dismissing my case with prejudice prevents me from seeking the legal dissolution of my partnership, which is a right that cannot be forfeited.
Excusable Neglect:
- I missed the pretrial hearing due to a misunderstanding about the jury trial date and not paying attention to emails. I have since created a dedicated email for court notifications and notified the court clerk.
Newly Discovered Evidence:
- Mr. DiOrio, Trustee for the bankruptcy court, filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC, raising concerns about ongoing fraud and bad faith. If my case is dismissed, the defendantscould enforce a $*,* judgment against me, causing irreparable harm.
Merits of the Case:
- The forensic accountant’s report evidences commingling of funds, tax evasion, and sham transactions, indicating partnership activities.
- The stock power documents transferring my shares to the other partner, executed and signed by my CPA, serve as concrete evidence of the partnership.
Opposing Counsel’s Misconduct:
- Opposing counsel argues there was no partnership, yet the evidence contradicts this claim.
- They violated Rule * by not paying the forensic accountant's deposition fees and submitting new evidence in limine without following proper procedures.
Request for Declaratory Judgment Hearing:
- To establish the legal recognition of the partnership, I request a declaratory judgment hearing. This hearing is essential to determine that the defendants were my partners, owed me fiduciary duties, and to facilitate the fair dissolution of our partnership.
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. I respectfully request an immediate hearing to establish the partnership fiduciary relationship between us under Rhode Island
Please change this becuase I have already said it. Human beings can not just let somebody free from their mistakes especially a judge . So I have to show him that I am deseriving of him chnaging his mind . So I ma trying come up with the right words. Please onky send me the conclusion as its getting cutt off.
Sure! Here’s a concise and compelling conclusion for your motion:
---
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. I respectfully request an immediate declaratory judgment hearing to establish the fiduciary relationship between us under Rhode Island Partnership Law. This step is crucial to expedite the dissolution of our partnership and address the defendants' ongoing misconduct. I have taken proactive measures to avoid future issues, including setting up a dedicated court email address, demonstrating my commitment to moving this case forward efficiently. I humbly ask the court to allow my case to proceed, ensuring that justice and fairness prevail.
---
- 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.
Sure, here’s the refined conclusion that emphasizes your proactive steps and commitment to resolving the case fairly:
---
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. I apologize for missing the hearing and have taken appropriate measures, including setting up a dedicated court email address, to prevent this from happening again. I respectfully request an immediate declaratory judgment hearing to establish the partnership fiduciary relationship between us under Rhode Island law. This step is essential to expedite the fair dissolution of our partnership and 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 for all parties involved. Your reputation for fairness and justice is well-known, and I trust that you will see the importance of allowing this case to proceed on its merits.
Would you like any additional assistance or modifications?
Your Honor, Your Honor, I apologize for missing the hearing I understand that you probably would like to move this case along and since I made what appears like a major mistake by missing a hearing this court may take it as a sign that I disrespect the time of the court. I apologize for missing the hearing and had I seen the emials I wuld have never missed the hearing. Ever. And, thats the truth. To put action behind my words, I have taken appropriate measures, including setting up a dedicated court email address, to prevent this from happening again. I respectfully request an immediate declaratory judgment hearing to establish the partnership fiduciary relationship between us under Rhode Island law. This will move the case forward in furtherance... please update and send me only the revised Conclusion. Please add something to make it stronger.
Sure, here’s the refined conclusion with your additional points:
---
Conclusion:
Your Honor, I apologize for missing the hearing. I understand that you probably would like to move this case along, and I made what appears to be a major mistake by missing a hearing. This court may take it as a sign that I disrespect the time of the court, but I assure you that is not the case. Had I seen the emails, I would have never missed the hearing. Ever. And that’s the truth. To put action behind my words, I have taken appropriate measures, including setting up a dedicated court email address, to prevent this from happening again. I respectfully request an immediate declaratory judgment hearing to establish the partnership fiduciary relationship between us under Rhode Island law. This step is essential to move the case forward and address the defendants' ongoing misconduct. Your Honor, I trust in your reputation for fairness and justice, and I believe that allowing this case to proceed on its merits will ensure a just resolution for all parties involved.
---
Would you like any additional assistance or modifications?
For clarity_ I just looked at the stock powers documents. It certifies from the stae of rhode island that ralph Grieco, my long held trusted financial advisor and CPA and James tiernan and myself own * shares of the Classic Group Inc. Then theres another document that i signed giving my * shares to James Tiernan. Then there's a letter from an attorney to ralph grieco saying here is the transfer of the shares from James cronan to james tiernan once you have them sign it please return it to me and i will update it in the corporate form.
It seems you have strong evidence to support the existence of a partnership and the need for its legal dissolution. Here’s an updated version of your conclusion, incorporating the new evidence:
---
Conclusion:
Your Honor, I apologize for missing the hearing. I understand that you probably would like to move this case along, and I made what appears to be a major mistake by missing a hearing. This court may take it as a sign that I disrespect the time of the court, but I assure you that is not the case. Had I seen the emails, I would have never missed the hearing. Ever. And that’s the truth. To put action behind my words, I have taken appropriate measures, including setting up a dedicated court email address, to prevent this from happening again.
Additionally, I have reviewed the stock power documents, which certify from the state of Rhode Island that Ralph Grieco, my long-held trusted financial advisor and CPA, James Tiernan, and I own * shares of the Classic Group Inc. I signed another document transferring my * shares to James Tiernan. Furthermore, a letter from an attorney to Ralph Grieco instructs the transfer of the shares from me to James Tiernan, to be updated in the corporate formThis evidence further substantiates the existence of a partnership.
I respectfully request an immediate declaratory judgment hearing to establish the partnership fiduciary relationship between us under Rhode Island law. This step is essential to move the case forward and address the defendants' ongoing misconduct. Your Honor, I trust in your reputation for fairness and justice, and I believe that allowing this case to proceed on its merits will ensure a just resolution for all parties involved.
---
Would you like any additional assistance or modifications?
This is just one piece of evidence i have that ralph Grieco was my cpa. I have tax returns establishing this for several years. I have tax returns establishing me as officer of the Classic group Inc.
It sounds like you have strong evidence to support your case. Here’s the refined conclusion incorporating your points:
---
Conclusion:
Your Honor, I apologize for missing the hearing. I understand that you probably would like to move this case along, and I made what appears to be a major mistake by missing a hearing. This court may take it as a sign that I disrespect the time of the court, but I assure you that is not the case. Had I seen the emails, I would have never missed the hearing. Ever. And that’s the truth. To put action behind my words, I have taken appropriate measures, including setting up a dedicated court email address, to prevent this from happening again.
I respectfully request an immediate declaratory judgment hearing to establish the partnership fiduciary relationship between us under Rhode Island law. This step is essential to move the case forward and address the defendants' ongoing misconduct. The stock powers documents, certified by the state of Rhode Island, show that Ralph Grieco, my long-held trusted financial advisor and CPA, along with James Tiernan and myself, own * shares of the Classic Group Inc. Furthermore, I have signed documents transferring my * shares to James Tiernan, along with a letter from anattorney confirming the transfer. Additionally, I have several years of tax returns establishing Ralph Grieco as my CPA and myself as an officer of the Classic Group Inc.
Your Honor, I trust in your reputation for fairness and justice, and I believe that allowing this case to proceed on its merits will ensure a just resolution for all parties involved.
---
Would you like any additional assistance or modifications?
I have the asset purchase document of my business's assets from the bankr court by Ralph Grieco and i have him on tape saying that he was my accountant and that we were going into buisness together. I believe once we establish the partnership this case will case will move forward.
---
Conclusion:
Your Honor, I apologize for missing the hearing. I understand that you probably would like to move this case along, and I made what appears to be a major mistake by missing a hearing. This court may take it as a sign that I disrespect the time of the court, but I assure you that is not the case. Had I seen the emails, I would have never missed the hearing. Ever. And that’s the truth. To put action behind my words, I have taken appropriate measures, including setting up a dedicated court email address, to prevent this from happening again.
I respectfully request an immediate declaratory judgment hearing to establish the partnership fiduciary relationship between us under Rhode Island law. This step is essential to move the case forward and address the defendants' ongoing misconduct. I have substantial evidence, including stock powers documents certified by the state of Rhode Island, showing that Ralph Grieco, my long-held trusted financial advisor and CPA, along with James Tiernan and myself, own * shares of the Classic Group Inc. Additionally, I have signed documents transferring my * shares to James Tiernan, a letter from an attorney confirming the transfer, and several years of tax returns establishing Ralph Griecoas my CPA and myself as an officer of the Classic Group Inc. Furthermore, I have the asset purchase document of my business's assets from the bankruptcy court by Ralph Grieco and a recorded statement of him confirming that he was my accountant and that we were going into business together.
Your Honor, I trust in your reputation for fairness and justice, and I believe that allowing this case to proceed on its merits will ensure a just resolution for all parties involved.
---
Would you like any additional assistance or modifications?
I like the follow up motion but I want to keep it brief as i dont want to irritate the judge more. Is the request for a declarartory appropriate when he hasent even reopened my case yet. Am I being presumtive?
It's understandable to keep your motion brief to avoid irritating the judge. Here's a concise version that still makes your key points without being overly presumptive. Instead of requesting a declaratory judgment hearing directly, you can frame it as a request for relief if the case is reopened.
---
MOTION TO VACATE DISMISSAL UNDER RULE *(b)(*) AND (*)
Introduction:
The Plaintiff, [Your Name], respectfully submits this motion to vacate the dismissal of my case due to fraud upon the court and other justifying reasons.
Legal Requirement for Partnership Dissolution:
In Rhode Island, the dissolution of a partnership must be legally recognized and officially dissolved by the court (R.I. Gen. Laws § *-*-* et seq.). Dismissing my case with prejudice prevents me from seeking the legal dissolution of my partnership, which is a right that cannot be forfeited.
Excusable Neglect:
I missed the pretrial hearing due to a misunderstanding about the jury trial date and not paying attention to emails. I have since created a dedicated email for court notifications and notified the court clerk.
Newly Discovered Evidence:
Mr. DiOrio, Trustee for the bankruptcy court,filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC, raising concerns about ongoing fraud and bad faith. If my case is dismissed, the defendants could enforce a $*,* judgment against me, causing irreparable harm.
Merits of the Case:
- The forensic accountant’s report evidences commingling of funds, tax evasion, and sham transactions, indicating partnership activities.
- The stock power documents transferring my shares to the other partner, executed and signed by my CPA, serve as concrete evidence of the partnership.
Opposing Counsel’s Misconduct:
- Opposing counsel argues there was no partnership, yet the evidence contradicts this claim.
- They violated Rule * by not paying the forensic accountant's deposition fees and submitting new evidence in limine without following proper procedures.
Conclusion:
Your Honor, I apologize for missing the hearing. I understand that you probably would like to move this case along, and I made what appears to be a major mistake by missing a hearing. This court may take it as a sign that I disrespect the time of the court, but I assure you that is not the case. Had I seen the emails, I would have never missed the hearing. Ever. And that’s
see above
I understand your concern. Here’s a more concise and focused conclusion that emphasizes the essential points without being presumptive:
---
Conclusion:
Your Honor, I sincerely apologize for missing the hearing. I understand the importance of respecting the court's time and assure you that my absence was unintentional. To prevent this from happening again, I have taken measures such as setting up a dedicated court email address.
I respectfully request the court to vacate the dismissal of my case. The dissolution of a partnership under Rhode Island law requires legal recognition and an official court order. My evidence, including stock powers documents, tax returns, and the asset purchase document, substantiates the existence of the partnership.
Allowing this case to proceed on its merits will ensure a fair resolution and address the defendants' ongoing misconduct. Your reputation for fairness and justice is well-known, and I trust in your ability to see the importance of allowing this case to move forward.
---
Would you like any additional assistance or modifications?
i like it please provide me with the complete Verfied Emergency Followup Motion?
Sure, here’s the complete Verified Emergency Follow-Up Motion:
---
SUPPLEMENTAL VERIFIED EMERGENCY FOLLOW-UP MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS
NEW EVIDENCE:
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.
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:
The stock power document transferring my shares of Classic Display to JamesTiernan (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.
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by their fraudulent gains. This inequity forces me to continue pro se,
Theres confusion I do not want to send him my previous motion. Rather what else can i include in my follow up Motion to go with the conclusion that you just wrote?
Certainly! Here’s a concise and focused version of your follow-up motion, emphasizing the key points and avoiding repetition from your previous motion:
---
SUPPLEMENTAL VERIFIED EMERGENCY FOLLOW-UP MOTION TO VACATE DISMISSAL AND STRIKE DEFENDANT’S EXHIBITS
NEW EVIDENCE:
- 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. 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.
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. 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:
- The stock power document transferring myshares of Classic Display 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.
INTRODUCTION:
The Plaintiff, [Your Name], respectfully submits this Supplemental Motion to include additional relief requested in the original Motion to Vacate Dismissal and Strike Defendant’s Exhibits.
CHALLENGES AS A PRO SE LITIGANT:
I am compelled to represent myself due to severe financial crimes committed by my trusted financial advisor and partners, leaving me insolvent while enriching them by millions. These crimes include the fraudulent conversion of my shares in our partnered company and the commercial building at * Fountain St., R.I., for which I received nothing. The bankruptcy court was abused, and creditors misled. Left paying the Small Business Loan and a default judgment, I face defendants who have hired two attorneys funded by
see above
I understand your concern. Here’s a concise and focused Verified Emergency Follow-Up Motion that includes the necessary points without repeating your previous motion in full:
---
SUPPLEMENTAL VERIFIED EMERGENCY FOLLOW-UP MOTION TO VACATE DISMISSAL
NEW EVIDENCE:
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. This 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.
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:
The stock power document transferring my shares of Classic Display 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.

EXCUSABLE NEGLECT:
I missed the pretrial hearing due to a misunderstanding about the jury trial date and not paying attention to emails. I have since created a dedicated email for court notifications and notified the court clerk.

NEWLY DISCOVERED EVIDENCE:
Mr. DiOrio, Trustee for the bankruptcy court, filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC, raising concerns about ongoing fraud and bad faith. If my case is dismissed, the defendants could enforce a $*,* judgment against me, causing irreparable harm.

Motion To Strike Defendants Exhibits

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