Legal Motion Filing Guidance

Summary

You are filing three motions: 1) Motion for Clarification and Extension of Time under the ADA, requesting an extension to respond to the summons until March 2, 2025, and seeking clarification on the status of the extension request. 2) Motion to Oppose Oral Arguments, stating objections to the request for oral arguments and requesting they be scheduled after March 2, 2025. 3) Motion for Reasonable Accommodations under the ADA, requesting reasonable accommodations due to disability, including an extension of time and assistance to ensure equal access to the legal proceedings. Additionally, you are addressing fraudulent circumstances and significant legal issues in your case, emphasizing the need for thorough examination and preparation.

Full Conversation

do I have to take any action at this time. This is the email that I got from opposng counsel-this is to advise you that Karen’s Motion with my client’s opposition and Request for Oral Argument needs to be either efiled or filed by hand by close of business tomorrow which is the day Karen’s Answer or responsive pleading is due. However he is wrong becuase On 28th * Verified Request for Extension of Time to Respond to Summons Under the ADA */*/* Defendant Karen Merritt's Request for Extension of Time to Respond to Summons Under the ADA
It sounds like you need to clarify the situation since the deadline is approaching. Here are steps you can take:
*. Call the Clerk's Office: Verify the status of your extension request.
*. File a Motion for Clarification: Explain your request for an extension under the ADA and the lack of response, and seek guidance on how to proceed.
Would you like assistance with drafting the motion?
Now comes Defendant, Karen Merritt, respectfully requesting an extension of time to respond to the summons in the case Civil Docket No. 2573CV00006. Due to her disability, Ms. Merritt requires additional time to gather necessary evidence and prepare her response. Although opposing counsel states that this matter is merely an administrative proceeding, this is untrue. This is the tip of the iceberg, as they say. Therefore, Ms. Merritt needs time to gather all of the evidence to support her arguments. Additionally, she has severe health issues which prevent her from working swiftly.
It looks like you need to take immediate action since the deadline is today. Here's what you can do:
*. Call the Clerk's Office: Verify the status of your extension request under the ADA and explain the urgency.
*. File a Motion for Clarification: If you haven't heard back, file a motion to clarify the status of your extension request and ask for immediate guidance.
Would you like assistance with drafting the motion for clarification?
please draft the morion. so I can file it now. I needmore time and under the ADA Heres more information: On january * * at *:45am I recived a summons staing You are being Sued. The Plaintiff(s) named above has started a lawsuit against you. . Section * states: you must resond to this lawsuit in writing within 20 days. Additionally it stated IF you need more time to respond, you may request an extension of time in writing from the court, with instructions how to repond.
Case Rating: *
It sounds like you need immediate assistance. Here is a draft of the motion you can file:
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COMMONWEALTH OF MASSACHUSETTS
[Name of the Court]
[Docket No. 2573CV00006]
Plaintiff(s):
[Plaintiff's Name]
Defendant:
Karen Merritt
MOTION FOR CLARIFICATION AND EXTENSION OF TIME UNDER THE ADA
Now comes the Defendant, Karen Merritt, respectfully requesting an extension of time to respond to the summons in the case Civil Docket No. 2573CV00006. Due to her disability, Ms. Merritt requires additional time to gather necessary evidence and prepare her response. Although opposing counsel states that this matter is merely an administrative proceeding, this is untrue. This is the tip of the iceberg, as they say. Therefore, Ms. Merritt needs time to gather all of the evidence to support her arguments. Additionally, she has severe health issues which prevent her from working swiftly.
In support of this Motion, Defendant states as follows:
*. On January *, *, at *:* AM, Defendant received a summons stating that she
I did as instructed and hand delivered a wrritten resonds requesting the additional time of 30 days or until March *, *. now opposing counsel is opposing my reguest staing that I am not getting sued and that the case is merely an administratvie task seeking oral arguments. i object to the oral argument request at this time. It seems like a waste of judicial time given that i need to foucus on affirmative defemses and counterclaims . In addition i will be seeking to remove the case to rhode island federal court due to diversity and federal questions.
Case Rating: *
It seems you need to clarify your request for an extension due to opposing counsel's opposition. Here's a brief guide:
- Call the Clerk's Office: Confirm the status of your extension request.
- File a Motion to Oppose Oral Arguments: State your objections and reasons for focusing on defenses and counterclaims.
Would you like assistance drafting the motion to oppose the oral arguments?
now send from "In support of this Motion, Defendant states as follows: *. On January *, *, at *:* AM, Defendant received a summons stating that she" onward
Case Rating: *
Sure, here's the continuation of your motion:
---
In support of this Motion, Defendant states as follows:
*. On January *, *, at *:* AM, Defendant received a summons stating that she was being sued and that she must respond to the lawsuit in writing within 20 days.
*. Defendant requested an extension of time to respond under the ADA on January *, *, but has yet to receive a response.
*. Opposing counsel has stated that this is an administrative task and requested oral arguments, which Defendant opposes due to a need to focus on affirmative defenses and counterclaims.
*. Defendant's severe health issues require additional time to gather necessary evidence and prepare a response.
Wherefore, Defendant respectfully requests:
*. An extension of time to respond to the summons until March *, *.
*. Clarification on the status of the extension request.
*. Denial of the request for oral arguments at this time.
---
Would you like any further assistance with this motion?
*. Defendant's severe health issues require additional time to gather necessary evidence and prepare a response. I will be please to send my doctors letter to verify my sever health issues. Please just instruct me to do so for privacy.
Case Rating: *
For privacy, follow these steps:
*. Call the Clerk's Office: Explain that you have severe health issues and request guidance on how to submit your doctor's letter confidentially.
*. File a Motion: Indicate your willingness to provide medical documentation confidentially.
Would you like assistance drafting a specific part of your motion?
yes file a motion to provide medical documentaion
Case Rating: *
Sure, here's a draft of the motion for providing medical documentation:
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COMMONWEALTH OF MASSACHUSETTS
[Name of the Court]
[Docket No. 2573CV00006]
Plaintiff(s):
[Plaintiff's Name]
Defendant:
Karen Merritt
MOTION TO PROVIDE MEDICAL DOCUMENTATION UNDER SEAL
Now comes the Defendant, Karen Merritt, respectfully requesting permission to provide medical documentation under seal in support of her request for an extension of time in the case Civil Docket No. 2573CV00006.
In support of this Motion, Defendant states as follows:
*. On January *, *, at *:* AM, Defendant received a summons stating that she was being sued and that she must respond to the lawsuit in writing within 20 days.
*. Defendant requested an extension of time to respond under the ADA on January *, *, but has yet to receive a response.
*. Opposing counsel has stated that this is an administrative task and requested oral arguments, which Defendant opposes due to a need to focus on affirmative defenses and counter
now from '*. Opposing counsel has stated that this is an administrative task and requested oral arguments, which Defendant opposes due to a need to focus on affirmative defenses and counter" onward.
Case Rating: *
Sure, here's the continuation from where you left off:
---
*. Opposing counsel has stated that this is an administrative task and requested oral arguments, which Defendant opposes due to a need to focus on affirmative defenses and counterclaims.
*. Defendant's severe health issues require additional time to gather necessary evidence and prepare a response. Defendant is willing to submit a letter from her doctor to verify her health issues, under seal for privacy.
Wherefore, Defendant respectfully requests:
*. An extension of time to respond to the summons until March *, *.
*. Clarification on the status of the extension request.
*. Denial of the request for oral arguments at this time.
*. Permission to submit medical documentation under seal.
Would you like any further assistance with this motion?
Please finish the dratt with signature /s/Karen Merritt and verification.
Case Rating: *
Sure, here's the finished draft:
---
COMMONWEALTH OF MASSACHUSETTS
[Name of the Court]
[Docket No. 2573CV00006]
Plaintiff(s):
[Plaintiff's Name]
Defendant:
Karen Merritt
MOTION FOR CLARIFICATION AND EXTENSION OF TIME UNDER THE ADA
Now comes the Defendant, Karen Merritt, respectfully requesting an extension of time to respond to the summons in the case Civil Docket No. 2573CV00006. Due to her disability, Ms. Merritt requires additional time to gather necessary evidence and prepare her response. Although opposing counsel states that this matter is merely an administrative proceeding, this is untrue. This is the tip of the iceberg, as they say. Therefore, Ms. Merritt needs time to gather all of the evidence to support her arguments. Additionally, she has severe health issues which prevent her from working swiftly.
In support of this Motion, Defendant states as follows:
*. On January *, *, at *:* AM, Defendant received a summons stating that she was being sued and that she
Now from " *. On January *, *, at *:* AM, Defendant received a summons stating that she was being sued and that she' onward
Case Rating: *
Sure, here's the continuation from where you left off:
---
*. On January *, *, at *:* AM, Defendant received a summons stating that she was being sued and that she must respond to the lawsuit in writing within 20 days.
*. Defendant requested an extension of time to respond under the ADA on January *, *, but has yet to receive a response.
*. Opposing counsel has stated that this is an administrative task and requested oral arguments, which Defendant opposes due to a need to focus on affirmative defenses and counterclaims.
*. Defendant's severe health issues require additional time to gather necessary evidence and prepare a response. Defendant is willing to submit a letter from her doctor to verify her health issues, under seal for privacy.
Wherefore, Defendant respectfully requests:
*. An extension of time to respond to the summons until March *, *.
*. Clarification on the status of the extension request.
*. Denial of the request for oral arguments at this time.
*. Permission to submit medical documentation under seal.

/s/Karen Merritt

---
Would you like any further assistance with this motion?
*. Opposing counsel has stated that this is an administrative task and requested oral arguments, Oral argements tkae time to prepare Its a serious hearing. I seek for the oral argement to be given after March * * giving me the time requested to prepare for the affirmative defense, counterclaims and oral argument. I believ that this is a reasonable request.
Case Rating: *
It sounds like you're dealing with a complex situation. Here's the final draft with your requested changes:
---
COMMONWEALTH OF MASSACHUSETTS
[Name of the Court]
[Docket No. 2573CV00006]
Plaintiff(s):
[Plaintiff's Name]
Defendant:
Karen Merritt
MOTION FOR CLARIFICATION AND EXTENSION OF TIME UNDER THE ADA
Now comes the Defendant, Karen Merritt, respectfully requesting an extension of time to respond to the summons in the case Civil Docket No. 2573CV00006. Due to her disability, Ms. Merritt requires additional time to gather necessary evidence and prepare her response. Although opposing counsel states that this matter is merely an administrative proceeding, this is untrue. This is the tip of the iceberg, as they say. Therefore, Ms. Merritt needs time to gather all of the evidence to support her arguments. Additionally, she has severe health issues which prevent her from working swiftly.
In support of this Motion, Defendant states as follows:
*. On January *, *, at *:* AM, Defendant received
now from "In support of this Motion, Defendant states as follows" onward
Case Rating: *
Sure, here's the continuation from where you left off:
---
In support of this Motion, Defendant states as follows:
*. On January *, *, at *:* AM, Defendant received a summons stating that she was being sued and that she must respond to the lawsuit in writing within 20 days.
*. Defendant requested an extension of time to respond under the ADA on January *, *, but has yet to receive a response.
*. Opposing counsel has stated that this is an administrative task and requested oral arguments, which Defendant opposes due to a need to focus on affirmative defenses and counterclaims. Oral arguments take time to prepare and are a serious hearing. Defendant seeks for the oral argument to be given after March *, *, providing the requested time to prepare for affirmative defenses, counterclaims, and oral argument. Defendant believes this is a reasonable request.
*. Defendant's severe health issues require additional time to gather necessary evidence and prepare a response. Defendant is willing to submit a letter from her doctor to verify her health issues, under seal for privacy.
Wherefore, Defendant respectfully requests:
*. An extension of time to respond to the summons until
i think that i got dates wrong. Please update. The docket states that service was made to karen merritt on January 13m * . January *, * reguest for time was made by me.
Case Rating: *
Sure, here is the updated draft with the corrected dates:
---
COMMONWEALTH OF MASSACHUSETTS
[Name of the Court]
[Docket No. 2573CV00006]
Plaintiff(s):
[Plaintiff's Name]
Defendant:
Karen Merritt
MOTION FOR CLARIFICATION AND EXTENSION OF TIME UNDER THE ADA
Now comes the Defendant, Karen Merritt, respectfully requesting an extension of time to respond to the summons in the case Civil Docket No. 2573CV00006. Due to her disability, Ms. Merritt requires additional time to gather necessary evidence and prepare her response. Although opposing counsel states that this matter is merely an administrative proceeding, this is untrue. This is the tip of the iceberg, as they say. Therefore, Ms. Merritt needs time to gather all of the evidence to support her arguments. Additionally, she has severe health issues which prevent her from working swiftly.
In support of this Motion, Defendant states as follows:
*. On January *, *, Defendant received a summons stating that she was being sued and that she must respond to
Now from "In support of this Motion, Defendant states as follows" onward
Case Rating: *
Sure, here's the continuation from where you left off with the corrected dates:
---
In support of this Motion, Defendant states as follows:
*. On January *, *, Defendant received a summons stating that she was being sued and that she must respond to the lawsuit in writing within 20 days.
*. Defendant requested an extension of time to respond under the ADA on January *, *, but has yet to receive a response.
*. Opposing counsel has stated that this is an administrative task and requested oral arguments, which Defendant opposes due to a need to focus on affirmative defenses and counterclaims. Oral arguments take time to prepare and are a serious hearing. Defendant seeks for the oral argument to be given after March *, *, providing the requested time to prepare for affirmative defenses, counterclaims, and oral argument. Defendant believes this is a reasonable request.
*. Defendant's severe health issues require additional time to gather necessary evidence and prepare a response. Defendant is willing to submit a letter from her doctor to verify her health issues, under seal for privacy.
Wherefore, Defendant respectfully requests:
*. An extension of time to respond to the summons until March *
Instaed say *. Acceptance of opposoing counsel's reguest for for oral arguments given me the time needed to prepare , after March *, *.
Case Rating: *
Sure, here's the updated section with your request:
---
In support of this Motion, Defendant states as follows:
*. On January *, *, Defendant received a summons stating that she was being sued and that she must respond to the lawsuit in writing within 20 days.
*. Defendant requested an extension of time to respond under the ADA on January *, *, but has yet to receive a response.
*. Opposing counsel has stated that this is an administrative task and requested oral arguments. Defendant accepts the request for oral arguments, provided they are scheduled after March *, *, allowing sufficient time to prepare for affirmative defenses, counterclaims, and the oral argument. Defendant believes this is a reasonable request.
*. Defendant's severe health issues require additional time to gather necessary evidence and prepare a response. Defendant is willing to submit a letter from her doctor to verify her health issues, under seal for privacy.
Wherefore, Defendant respectfully requests:
*. An extension of time to respond to the summons until March *, *.
*. Clarification on the status of the extension request.
*. Acceptance of opposing counsel's request for oral arguments, given the
from * onward
Case Rating: *
Sure, here's the continuation from your requested point:
---
*. Opposing counsel has stated that this is an administrative task and requested oral arguments. Defendant accepts the request for oral arguments, provided they are scheduled after March *, *, allowing sufficient time to prepare for affirmative defenses, counterclaims, and the oral argument. Defendant believes this is a reasonable request.
*. Defendant's severe health issues require additional time to gather necessary evidence and prepare a response. Defendant is willing to submit a letter from her doctor to verify her health issues, under seal for privacy.
Wherefore, Defendant respectfully requests:
*. An extension of time to respond to the summons until March *, *.
*. Clarification on the status of the extension request.
*. Acceptance of opposing counsel's request for oral arguments, given the time needed to prepare, after March *, *.
*. Permission to submit medical documentation under seal.

/s/Karen Merritt

---
Would you like any further assistance with this motion?
*. Defendant requested an extension of time to respond under the ADA on January *, *, but has yet to receive a response. Please state what rights i have under the American Disabilty Act (citing the law) to make reasonable accomadation time being one of them. Should i request an admistarvtive body to work with me to represent me in this case effectively ensuring me rights? Can I ask for this/
Case Rating: *
You have a right under the Americans with Disabilities Act (ADA) to request reasonable accommodations, including extensions of time. Here are some relevant points from the ADA:
- Title II of the ADA: Requires state and local governments to make reasonable modifications in policies, practices, or procedures to avoid discrimination based on disability (* U.S.C. § *).
- Reasonable Accommodation: This includes modifications needed to ensure that people with disabilities have equal access to legal proceedings.
Steps:
*. File a Motion for Reasonable Accommodation: Clearly state your need for an extension due to your disability.
*. Request Assistance: You can ask the court to appoint an administrative body or legal aid organization to help ensure your rights are protected.
Would you like a draft for the motion requesting reasonable accommodation and assistance?
Please file a motion for reasonable accomodations.
Case Rating: *
Sure, here is a draft for your motion requesting reasonable accommodations:
---
COMMONWEALTH OF MASSACHUSETTS
[Name of the Court]
[Docket No. 2573CV00006]
Plaintiff(s):
[Plaintiff's Name]
Defendant:
Karen Merritt
MOTION FOR REASONABLE ACCOMMODATIONS UNDER THE ADA
Now comes the Defendant, Karen Merritt, respectfully requesting reasonable accommodations under the Americans with Disabilities Act (ADA) in the case Civil Docket No. 2573CV00006. Due to her disability, Ms. Merritt requires additional time and assistance to effectively participate in this legal proceeding.
In support of this Motion, Defendant states as follows:
*. On January *, *, Defendant received a summons stating that she was being sued and that she must respond to the lawsuit in writing within 20 days.
*. Defendant requested an extension of time to respond under the ADA on January *, *, but has yet to receive a response.
*. Opposing counsel has stated that this is an administrative task and requested oral arguments. Defendant accepts the
section * onward.
Case Rating: *
---
Sure, here's the continuation from section * onward:
---
*. Opposing counsel has stated that this is an administrative task and requested oral arguments. Defendant accepts the request for oral arguments, provided they are scheduled after March *, *, allowing sufficient time to prepare for affirmative defenses, counterclaims, and the oral argument. Defendant believes this is a reasonable request.
*. Defendant's severe health issues require additional time to gather necessary evidence and prepare a response. Defendant is willing to submit a letter from her doctor to verify her health issues, under seal for privacy.
*. Under Title II of the ADA (* U.S.C. § *), state and local governments must make reasonable modifications in policies, practices, or procedures to avoid discrimination based on disability. Defendant requests reasonable accommodations to ensure equal access to this legal proceeding.
Wherefore, Defendant respectfully requests:
*. An extension of time to respond to the summons until March *, *.
*. Clarification on the status of the extension request.
*. Acceptance of opposing counsel's request for oral arguments, provided they are scheduled after March *, *, to allow sufficient preparation time
from * onward.
Case Rating: *
Sure, here's the continuation from section * onward:
---
*. Opposing counsel has stated that this is an administrative task and requested oral arguments. Defendant accepts the request for oral arguments, provided they are scheduled after March *, *, allowing sufficient time to prepare for affirmative defenses, counterclaims, and the oral argument. Defendant believes this is a reasonable request.
*. Defendant's severe health issues require additional time to gather necessary evidence and prepare a response. Defendant is willing to submit a letter from her doctor to verify her health issues, under seal for privacy.
*. Under Title II of the ADA (* U.S.C. § *), state and local governments must make reasonable modifications in policies, practices, or procedures to avoid discrimination based on disability. Defendant requests reasonable accommodations to ensure equal access to this legal proceeding.
Wherefore, Defendant respectfully requests:
*. An extension of time to respond to the summons until March *, *.
*. Clarification on the status of the extension request.
*. Acceptance of opposing counsel's request for oral arguments, provided they are scheduled after March *, *, to allow sufficient preparation time.
*
Please tell me what motions i am filing, are there three?
Case Rating: *
Based on the information provided, you are filing three motions:
*. Motion for Clarification and Extension of Time under the ADA:
- Requests an extension to respond to the summons until March *, *.
- Seeks clarification on the status of the extension request.
- Accepts opposing counsel's request for oral arguments, provided they are scheduled after March *, *.
- Requests permission to submit medical documentation under seal.
*. Motion to Oppose Oral Arguments:
- States objections to the request for oral arguments, emphasizing the need to focus on affirmative defenses and counterclaims and requesting the oral argument be scheduled after March *, *.
*. Motion for Reasonable Accommodations under the ADA:
- Requests reasonable accommodations due to disability, including an extension of time and assistance to ensure equal access to the legal proceedings.
*. Defendant requested an extension of time to respond under the ADA on January *, *, and due to formatting issues she understands the answer is in pending status. please polsih
Case Rating: *
Sure, here's the polished version:
---
COMMONWEALTH OF MASSACHUSETTS
[Name of the Court]
[Docket No. 2573CV00006]
Plaintiff(s):
[Plaintiff's Name]
Defendant:
Karen Merritt
MOTION FOR CLARIFICATION AND EXTENSION OF TIME UNDER THE ADA
Now comes the Defendant, Karen Merritt, respectfully requesting an extension of time to respond to the summons in the case Civil Docket No. 2573CV00006. Due to her disability, Ms. Merritt requires additional time to gather necessary evidence and prepare her response. Although opposing counsel states that this matter is merely an administrative proceeding, this is untrue. This is the tip of the iceberg, as they say. Therefore, Ms. Merritt needs time to gather all of the evidence to support her arguments. Additionally, she has severe health issues which prevent her from working swiftly.
In support of this Motion, Defendant states as follows:
*. On January *, *, Defendant received a summons
please only send me the section whith the pending status
Case Rating: *
Sure, here's the section with the pending status:
---
*. Defendant requested an extension of time to respond under the ADA on January *, *, and due to formatting issues, she understands the answer is in pending status.
---
Would you like any further assistance with this motion?
please revise giving the official ADA legal citing.
Case Rating: *
Sure, here's the revised section with the official ADA citation:
---
*. Defendant requested an extension of time to respond under the ADA on January *, *, and due to formatting issues, she understands the answer is in pending status. Under Title II of the ADA (* U.S.C. § *), state and local governments are required to make reasonable modifications to avoid discrimination based on disability.
---
Would you like any further assistance with this motion?
Under MOTION FOR REASONABLE ACCOMMODATIONS UNDER THE ADA should i ask the court to assign me to theThe Judiciary has designated ADA Coordinators to coordinate its efforts to comply with the requirements of the Americans with Disabilities Act and other federal and state laws protecting the rights of people with disabilities. Inquiries, requests, and complaints that a program, service, or activity of a particular court is not accessible to persons with disabilities should be directed to one of the ADA Coordinators for that court. do i ask for ADA coordinator here if that is need to fasciliate my reasonable regues/What the ADA does allow: Courts are obligated to provide reasonable accommodations to individuals with disabilities, which can include things like sign language interpreters, assistive listening devices, extended time for responses, or modified scheduling
Case Rating: *
Yes, you should request the assistance of an ADA Coordinator to facilitate your reasonable accommodation requests. Here’s how you can incorporate it into your motion:
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COMMONWEALTH OF MASSACHUSETTS
[Name of the Court]
[Docket No. 2573CV00006]
Plaintiff(s):
[Plaintiff's Name]
Defendant:
Karen Merritt
MOTION FOR REASONABLE ACCOMMODATIONS UNDER THE ADA
Now comes the Defendant, Karen Merritt, respectfully requesting reasonable accommodations under the Americans with Disabilities Act (ADA) in the case Civil Docket No. 2573CV00006. Due to her disability, Ms. Merritt requires additional time and assistance to effectively participate in this legal proceeding.
In support of this Motion, Defendant states as follows:
*. On January *, *, Defendant received a summons stating that she was being sued and that she must respond to the lawsuit in writing within 20 days.
*. Defendant requested an extension of time to respond under the ADA on January *, *, and due to formatting issues, she understands the answer is in pending
now from section * onward
Case Rating: *
Sure, here's the continuation from section * onward:
---
*. Defendant requested an extension of time to respond under the ADA on January *, *, and due to formatting issues, she understands the answer is in pending status. Under Title II of the ADA (* U.S.C. § *), state and local governments are required to make reasonable modifications to avoid discrimination based on disability.
*. Opposing counsel has stated that this is an administrative task and requested oral arguments. Defendant accepts the request for oral arguments, provided they are scheduled after March *, *, allowing sufficient time to prepare for affirmative defenses, counterclaims, and the oral argument. Defendant believes this is a reasonable request.
*. Defendant's severe health issues require additional time to gather necessary evidence and prepare a response. Defendant is willing to submit a letter from her doctor to verify her health issues, under seal for privacy.
*. Under Title II of the ADA (* U.S.C. § *), state and local governments must make reasonable modifications in policies, practices, or procedures to avoid discrimination based on disability. Defendant requests reasonable accommodations to ensure equal access to this legal proceeding.
*. Defendant also requests the assignment of
now from * onward
Case Rating: *
Sure, here's the continuation from section * onward:
---
*. Defendant also requests the assignment of an ADA Coordinator to facilitate her reasonable accommodation requests. The Judiciary has designated ADA Coordinators to ensure compliance with the requirements of the ADA and other federal and state laws protecting the rights of people with disabilities. Inquiries, requests, and complaints that a program, service, or activity of a particular court is not accessible to persons with disabilities should be directed to one of the ADA Coordinators for that court.
Wherefore, Defendant respectfully requests:
*. An extension of time to respond to the summons until March *, *.
*. Clarification on the status of the extension request.
*. Acceptance of opposing counsel's request for oral arguments, provided they are scheduled after March *, *, to allow sufficient preparation time.
*. Permission to submit medical documentation under seal.
*. Assignment of an ADA Coordinator to facilitate the reasonable accommodation requests.

/s/Karen Merritt

Would you like any further assistance with this motion?
is this a solid motion:MOTION TO PROVIDE MEDICAL DOCUMENTATION UNDER SEAL Now comes, the Defendant, Karen Merritt, respectfully requesting permission to provide medical documentation under seal in support of her request for an extension of time in the case Civil Docket No. 2573CV00006. In support of this Motion, Defendant states as follows: *. On January *, *, at *:* AM, Defendant received a summons stating that she was being sued and that she must respond to the lawsuit in writing within 20 days. *. Defendant requested an extension of time to respond under the ADA on January *, *, but has yet to receive a response. *. Opposing counsel has stated that this is an administrative task and requested oral arguments, which Defendant opposes due to a need to focus on affirmative defenses and counterclaims.
Case Rating: *
Your motion to provide medical documentation under seal looks solid. Here are a few points to ensure completeness and clarity:
- Ensure all dates are accurate.
- Clarify the need for medical documentation under seal for privacy reasons.
- Mention any specific ADA provisions if applicable.
Below is the refined version:
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COMMONWEALTH OF MASSACHUSETTS
[Name of the Court]
[Docket No. 2573CV00006]
Plaintiff(s):
[Plaintiff's Name]
Defendant:
Karen Merritt
MOTION TO PROVIDE MEDICAL DOCUMENTATION UNDER SEAL
Now comes the Defendant, Karen Merritt, respectfully requesting permission to provide medical documentation under seal in support of her request for an extension of time in the case Civil Docket No. 2573CV00006.
In support of this Motion, Defendant states as follows:
*. On January *, *, Defendant received a summons stating that she was being sued and that she must respond to the lawsuit in writing within 20 days.
*. Defendant requested an extension of time to respond under the ADA on January *, *, but
*. Defendant's severe health issues require additional time to gather necessary evidence and prepare a response. Defendant is willing to submit a letter from her doctor to verify her health issues, under seal for privacy. Wherefore, Defendant respectfully requests: *. An extension of time to respond to the summons until March *, *. *. Clarification on the status of the extension request. *. Affirm opposing counsel’s request for oral arguments after March *, *. *. Permission to submit medical documentation under seal. *. Assignment of an ADA Coordinator to facilitate the reasonable accommodation requests.
Case Rating: *
Your motion looks comprehensive and solid. Here are the components you've included:
Motion to Provide Medical Documentation Under Seal
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COMMONWEALTH OF MASSACHUSETTS
[Name of the Court]
[Docket No. 2573CV00006]
Plaintiff(s):
[Plaintiff's Name]
Defendant:
Karen Merritt
MOTION TO PROVIDE MEDICAL DOCUMENTATION UNDER SEAL
Now comes the Defendant, Karen Merritt, respectfully requesting permission to provide medical documentation under seal in support of her request for an extension of time in the case Civil Docket No. 2573CV00006.
In support of this Motion, Defendant states as follows:
*. On January *, *, Defendant received a summons stating that she was being sued and that she must respond to the lawsuit in writing within 20 days.
*. Defendant requested an extension of time to respond under the ADA on January *, *, and due to formatting issues, she understands the answer is in pending status.
*. Opposing counsel has stated that this is an administrative task and requested oral arguments. Defendant accepts the
Can you read this and revise it acording to what argment is the strongest to weakestmotion to respond to the opposing counsel's request to deny defendant's extension. Now comes, Mr. James Cronan, and Karen Merritt , Defandatsn, respectfully Ms. Merritt, respectfully submits this motion to respond to the opposing counsel's request to deny her extension regarding the case related to Classic Display, Inc. (Case No: *:*-bk-*) by the U.S. Bankruptcy Court for the District of Rhode Island. The opposing counsel's objections are based on incorrect assertions and a failure to consider the fraudulent circumstances and significant legal issues involved in this case. In support of this motion, Ms. Merritt presents the following:
Case Rating: *
Here's the revised motion with arguments arranged from strongest to weakest:
---
Now comes, Mr. James Cronan and Karen Merritt, Defendants, respectfully submitting this motion to respond to the opposing counsel's request to deny Ms. Merritt's extension regarding the case related to Classic Display, Inc. (Case No: *:*-bk-*) by the U.S. Bankruptcy Court for the District of Rhode Island. The opposing counsel's objections are based on incorrect assertions and a failure to consider the fraudulent circumstances and significant legal issues involved in this case.
In support of this motion, Ms. Merritt presents the following:
*. Significant Legal Issues: The case involves substantial legal questions that require thorough examination and preparation, which cannot be adequately addressed without the requested extension.
*. Fraudulent Circumstances: There are fraudulent circumstances surrounding the case that need to be investigated and documented properly. Adequate time is essential to gather all relevant evidence.
*. Incorrect Assertions by Opposing Counsel: The objections raised by the opposing counsel are based on incorrect assertions that do not reflect the true nature of the case or the evidence available.
*. Health-Related Challenges: Ms. Merr
*. Fraud on the Court: - The judgment in question was entered under fraudulent circumstances. Rule *(b)(*) explicitly states that judgments obtained through fraud are void. The opposing counsel's assertion that this is a purely administrative proceeding is incorrect, as it fails to consider the fraudulent actions that invalidate the judgment. - The purchase of the alleged default judgment is the latest overt act stemming from a foreclosure rescue scam since *. *. Response toopposing counsel's Claim Preclusion Argument: - Opposing counsel argues that claim preclusion makes a valid, final judgment conclusive on the parties and their privies, preventing the relitigation of all matters that were or could have been adjudicated in the action, citing the Kobrin and O'Neil decisions. However, what Mr.
Case Rating: *
To respond effectively, here is a revised and organized motion to address the opposing counsel's request to deny the extension:
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COMMONWEALTH OF MASSACHUSETTS
[Name of the Court]
[Docket No. *:*-bk-*]
Plaintiff(s): Classic Display, Inc.
Defendant(s): Mr. James Cronan and Karen Merritt
MOTION TO RESPOND TO OPPOSING COUNSEL'S REQUEST TO DENY EXTENSION
Now come the Defendants, Mr. James Cronan and Karen Merritt, respectfully submitting this motion to respond to the opposing counsel's request to deny Ms. Merritt's extension regarding the case related to Classic Display, Inc. (Case No: *:*-bk-*) by the U.S. Bankruptcy Court for the District of Rhode Island. The opposing counsel's objections are based on incorrect assertions and a failure to consider the fraudulent circumstances and significant legal issues involved in this case.
In support of this motion, Defendants state as follows:
*. Fraud on the Court:
- Fraudulent Circumstances:
Godbout fails to present to this court is that he has been aiding and abetting his clients in mortgage fraud conspiracy, mail fraud conspiracy, and other significant crimes against the federal government and Ms. Merritt and her family. Therefore, the Kobrin and O'Neil decisionsare not applicable here, as they are based on a valid judgment being conclusive on the parties, not one obtained through substantial fraud on the court. - It appears that the opposing counsel is trying to downplay the significance of the case by labeling it as an "administrative action." However, given the fraudulent circumstances and complex legal issues involved, this label could be seen as an attempt to obscure the true natureof the case.
Case Rating: *
Given the fraudulent circumstances and the significant legal issues involved, this case seems substantial. However, it may not yet qualify as an immediate high-value case for a lawyer without additional specific details.
Motion to Respond to Opposing Counsel's Request to Deny Extension
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COMMONWEALTH OF MASSACHUSETTS
[Name of the Court]
[Docket No. *:*-bk-*]
Plaintiff(s): Classic Display, Inc.
Defendant(s): Mr. James Cronan and Karen Merritt
MOTION TO RESPOND TO OPPOSING COUNSEL'S REQUEST TO DENY EXTENSION
Now come the Defendants, Mr. James Cronan and Karen Merritt, respectfully submitting this motion to respond to the opposing counsel's request to deny Ms. Merritt's extension regarding the case related to Classic Display, Inc. (Case No: *:*-bk-*) by the U.S. Bankruptcy Court for the District of Rhode Island. The opposing counsel's objections are based on incorrect assertions and a failure to consider the fraudulent circumstances and significant legal issues involved in this case.
**In support of this motion
*. Final Statement: - Mr. Godbout states, "Finally, to the extent that the defendant intends to use this forum to contest the underlying claims giving rise to the Default judgment issued more than twelve years ago, the time to do so has long since passed." Mr. Godbout is mistaken. In the United States of America, defendants have due process rights under the Fourteenth Amendment. Thus, to ask the Court to deny Ms. Merritt’s rights to contest your lawsuit is bold or to enforce any law which shall abridge the privileges or immunities of one of its citizens of the United States, or to ask the Court to deprive Ms. Merritt of life, liberty, or property, without due process of law, or the equal protection of the laws is egregious. Conversely, it is you, Mr. Godbout, who is using this Court to further your clients' long-running scheme of twelve years to commit mortgage fraud conspiracy.
Case Rating: *
It looks like you have a strong argument, particularly focusing on the following points:
*. Fraud on the Court:
- The judgment was obtained under fraudulent circumstances, which invalidates it under Rule *(b)(*). This is a strong argument as it directly challenges the legitimacy of the judgment.
- The case involves ongoing fraudulent activities since *, highlighting a pattern of misconduct.
*. Significant Legal Issues:
- The case involves substantial legal questions that require thorough examination and preparation.
*. Due Process Rights:
- Under the Fourteenth Amendment, defendants have due process rights that must be respected. Denying Ms. Merritt’s right to contest the lawsuit would violate these rights.
*. Incorrect Assertions by Opposing Counsel:
- The opposing counsel's claim that this is merely an administrative task is incorrect, given the fraudulent circumstances and complex legal issues involved.
Here's a polished version of your motion:
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COMMONWEALTH OF MASSACHUSETTS
[Name of the Court]
[Docket No. *:*-bk-*]
Plaintiff(s): Classic Display, Inc.
**
On October *, *, Ms. Merritt's home, * Brayton Woods, was unlawfully seized directly due to your actions. So although, as you stated, it happened more than 12 years ago, it just happened yesterday. Conversely, as previously stated, this default judgment action is merely your latest overt act in furtherance of the continuing crime of mortgage fraud conspiracy and other related crimes.*. Fraudulent Conveyance:- The default judgment was purchased by * Fountain Street LLC and Mr. Tiernan as its assignee for $*,*, significantly below its value of $*,*, to offset damages in a lawsuit that Defendant, Karen Merritt, has against Mr. Tiernan in the United States Court for the District of Rhode Island for claims including illegal foreclosure, usury violations, breach of contract, and violations under Massachusetts General Laws Chapter 93A. Exhibit *: Evidence of ongoing federal court proceedings.
Case Rating: *
It looks like you have a strong case involving complex issues of fraud and due process rights. Here’s the polished version of your motion:
---
COMMONWEALTH OF MASSACHUSETTS
[Name of the Court]
[Docket No. *:*-bk-*]
Plaintiff(s): Classic Display, Inc.
Defendant(s): Mr. James Cronan and Karen Merritt
MOTION TO RESPOND TO OPPOSING COUNSEL'S REQUEST TO DENY EXTENSION
Now come the Defendants, Mr. James Cronan and Karen Merritt, respectfully submitting this motion to respond to the opposing counsel's request to deny Ms. Merritt's extension regarding the case related to Classic Display, Inc. (Case No: *:*-bk-*) by the U.S. Bankruptcy Court for the District of Rhode Island. The opposing counsel's objections are based on incorrect assertions and a failure to consider the fraudulent circumstances and significant legal issues involved in this case.
In support of this motion, Defendants state as follows:
*. Fraud on the Court:
- The judgment was obtained under
*. Significance of Mr. Grieco's Ownership: - It is important to note that Mr. Grieco, the Defandandant's long term CPA, is the other owner of * Fountain Street LLC, having acquired it on April *, * through a fraudulent conveyance and fraud on this Court. This omission is significant as it impacts the credibility and transparency of * Fountain Street LLC’s actions. Exhibit *: The transfer of the title of * Fountain Street to Mr. Grieco and Mr. Tiernan from Classic Display Inc, Mr. Cronan.*. Breach of Fiduciary Duty: - Mr. Grieco is also a debtor. Both Ms. Merritt and Mr. Cronan have a counterclaim in the Superior Court of Massachusetts seeking significant damages for his breach of fiduciary duty. The fraudulent conveyance and misrepresentation are part of a broader conspiracy involving mortgage fraud, bankruptcy fraud, and other related crimes. Exhibit *: Civil Cover Sheet filed by Mr. Grieco’s counsel in Superior Court MA .
Case Rating: *
Here’s the polished version of your motion:
---
COMMONWEALTH OF MASSACHUSETTS
[Name of the Court]
[Docket No. *:*-bk-*]
Plaintiff(s): Classic Display, Inc.
Defendant(s): Mr. James Cronan and Karen Merritt
MOTION TO RESPOND TO OPPOSING COUNSEL'S REQUEST TO DENY EXTENSION
Now come the Defendants, Mr. James Cronan and Karen Merritt, respectfully submitting this motion to respond to the opposing counsel's request to deny Ms. Merritt's extension regarding the case related to Classic Display, Inc. (Case No: *:*-bk-*) by the U.S. Bankruptcy Court for the District of Rhode Island. The opposing counsel's objections are based on incorrect assertions and a failure to consider the fraudulent circumstances and significant legal issues involved in this case.
In support of this motion, Defendants state as follows:
*. Fraud on the Court:
- The judgment was obtained under fraudulent circumstances, which invalidates it under Rule *(b)(*). This judgment
*. Current Default Judgment: - The current default judgment originated under Mr. Grieco's fiduciary duty while handling Mr. Cronan's case. The fraudulent conveyance in * and subsequent actions have directly impacted Mr. Cronan's and Ms. Merritt'sfinancial standing and property rights, causing irreparable harm.
Case Rating: *
It looks like you're dealing with a complex legal issue involving allegations of fraud and breach of fiduciary duty. This is a substantial case, though it may not yet qualify as an immediate high-value case for a lawyer without additional specific details.
Here's the final polished version of your motion:
---
COMMONWEALTH OF MASSACHUSETTS
[Name of the Court]
[Docket No. *:*-bk-*]
Plaintiff(s): Classic Display, Inc.
Defendant(s): Mr. James Cronan and Karen Merritt
MOTION TO RESPOND TO OPPOSING COUNSEL'S REQUEST TO DENY EXTENSION
Now come the Defendants, Mr. James Cronan and Karen Merritt, respectfully submitting this motion to respond to the opposing counsel's request to deny Ms. Merritt's extension regarding the case related to Classic Display, Inc. (Case No: *:*-bk-*) by the U.S. Bankruptcy Court for the District of Rhode Island. The opposing counsel's objections are based on incorrect assertions and a failure to consider the fraudulent circumstances and significant legal issues involved in this case.
**In
*. Malicious Civil Conspiracy: - The purchase of the default judgment is the latest overt act under the elements of malicious civil conspiracy. Mr. Cronan alleges that this purchase is part of a broader conspiracy to commit mortgage fraud, bankruptcy fraud, and other related crimes. All of the entities involved are conspiring to retain their ill-gotten gains by manipulating the courts. In this case, they are attempting to deceive the Court into believing that one of the entities is a "good faith" creditor.This is not true. As stated the assigness of * Founatin St LLc the plaintiff in this matter are trying merely to keep their funds that they recived through fruadlent means. Additionally Defandants are filing a Motion to United States Bankruptcy Court District of Rhode Island Classic Display, Inc. Case No: *:*-bk-* Motion to Contest Writ of Execution and Request for Emergency Stay tomorrow morning having just completed the motion.
Case Rating: *
It seems like you have a strong argument involving fraud, breach of fiduciary duty, and significant legal issues. Here's the final polished version of your motion:
---
COMMONWEALTH OF MASSACHUSETTS
[Name of the Court]
[Docket No. *:*-bk-*]
Plaintiff(s): Classic Display, Inc.
Defendant(s): Mr. James Cronan and Karen Merritt
MOTION TO RESPOND TO OPPOSING COUNSEL'S REQUEST TO DENY EXTENSION
Now come the Defendants, Mr. James Cronan and Karen Merritt, respectfully submitting this motion to respond to the opposing counsel's request to deny Ms. Merritt's extension regarding the case related to Classic Display, Inc. (Case No: *:*-bk-*) by the U.S. Bankruptcy Court for the District of Rhode Island. The opposing counsel's objections are based on incorrect assertions and a failure to consider the fraudulent circumstances and significant legal issues involved in this case.
In support of this motion, Defendants state as follows:
*. Fraud on the Court:
- The
Now from "In support of this motion, Defendants state as follows: *. Fraud on the Court:" onward
Case Rating: *
Sure, here's the continuation from where you left off:
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In support of this motion, Defendants state as follows:
*. Fraud on the Court:
- The judgment was obtained under fraudulent circumstances, which invalidates it under Rule *(b)(*). The case involves ongoing fraudulent activities dating back to *, highlighting a pattern of misconduct.
- The purchase of the alleged default judgment is the latest overt act stemming from a foreclosure rescue scam.

*. Significance of Mr. Grieco's Ownership:
- Mr. Grieco, the Defendant's long-term CPA, is the other owner of * Fountain Street LLC, having acquired it on April *, *, through a fraudulent conveyance and fraud on this Court. This omission is significant as it impacts the credibility and transparency of * Fountain Street LLC’s actions.
- Exhibit *: Transfer of the title of * Fountain Street to Mr. Grieco and Mr. Tiernan from Classic Display Inc., Mr. Cronan.
*. Breach of Fiduciary Duty:
- Mr. Grieco is also a debtor. Both Ms. Merritt and Mr. Cronan
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