Court Prioritizes Case Merits

Summary

The U.S. Supreme Court case Pioneer Investment Services Co. V. Brunswick Associates Ltd. Partnership highlights that equitable considerations and case merits can outweigh procedural issues under Rule 60(b). This supports motions to vacate dismissals due to excusable neglect, lack of notice, or newly discovered evidence. The forensic accountants deposition and the plaintiffs expert interrogatory provide substantial evidence of financial misconduct, supporting the argument for piercing the corporate veil. Including both the deposition and interrogatory as exhibits strengthens the case by demonstrating the entities disregard for corporate structure and fraudulent practices.

Full Conversation

- Rule *(b)(*) allows the court to grant relief from a judgment or order due to mistake, inadvertence, surprise, or excusable neglect. The missed hearing resulted from a lack of proper notice and my severe health issues, including Stage * kidney disease, which significantly impacted my ability to stay abreast of court communications. - Rule *(b)(*) permits relief based on newly discovered evidence that could not have been discovered in time to move for a new trial under Rule *(b). The recent purchase of a $*,* judgment for $*,* by one of the defendants, coupled with their fraudulent activities, constitutes newly discovered evidence that was not available during the initial proceedings.

For your situation, the U.S. Supreme Court case *Pioneer Investment Services Co. v. Brunswick Associates Ltd. Partnership*, * U.S. * (*) is relevant. The Court emphasized that equitable considerations and the merits of the case can outweigh technical procedural issues under Rule *(b).
Would you like more information on how to proceed with your Rule *(b) motion?

- The forensic accountant’s findings and the deposition provide substantial evidence of fraudulent accounting practices by the defendants, further supporting the need for relief from the dismissal. - These legal grounds justify vacating the dismissal to ensure that justice prevails and the case proceeds on its merits rather than being dismissed on procedural grounds.

I have already written the motion with 'you". Could you please intergrade that U.S. Supreme case in my Backgotund section? Do you think I need to reiteriate this point again in my conclusion. If so I will send you the Conclusion?

You can integrate the U.S. Supreme Court case *Pioneer Investment Services Co. v. Brunswick Associates Ltd. Partnership*, * U.S. * (*) in your Background section as follows:

Background
In your Background section, you can include:
- Pioneer Investment Services Co. v. Brunswick Associates Ltd. Partnership, * U.S. * (*). This case emphasizes that equitable considerations and the merits of the case can outweigh technical procedural issues under Rule *(b).
Yes, reiterating this in the Conclusion to reinforce the argument can be helpful. Please send me your Conclusion for further assistance.

see above

Sure, you can integrate the U.S. Supreme Court case into your background section as follows:
"In support of this motion, I draw attention to the U.S. Supreme Court case *Pioneer Investment Services Co. v. Brunswick Associates Ltd. Partnership*, * U.S. * (*), where the Court emphasized that equitable considerations and the merits of the case can outweigh technical procedural issues under Rule *(b)."
Yes, reiterating this point in your conclusion can strengthen your argument. Please send your conclusion if you need help with it.

see above

Sure! Here’s how you can integrate the U.S. Supreme Court case into your background section:

Background
- Under Rule *(b)(*) and (*) of the Massachusetts Rules of Civil Procedure, I seek relief from the dismissal of my case due to excusable neglect, lack of notice, and newly discovered evidence.
- Rule *(b)(*) allows the court to grant relief from a judgment or order due to mistake, inadvertence, surprise, or excusable neglect. The missed hearing resulted from a lack of proper notice and my severe health issues, including Stage * kidney disease, which significantly impacted my ability to stay abreast of court communications.
- Rule *(b)(*) permits relief based on newly discovered evidence that could not have been discovered in time to move for a new trial under Rule *(b). The recent purchase of a $*,* judgment for $*,* by one of the defendants, coupled with their fraudulent activities, constitutes newly discovered evidence that was not available during the initial proceedings.
- The forensic accountant’s findings and the deposition provide substantial evidence of fraudulent accounting practices by the defendants, further supporting the need for relief from the dismissal.
- In *Pioneer Investment Services Co. v. Brunswick Associates Ltd. Partnership*, * U.S. * (*), the U.S. Supreme Court emphasized that equitable considerations and the merits of the case can outweigh technical procedural issues under Rule *(b). This precedent supports the argument that my case should be judged on its merits rather than dismissed on procedural grounds.
Would you like help with reiterating this point in your conclusion?

Conclusion: In light of the above, I respectfully request that this honorable court grant my supplemental motion to vacate the dismissal of my case under Rule *(b)(*) and (*) due to excusable neglect, lack of notice, and newly discovered evidence. I also request the additional relief outlined in my initial motion to ensure fairness and justice in these proceedings. This motion is supported by substantial evidence of fraud, bad faith, and procedural violations by the defendants, and it is imperative that the court allows this case to proceed on its merits. I declare under penalty of perjury that the foregoing is true and correct. Respectfully submitted,

To strengthen your conclusion, you can include the Supreme Court case to emphasize the importance of merits over technicalities. Here’s a revised version:
---
Conclusion:
In light of the above, I respectfully request that this honorable court grant my supplemental motion to vacate the dismissal of my case under Rule *(b)(*) and (*) due to excusable neglect, lack of notice, and newly discovered evidence. In *Pioneer Investment Services Co. v. Brunswick Associates Ltd. Partnership*, * U.S. * (*), the U.S. Supreme Court emphasized that equitable considerations and the merits of the case can outweigh technical procedural issues under Rule *(b). This supports the argument that my case should be judged on its merits rather than dismissed on procedural grounds.
I also request the additional relief outlined in my initial motion to ensure fairness and justice in these proceedings. This motion is supported by substantial evidence of fraud, bad faith, and procedural violations by the defendants, and it is imperative that the court allows this case to proceed on its merits.
I declare under penalty of perjury that the foregoing is true and correct.
Respectfully submitted,
---
Would you like more assistance with any other part of your motion?

I would like you to please edit this section Forensic Accountant’s Findings: - The forensic accountant's report (Exhibit C) highlights severe bookkeeping irregularities, such as commingling of funds and tax evasion. - Deposition excerpts provide evidence of inconsistent records and sham transactions. - These findings are crucial to the integrity of the case and demonstrate significant financial misconduct by the defendant. Please Note that the "findings" that we are adressing here are from PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY. In addition I have anoter section Deposition of Forensic Accountant: which has been done. Can i share with you key points in the Interrogatory?

Sure! Here’s the edited section for "Forensic Accountant’s Findings":
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Forensic Accountant’s Findings:
- The forensic accountant's report (Exhibit C) highlights severe bookkeeping irregularities, such as commingling of funds and tax evasion.
- Deposition excerpts provide evidence of inconsistent records and sham transactions.
- PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY further supports these findings, demonstrating significant financial misconduct by the defendant.
---
Feel free to share the key points in the Interrogatory if you'd like further assistance!

see above

Sure, here's an edited version of the section on the forensic accountant's findings:

Forensic Accountant’s Findings:
- The forensic accountant's report (Exhibit C) from PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY highlights severe bookkeeping irregularities, such as commingling of funds and tax evasion.
- Deposition excerpts provide evidence of inconsistent records and sham transactions.
- These findings are crucial to the integrity of the case and demonstrate significant financial misconduct by the defendant.
Would you like to share the key points from the Interrogatory section for further assistance?

Or do i just need to provide PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY in the exhibit and let the judge review?

You should provide the detailed forensic accountant's findings in your exhibits and let the judge review them. Here’s an edited version of the section you mentioned:

Forensic Accountant’s Findings
- The forensic accountant's report (Exhibit C) highlights severe bookkeeping irregularities, such as commingling of funds and tax evasion.
- Deposition excerpts provide evidence of inconsistent records and sham transactions.
- These findings, from *PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY*, are crucial to the integrity of the case and demonstrate significant financial misconduct by the defendant.
Would you like help with summarizing key points from the interrogatory?

May I provide you this section to determine if we still need the Interrogatory section?

Sure! Please provide the section, and I'll help you determine if the Interrogatory section is still necessary.

Deposition of Forensic Accountant: The forensic accountant’s deposition (Exhibit D) provides detailed evidence of severe bookkeeping irregularities, commingling of funds, and tax evasion. The deposition highlights: - Page *, Section *-*: Shared operations between * Fountain and Classic Group, indicating commingling of funds. - Page *, Section *-*: Inconsistent records and sham transactions, demonstrating financial misconduct. - Page *, Section *-*: Accounting entries designed for tax avoidance, showcasing illegal financial practices. - Page *, Section *-*: Questionable stock transfer without proper documentation, raising further concerns about financial propriety.

Your deposition section is quite detailed and seems comprehensive. Including the *PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY* as an exhibit for the judge to review can further reinforce your case. Here’s an integrated version:

Deposition of Forensic Accountant
The forensic accountant’s deposition (Exhibit D) provides detailed evidence of severe bookkeeping irregularities, commingling of funds, and tax evasion. The deposition highlights:
- Page *, Section *-*: Shared operations between * Fountain and Classic Group, indicating commingling of funds.
- Page *, Section *-*: Inconsistent records and sham transactions, demonstrating financial misconduct.
- Page *, Section *-*: Accounting entries designed for tax avoidance, showcasing illegal financial practices.
- Page *, Section *-*: Questionable stock transfer without proper documentation, raising further concerns about financial propriety.
Including both sections will provide a robust argument by presenting the findings clearly and concisely. Would you like help with anything else?

Veil Piercing Argument: The defendants argue that there were two separate companies; however, the forensic accountant’s findings strongly establish that * Fountain and Classic Group operated as a single entity in practice. This court should pierce the corporate veil based on the following: - Unified Operation: The forensic accountant's report confirms that both companies were operated asa single business, with shared employees, office space, and financial resources.

Sure! Here’s a concise version of your argument integrating the forensic accountant's findings:

Veil Piercing Argument:
The defendants contend there were two separate companies, but the forensic accountant’s findings prove that * Fountain and Classic Group operated as a single entity. This court should pierce the corporate veil based on the following:
- Unified Operation: The forensic accountant's report confirms both companies functioned as a single business, sharing employees, office space, and financial resources.
Would you like any further assistance with this section or other parts of your motion?

- Commingling of Funds: The deposition (Page *, Section *-*) clearly indicates funds were commingled between the two entities, blurring the lines of separation. - Inconsistent Records: Documented in the deposition (Page *, Section *-*), the inconsistent and fraudulent records further support the argument for piercing the corporate veil. - Fraudulent Practices: As evidenced on Page *, Section *-*, and Page *, Section *-*, the defendants engaged in accounting practices designed to evade taxes and misrepresent financial realities. These points collectively demonstrate that the defendants treated the two companies as one, justifying the court's decision to pierce the corporate veil and hold them accountable for their unified operations and financial misconduct.

Your argument for piercing the corporate veil appears strong based on the forensic accountant’s findings and deposition. Here’s a refined version of your veil piercing argument:
---
Veil Piercing Argument:
The defendants argue that there were two separate companies; however, the forensic accountant’s findings strongly establish that * Fountain and Classic Group operated as a single entity in practice. This court should pierce the corporate veil based on the following:
- Unified Operation: The forensic accountant's report confirms that both companies were operated as a single business, with shared employees, office space, and financial resources.
- Commingling of Funds: The deposition (Page *, Section *-*) clearly indicates funds were commingled between the two entities, blurring the lines of separation.
- Inconsistent Records: Documented in the deposition (Page *, Section *-*), the inconsistent and fraudulent records further support the argument for piercing the corporate veil.
- Fraudulent Practices: As evidenced on Page *, Section *-*, and Page *, Section *-*, the defendants engaged in accounting practices designed to evade taxes and misrepresent financial realities.
These points collectively demonstrate that the defendants treatedthe two companies as one, justifying the court's decision to pierce the corporate veil and hold them accountable for their unified operations and financial misconduct.
Would you like assistance with any other part of your motion or any additional legal questions?

Do I need the Interrogatory section too?

No, you likely don't need the Interrogatory section if you've already included detailed and specific findings in your exhibits. Your current presentation with the forensic accountant's findings and deposition excerpts appears comprehensive and robust. Integrating the *PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY* as an exhibit should suffice.
Would you like more assistance with any other part of your motion?

Stiil confused. I would ONLY be entering the Deposition of Forensic Accountant: Is this ok?

Yes, it is acceptable to only enter the Deposition of Forensic Accountant as it provides detailed and specific evidence crucial to your case. Ensure it's clearly referenced and included as Exhibit D. Would you like guidance on how to structure this in your motion?

Yes I have provided you with the section Deposition of Forensic Accountant: please include anything that you believe that i need.

Here’s a refined version of your section, incorporating everything necessary:

~Deposition of Forensic Accountant~##
The forensic accountant’s deposition (Exhibit D) provides detailed evidence of severe bookkeeping irregularities, commingling of funds, and tax evasion. Key points include:
- Page *, Section *-*: Shared operations between * Fountain and Classic Group, indicating commingling of funds.
- Page *, Section *-*: Inconsistent records and sham transactions, demonstrating financial misconduct.
- Page *, Section *-*: Accounting entries designed for tax avoidance, showcasing illegal financial practices.
- Page *, Section *-*: Questionable stock transfer without proper documentation, raising further concerns about financial propriety.

~Veil Piercing Argument~##
The defendants argue that there were two separate companies; however, the forensic accountant’s findings strongly establish that * Fountain and Classic Group operated as a single entity in practice. This court should pierce the corporate veil based on the following:
- Unified Operation: The forensic accountant's report confirms that both companies were operated as a single business, with shared employees, office space, and financial resources.
-- Commingling of Funds: The deposition (Page *, Section *-*) clearly indicates funds were commingled between the two entities, blurring the lines of separation.
- Inconsistent Records: Documented in the deposition (Page *, Section *-*), the inconsistent and fraudulent records further support the argument for piercing the corporate veil.
- Fraudulent Practices: As evidenced in the deposition (Page *, Section *-*, and Page *, Section *-*), the defendants engaged in accounting practices designed to evade taxes and misrepresent financial realities.
These points collectively demonstrate that the defendants treated the two companies as one, justifying the court's decision to pierce the corporate veil and hold them accountable for their unified operations and financial misconduct.
Would you like more assistance with any other part of your motion or any additional questions?

see above

Sure, here’s a structured version of your motion, integrating all the necessary elements:
---
Forensic Accountant’s Findings:
- The forensic accountant's report (Exhibit C) highlights severe bookkeeping irregularities, such as commingling of funds and tax evasion.
- Deposition excerpts provide evidence of inconsistent records and sham transactions.
- These findings, from *PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY*, are crucial to the integrity of the case and demonstrate significant financial misconduct by the defendant.
Deposition of Forensic Accountant:
The forensic accountant’s deposition (Exhibit D) provides detailed evidence of severe bookkeeping irregularities, commingling of funds, and tax evasion. The deposition highlights:
- Page *, Section *-*: Shared operations between * Fountain and Classic Group, indicating commingling of funds.
- Page *, Section *-*: Inconsistent records and sham transactions, demonstrating financial misconduct.
- Page *, Section *-*: Accounting entries designed for tax avoidance, showcasing illegal financial practices.
- Page *, Section *-*: Questionable stock transfer without proper documentation, raising further concerns about financial proprVeil Piercing Argument:
The defendants argue that there were two separate companies; however, the forensic accountant’s findings strongly establish that * Fountain and Classic Group operated as a single entity in practice. This court should pierce the corporate veil based on the following:
- Unified Operation: The forensic accountant's report confirms that both companies were operated as a single business, with shared employees, office space, and financial resources.
- Commingling of Funds: The deposition (Page *, Section *-*) clearly indicates funds were commingled between the two entities, blurring the lines of separation.
- Inconsistent Records: Documented in the deposition (Page *, Section *-*), the inconsistent and fraudulent records further support the argument for piercing the corporate veil.
- Fraudulent Practices: As evidenced on Page *, Section *-*, and Page *, Section *-*, the defendants engaged in accounting practices designed to evade taxes and misrepresent financial realities.
These points collectively demonstrate that the defendants treated the two companies as one, justifying the court's decision to pierce the corporate veil and hold them accountable for their unified operations and financial misconduct.
Would you like help with any other

Just be clear the *PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY has language like this: Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively, the “Entities”) acted as the agent and alter ego of one another with disregard for their separate identities in corporate form. She is expected to testify that the Entities acted as a single business enterprise and single economic entity while engaging in their business operations.

Here’s a revised structure, including the key language from *PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY*:
---
Forensic Accountant’s Findings:
- The forensic accountant's report (Exhibit C) highlights severe bookkeeping irregularities, such as commingling of funds and tax evasion.
- Deposition excerpts provide evidence of inconsistent records and sham transactions.
- These findings are crucial to the integrity of the case and demonstrate significant financial misconduct by the defendant.
Deposition of Forensic Accountant:
The forensic accountant’s deposition (Exhibit D) provides detailed evidence of severe bookkeeping irregularities, commingling of funds, and tax evasion. The deposition highlights:
- Page *, Section *-*: Shared operations between * Fountain and Classic Group, indicating commingling of funds.
- Page *, Section *-*: Inconsistent records and sham transactions, demonstrating financial misconduct.
- Page *, Section *-*: Accounting entries designed for tax avoidance, showcasing illegal financial practices.
- Page *, Section *-*: Questionable stock transfer without proper documentation, raising further concerns about financial propriety.
Veil PiercingVeil Piercing Argument:
The defendants argue that there were two separate companies; however, the forensic accountant’s findings strongly establish that * Fountain and Classic Group operated as a single entity in practice. This court should pierce the corporate veil based on the following:
- Unified Operation: The forensic accountant's report confirms that both companies were operated as a single business, with shared employees, office space, and financial resources.
- Commingling of Funds: The deposition (Page *, Section *-*) clearly indicates funds were commingled between the two entities, blurring the lines of separation.
- Inconsistent Records: Documented in the deposition (Page *, Section *-*), the inconsistent and fraudulent records further support the argument for piercing the corporate veil.
- Fraudulent Practices: As evidenced on Page *, Section *-*, and Page *, Section *-*, the defendants engaged in accounting practices designed to evade taxes and misrepresent financial realities.
PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY:**
- Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively

Theres more in the Interrogatory do we go on. Or do we have enough?"

Your inclusion of the forensic accountant’s deposition and the detailed findings seems robust. However, adding select key points from PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY may further strengthen your case. Here’s a condensed version integrating both:
---
Forensic Accountant’s Findings:
- The forensic accountant's report (Exhibit C) highlights severe bookkeeping irregularities, such as commingling of funds and tax evasion.
- Deposition excerpts provide evidence of inconsistent records and sham transactions.
- These findings are crucial to the integrity of the case and demonstrate significant financial misconduct by the defendant.
Deposition of Forensic Accountant:
The forensic accountant’s deposition (Exhibit D) provides detailed evidence of severe bookkeeping irregularities, commingling of funds, and tax evasion. The deposition highlights:
- Page *, Section *-*: Shared operations between * Fountain and Classic Group, indicating commingling of funds.
- Page *, Section *-*: Inconsistent records and sham transactions, demonstrating financial misconduct.
- Page *, Section *-*: Accounting entries designed for tax avoidance, showcasing illegal financial practices.
- Page *, Section *-*: Questionable stock transfer without proper documentation, raising further concerns about financial propriety.
Veil Piercing Argument:
The defendants argue that there were two separate companies; however, the forensic accountant’s findings strongly establish that * Fountain and Classic Group operated as a single entity in practice. This court should pierce the corporate veil based on the following:
- Unified Operation: The forensic accountant's report confirms that both companies were operated as a single business, with shared employees, office space, and financial resources.
- Commingling of Funds: The deposition (Page *, Section *-*) clearly indicates funds were commingled between the two entities, blurring the lines of separation.
- Inconsistent Records: Documented in the deposition (Page *, Section *-*), the inconsistent and fraudulent records further support the argument for piercing the corporate veil.
- Fraudulent Practices: As evidenced on Page *, Section *-*, and Page *, Section *-*, the defendants engaged in accounting practices designed to evade taxes and misrepresent financial realities.
PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY:
- Ms. Horton is expected to testify

see above. Or do we not include the Interrogatory because the Deposition of Forensic Accountant is sufficient?

You have a solid basis with the Deposition of Forensic Accountant, which provides comprehensive evidence. Including the *PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY* as an exhibit will further strengthen your case by providing additional context and expert testimony. It is advisable to include both for a robust argument.
Would you like assistance in integrating the Interrogatory details into your motion?

I will provide you with more from the Interrogatory.Ms. Horton is expected to testify that Tiernan and Grieco’s profit sharing arrangement relative to * Fountain Street, LLC is highly unusual, if not unheard of, and admittedly has no economic substance or business purpose other than tax avoidance, and thus runs afoul of the “sham transaction doctrine.” Ms. Horton is further expected to testify that The Classic

Here's an integrated structure for your motion, including both the deposition and the interrogatory details:
---
Forensic Accountant’s Findings:
- The forensic accountant's report (Exhibit C) highlights severe bookkeeping irregularities, such as commingling of funds and tax evasion.
- Deposition excerpts provide evidence of inconsistent records and sham transactions.
- These findings are crucial to the integrity of the case and demonstrate significant financial misconduct by the defendant.
Deposition of Forensic Accountant:
The forensic accountant’s deposition (Exhibit D) provides detailed evidence of severe bookkeeping irregularities, commingling of funds, and tax evasion. The deposition highlights:
- Page *, Section *-*: Shared operations between * Fountain and Classic Group, indicating commingling of funds.
- Page *, Section *-*: Inconsistent records and sham transactions, demonstrating financial misconduct.
- Page *, Section *-*: Accounting entries designed for tax avoidance, showcasing illegal financial practices.
- Page *, Section *-*: Questionable stock transfer without proper documentation, raising further concerns about financial propriety.
Veil Piercing Argument:
The defendants argue that there were two separate companies;however, the forensic accountant’s findings strongly establish that * Fountain and Classic Group operated as a single entity in practice. This court should pierce the corporate veil based on the following:
- Unified Operation: The forensic accountant's report confirms that both companies were operated as a single business, with shared employees, office space, and financial resources.
- Commingling of Funds: The deposition (Page *, Section *-*) clearly indicates funds were commingled between the two entities, blurring the lines of separation.
- Inconsistent Records: Documented in the deposition (Page *, Section *-*), the inconsistent and fraudulent records further support the argument for piercing the corporate veil.
- Fraudulent Practices: As evidenced on Page *, Section *-*, and Page *, Section *-*, the defendants engaged in accounting practices designed to evade taxes and misrepresent financial realities.
PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY:
- Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively, the “Entities”) acted as the agent and alter ego of one another with disregard for

Group, Inc. paid Cronan officer wages for * to * even though Cronan was not identified as an officer of The Classic Group, Inc. in state corporate filings. Ms. Horton is further expected to testify that the Entities illegally paid some employees in cash, illegally classified and paid employees as independent contractors, and engaged in sham transfers of funds disguised as

Here’s an integrated and comprehensive structure for your motion:
---
Forensic Accountant’s Findings:
- The forensic accountant's report (Exhibit C) highlights severe bookkeeping irregularities, such as commingling of funds and tax evasion.
- Deposition excerpts provide evidence of inconsistent records and sham transactions.
- These findings are crucial to the integrity of the case and demonstrate significant financial misconduct by the defendant.
Deposition of Forensic Accountant:
The forensic accountant’s deposition (Exhibit D) provides detailed evidence of severe bookkeeping irregularities, commingling of funds, and tax evasion. The deposition highlights:
- Page *, Section *-*: Shared operations between * Fountain and Classic Group, indicating commingling of funds.
- Page *, Section *-*: Inconsistent records and sham transactions, demonstrating financial misconduct.
- Page *, Section *-*: Accounting entries designed for tax avoidance, showcasing illegal financial practices.
- Page *, Section *-*: Questionable stock transfer without proper documentation, raising further concerns about financial propriety.
Veil Piercing Argument:
The defendants argue that there were two separate companies; however, the forensic accountant’s findingsstrongly establish that * Fountain and Classic Group operated as a single entity in practice. This court should pierce the corporate veil based on the following:
- Unified Operation: The forensic accountant's report confirms that both companies were operated as a single business, with shared employees, office space, and financial resources.
- Commingling of Funds: The deposition (Page *, Section *-*) clearly indicates funds were commingled between the two entities, blurring the lines of separation.
- Inconsistent Records: Documented in the deposition (Page *, Section *-*), the inconsistent and fraudulent records further support the argument for piercing the corporate veil.
- Fraudulent Practices: As evidenced on Page *, Section *-*, and Page *, Section *-*, the defendants engaged in accounting practices designed to evade taxes and misrepresent financial realities.
PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY:
- Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively, the “Entities”) acted as the agent and alter ego of one another with disregard for their separate identities in corporate form

“management fees” for tax avoidance purposes. Ms. Horton is expected to testify that the above arrangements and transactions, alone or in combination, show that Entities’ tax returns and records do not reflect economic reality, lack economic substance, are against good business practices, evidence a disregard of corporate structure, and support the conclusion that Cronan is (and Tiernan and Grieco considered him to be) a one-third partner with Tiernan and Grieconotwithstanding the fact that Grieco and Tiernan are nominally listed as the owners of TheClassic Group, Inc. and * Fountain Street, LLC.

Here's the integrated structure for your motion, including both the deposition and the interrogatory details:
---
Forensic Accountant’s Findings:
- The forensic accountant's report (Exhibit C) highlights severe bookkeeping irregularities, such as commingling of funds and tax evasion.
- Deposition excerpts provide evidence of inconsistent records and sham transactions.
- These findings are crucial to the integrity of the case and demonstrate significant financial misconduct by the defendant.
Deposition of Forensic Accountant:
The forensic accountant’s deposition (Exhibit D) provides detailed evidence of severe bookkeeping irregularities, commingling of funds, and tax evasion. The deposition highlights:
- Page *, Section *-*: Shared operations between * Fountain and Classic Group, indicating commingling of funds.
- Page *, Section *-*: Inconsistent records and sham transactions, demonstrating financial misconduct.
- Page *, Section *-*: Accounting entries designed for tax avoidance, showcasing illegal financial practices.
- Page *, Section *-*: Questionable stock transfer without proper documentation, raising further concerns about financial propriety.
Veil Piercing Argument:
The defendants argue that there were two separate companies;however, the forensic accountant’s findings strongly establish that * Fountain and Classic Group operated as a single entity in practice. This court should pierce the corporate veil based on the following:
- Unified Operation: The forensic accountant's report confirms that both companies were operated as a single business, with shared employees, office space, and financial resources.
- Commingling of Funds: The deposition (Page *, Section *-*) clearly indicates funds were commingled between the two entities, blurring the lines of separation.
- Inconsistent Records: Documented in the deposition (Page *, Section *-*), the inconsistent and fraudulent records further support the argument for piercing the corporate veil.
- Fraudulent Practices: As evidenced on Page *, Section *-*, and Page *, Section *-*, the defendants engaged in accounting practices designed to evade taxes and misrepresent financial realities.
PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY:
- Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively, the “Entities”) acted as the agent and alter ego of one another with disregard for

So it appears that we dont need this section Right?Forensic Accountant’s Findings: - The forensic accountant's report (Exhibit C) highlights severe bookkeeping irregularities, such as commingling of funds and tax evasion. - Deposition excerpts provide evidence of inconsistent records and sham transactions. - These findings are crucial to the integrity of the case and demonstrate significant financial misconduct by the defendant.

It seems like your motion already has robust evidence from the forensic accountant’s deposition, which provides detailed and specific evidence crucial to your case. Including the *PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY* as an exhibit can further strengthen your argument by adding additional context and expert testimony. You should include both for a comprehensive presentation.
Here's the integrated structure:
---
Forensic Accountant’s Findings:
- The forensic accountant's report (Exhibit C) highlights severe bookkeeping irregularities, such as commingling of funds and tax evasion.
- Deposition excerpts provide evidence of inconsistent records and sham transactions.
- These findings are crucial to the integrity of the case and demonstrate significant financial misconduct by the defendant.
Deposition of Forensic Accountant:
The forensic accountant’s deposition (Exhibit D) provides detailed evidence of severe bookkeeping irregularities, commingling of funds, and tax evasion. The deposition highlights:
- Page *, Section *-*: Shared operations between * Fountain and Classic Group, indicating commingling of funds.
- Page *, Section *-*: Inconsistent records and sham transactions, demonstrating financial misconduct.
- Page *, Section *-*: Accounting entries designed for tax avoidance, showcasing illegal financial practices.
- Page *, Section *-*: Questionable stock transfer without proper documentation, raising further concerns about financial propriety.
Veil Piercing Argument:
The defendants argue that there were two separate companies; however, the forensic accountant’s findings strongly establish that * Fountain and Classic Group operated as a single entity in practice. This court should pierce the corporate veil based on the following:
- Unified Operation: The forensic accountant's report confirms that both companies were operated as a single business, with shared employees, office space, and financial resources.
- Commingling of Funds: The deposition (Page *, Section *-*) clearly indicates funds were commingled between the two entities, blurring the lines of separation.
- Inconsistent Records: Documented in the deposition (Page *, Section *-*), the inconsistent and fraudulent records further support the argument for piercing the corporate veil.
- Fraudulent Practices: As evidenced on Page *, Section *-*, and Page *, Section *

Im still confused because i am agreeing with you. Could you please only send me the section about the Intererogatory?

Sure, here's the section about the Interrogatory:
---
PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY:
- Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively, the “Entities”) acted as the agent and alter ego of one another with disregard for their separate identities in corporate form.
- She is expected to testify that the Entities acted as a single business enterprise and single economic entity while engaging in their business operations.
- Ms. Horton is expected to testify that Tiernan and Grieco’s profit sharing arrangement relative to * Fountain Street, LLC is highly unusual, if not unheard of, and admittedly has no economic substance or business purpose other than tax avoidance, and thus runs afoul of the “sham transaction doctrine.”
- Ms. Horton is further expected to testify that The Classic Group, Inc. paid Cronan officer wages for * to * even though Cronan was not identified as an officer of The Classic Group, Inc. in state corporate filings.
- Ms. Horton is also expected to testify that the Entities illegally paid some employees in cash, illegally classified and paid employees as independent contractors, andengaged in sham transfers of funds disguised as “management fees” for tax avoidance purposes.
- Ms. Horton is expected to testify that the above arrangements and transactions, alone or in combination, show that the Entities’ tax returns and records do not reflect economic reality, lack economic substance, are against good business practices, evidence a disregard of corporate structure, and support the conclusion that Cronan is (and Tiernan and Grieco considered him to be) a one-third partner with Tiernan and Grieco notwithstanding the fact that Grieco and Tiernan are nominally listed as the owners of The Classic Group, Inc. and * Fountain Street, LLC.
Would you like help with anything else?

see above

Certainly! Here’s the section focused solely on the interrogatory:
---
PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY:
- Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively, the “Entities”) acted as the agent and alter ego of one another with disregard for their separate identities in corporate form. She is expected to testify that the Entities acted as a single business enterprise and single economic entity while engaging in their business operations.
- Ms. Horton is expected to testify that Tiernan and Grieco’s profit-sharing arrangement relative to * Fountain Street, LLC is highly unusual, if not unheard of, and admittedly has no economic substance or business purpose other than tax avoidance, and thus runs afoul of the “sham transaction doctrine.”
- Ms. Horton is further expected to testify that The Classic Group, Inc. paid Cronan officer wages for * to * even though Cronan was not identified as an officer of The Classic Group, Inc. in state corporate filings.
- Ms. Horton is expected to testify that the Entities illegally paid some employees in cash, illegally classified and paid employees as independent contractors, andengaged in sham transfers of funds disguised as “management fees” for tax avoidance purposes.
- Ms. Horton is expected to testify that the above arrangements and transactions, alone or in combination, show that Entities’ tax returns and records do not reflect economic reality, lack economic substance, are against good business practices, evidence a disregard of corporate structure, and support the conclusion that Cronan is (and Tiernan and Grieco considered him to be) a one-third partner with Tiernan and Grieco notwithstanding the fact that Grieco and Tiernan are nominally listed as the owners of The Classic Group, Inc. and * Fountain Street, LLC.
---
Would you like any further assistance with your motion?

We ahve two sections rather than three. Could you provide me with the two sections?

Here are the two sections you requested:
---
Deposition of Forensic Accountant:
- The forensic accountant’s deposition (Exhibit D) provides detailed evidence of severe bookkeeping irregularities, commingling of funds, and tax evasion. The deposition highlights:
- Page *, Section *-*: Shared operations between * Fountain and Classic Group, indicating commingling of funds.
- Page *, Section *-*: Inconsistent records and sham transactions, demonstrating financial misconduct.
- Page *, Section *-*: Accounting entries designed for tax avoidance, showcasing illegal financial practices.
- Page *, Section *-*: Questionable stock transfer without proper documentation, raising further concerns about financial propriety.
PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY:
- Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively, the “Entities”) acted as the agent and alter ego of one another with disregard for their separate identities in corporate form.
- Ms. Horton is expected to testify that the Entities acted as a single business enterprise and single economic entity while engagingin their business operations.
- Ms. Horton is expected to testify that Tiernan and Grieco’s profit-sharing arrangement relative to * Fountain Street, LLC is highly unusual, if not unheard of, and has no economic substance other than tax avoidance.
- Ms. Horton is further expected to testify that The Classic Group, Inc. paid Cronan officer wages for * to *, even though Cronan was not identified as an officer in state corporate filings.
- Additionally, she will testify that the Entities illegally paid some employees in cash, classified and paid employees as independent contractors, and engaged in sham transfers of funds disguised as “management fees” for tax avoidance purposes.
- These arrangements and transactions, alone or in combination, show that the Entities’ tax returns and records do not reflect economic reality, lack economic substance, and evidence a disregard of corporate structure, supporting the conclusion that Cronan is a one-third partner with Tiernan and Grieco despite their nominal listing as owners.
Would you like any additional assistance with your motion or further clarification on any points?

Where do i put exhibit in this section?

You can mention the exhibits within the sections where you reference specific evidence. Here’s how you can integrate the exhibits into the two sections:
---
Deposition of Forensic Accountant:
- The forensic accountant’s deposition (Exhibit D) provides detailed evidence of severe bookkeeping irregularities, commingling of funds, and tax evasion. The deposition highlights:
- Page *, Section *-*: Shared operations between * Fountain and Classic Group, indicating commingling of funds.
- Page *, Section *-*: Inconsistent records and sham transactions, demonstrating financial misconduct.
- Page *, Section *-*: Accounting entries designed for tax avoidance, showcasing illegal financial practices.
- Page *, Section *-*: Questionable stock transfer without proper documentation, raising further concerns about financial propriety.
PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY:
- Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively, the “Entities”) acted as the agent and alter ego of one another with disregard for their separate identities in corporate form (Exhibit E- Ms. Horton is expected to testify that the Entities acted as a single business enterprise and single economic entity while engaging in their business operations.
- Ms. Horton is expected to testify that Tiernan and Grieco’s profit-sharing arrangement relative to * Fountain Street, LLC is highly unusual, if not unheard of, and has no economic substance other than tax avoidance.
- Ms. Horton is further expected to testify that The Classic Group, Inc. paid Cronan officer wages for * to *, even though Cronan was not identified as an officer in state corporate filings.
- Additionally, she will testify that the Entities illegally paid some employees in cash, classified and paid employees as independent contractors, and engaged in sham transfers of funds disguised as “management fees” for tax avoidance purposes.
- These arrangements and transactions, alone or in combination, show that the Entities’ tax returns and records do not reflect economic reality, lack economic substance, and evidence a disregard of corporate structure, supporting the conclusion that Cronan is a one-third partner with Tiernan and Grieco despite their nominal listing as owners.
Would you like any further assistance with your motion or any clarification on specific points?

PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY:

Here’s the revised section with Exhibit references:
---
Deposition of Forensic Accountant:
- The forensic accountant’s deposition (Exhibit D) provides detailed evidence of severe bookkeeping irregularities, commingling of funds, and tax evasion. The deposition highlights:
- Page *, Section *-*: Shared operations between * Fountain and Classic Group, indicating commingling of funds.
- Page *, Section *-*: Inconsistent records and sham transactions, demonstrating financial misconduct.
- Page *, Section *-*: Accounting entries designed for tax avoidance, showcasing illegal financial practices.
- Page *, Section *-*: Questionable stock transfer without proper documentation, raising further concerns about financial propriety.
PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY (Exhibit E):
- Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively, the “Entities”) acted as the agent and alter ego of one another with disregard for their separate identities in corporate form.
- Ms. Horton is expected to testify that the Entities acted as a single business enterprise andsingle economic entity while engaging in their business operations.
- Ms. Horton is expected to testify that Tiernan and Grieco’s profit-sharing arrangement relative to * Fountain Street, LLC is highly unusual, if not unheard of, and has no economic substance other than tax avoidance.
- Ms. Horton is further expected to testify that The Classic Group, Inc. paid Cronan officer wages for * to *, even though Cronan was not identified as an officer in state corporate filings.
- Additionally, she will testify that the Entities illegally paid some employees in cash, classified and paid employees as independent contractors, and engaged in sham transfers of funds disguised as “management fees” for tax avoidance purposes.
- These arrangements and transactions, alone or in combination, show that the Entities’ tax returns and records do not reflect economic reality, lack economic substance, and evidence a disregard of corporate structure, supporting the conclusion that Cronan is a one-third partner with Tiernan and Grieco despite their nominal listing as owners.
Would you like more guidance on structuring your motion or adding any additional details?

Si in my motion it would proceed as follows: Plaintiffs answer to Def., Deposition of forensic Accountant and Veil Piercing Argument?

Yes, here's how you can structure your motion, integrating the sections for the Plaintiffs' Answer to Defendants' Expert Interrogatory, Deposition of Forensic Accountant, and Veil Piercing Argument:
---
PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY (Exhibit E):
- Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively, the “Entities”) acted as the agent and alter ego of one another with disregard for their separate identities in corporate form.
- Ms. Horton is expected to testify that the Entities acted as a single business enterprise and single economic entity while engaging in their business operations.
- Ms. Horton is expected to testify that Tiernan and Grieco’s profit-sharing arrangement relative to * Fountain Street, LLC is highly unusual, if not unheard of, and has no economic substance other than tax avoidance.
- Ms. Horton is further expected to testify that The Classic Group, Inc. paid Cronan officer wages for * to *, even though Cronan was not identified as an officer in state corporate filings.
- Additionally, she will testify that the Entities illegally paid some employees in cash, classified and paid employees as independent contractors, and engaged in sham transfers of funds disguised as “management fees” for tax avoidance purposes.
- These arrangements and transactions, alone or in combination, show that the Entities’ tax returns and records do not reflect economic reality, lack economic substance, and evidence a disregard of corporate structure, supporting the conclusion that Cronan is a one-third partner with Tiernan and Grieco despite their nominal listing as owners.
Deposition of Forensic Accountant (Exhibit D):
- The forensic accountant’s deposition provides detailed evidence of severe bookkeeping irregularities, commingling of funds, and tax evasion. The deposition highlights:
- Page *, Section *-*: Shared operations between * Fountain and Classic Group, indicating commingling of funds.
- Page *, Section *-*: Inconsistent records and sham transactions, demonstrating financial misconduct.
- Page *, Section *-*: Accounting entries designed for tax avoidance, showcasing illegal financial practices.
- Page *, Section *-*: Questionable stock transfer without proper documentation, raising further concerns about financial propriety.
Veil Piercing Argument:
The defendants argue that there were two separate companies; however,

The PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY include the Curriculum Vitae of Lorraine A. Horton, CPA/CFF, CFE, CICA- do I add this?

Yes, you should include the Curriculum Vitae (CV) of Lorraine A. Horton, CPA/CFF, CFE, CICA in the PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY. The CV will establish her credentials and expertise, enhancing the credibility of her findings and testimony.
Would you like assistance with formatting or including any additional information in your motion?

see above

Yes, including the Curriculum Vitae (CV) of Lorraine A. Horton, CPA/CFF, CFE, CICA, as part of Exhibit E would strengthen your case by establishing her qualifications and credibility as an expert witness. Here’s the revised structure with the addition of the CV:
---
PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY (Exhibit E):
- Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively, the “Entities”) acted as the agent and alter ego of one another with disregard for their separate identities in corporate form.
- Ms. Horton is expected to testify that the Entities acted as a single business enterprise and single economic entity while engaging in their business operations.
- Ms. Horton is expected to testify that Tiernan and Grieco’s profit-sharing arrangement relative to * Fountain Street, LLC is highly unusual, if not unheard of, and has no economic substance other than tax avoidance.
- Ms. Horton is further expected to testify that The Classic Group, Inc. paid Cronan officer wages for * to *, even though Cronan was not identified as an officer in state corporate filings.
- Additionally, she will testify that the Entities illegally paid some employees in cash, classified and paid employees as independent contractors, and engaged in sham transfers of funds disguised as “management fees” for tax avoidance purposes.
- These arrangements and transactions, alone or in combination, show that the Entities’ tax returns and records do not reflect economic reality, lack economic substance, and evidence a disregard of corporate structure, supporting the conclusion that Cronan is a one-third partner with Tiernan and Grieco despite their nominal listing as owners.
- Curriculum Vitae of Lorraine A. Horton, CPA/CFF, CFE, CICA is included to establish her qualifications and credibility as an expert witness.
Deposition of Forensic Accountant (Exhibit D):
- The forensic accountant’s deposition provides detailed evidence of severe bookkeeping irregularities, commingling of funds, and tax evasion. The deposition highlights:
- Page *, Section *-*: Shared operations between * Fountain and Classic Group, indicating commingling of funds.
- Page *, Section *-*: Inconsistent records and sham transactions, demonstrating financial misconduct.
- Page *, Section *-*: Accounting entries designed for tax avoidance, showcasing illegal financial practices

how do I sign my name with the "s"

You typically sign your name with an "/s/" to indicate that the signature is electronic. Here’s how you can do it:
---
Respectfully submitted,
/s/ [Your Name]
[Your Name]
---
Would you like any more assistance with your motion or any other legal questions?

Can you polish this Newly Discovered Evidence and Significant Factual Developments: This motion is grounded on newly discovered evidence and significant factual developments. Recently, Mr. DiOreio Trustee for the bankruptcy court has filed a Motion For Approval Of Sale Of Judgements to * Fountain Street, LLC (the “buyer”) to purchase a $*,* judgment against myself and my former wife for $*,*, raising serious concerns about ongoing fraud and bad faith. Is this ok?

Here’s a polished version of the section:
---
Newly Discovered Evidence and Significant Factual Developments:
This motion is based on newly discovered evidence and significant factual developments. Recently, Mr. DiOreio, Trustee for the bankruptcy court, filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”), to purchase a $*,* judgment against myself and my former wife for $*,*. This raises serious concerns about ongoing fraud and bad faith.
---
Would you like assistance with anything else?

see above.

Sure, here's a polished version of that section:
---
Newly Discovered Evidence and Significant Factual Developments:
This motion is based on newly discovered evidence and significant factual developments. Recently, Mr. DiOreio, Trustee for the bankruptcy court, filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”) to purchase a $*,* judgment against myself and my former wife for $*,*. This transaction raises serious concerns about ongoing fraud and bad faith.
---
Would you like any further assistance or adjustments?

see above

Here is a polished version of your section:
---
Newly Discovered Evidence and Significant Factual Developments:
This motion is grounded on newly discovered evidence and significant factual developments. Recently, Mr. DiOreio, Trustee for the bankruptcy court, has filed a Motion For Approval Of Sale Of Judgments to * Fountain Street, LLC (the “buyer”) to purchase a $*,* judgment against myself and my former wife for $*,*. This development raises serious concerns about ongoing fraud and bad faith.
---
Would you like any further assistance with this section or other parts of your motion?

I go on to say:My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court. While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court. The defendants now use the lawsuit filed against me by Trustee D'Oreo in the bankruptcy court as a means to challenge my credibility in this court. However, they come with unclean hands, having knowingly and willfully orchestrated the D'Oreo lawsuit to gain an unfair advantage and seize the valuable * Fountain Street property in Rhode Island. After filing the lawsuit, my financial advisor used it as justification for not returning my name to the title of the commercial mill building, stating, "Mike, I can't put your name back on the Mill building because of D'Oreo's lawsuit against you." This lawsuit, in fact, was instigated by him while he was my trusted advisor.

Sure, here’s a polished version of your section:
---
Newly Discovered Evidence and Significant Factual Developments:
This motion is grounded on newly discovered evidence and significant factual developments. Recently, Mr. DiOreio, Trustee for the bankruptcy court, filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”) to purchase a $*,* judgment against myself and my former wife for $*,*. This raises serious concerns about ongoing fraud and bad faith.
My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court. While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court. The defendants now use the lawsuit filed against me by Trustee D'Oreo in the bankruptcy court as a means to challenge my credibility in this court. However, they come with unclean hands, having knowingly and willfully orchestrated the D'Oreo lawsuit to gain an unfair advantage and seize the valuable * Fountain Street property in Rhode Island.
After filing the lawsuit, my financial advisor used it as justification for not returning my name to the title of thecommercial mill building, stating, "Mike, I can't put your name back on the Mill building because of D'Oreo's lawsuit against you." This lawsuit, in fact, was instigated by him while he was my trusted advisor.
---
Would you like help with anything else?

After Mr. DiOrio filed the lawsuit, the defendants used it as...

Here's a polished version of the sections you provided:
---
Newly Discovered Evidence and Significant Factual Developments:
This motion is grounded on newly discovered evidence and significant factual developments. Recently, Mr. DiOrio, Trustee for the bankruptcy court, filed a Motion For Approval Of Sale Of Judgments to * Fountain Street, LLC (the “buyer”), to purchase a $*,* judgment against myself and my former wife for $*,*. This raises serious concerns about ongoing fraud and bad faith.
Further Details:
My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court. While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court. The defendants now use the lawsuit filed against me by Trustee D'Oreo in the bankruptcy court as a means to challenge my credibility in this court. However, they come with unclean hands, having knowingly and willfully orchestrated the D'Oreo lawsuit to gain an unfair advantage and seize the valuable * Fountain Street property in Rhode Island.
After Mr. DiOrio filed the lawsuit, my financial advisor used it as justification fornot returning my name to the title of the commercial mill building, stating, "Mike, I can't put your name back on the Mill building because of D'Oreo's lawsuit against you." This lawsuit, in fact, was instigated by him while he was my trusted advisor.
---
Would you like any further assistance with your motion or any other legal questions?

Newly Discovered Evidence and Significant Factual Developments: This motion is grounded on newly discovered evidence and significant factual developments. Recently, * Fountain Street, LLC (the “buyer”) purchased a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee against me, which was a direct result of my financial advisor's accounting representation in the bankruptcy court.

Here's a polished version of your statement:
---
Newly Discovered Evidence and Significant Factual Developments:
This motion is grounded on newly discovered evidence and significant factual developments. Recently, * Fountain Street, LLC (the “buyer”) purchased a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
---
Context and Background:
My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court. While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court. The defendants now use the lawsuit filed against me by Trustee D'Oreo in the bankruptcy court as a means to challenge my credibility in this court.
However, they come with unclean hands, having knowingly and willfully orchestrated the D'Oreo lawsuit to gain an unfair advantage and seize the valuable * Fountain Street property in Rhode Island. After filing the lawsuit, my financial advisor used it as justification for not returning my name to the title of thecommercial mill building, stating, "Mike, I can't put your name back on the Mill building because of D'Oreo's lawsuit against you." This lawsuit, in fact, was instigated by him while he was my trusted advisor.
---
Would you like any additional assistance with your motion or any other part of your legal process?

They have not has the closing yet. Mr DiOrio filed the Motion to execute the upcoming transer.

Understood. Here’s the revised and polished version incorporating the latest details:
---
Newly Discovered Evidence and Significant Factual Developments:
This motion is grounded on newly discovered evidence and significant factual developments. Recently, * Fountain Street, LLC (the “buyer”) purchased a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
Context and Background:
My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court. While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court. The defendants now use the lawsuit filed against me by Trustee D'Oreo in the bankruptcy court as a means to challenge my credibility in this court.
However, they come with unclean hands, having knowingly and willfully orchestrated the D'Oreo lawsuit to gain an unfair advantage and seize the valuable * Fountain Street property in Rhode Island. After filing the lawsuit, my financial advisor used it as justification for not returning my nameto the title of the commercial mill building, stating, "Mike, I can't put your name back on the Mill building because of D'Oreo's lawsuit against you." This lawsuit, in fact, was instigated by him while he was my trusted advisor.
---
Would you like more assistance with any other part of your motion or further clarification on any points?

had

Got it! Here’s the revised version with the necessary adjustments:
---
Newly Discovered Evidence and Significant Factual Developments:
This motion is grounded on newly discovered evidence and significant factual developments. Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”) to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
Context and Background:
My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court. While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court. The defendants now use the lawsuit filed against me by Trustee D'Oreo in the bankruptcy court as a means to challenge my credibility in this court. However, they come with unclean hands, having knowingly and willfully orchestrated the D'Oreo lawsuit to gain an unfair advantage and seize the valuable * FountainStreet property in Rhode Island. After filing the lawsuit, my financial advisor used it as justification for not returning my name to the title of the commercial mill building, stating, "Mike, I can't put your name back on the Mill building because of D'Oreo's lawsuit against you." This lawsuit, in fact, was instigated by him while he was my trusted advisor.
Would you like any additional assistance with your motion or any other part of your legal process?

After Mr. Diorio filed the lawsuit, my financial...

---
Here’s the revised version, incorporating your latest input:
---

Newly Discovered Evidence and Significant Factual Developments:
This motion is grounded on newly discovered evidence and significant factual developments. Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”) to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.

Context and Background:
My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court. While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court. The defendants now use the lawsuit filed against me by Trustee D'Oreo in the bankruptcy court as a means to challenge my credibility in this court. However, they come with unclean hands, having knowingly and willfully orchestrated the D'Oreo lawsuit to gain an unfair advantage and seize the valuable * Fountain Street property in RhodeIsland. After Mr. DiOrio filed the lawsuit, my financial advisor used it as justification for not returning my name to the title of the commercial mill building, stating, "Mike, I can't put your name back on the Mill building because of D'Oreo's lawsuit against you." This lawsuit, in fact, was instigated by him while he was my trusted advisor.
---
Would you like any additional assistance with your motion or any other part of your legal process?

Please place the exhibit wording.

Certainly! Here’s the wording for the exhibits:
---

~Exhibit D: Deposition of Forensic Accountant
- Page *, Section *-*: Shared operations between * Fountain and Classic Group, indicating commingling of funds.
- Page *, Section *-*: Inconsistent records and sham transactions, demonstrating financial misconduct.
- Page *, Section *-*: Accounting entries designed for tax avoidance, showcasing illegal financial practices.
- Page *, Section *-*: Questionable stock transfer without proper documentation, raising further concerns about financial propriety.

~Exhibit E: PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY
- Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively, the “Entities”) acted as the agent and alter ego of one another with disregard for their separate identities in corporate form.
- Ms. Horton is expected to testify that the Entities acted as a single business enterprise and single economic entity while engaging in their business operations.
- Ms. Horton is expected to testify that Tiernan and Grieco’s profit-sharing arrangement relative to80 Fountain Street, LLC is highly unusual, if not unheard of, and has no economic substance other than tax avoidance.
- Ms. Horton is further expected to testify that The Classic Group, Inc. paid Cronan officer wages for * to *, even though Cronan was not identified as an officer in state corporate filings.
- Additionally, she will testify that the Entities illegally paid some employees in cash, classified and paid employees as independent contractors, and engaged in sham transfers of funds disguised as “management fees” for tax avoidance purposes.
- These arrangements and transactions, alone or in combination, show that the Entities’ tax returns and records do not reflect economic reality, lack economic substance, and evidence a disregard of corporate structure, supporting the conclusion that Cronan is a one-third partner with Tiernan and Grieco despite their nominal listing as owners.
- Curriculum Vitae of Lorraine A. Horton, CPA/CFF, CFE, CICA is included to establish her qualifications and credibility as an expert witness.
---
Would you like any more help with your motion or any other legal questions?

see above

Certainly! Here's the revised version with exhibit references:
---
Newly Discovered Evidence and Significant Factual Developments:
This motion is grounded on newly discovered evidence and significant factual developments. Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”) to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court (Exhibit F).
Context and Background:
My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court. While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court. The defendants now use the lawsuit filed against me by Trustee D'Oreo in the bankruptcy court as a means to challenge my credibility in this court. However, they come with unclean hands, having knowingly and willfully orchestrated the D'Oreo lawsuit to gain an unfair advantage and seize the valuable 80Fountain Street property in Rhode Island. After Mr. DiOrio filed the lawsuit, my financial advisor used it as justification for not returning my name to the title of the commercial mill building, stating, "Mike, I can't put your name back on the Mill building because of D'Oreo's lawsuit against you." This lawsuit, in fact, was instigated by him while he was my trusted advisor (Exhibit G).
---
Would you like any additional assistance with your motion or any other part of your legal process?

How do i state this providing two exhibits, the property, * fountain Street, R.I., transferred to me, Cronan Realty LLc, by a warranty deed and the transfer from me to the Defandants within this sentence, "This is demonstrated by the fraudulent conversion of my shares in our partnered company, initiated by unfulfilled empty promises for which I received nothing (Exhibit H), and the fraudulent conversion of the expensive commercial building at * Fountain St, R.I., for which I received nothing (Exhibit H)

Here's a revised version of your sentence including the two exhibits:
"This is demonstrated by the fraudulent conversion of my shares in our partnered company, initiated by unfulfilled empty promises for which I received nothing (Exhibit H), and the fraudulent conversion of the expensive commercial building at * Fountain St, R.I., transferred to me by a warranty deed (Exhibit I) and subsequently transferred from me to the Defendants, for which I received nothing (Exhibit J)."

I have two sections that i am wondering if we need to put it into one Relief Requested section rather than a section called Next Steps. Will you look?

Sure! You can combine the "Relief Requested" section and the "Next Steps" section into one cohesive section if it makes the document more streamlined and easier to follow. Here’s a suggestion on how you could structure it:
---
Relief Requested and Next Steps:
- Vacate Dismissal: I respectfully request that this honorable court grant my motion to vacate the dismissal of my case under Rule *(b)(*) and (*) due to excusable neglect, lack of notice, and newly discovered evidence.

- Equitable Considerations: In *Pioneer Investment Services Co. v. Brunswick Associates Ltd. Partnership*, * U.S. * (*), the U.S. Supreme Court emphasized that equitable considerations and the merits of the case can outweigh technical procedural issues under Rule *(b). This supports the argument that my case should be judged on its merits rather than dismissed on procedural grounds.

- Additional Relief: I also request any additional relief outlined in my initial motion to ensure fairness and justice in these proceedings. This includes addressing substantial evidence of fraud, bad faith, and procedural violations by the defendants.

- Next Steps: Should the court grant this motion, I amprepared to proceed with presenting the newly discovered evidence and significant factual developments, including the detailed forensic accountant’s findings and deposition excerpts, to substantiate my claims and ensure that justice prevails.
Would you like any further assistance with this or any other part of your legal process?

Next Steps: - I propose that the court order the defendants to address their procedural violation by paying for the forensic accountant's deposition, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure. - Additionally, the court should require the defendants to provide supplementary forensic accounting. Given the serious findings in the initial forensic accountant's report, it would be appropriate for the court to consider my next motion, which will seek to have the defendants bear the cost of the forensic accountant verifying the credibility of any supplementary accounting. I have already paid for the initial report, and it would be unfair for me to continue bearing the financial burden to ensure the honesty and integrity of evidence submitted in this court.

Combining the "Next Steps" into a "Relief Requested" section could provide a clearer and more cohesive structure for your motion. Here’s how you can do it:
---
Relief Requested:
- Order Defendants to Address Procedural Violation: The court should mandate that the defendants pay for the forensic accountant's deposition, as required under Rule *(h) of the Rhode Island Rules of Civil Procedure.

- Supplementary Forensic Accounting: The court should require the defendants to provide supplementary forensic accounting. Given the serious findings in the initial forensic accountant's report, the defendants should bear the cost of the forensic accountant verifying the credibility of any supplementary accounting. I have already paid for the initial report, and it would be unfair for me to continue bearing the financial burden to ensure the honesty and integrity of evidence submitted in this court.
Would you like any further assistance with your motion or any other legal questions?

Request for Relief: 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. These exhibits are based on established fraudulent accounting practices, as confirmed by the forensic accountant’s report. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process and violates my due process rights.

Combining the sections can streamline and strengthen your motion. Here’s a revised version integrating the Next Steps into the Request for Relief section:
---
Request for Relief:
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. These exhibits are based on established fraudulent accounting practices, as confirmed by the forensic accountant’s report. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process and violates my due process rights.
*. Order for Procedural Compliance: I propose that the court order the defendants to address their procedural violation by paying forthe forensic accountant's deposition, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure.
*. Supplementary Forensic Accounting: The court should require the defendants to provide supplementary forensic accounting. Given the serious findings in the initial forensic accountant's report, it would be appropriate for the court to consider my next motion, which will seek to have the defendants bear the cost of the forensic accountant verifying the credibility of any supplementary accounting. I have already paid for the initial report, and it would be unfair for me to continue bearing the financial burden to ensure the honesty and integrity of evidence submitted in this court.
---
Would you like any further assistance with your motion or any other legal matters?

*. 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. Their failure to pay these fees violates procedural rules and highlights their disregard for proper legal protocols. *. Supplementary Forensic Accounting Costs: I propose that the court require the defendants to provide supplementary forensic accounting and bear the cost of the forensic accountant verifying the credibility of any supplementary accounting. This is necessary to maintain the integrity of the judicial process and ensure the honesty of evidence submitted to the court.

Case Rating: *
Combining the "Next Steps" and "Request for Relief" sections into a single "Relief Requested" section makes sense for clarity and conciseness. Here’s a polished and combined 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. 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. These exhibits are based on established fraudulent accounting practices, as confirmed by the forensic accountant’s report. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process and violates my due process rights.
*. Order for Payment of Deposition Fees: I request that the court order the defendants to paythe forensic accountant's deposition fees, as this was their responsibility under Rule *(h) of the Rhode Island Rules of Civil Procedure. Their failure to pay these fees violates procedural rules and highlights their disregard for proper legal protocols.
*. Supplementary Forensic Accounting Costs: I propose that the court require the defendants to provide supplementary forensic accounting and bear the cost of the forensic accountant verifying the credibility of any supplementary accounting. This is necessary to maintain the integrity of the judicial process and ensure the honesty of evidence submitted to the court.
---
Would you like any further assistance with your motion or any other legal questions?

*. Addressing Challenges as a Pro Se Litigant: I respectfully request that the court consider the challenges I face as a pro se litigant, forced into this position due to the severe financial crimes committed against me. These crimes have left me insolvent while enriching the defendants by millions of dollars. One of the defendants is an owner or president of a major accounting firm in Rhode Island, and the public needs to be protected from his unscrupulous business practices. It is crucial for the court to ensure that I have a fair opportunity to present my case and that justice is served based on the merits of the case rather than procedural technicalities.

You can combine the "Next Steps" and "Request for Relief" sections into one comprehensive "Relief Requested" section. This will streamline your motion and clearly present your requests to the court. Here’s how you can structure it:
---

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. These exhibits are based on established fraudulent accounting practices, as confirmed by the forensic accountant’s report. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process and violates my due process rights.
*. Order for Payment of Deposition Fees: I request thatthe 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. Their failure to pay these fees violates procedural rules and highlights their disregard for proper legal protocols.
*. Supplementary Forensic Accounting Costs: I propose that the court require the defendants to provide supplementary forensic accounting and bear the cost of the forensic accountant verifying the credibility of any supplementary accounting. This is necessary to maintain the integrity of the judicial process and ensure the honesty of evidence submitted to the court.
*. Addressing Challenges as a Pro Se Litigant: I respectfully request that the court consider the challenges I face as a pro se litigant, forced into this position due to the severe financial crimes committed against me. These crimes have left me insolvent while enriching the defendants by millions of dollars. One of the defendants is an owner or president of a major accounting firm in Rhode Island, and the public needs to be protected from his unscrupulous business practices. It is crucial for the court to ensure that I have a fair opportunity to present my case and that justice is served based on the merits of the case rather than procedural technicalities.
---
Would you like any further assistance or revisions?

see above

Sure, combining the sections into a single "Relief Requested" section would streamline your motion. Here’s a polished and integrated 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. 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. These exhibits are based on established fraudulent accounting practices, as confirmed by the forensic accountant’s report. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process and violates 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 Rule30(h) of the Rhode Island Rules of Civil Procedure. Their failure to pay these fees violates procedural rules and highlights their disregard for proper legal protocols.
*. Supplementary Forensic Accounting Costs: I propose that the court require the defendants to provide supplementary forensic accounting and bear the cost of the forensic accountant verifying the credibility of any supplementary accounting. This is necessary to maintain the integrity of the judicial process and ensure the honesty of evidence submitted to the court.
*. Addressing Challenges as a Pro Se Litigant: I respectfully request that the court consider the challenges I face as a pro se litigant, forced into this position due to the severe financial crimes committed against me. These crimes have left me insolvent while enriching the defendants by millions of dollars. One of the defendants is an owner or president of a major accounting firm in Rhode Island, and the public needs to be protected from his unscrupulous business practices. It is crucial for the court to ensure that I have a fair opportunity to present my case and that justice is served based on the merits of the case rather than procedural technicalities.
---
Would you like any further adjustments or assistance with your motion?

*. Supplementary Forensic Accounting Costs: I propose that the court require the defendants to provide supplementary forensic accounting and bear the cost of the forensic accountant verifying the credibility of any supplementary accounting since it is their fruadulent behavoir I should not havr to bear the burden of the continued cost of the forensic accountant. i have alreqady paid her for the intial report which was a hardsip.

Here’s the revised "Relief Requested" section with your additional input:
---
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. These exhibits are based on established fraudulent accounting practices, as confirmed by the forensic accountant’s report. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process and violates 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. Their failure to pay these fees violates procedural rules and highlights their disregard for proper legal protocols.
*. Supplementary Forensic Accounting Costs: I propose that the court require the defendants to provide supplementary forensic accounting and bear the cost of the forensic accountant verifying the credibility of any supplementary accounting. Given their fraudulent behavior, I should not have to bear the burden of the continued cost of the forensic accountant. I have already paid for the initial report, which was a hardship.
*. Addressing Challenges as a Pro Se Litigant: I respectfully request that the court consider the challenges I face as a pro se litigant, forced into this position due to the severe financial crimes committed against me. These crimes have left me insolvent while enriching the defendants by millions of dollars. One of the defendants is an owner or president of a major accounting firm in Rhode Island, and the public needs to be protected from his unscrupulous business practices. It is crucial for the court to ensure that I have a fair opportunity to present my case and that justice is served based on the merits of the case rather than procedural technicalities.
---
Would you like any further adjustments or assistance with your motion?

Could you polish

Here’s the polished version of your "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. These exhibits are based on established fraudulent accounting practices, as confirmed by the forensic accountant’s report. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process and violates 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 Forensic Accounting Costs: I propose that the court require the defendants to provide supplementary forensic accounting and bear the cost of the forensic accountant verifying the credibility of any supplementary accounting. Due to their fraudulent behavior, I should not have to bear the burden of the continued cost of the forensic accountant. I have already paid for the initial report, which was a hardship.
*. Addressing Challenges as a Pro Se Litigant: I respectfully request that the court consider the challenges I face as a pro se litigant, forced into this position due to the severe financial crimes committed against me. These crimes have left me insolvent while enriching the defendants by millions of dollars. One of the defendants is an owner or president of a major accounting firm in Rhode Island, and the public needs to be protected from his unscrupulous business practices. It is crucial for the court to ensure that I have a fair opportunity to present my case and that justice is served based on the merits of the case rather than procedural technicalities.
Would you like any further adjustments or assistance with your motion?

- The bankruptcy court was abused, and the creditors were misled. I was left paying the Small Business Loan and a default judgement against me while my so-called partners immediately refinanced the building, stealing my hard-earned equity and subsequently executing an illegal self-help eviction by changing the locks to the building, stripping me of my business and the property. Do I need to express the default judgement here differently or is this ok?

Your expression of the default judgment is clear and effectively conveys the critical points. However, to ensure maximum clarity and impact, you might consider slightly rephrasing it for better readability. Here’s a polished version:
---
The bankruptcy court was abused, and the creditors were misled. I was left paying the Small Business Loan and a default judgment against me, while my so-called partners immediately refinanced the building, stealing my hard-earned equity. They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property.
---
Is there anything else you need help with?

would you please write an email to Ms. carin Miley who is Judge Stern's clerk. I wish to probide her with my Motion to Supplement ebsuring it delivery to Judge Sterns with exhibits. In addition i will eFile and serve to opposing counsel.

Sure, here’s a draft of the email for you:
---
Subject: Submission of Motion to Supplement with Exhibits
Dear Ms. Miley,
I hope this email finds you well.
I am writing to submit my Motion to Supplement, including relevant exhibits, for delivery to Judge Stern. In addition to this submission, I will eFile the document and serve it to opposing counsel.
Please find attached the Motion to Supplement along with the following exhibits:
- Exhibit D: Deposition of Forensic Accountant
- Exhibit E: Plaintiff’s Answer to Defendants’ Expert Interrogatory
- Exhibit F: Motion for Approval of Sale of Judgments
- Exhibit G: Context and Background Details
- Exhibit H: Fraudulent Conversion of Company Shares
- Exhibit I: Warranty Deed of * Fountain St., R.I.
- Exhibit J: Transfer from Me to Defendants
Thank you for your assistance in ensuring the timely delivery of these documents to Judge Stern. If you have any questions or need further information, please do not hesitate to contact me.
Best regards,
/s/ [Your Name]
[Your Name]
[Your Contact Information]
---
Would you like any further adjustments to this email?

provide

Sure, here's a draft email you can use to send to Ms. Carin Miley:
---
Subject: Submission of Motion to Supplement with Exhibits
Dear Ms. Miley,
I hope this email finds you well. I am writing to submit my Motion to Supplement, along with the accompanying exhibits, for Judge Stern's review. I have also eFiled the motion and served it to opposing counsel.
Please find attached the following documents:
*. Motion to Supplement
*. Exhibits A through H
Thank you for your assistance in ensuring these documents are delivered to Judge Stern. If there are any additional steps I need to take or further information required, please let me know.
Best regards,
[Your Full Name]
[Your Contact Information]
/s/ [Your Full Name]
---
Would you like any adjustments or additional details included in the email?

Question Unbeknownst to me as I do not recall if I was served I got a default judgment against from a trustee in Bankruptcy Court . The background i was recently divorced an I was getting child support checks from my former husband who filed in bankrupcty and although his financial advisor/CPA was representing him the trustte filed a lawsuit against him claiming that we were stealing from the estate. It was wrong but I didint go to a hearing , I guess and hence the default judgement. I owe $*,*. This trustte filed a motion which i got notice that he was selling the judgement to a party who I am sueing for illegal forclsoure, usuary, 93A and breach of contract. What are my due process rights currently?

Case Rating: *
Your situation involves complex legal issues, including default judgments, bankruptcy proceedings, and potential fraud. Here are some general points on your due process rights:
- Notice and Opportunity to be Heard: You have a right to be properly notified of legal actions against you and an opportunity to present your case. If you did not receive notice, you might challenge the default judgment.
- Motion to Vacate Judgment: Under Rule *(b) of the Massachusetts Rules of Civil Procedure, you can file a motion to vacate the default judgment due to lack of notice or other reasons such as fraud or mistake.
- Fraud and Misrepresentation: If you have evidence of fraud or misrepresentation by your ex-husband’s financial advisor or the trustee, you can present this evidence to the court.
Would you like more detailed information on how to file a motion to vacate the judgment?

Can i file that motion now? How would that affect the sale of the judgement?

Yes, you can file a motion to vacate the default judgment now. Here's how it may affect the sale of the judgment:
- Filing the Motion to Vacate: If you file a motion to vacate the judgment under Rule *(b) of the Massachusetts Rules of Civil Procedure, you must provide reasons such as lack of notice or newly discovered evidence.
- Impact on Sale of Judgment: Filing the motion to vacate could potentially stay or delay the sale of the judgment. The court may need to resolve your motion before allowing the sale to proceed. Notify the trustee and the court about your motion.
Would you like guidance on how to draft and file the motion to vacate the judgment?

see above

Yes, you can file a Motion to Vacate Judgment pursuant to Rule *(b) of the Massachusetts Rules of Civil Procedure. Here's how it might affect the sale:
- Immediate Effect: Filing the motion can potentially stay the sale until the court rules on your motion.
- Challenge the Sale: You can argue that the judgment should not be sold due to the pending motion to vacate.
Would you like guidance on drafting the motion to vacate?

Further questions. Can the party who is buying that judgement file liens on the other cases he is in that are pending?

The party buying the judgment can potentially file liens on other cases if they obtain a valid judgment against you. Here are some key points to consider:
- Judgment Liens: If they buy the judgment, they may seek to enforce it by placing liens on your property.
- Pending Cases: They typically need to wait for a final judgment in other cases before filing liens related to those cases.
Would you like more information on how to challenge the enforcement of a judgment lien?

It sounds to me like it would be wise of me to file a notice of rule *(b) for fruad upon the court as at the very least it would delay the sale of the judgment. Correct?

Yes, filing a Motion to Vacate Judgment under Rule *(b) for fraud upon the court is a strategic move. This can potentially delay the sale of the judgment and allow you to present evidence of fraud and lack of proper notice.
Would you like guidance on drafting your Rule *(b) motion?

see above

Yes, filing a Motion to Vacate Judgment under Rule *(b) for fraud upon the court can delay the sale of the judgment and potentially prevent further harm. Here are some steps to consider:
*. Draft the Motion: Clearly outline the basis for your motion, including lack of notice and fraud.
*. File the Motion: Submit it as soon as possible to the relevant court.
*. Request a Stay: In your motion, request that the court stay the sale of the judgment until your motion is resolved.
Would you like detailed guidance on drafting the Motion to Vacate Judgment?

could you please help me draft the motion? Its Rhode Island. Heres the opening paragraph of the judgement . Note I have two pieces of substantial evidence. At the time of the lawsuit my financial advisor, Ralph Grieco formed a partnership with me and he bought my business through the sale of the bankruptcy court buying the equipment and invoices which I have on tape. Then we opened a new buisness together. He advised me to give my shares of that business to the third partner in the newly formed business

Sure, here’s a draft of your motion to vacate the judgment under Rule *(b) for fraud upon the court:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
[Your Name],
Plaintiff,
v.
[Defendant’s Name],
Defendant.
Case No. [Your Case Number]
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Massachusetts Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape.
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to thethird partner in the newly formed business.
LEGAL GROUNDS
*. Excusable Neglect and Lack of Notice:
- I did not receive proper notice of the hearing, which led to the default judgment against me.
- My severe health issues and other extenuating circumstances prevented me from staying abreast of court communications.
*. Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”) to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith.
- This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
*. Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The defendants now use the lawsuit filed against me by Trustee D'O

James Tiernan to give him tax shelter. He promised that he would return my name to the stock power documents the following year. He didnt . I never got any money for the transfer. Throughout the partnership the two partners continually made promises to me because next they advised me to move from chapter * on the commercial building that was in my name as title owner and then part of the banruptcy estate to chapter * and liguidate and the two partners would buy the building from the court and once the transfer was doen they would add my name back on the title of the property. I did as my advisor told , the transfer was done. But they then refused to put my name back on the building claiming it was due to the trustee filing a lawsuit against me which he was

Sure, here’s a comprehensive draft of your Motion to Vacate Judgment under Rule *(b) for fraud upon the court, incorporating the background you provided:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
[Your Name],
Plaintiff,
v.
[Defendant’s Name],
Defendant.
Case No. [Your Case Number]
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Massachusetts Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape.
- Subsequently, we opened a new business together, and he advised me to give myshares of that business to the third partner in the newly formed business.
- James Tiernan advised me to give him my shares for tax shelter purposes, promising to return my name to the stock power documents the following year. He never did, and I did not receive any money for the transfer.
- Throughout the partnership, both partners made repeated promises, including advising me to move from Chapter * to Chapter * bankruptcy on the commercial building in my name. They promised to buy the building from the court and return my name to the title afterward.
- I followed their advice, but after the transfer, they refused to put my name back on the building, citing a lawsuit filed by the trustee against me, which they had orchestrated.
LEGAL GROUNDS
*. Excusable Neglect and Lack of Notice:
- I did not receive proper notice of the hearing, which led to the default judgment against me.
- My severe health issues and other extenuating circumstances prevented me from staying abreast of court communications.
*. Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “

in charge of. Then they did an illegal self help eviction locking me out of the building. I filed a lawsuit against them in Superior R.I. court with a lawyer who left me because I could not keep up with his payments though I had hired him under a contingency case which he changes to hourly. The case is pending and the former partners bouth that default judgement. Meanwhile during the representation with my counsel I had hired a forensic accountant to report on the financials that the court reguired them to submit to disolve the partnership. She reported extensive comminginging of funds, tax evasion, sham transaction etc. So to file the motion I believe that I have enough premafascia evidence.

Sure, here’s a revised draft of your motion to vacate the judgment under Rule *(b) for fraud upon the court:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
[Your Name],
Plaintiff,
v.
[Defendant’s Name],
Defendant.
Case No. [Your Case Number]
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Massachusetts Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape.
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partnerin the newly formed business, James Tiernan, to give him tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer.
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as title owner and part of the bankruptcy estate, to Chapter * and liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back on the title of the property.
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property.
- I filed a lawsuit against them in Superior R.I. court, but my lawyer left the case due to my inability to keep up with his payments, despite being hired under a contingency case which he changed to hourly. The case is still pending.
- During the representation

Please starta again from "during the repres..."

Certainly! Here’s the continued draft of your motion starting from "during the representation":
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
[Your Name],
Plaintiff,
v.
[Defendant’s Name],
Defendant.
Case No. [Your Case Number]
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Massachusetts Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape.
- Subsequently, we opened a new business together,and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer.
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property.
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property.
- I filed a lawsuit against them in Superior R.I. court, but my lawyer left the case due to my inability to keep up with his payments, despite being

Please send from - I filed a lawsuit against them in Superior R.I. court, but my lawyer left the case due to my inability to keep up with his payments, despite being down

Sure, here’s the continuation starting from that point:
---
- I filed a lawsuit against them in Superior R.I. court, but my lawyer left the case due to my inability to keep up with his payments, despite being hired under a contingency case which he changed to hourly. The case is still pending.
- During the representation, I hired a forensic accountant to report on the financials required by the court to dissolve the partnership. Her report revealed extensive commingling of funds, tax evasion, sham transactions, and other fraudulent activities.
LEGAL GROUNDS
*. Excusable Neglect and Lack of Notice:
- I did not receive proper notice of the hearing, which led to the default judgment against me.
- My severe health issues and other extenuating circumstances prevented me from staying abreast of court communications.
*. Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”) to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated fromthe bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
*. Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The defendants now use the lawsuit filed against me by Trustee D'Oreo in the bankruptcy court as a means to challenge my credibility in this court. However, they come with unclean hands, having knowingly and willfully orchestrated the D'Oreo lawsuit to gain an unfair advantage and seize the valuable * Fountain Street property in Rhode Island.
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

see above

Sure! Here’s the continuation from "I filed a lawsuit against them in Superior R.I. court...":
---
I filed a lawsuit against them in Superior R.I. court, but my lawyer left the case due to my inability to keep up with his payments, despite being hired under a contingency case which he changed to hourly. The case is still pending. During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required them to submit to dissolve the partnership. The forensic accountant reported extensive commingling of funds, tax evasion, sham transactions, and other fraudulent practices.
LEGAL GROUNDS
*. Excusable Neglect and Lack of Notice:
- I did not receive proper notice of the hearing, which led to the default judgment against me.
- My severe health issues and other extenuating circumstances prevented me from staying abreast of court communications.
*. Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”) to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith.
- This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
*. Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The defendants now use the lawsuit filed against me by Trustee D'Orio in the bankruptcy court as a means to challenge my credibility in this court. However, they come with unclean hands, having knowingly and willfully orchestrated the D'Orio lawsuit to gain an unfair advantage and seize the valuable * Fountain Street property in Rhode Island.
REQUEST FOR RELIEF
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 Judgment: I request that the court vacate the default judgment entered against me due to excusable neglect, lack of notice, and newly

I need to clarify this section: LEGAL GROUNDS . I did reive notice and told my advisor but he said that the trustee was wrong but didnot take further action. I didnt understand the implication or the damge to me. Then I learned that I got a default judgement against me at which time I immiedietly met with the trusttee at his office and one of his staff told me that they would settle the case for $*,*. I did nt have that being insolvent at the time . Despite that Mr. D'Orio met at the office of my lawyer regarding the judgement and the affect it would have on my case against my partners in Superior court and at that time Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife which he is now selling for a propsosed $*,* to my partners.

Sure, here is the revised section for "Legal Grounds" based on the information you provided:
---

LEGAL GROUNDS
*. Excusable Neglect and Lack of Notice:
- Although I received notice of the hearing, I informed my advisor, who assured me that the trustee was wrong and took no further action.
- I did not understand the implications or the damage this would cause me. Consequently, a default judgment was entered against me.
- Upon learning about the default judgment, I immediately met with the trustee, who offered to settle the case for $*,*. Being insolvent at the time, I could not pay this amount.
- Mr. D'Orio later met with my lawyer to discuss the judgment and its impact on my Superior Court case against my partners. During this meeting, Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife, which he now proposes to sell for $*,* to my partners.
---
Would you like any more adjustments or assistance with any other part of your motion?

see above

Got it. Here’s the revised section for your motion:
---
LEGAL GROUNDS
*. Excusable Neglect and Lack of Notice:
- Karen, my former wife, did not receive proper notice or does not recall receiving notice of the hearing, which led to the default judgment against us.
- I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage this would cause me.
- Upon learning about the default judgment against me, I immediately met with the trustee at his office. One of his staff told me that they would settle the case for $*,*, which I could not afford, being insolvent at the time.
- Despite this, Mr. D'Orio met with my lawyer regarding the judgment and its impact on my case against my partners in Superior Court. During this meeting, Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife, which he is now selling for a proposed $*,* to my partners.
*. Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”) to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith.
- This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
*. Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The defendants now use the lawsuit filed against me by Trustee D'Orio in the bankruptcy court as a means to challenge my credibility in this court. However, they come with unclean hands, having knowingly and willfully orchestrated the D'Orio lawsuit to gain an unfair advantage and seize the valuable * Fountain Street property in Rhode Island.
---
Would you like to proceed with the Request for Relief section now?

In addition during the bankruptcy case i have documents that do not show that creditors were paid.

Got it. Here’s the continuation of your motion, incorporating the additional details about the bankruptcy case:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
[Your Name],
Plaintiff,
v.
[Defendant’s Name],
Defendant.
Case No. [Your Case Number]
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Massachusetts Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape.
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan,to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer.
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property.
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property.
- I filed a lawsuit against them in Superior R.I. court, but my lawyer left the case due to my inability to keep up with his payments, despite being hired under a contingency case which he changed to hourly. The case is still pending.
- During the representation with my counsel, I hired a forensic

Its Rhode Island

Sure, here’s the continuation of your motion tailored to Rhode Island, incorporating the additional details about the bankruptcy case:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
[Your Name],
Plaintiff,
v.
[Defendant’s Name],
Defendant.
Case No. [Your Case Number]
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape.
- Subsequently, we opened a new business together, and he advised me to give my shares of thatbusiness to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer.
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property.
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property.
- I filed a lawsuit against them in Superior R.I. court, but my lawyer left the case due to my inability to keep up with his payments, despite being hired under a contingency case which he changed to hourly. The case is

see above

Ah, I see. Thank you for the clarification. Here's the revised version for Rhode Island:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
[Your Name],
Plaintiff,
v.
[Defendant’s Name],
Defendant.
Case No. [Your Case Number]
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape.
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, JamesTiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer.
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property.
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property.
- I filed a lawsuit against them in Superior R.I. court, but my lawyer left the case due to my inability to keep up with his payments, despite being hired under a contingency case which he changed to hourly. The case is still pending.
- During the representation with my counsel, I

Before we move on although this is a true staement this lawyer is still representing me in two cases in this matter and although he didi a "bait and switch" in this matter I am concerned that he will not like this statement and I will get repercusions, - I filed a lawsuit against them in Superior R.I. court, but my lawyer left the case due to my inability to keep up with his payments, despite being hired under a contingency case which he changed to hourly.

Understood. Here’s a revised version that omits the potentially sensitive information about your lawyer while still conveying the necessary background:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
[Your Name],
Plaintiff,
v.
[Defendant’s Name],
Defendant.
Case No. [Your Case Number]
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape.
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner inthe newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer.
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property.
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property.
- I filed a lawsuit against them in Superior R.I. court, but due to financial strain, the case is still pending.
- During the representation with my counsel, I hired a forensic accountant to report on the financials that the court

please provide from - During the representation with my counsel, I hired a forensic accountant to report on the financials that the court

Certainly! Here’s the continuation:
---
- During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the defendants to submit to dissolve the partnership. The forensic accountant reported extensive commingling of funds, tax evasion, sham transactions, and other fraudulent practices, which are detailed in the forensic accountant’s report (Exhibit D).
---
LEGAL GROUNDS
*. Excusable Neglect and Lack of Notice:
- Karen, my former wife, did not receive proper notice or does not recall receiving notice of the hearing, which led to the default judgment against us.
- I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage this would cause me.
- Upon learning about the default judgment against me, I immediately met with the trustee at his office. One of his staff told me that they would settle the case for $*,*, which I could not afford, being insolvent at the time.
- Despite this, Mr. D'Orio met with my lawyer regarding the judgment and its impact on my case against my partners in SuperiorCourt. During this meeting, Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife, which he is now selling for a proposed $*,* to my partners.
*. Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”) to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith.
- This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
*. Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The defendants now use the lawsuit filed against me by Trustee D'Orio in the bankruptcy court as a means to challenge my credibility in this

see above

Sure, here’s the continuation from "During the representation with my counsel, I hired a forensic accountant..."
---
- During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the defendants to submit to dissolve the partnership. The forensic accountant reported extensive commingling of funds, tax evasion, sham transactions, and other fraudulent practices.
LEGAL GROUNDS
*. Excusable Neglect and Lack of Notice:
- Karen, my former wife, did not receive proper notice or does not recall receiving notice of the hearing, which led to the default judgment against us.
- I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage this would cause me.
- Upon learning about the default judgment against me, I immediately met with the trustee at his office. One of his staff told me that they would settle the case for $*,*, which I could not afford, being insolvent at the time.
- Despite this, Mr. D'Orio met with my lawyer regarding the judgment and its impact on my case against mypartners in Superior Court. During this meeting, Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife, which he is now selling for a proposed $*,* to my partners.
*. Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”) to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith.
- This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
*. Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The defendants now use the lawsuit filed against me by Trustee D'Orio in the bankruptcy court as a means to challenge my credibility in this court. However

Please give me from * down.

Sure, here’s the continuation from point *:
---
*. Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The defendants now use the lawsuit filed against me by Trustee D'Orio in the bankruptcy court as a means to challenge my credibility in this court. However, they come with unclean hands, having knowingly and willfully orchestrated the D'Orio lawsuit to gain an unfair advantage and seize the valuable * Fountain Street property in Rhode Island.
- Additionally, during the bankruptcy case, I have documents that do not show that creditors were paid.
---
REQUEST FOR RELIEF:
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 Judgment: I request that the court vacate the default judgment entered against me due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the recent purchase of the judgmentand 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. These exhibits are based on established fraudulent accounting practices, as confirmed by the forensic accountant’s report. Additionally, the manner in which these exhibits were submitted undermines the integrity of the judicial process and violates 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. Their failure to pay these fees violates procedural rules and highlights their disregard for proper legal protocols.
*. Supplementary Forensic Accounting Costs: I propose that the court require the defendants to provide supplementary forensic accounting and bear the cost of the forensic accountant verifying the credibility of any supplementary accounting. Due to their fraudulent behavior, I should not have to bear the burden of the continued cost of the forensic accountant. I have already paid for the initial report, which was a hardship.
*. Addressing Challenges as a Pro Se Litigant: I respectfully request

Theres confusion: the above relief is for the Superior Court case gainst my partners. However this motion rule *(b) is to the rhode island bankruptcy court to stay the sale of the motion to sell the default judgement. Or other relief that you think that given my background and the serious harm that was done by the advisor and partners would be appropriate.

Got it. Let's focus on the specific relief you're seeking from the Rhode Island Bankruptcy Court under Rule *(b) to stay the sale of the default judgment and address the serious harm caused by your advisor and partners. Here’s the revised draft:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
[Your Name],
Plaintiff,
v.
[Defendant’s Name],
Defendant.
Case No. [Your Case Number]
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape.
- Subsequently, we opened a new business together, andhe advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer.
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property.
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property.
- I filed a lawsuit against them in Superior R.I. court, but due to financial strain, the case is still pending.
- During the representation with my counsel, I hired a forensic

see above

Got it. Here’s a revised version, focusing specifically on the Rhode Island bankruptcy court to stay the sale of the motion to sell the default judgment and addressing the harm caused by your financial advisor and partners:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
[Your Name],
Plaintiff,
v.
[Defendant’s Name],
Defendant.
Case No. [Your Case Number]
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape.
- Subsequently, we opened a new business together,and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer.
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property.
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property.
- I filed a lawsuit against them in Superior R.I. court, but due to financial strain, the case is still pending.
- During the representation with my

Your revisement stopped at - During the representation with my.

Certainly! Here’s the continuation and completion of your draft:
---
- During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the defendants to submit to dissolve the partnership. The forensic accountant reported extensive commingling of funds, tax evasion, sham transactions, and other fraudulent practices.
LEGAL GROUNDS
*. Excusable Neglect and Lack of Notice:
- Karen, my former wife, did not receive proper notice or does not recall receiving notice of the hearing, which led to the default judgment against us.
- I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage this would cause me.
- Upon learning about the default judgment against me, I immediately met with the trustee at his office. One of his staff told me that they would settle the case for $*,*, which I could not afford, being insolvent at the time.
- Despite this, Mr. D'Orio met with my lawyer regarding the judgment and its impact on my case against my partners in Superior Court. During this meeting, Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife, which he is now selling for a proposed $*,* to my partners.
*. Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”) to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith.
- This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
*. Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The defendants now use the lawsuit filed against me by Trustee D'Orio in the bankruptcy court as a means to challenge my credibility in this court. However, they come with unclean hands

It stops at- The defendants now use the lawsuit filed against me by Trustee D'Orio in the bankruptcy court as a means to challenge my credibility in this court. However, they come with unclean hands...this is a passage from Superior court case . I dont think its appropriate here. Right. Also could you please send from this downward.

Certainly! Here’s the revised and continued draft, omitting the passage from the Superior Court case and focusing on the relevant details for the bankruptcy court motion:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
[Your Name],
Plaintiff,
v.
[Defendant’s Name],
Defendant.
Case No. [Your Case Number]
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape.
- Subsequently, we opened a new business together, and he advised me to give my sharesof that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer.
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property.
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property.
- I filed a lawsuit against them in Superior R.I. court, but due to financial strain, the case is still pending.
- During the representation with my counsel, I hired a forensic accountant to

see above

Certainly! Here’s the continuation and revised section without the passage from the Superior Court case:
---
*. Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The same financial advisor orchestrated the transfer of my business assets and shares under false pretenses, without fulfilling the promises made, thereby committing fraud upon the court.
- Additionally, during the bankruptcy case, I have documents that do not show that creditors were paid.
---
REQUEST FOR RELIEF:
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 Judgment: I request that the court vacate the default judgment entered against me due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the trustee's motion to sell the judgment and the fraudulent activities of my financial advisor, provides substantial grounds for relief that were not available during the initial proceedings.
*. Stayof Sale: I request that the court stay the sale of the judgment pending the resolution of this motion to vacate the judgment.
*. 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. Their failure to pay these fees highlights their disregard for proper legal protocols.
*. Supplementary Forensic Accounting Costs: I propose that the court require the defendants to provide supplementary forensic accounting and bear the cost of the forensic accountant verifying the credibility of any supplementary accounting. Due to their fraudulent behavior, I should not have to bear the burden of the continued cost of the forensic accountant. I have already paid for the initial report, which was a hardship.
*. Addressing Challenges as a Pro Se Litigant: I respectfully request that the court consider the challenges I face as a pro se litigant, forced into this position due to the severe financial crimes committed against me. These crimes have left me insolvent while enriching the defendants by millions of dollars. One of the defendants is an owner or president of a major accounting firm in Rhode Island, and the public needs to be protected from his unscrupulous

Please revise because *,*,* are not appropriate for this bankruptcy case filing. Right?

Certainly, let’s focus on the specific relief you are seeking from the bankruptcy court and tailor the request for relief accordingly.
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
[Your Name],
Plaintiff,
v.
[Defendant’s Name],
Defendant.
Case No. [Your Case Number]
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape.
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newlyformed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer.
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property.
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property.
- I filed a lawsuit against them in Superior R.I. court, but due to financial strain, the case is still pending.
- During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the defendants to submit to dissolve

ok lets do it section to section and please keep in the above formatt without the outlines.Next section from " During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the defendants to submit to dissolve," down.

---
During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the defendants to submit to dissolve the partnership. The forensic accountant reported extensive commingling of funds, tax evasion, sham transactions, and other fraudulent practices.
LEGAL GROUNDS
*. Excusable Neglect and Lack of Notice:
- Karen, my former wife, did not receive proper notice or does not recall receiving notice of the hearing, which led to the default judgment against us.
- I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage this would cause me.
- Upon learning about the default judgment against me, I immediately met with the trustee at his office. One of his staff told me that they would settle the case for $*,*, which I could not afford, being insolvent at the time.
- Despite this, Mr. D'Orio met with my lawyer regarding the judgment and its impact on my case against my partners in Superior Court. During this meeting, Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife, which he is now selling for a proposed $*,* to my partners.
*. Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”) to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith.
- This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
*. Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The same financial advisor orchestrated the transfer of my business assets and shares under false pretenses, without fulfilling the promises made, thereby committing fraud upon the court.
- Additionally, during the bankruptcy case, I have documents that do not show that creditors were paid.
**REQUEST FOR

see above

Certainly! Here’s the continuation from "During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the defendants to submit to dissolve," down:
---
During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the defendants to submit to dissolve the partnership. The forensic accountant reported extensive commingling of funds, tax evasion, sham transactions, and other fraudulent practices.
LEGAL GROUNDS
Excusable Neglect and Lack of Notice:
Karen, my former wife, did not receive proper notice or does not recall receiving notice of the hearing, which led to the default judgment against us. I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage this would cause me.
Upon learning about the default judgment against me, I immediately met with the trustee at his office. One of his staff told me that they would settle the case for $*,*, which I could not afford, being insolvent at the time. Despite this, Mr. D'Orio met with my lawyer regarding the judgment and its impact on my case against my partners in Superior Court. Duringthis meeting, Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife, which he is now selling for a proposed $*,* to my partners.
Newly Discovered Evidence:
Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”) to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
Fraud Upon the Court:
My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court. While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court. The same financial advisor orchestrated the transfer of my business assets and shares under false pretenses, without fulfilling the promises made, thereby committing fraud upon the court. Additionally, during the bankruptcy case, I have documents that do not show that creditors were paid.
REQUEST FOR REL

Next please send the next section Request For relief. Thank you!

Sure! Here’s the continuation with the "Request for Relief" section:
---
REQUEST FOR RELIEF
Given the substantial evidence of fraud, bad faith, and procedural violations, I respectfully request the following relief from this honorable court:
*. Motion to Vacate Judgment: I request that the court vacate the default judgment entered against me due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the trustee's motion to sell the judgment and the fraudulent activities of my financial advisor, provides substantial grounds for relief that were not available during the initial proceedings.
*. Stay of Sale: I request that the court stay the sale of the judgment pending the resolution of this motion to vacate the judgment.
*. Investigation into Fraud: I request that the court initiate an investigation into the fraudulent actions of my financial advisor and partners as they relate to this case and the subsequent sale of the judgment.
Respectfully submitted,
/s/ [Your Name]
[Your Name]
[Your Contact Information]
---
Would you like any further assistance or adjustments to this section?

see above

Sure, here’s the continuation with the "Request for Relief" section:
---

REQUEST FOR RELIEF
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 Judgment: I request that the court vacate the default judgment entered against me due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the trustee's motion to sell the judgment and the fraudulent activities of my financial advisor, provides substantial grounds for relief that were not available during the initial proceedings.
*. Stay of Sale: I request that the court stay the sale of the judgment pending the resolution of this motion to vacate the judgment. The sale of the judgment to the defendants, who have engaged in fraudulent activities, would cause significant and irreparable harm.
*. Additional Relief: Any other relief that this honorable court deems just and proper in light of the serious harm caused by the fraudulent actions of my financial advisor and the defendants.
---
Would you like any further adjustments or assistance with your motion?

Also Sale of Judgments to * Fountain Street, LLC (the “buyer”) which is owned and operated by partners and finanacial advisor.

Sure! Here’s the next section, "Request for Relief":
---
REQUEST FOR RELIEF
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 Judgment: I request that the court vacate the default judgment entered against me due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the trustee's motion to sell the judgment and the fraudulent activities of my financial advisor, provides substantial grounds for relief that were not available during the initial proceedings.
*. Stay of Sale: I request that the court stay the sale of the judgment pending the resolution of this motion to vacate the judgment to prevent any further harm or injustice.
*. Further Relief: Given the serious harm caused by the fraudulent activities of my financial advisor and partners, I request any further relief that the court deems appropriate to ensure justice is served and to address the severe financial and personal damages I have suffered.
---
Would you like any additional adjustments or assistance with any other part of your motion?

*. Further Relief: Given the serious harm caused by the fraudulent activities of my financial advisor and partners, I request any further relief that the court deems appropriate to ensure justice is served and to address the severe financial and personal damages I have suffered and the bankruptcy estate and the former creditors have suffered because millions of dollars in both property value and shares of a business have been frudlently conveyed. Is this appropriate?

Yes, your request for further relief is appropriate and adds a necessary emphasis on the broader impact of the fraudulent actions. Here’s the polished version:
---
REQUEST FOR RELIEF
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 Judgment: I request that the court vacate the default judgment entered against me due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the trustee's motion to sell the judgment and the fraudulent activities of my financial advisor, provides substantial grounds for relief that were not available during the initial proceedings.
*. Stay of Sale: I request that the court stay the sale of the judgment pending the resolution of this motion to vacate the judgment to prevent any further harm or injustice.
*. Further Relief: Given the serious harm caused by the fraudulent activities of my financial advisor and partners, I request any further relief that the court deems appropriate to ensure justice is served and to address the severe financial and personal damages I have suffered, as well as the financial damages suffered by the bankruptcy estate and the former creditors due to millions of dollars inboth property value and shares of a business being fraudulently conveyed.
---
Would you like any further adjustments or assistance with any other part of your motion?

Can we now add exhibits in appropriate sections?

Certainly! Here’s how you can incorporate the exhibits into your motion:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
[Your Name],
Plaintiff,
v.
[Defendant’s Name],
Defendant.
Case No. [Your Case Number]
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape (Exhibit A).
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan,to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer (Exhibit B).
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property (Exhibit C).
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property (Exhibit D).
- I filed a lawsuit against them in Superior R.I. court, but due to financial strain, the case is still pending.
- During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the

see above

Sure! Here’s the revised version with exhibit references added to the appropriate sections:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
[Your Name],
Plaintiff,
v.
[Defendant’s Name],
Defendant.
Case No. [Your Case Number]
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape (Exhibit A).
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, JamesTiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer (Exhibit B).
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property (Exhibit C).
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property (Exhibit D).
- I filed a lawsuit against them in Superior R.I. court, but due to financial strain, the case is still pending.
- During the representation with my counsel, I hired a forensic accountant to report on the financials that the

I dont have proof of that, exhibit D. Howver as an exhibit do I include the two sections that we used in recent motion to superior court including PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY (Exhibit A):- Curriculum Vitae of Lorraine A. Horton, CPA/CFF, CFE, CICA is included to establish her qualifications and credibility as an expert witness. Deposition of Forensic Accountant: How do we include them in this bankr motion?

Sure, let’s integrate those exhibits effectively into your bankruptcy motion. Here’s the revised draft with references to the superior court exhibits and the forensic accountant’s deposition:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
[Your Name],
Plaintiff,
v.
[Defendant’s Name],
Defendant.
Case No. [Your Case Number]
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape (Exhibit A).
- Subsequently, we opened a new business together, and he advised me to givemy shares of that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer (Exhibit B).
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property (Exhibit C).
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property.
- I filed a lawsuit against them in Superior R.I. court, but due to financial strain, the case is still pending.
- During the representation with my counsel, I

Please give me from "- During the representation with my counsel, I" down.

Sure! Here’s the continuation from “- During the representation with my counsel, I” down:
---
- During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the defendants to submit to dissolve the partnership. The forensic accountant reported extensive commingling of funds, tax evasion, sham transactions, and other fraudulent practices. These findings are detailed in the forensic accountant’s report (Exhibit D) and the deposition of the forensic accountant (Exhibit E). Additionally, the forensic accountant's qualifications and credibility are established through her Curriculum Vitae (Exhibit F).
LEGAL GROUNDS
Excusable Neglect and Lack of Notice:
- Karen, my former wife, did not receive proper notice or does not recall receiving notice of the hearing, which led to the default judgment against us.
- I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage this would cause me.
- Upon learning about the default judgment against me, I immediately met with the trustee at his office. One of his staff told me that they would settle the case for $*,*, which I could not afford, being insolvent atthe time. Despite this, Mr. D'Orio met with my lawyer regarding the judgment and its impact on my case against my partners in Superior Court. During this meeting, Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife, which he is now selling for a proposed $*,* to my partners (Exhibit G).
Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”), which is owned and operated by my partners and financial advisor, to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court. The same financial

see above

Certainly! Here’s the continuation from "During the representation with my counsel, I":
---
- During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the defendants to submit to dissolve the partnership. The forensic accountant reported extensive commingling of funds, tax evasion, sham transactions, and other fraudulent practices (Exhibit D includes the forensic accountant’s report and deposition, and Exhibit E includes the Curriculum Vitae of Lorraine A. Horton, CPA/CFF, CFE, CICA to establish her qualifications and credibility as an expert witness).
LEGAL GROUNDS
Excusable Neglect and Lack of Notice:
- Karen, my former wife, did not receive proper notice or does not recall receiving notice of the hearing, which led to the default judgment against us.
- I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage this would cause me.
- Upon learning about the default judgment against me, I immediately met with the trustee at his office. One of his staff told me that they would settle the case for $*,*, which I could not afford, being insolvent at the time. Despitethis, Mr. D'Orio met with my lawyer regarding the judgment and its impact on my case against my partners in Superior Court. During this meeting, Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife, which he is now selling for a proposed $*,* to my partners.
Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”), which is owned and operated by my partners and financial advisor, to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The same financial advisor orchestrated the transfer of my

Lets clarify the " accountant’s report" is in the form of the PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY (Exhibit A): - Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively, the “Entities”) acted as the agent and alter ego of one another with disregard for their separate identities in corporate form.

Certainly! Here’s the revised draft incorporating the clarification about the forensic accountant's report and the relevant exhibits:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
[Your Name],
Plaintiff,
v.
[Defendant’s Name],
Defendant.
Case No. [Your Case Number]
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
---
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape (Exhibit A).
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the thirdpartner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer (Exhibit B).
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property (Exhibit C).
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property.
- I filed a lawsuit against them in Superior R.I. court, but due to financial strain, the case is still pending.
- During the representation with my counsel, I hired a forensic

Please send from " During the representation with my counsel, I hired a forensic" downward.

Certainly! Here’s the continuation from "During the representation with my counsel, I hired a forensic" downward:
---
During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the defendants to submit to dissolve the partnership. The forensic accountant reported extensive commingling of funds, tax evasion, sham transactions, and other fraudulent practices. This is detailed in the *PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY* (Exhibit D), where Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively, the “Entities”) acted as the agent and alter ego of one another with disregard for their separate identities in corporate form. Additionally, Exhibit E includes the Curriculum Vitae of Lorraine A. Horton, CPA/CFF, CFE, CICA to establish her qualifications and credibility as an expert witness.
LEGAL GROUNDS
Excusable Neglect and Lack of Notice:
- Karen, my former wife, did not receive proper notice or does not recall receiving notice of the hearing, which led to the default judgment against us.
- I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did nottake any further action. I did not understand the implications or the damage this would cause me.
- Upon learning about the default judgment against me, I immediately met with the trustee at his office. One of his staff told me that they would settle the case for $*,*, which I could not afford, being insolvent at the time. Despite this, Mr. D'Orio met with my lawyer regarding the judgment and its impact on my case against my partners in Superior Court. During this meeting, Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife, which he is now selling for a proposed $*,* to my partners.
Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”), which is owned and operated by my partners and financial advisor, to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
Fraud

see above

Certainly! Here’s the continuation from "During the representation with my counsel, I hired a forensic" downward:
---
During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the defendants to submit to dissolve the partnership. The forensic accountant reported extensive commingling of funds, tax evasion, sham transactions, and other fraudulent practices (Exhibit D includes the forensic accountant’s report and deposition, and Exhibit E includes the Curriculum Vitae of Lorraine A. Horton, CPA/CFF, CFE, CICA to establish her qualifications and credibility as an expert witness). The forensic accountant's findings are detailed in PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY (Exhibit F), where Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively, the “Entities”) acted as the agent and alter ego of one another with disregard for their separate identities in corporate form.
LEGAL GROUNDS
Excusable Neglect and Lack of Notice:
- Karen, my former wife, did not receive proper notice or does not recall receiving notice of the hearing, which led to the default judgment against us.
- I did receive notice and informed my advisor,but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage this would cause me.
- Upon learning about the default judgment against me, I immediately met with the trustee at his office. One of his staff told me that they would settle the case for $*,*, which I could not afford, being insolvent at the time. Despite this, Mr. D'Orio met with my lawyer regarding the judgment and its impact on my case against my partners in Superior Court. During this meeting, Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife, which he is now selling for a proposed $*,* to my partners.
Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”), which is owned and operated by my partners and financial advisor, to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my

Please provide from "This judgment originated from the bankruptcy trustee's actions against me, directly resulting from m"

Sure! Here’s the continuation:
---
This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The same financial advisor orchestrated the transfer of my business assets and shares under false pretenses, without fulfilling the promises made, thereby committing fraud upon the court.
- Additionally, during the bankruptcy case, I have documents that do not show that creditors were paid.
REQUEST FOR RELIEF:
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 Judgment: I request that the court vacate the default judgment entered against me due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the trustee's motion to sell the judgment and the fraudulent activities of my financial advisor, provides substantial grounds for relief that were not available during the initial proceedings.
*. Stay of Sale: I request that the court stay the sale of the judgment pending the resolution of this motion to vacate the judgment to prevent any further harm or injustice.
*. Further Relief: Given the serious harm caused by the fraudulent activities of my financial advisor and partners, I request any further relief that the court deems appropriate to ensure justice is served and to address the severe financial and personal damages I have suffered, as well as the financial damages suffered by the bankruptcy estate and the former creditors due to millions of dollars in both property value and shares of a business being fraudulently conveyed.
---
Would you like any additional adjustments or assistance with any other part of your motion?

Question this is the header of the motion filed by the trustee. To file this motion I should be able to go into my eFile R.I. account and see this pending case. Correct?UNITED STATES BANKRUPTCY COURT DISTRICT OF RHODE ISLAND In re: Classic Display, Inc. Case No. *:*-bk-* Debtor, Chapter *

Yes, you should be able to log into your eFileRI account and see the pending case for Classic Display, Inc. under Case No. *:*-bk-*. This case should be listed under the United States Bankruptcy Court, District of Rhode Island. If you have any issues accessing the case, you may want to contact the court's clerk for assistance.
Would you like guidance on any specific actions to take within your eFileRI account?

In addition. It is a bankr crime to make promises to a party so that they fail to act or act in accordance to the promises , so that you can take that property for your own personal gain like my adviosr and partner did in this case. Can we state this clearly and cite the law(s)?

Yes, you should be able to access your eFile account for the United States Bankruptcy Court for the District of Rhode Island to see the pending case.
Regarding the crime, it is indeed a federal crime to commit fraud in bankruptcy proceedings. Specifically, under * U.S.C. § *, it is illegal to knowingly and fraudulently make a false statement or conceal property in relation to a bankruptcy case.
Here's how you can incorporate this information into your motion:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financialadvisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape (Exhibit A).
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer (Exhibit B).
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property (Exhibit C).
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self

Please just send me that specific section where you updated the law.

Certainly! Here’s the specific section incorporating the law regarding bankruptcy fraud:
---
Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The same financial advisor orchestrated the transfer of my business assets and shares under false pretenses, without fulfilling the promises made, thereby committing fraud upon the court.
- Under * U.S.C. § *, it is illegal to knowingly and fraudulently make a false statement or conceal property in relation to a bankruptcy case. My advisor's actions constitute a violation of this law, as he made fraudulent promises to manipulate my actions for his personal gain.
- Additionally, during the bankruptcy case, I have documents that do not show that creditors were paid.
---
Would you like any more adjustments or assistance with any additional part of your motion?

* questions about this section:- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property. - I filed a lawsuit against them in Superior R.I. court, but due to financial strain, the case is still pending. *. My case is legally pending thaough it has been dismissed? Could we add on to this sentence..." stripping me of my business and property and then illegally forclosed on my children's and former's wife's home in Massachusetts using a usury at a *% interest rate. This action is pending in tow court cases one in Superior Court Massachusetss against the financial advisor and one in Federal Rhode Island Court gainst the private lender , who is my partner in this bankruptcy case buying the judgement.

Sure! Here’s the revised section with the additional details you provided:
---
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property, and then illegally foreclosed on my children's and former wife's home in Massachusetts using a usury at a *% interest rate. This action is pending in two court cases: one in Superior Court Massachusetts against the financial advisor and one in Federal Rhode Island Court against the private lender, who is my partner in this bankruptcy case buying the judgment (Exhibit G includes details of these court cases).
- I filed a lawsuit against them in Superior R.I. court, but due to financial strain, the case is still pending.
---
*. If your case has been dismissed, it is not considered legally pending. You would need to seek to re-open or appeal the dismissal to make it active again.
Would you like any further adjustments or assistance with your motion?

see above

Certainly! Here’s the revised section incorporating the updates:
---
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape (Exhibit A).
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer (Exhibit B).
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property (Exhibit C).
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it wasdue to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property, and then illegally foreclosed on my children's and former wife's home in Massachusetts using a usury rate of *% interest. This action is pending in two court cases: one in Superior Court, Massachusetts, against the financial advisor, and one in Federal Court, Rhode Island, against the private lender, who is my partner in this bankruptcy case buying the judgment.
- I filed a lawsuit against them in Superior R.I. court, but due to financial strain, the case is still pending.
---
Would you like any further adjustments or assistance with any other part of your motion?

Is this transition right, "... I filed a lawsuit against them in Superior R.I. court, but due to financial strain, the case is still pending. During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the defendants to submit to dissolve the partnership...."

Yes, that transition is clear and effectively conveys the progression of events. Here's a polished version for clarity:
---
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape (Exhibit A).
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer (Exhibit B).
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property (Exhibit C).
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property, and then illegally foreclosed on my children's and former wife's home in Massachusetts using a usury rate of *% interest. This action is pending in two court cases: one in Superior Court, Massachusetts, against the financial advisor, and one in Federal Court, Rhode Island, against the private lender, who is my partner in this bankruptcy case buying the judgment.
- I filed a lawsuit against them in Superior R.I. court, but due to financial strain, the case is still pending.
- During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the defendants to submit to dissolve the partnership. The forensic accountant reported extensive commingling of funds, tax evasion, sham transactions, and other fraudulent practices (Exhibit D includes the forensic accountant’s report and deposition, and Exhibit E includes the Curriculum Vitae of Lorraine A. Horton, CPA/CFF, CFE, CICA to establish her qualifications and credibility as an expert witness).

Do I add this as an exhibit and where please, MOTION FOR APPROVAL OF SALE OF JUDGEMENTS PURSUANT TO * U.S.C. §* AND NOTICE OF INTENT TO SELL JUDGEMENTS BY PRIVATE SALE AND INVITATION FOR COMPETING BIDS

Yes, you should add the "MOTION FOR APPROVAL OF SALE OF JUDGMENTS PURSUANT TO * U.S.C. §* AND NOTICE OF INTENT TO SELL JUDGMENTS BY PRIVATE SALE AND INVITATION FOR COMPETING BIDS" as an exhibit. This document is crucial as it directly pertains to the sale of the judgment and supports your argument of newly discovered evidence.
Here’s how you can include it in your motion:
```markdown
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me andpurchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape (Exhibit A).
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer (Exhibit B).
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property (Exhibit C).
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to

see above

Yes, you should add the "MOTION FOR APPROVAL OF SALE OF JUDGMENTS PURSUANT TO * U.S.C. §* AND NOTICE OF INTENT TO SELL JUDGMENTS BY PRIVATE SALE AND INVITATION FOR COMPETING BIDS" as an exhibit. It will support your argument regarding the newly discovered evidence. Here’s how to integrate it:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets throughthe bankruptcy court, buying the equipment and invoices, which I have on tape (Exhibit A).
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer (Exhibit B).
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property (Exhibit C).
- I followed my advisor's instructions, and the transfer was completed. However, they then refused to put my name back on the building, claiming it was due to the trustee filing a lawsuit against me, which he was in charge of.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of

Next section please from They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of

Certainly! Here’s the continuation from "They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of":
---
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property, and then illegally foreclosed on my children's and former wife's home in Massachusetts using a usury rate of *% interest. This action is pending in two court cases: one in Superior Court, Massachusetts, against the financial advisor, and one in Federal Court, Rhode Island, against the private lender, who is my partner in this bankruptcy case buying the judgment (Exhibit D).
- I filed a lawsuit against them in Superior R.I. court, but due to financial strain, the case is still pending.
- During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the defendants to submit to dissolve the partnership. The forensic accountant reported extensive commingling of funds, tax evasion, sham transactions, and other fraudulent practices (Exhibit E includes the forensic accountant’s report and deposition, and Exhibit F includes the Curriculum Vitae of Lorraine A. Horton, CPA/CFF, CFE, CICA to establish her qualifications and credibility as an expert witness).LEGAL GROUNDS
Excusable Neglect and Lack of Notice:
- Karen, my former wife, did not receive proper notice or does not recall receiving notice of the hearing, which led to the default judgment against us.
- I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage this would cause me.
- Upon learning about the default judgment against me, I immediately met with the trustee at his office. One of his staff told me that they would settle the case for $*,*, which I could not afford, being insolvent at the time. Despite this, Mr. D'Orio met with my lawyer regarding the judgment and its impact on my case against my partners in Superior Court. During this meeting, Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife, which he is now selling for a proposed $*,* to my partners (Exhibit G).
Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street,

From - Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, please closed with a verified motion with /s/ signing.

Sure, here’s the continuation with the verified motion and /s/ signing:
---
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”), which is owned and operated by my partners and financial advisor, to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court (Exhibit H).
Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The same financial advisor orchestrated the transfer of my business assets and shares under false pretenses, without fulfilling the promises made, thereby committing fraud upon the court.
- Under * U.S.C. § *, it is illegal to knowingly and fraudulently make a false statement or conceal property in relation to a bankruptcy case. My advisor's actions constitutea violation of this law, as he made fraudulent promises to manipulate my actions for his personal gain.
- Additionally, during the bankruptcy case, I have documents that do not show that creditors were paid.
REQUEST FOR RELIEF:
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 Judgment: I request that the court vacate the default judgment entered against me due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the trustee's motion to sell the judgment and the fraudulent activities of my financial advisor, provides substantial grounds for relief that were not available during the initial proceedings.
*. Stay of Sale: I request that the court stay the sale of the judgment pending the resolution of this motion to vacate the judgment to prevent any further harm or injustice.
*. Further Relief: Given the serious harm caused by the fraudulent activities of my financial advisor and partners, I request any further relief that the court deems appropriate to ensure justice is served and to address the severe financial and personal damages I have suffered, as well as the financial damages suffered by the bankruptcy estate and the former creditors due to millions of dollars in both property value

see above

Certainly! Here’s the continuation and closure with a verified motion and /s/ signing:
---
Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”), which is owned and operated by my partners and financial advisor, to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court (Exhibit H).
Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The same financial advisor orchestrated the transfer of my business assets and shares under false pretenses, without fulfilling the promises made, thereby committing fraud upon the court.
- Under * U.S.C. § *, it is illegal to knowingly and fraudulently make a false statement or conceal property in relation to a bankruptcy case. My advisor's actionsconstitute a violation of this law, as he made fraudulent promises to manipulate my actions for his personal gain.
- Additionally, during the bankruptcy case, I have documents that do not show that creditors were paid.
REQUEST FOR RELIEF:
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 Judgment: I request that the court vacate the default judgment entered against me due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the trustee's motion to sell the judgment and the fraudulent activities of my financial advisor, provides substantial grounds for relief that were not available during the initial proceedings.
*. Stay of Sale: I request that the court stay the sale of the judgment pending the resolution of this motion to vacate the judgment to prevent any further harm or injustice.
*. Further Relief: Given the serious harm caused by the fraudulent activities of my financial advisor and partners, I request any further relief that the court deems appropriate to ensure justice is served and to address the severe financial and personal damages I have suffered, as well as the financial damages suffered by the bankruptcy estate and the former creditors due to millions of dollars in both

From "personal damages I have suffered, as well as the financial damages suffered by the bankruptcy estate and the former creditors due to millions of dollars in both" down.

Sure, here’s the continuation and closure with a verified motion and /s/ signing:
---
personal damages I have suffered, as well as the financial damages suffered by the bankruptcy estate and the former creditors due to millions of dollars in both property value and shares of a business being fraudulently conveyed.
---
Respectfully submitted,
/s/ [Your Full Name]
[Your Full Name]
[Your Contact Information]
---
Would you like any further adjustments or assistance with any other part of your motion?

What is Exhibit D and G?

Exhibit D and Exhibit G were referenced in your motion as follows:
- Exhibit D: This is mentioned in the context of the forensic accountant's findings. It includes the forensic accountant’s report and deposition, highlighting extensive commingling of funds, tax evasion, sham transactions, and other fraudulent practices.
- Exhibit G: This is mentioned in the context of the lien placed by Mr. D'Orio. It includes documentation showing that Mr. D'Orio placed a lien on the Superior Court case for $*,* against you and $*,* against your former wife, which he is now selling for a proposed $*,* to your partners.
Would you like any further clarification or assistance with these exhibits or any other part of your motion?

see above

Let's clarify the exhibits in your motion:
- Exhibit A: Tape recording of the purchase of business assets.
- Exhibit B: Documentation of the promise to return your name to the stock power documents.
- Exhibit C: Evidence of the assurances given to you regarding the Chapter * liquidation and title transfer.
- Exhibit D: Documentation of the illegal foreclosure on your children's and former wife's home in Massachusetts.
- Exhibit E: Forensic accountant's report and deposition.
- Exhibit F: Curriculum Vitae of Lorraine A. Horton, CPA/CFF, CFE, CICA.
- Exhibit G: Documentation of the lien placed on the Superior Court case by Mr. D'Orio.
- Exhibit H: Motion for Approval of Sale of Judgments by the Trustee.
Here is the polished final version of your motion:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENTPURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, buying the equipment and invoices, which I have on tape (Exhibit A).
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer (Exhibit B).
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to

Lets clarify Exhibit A I have the tape (but Im unclear how to send it but I have the promissory note and the slae of the business from me to Ralph Grieco. I will get the offical title of te documents. Exhibit C - I have the deed transfering the commercial property from bankr court to my advisor and James Tiernan . I do not have the written promise. Hoever they both were my partners and owed me a duty of loyalty, honesty and free from a conflict of interest. It was not in my best interest to move from chapter * to chapter *. I would have stayed in chapter * and take other actions. of course who gives up a valuable assets and gets nothing in rreturn. Noone.

Got it. Here is the updated version with the clarified exhibits:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, including a promissory note and the sale of the business from me to Ralph Grieco (Exhibit A).
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan, to givehim a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the transfer.
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property. I have the deed transferring the commercial property from the bankruptcy court to my advisor and James Tiernan (Exhibit C).
- It was not in my best interest to move from Chapter * to Chapter *. I would have stayed in Chapter * and taken other actions. Of course, who gives up valuable assets and gets nothing in return? No one.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property, and then illegally foreclosed on my children's and former wife's home in Massachusetts using a usury rate of *% interest. This action is pending in two court cases: one in Superior Court,

He did not, and I never received any money for the share transfer. I have the share transfer document . Do we add this as an exhibit?

Yes, you should add the share transfer document as an exhibit. This document will provide further evidence supporting your claims. Let's include it as Exhibit B.
Here’s the revised version of your motion with the updated exhibits:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, including a promissory note and the sale of the business from me to Ralph Grieco (Exhibit A).
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the share transfer. I have the share transfer document (Exhibit B).
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property. I have the deed transferring the commercial property from the bankruptcy court to my advisor and James Tiernan (Exhibit C).
- It was not in my best interest to move from Chapter * to Chapter *. I would have stayed in Chapter * and taken other actions. Of course, who gives up valuable assets and gets nothing in return? No one.
- They subsequently executed an illegal self-help eviction by changing the locks to

see above

Yes, including the share transfer document as an exhibit is a good idea. Here’s the updated version with the share transfer document incorporated:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
---
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, including a promissory note and the sale of the business from me to Ralph Grieco (Exhibit A).
- Subsequently, we opened a new business together, and he advised me to give my sharesof that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the share transfer. I have the share transfer document (Exhibit B).
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property. I have the deed transferring the commercial property from the bankruptcy court to my advisor and James Tiernan (Exhibit C).
- It was not in my best interest to move from Chapter * to Chapter *. I would have stayed in Chapter * and taken other actions. Of course, who gives up valuable assets and gets nothing in return? No one.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property, and then illegally foreclosed

UPDATE we might not need exhibits. Please read this from the motion to sell the judgement. Please note that this ommitts the frudulent actions taken against me to procure these actions against me my former wife. Today howver I have three court cases trying to correct the wrong . I suffer in the process considerably. Here follows excerpts from the judgement motion:

It appears your situation involves significant fraudulent actions and misconduct by your financial advisor and partners. Here’s a revised version of your motion without the need for additional exhibits:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
---
BACKGROUND
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, including a promissory note and the sale of the business from me to Ralph Grieco.
- Subsequently, we opened a new business together, and he advised me to give my shares of that businessto the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the share transfer.
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property. I have the deed transferring the commercial property from the bankruptcy court to my advisor and James Tiernan.
- It was not in my best interest to move from Chapter * to Chapter *. I would have stayed in Chapter * and taken other actions. Of course, who gives up valuable assets and gets nothing in return? No one.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property, and then illegally foreclosed on my children's and former wife's home in Massachusetts using a usury rate of *% interest. This

*. On February *, *, Classic Display, Inc. (the “Debtor”) filed a voluntary petition for relief under Chapter * of the Bankruptcy Code (the “Code”). On July *, *, Joseph M. DiOrio was appointed Chapter * trustee. *. By Order dated September *, *, the Trustee sold the assets of the Debtor pursuant to § * of the Code to Ralph Grieco, James Michael Cronan, and James Tiernan or their nominee [Doc. *]. Case *:*-bk-* Doc * Filed */*/* Entered */*/* *:*:* Desc Main Document Page * of * *

Got it. Here’s how you can incorporate the key points from the judgment motion into your motion to vacate the judgment without needing additional exhibits:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
*. On February *, *, Classic Display, Inc. (the “Debtor”) filed a voluntary petition for relief under Chapter * of the Bankruptcy Code (the “Code”). On July *, *, Joseph M. DiOrio was appointed Chapter * trustee.
*. By Order dated September *, *. By Order dated September *, *, the Trustee sold the assets of the Debtor pursuant to § * of the Code to Ralph Grieco, James Michael Cronan, and James Tiernan or their nominee [Doc. *].
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, including a promissory note and the sale of the business from me to Ralph Grieco.
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the share transfer.
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title

*. On November *, *, the Case was converted to Chapter * and DiOrio was appointed Chapter * trustee. *. On May *, *, the Trustee filed adversary proceedings against the Debtor’s principal, James Cronan (“J. Cronan”), and Cronan’s ex-wife, Karen Cronan (“K. Cronan”), seeking to recover funds the Debtor fraudulently transferred to them. *. On November *, *, the Trustee obtained the Judgement.

Certainly! Here’s how you can integrate these excerpts into your motion to provide a thorough background, without needing additional exhibits:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
---
BACKGROUND
*. On February *, *, Classic Display, Inc. (the “Debtor”) filed a voluntary petition for relief under Chapter * of the Bankruptcy Code (the “Code”). On July *, *, Joseph M. DiOrio was appointed Chapter * trustee.
*. By Order dated September *, *, the Trustee sold the assets of the Debtorpursuant to § * of the Code to Ralph Grieco, James Michael Cronan, and James Tiernan or their nominee.
*. On November *, *, the Case was converted to Chapter * and DiOrio was appointed Chapter * trustee.
*. On May *, *, the Trustee filed adversary proceedings against the Debtor’s principal, James Cronan (“J. Cronan”), and Cronan’s ex-wife, Karen Cronan (“K. Cronan”), seeking to recover funds the Debtor fraudulently transferred to them.
*. On November *, *, the Trustee obtained the Judgment.
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, including a promissory note and the sale of the business from me to Ralph Grieco.
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any

From here Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any

money for the share transfer.
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property. I have the deed transferring the commercial property from the bankruptcy court to my advisor and James Tiernan.
- It was not in my best interest to move from Chapter * to Chapter *. I would have stayed in Chapter * and taken other actions. Of course, who gives up valuable assets and gets nothing in return? No one.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property, and then illegally foreclosed on my children's and former wife's home in Massachusetts using a usury rate of *% interest. This action is pending in two court cases: one in Superior Court, Massachusetts, against the financial advisor, and one in Federal Court, Rhode Island, against the private lender, who is my partner in this bankruptcy case buying thejudgment.
- I filed a lawsuit against them in Superior R.I. court, but due to financial strain, the case is still pending.
- During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the defendants to submit to dissolve the partnership. The forensic accountant reported extensive commingling of funds, tax evasion, sham transactions, and other fraudulent practices. The forensic accountant's findings are detailed in PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY, where Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively, the “Entities”) acted as the agent and alter ego of one another with disregard for their separate identities in corporate form.
---
LEGAL GROUNDS
Excusable Neglect and Lack of Notice:
- Karen, my former wife, did not receive proper notice or does not recall receiving notice of the hearing, which led to the default judgment against us.
- I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage

From here - I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage

Certainly! Here’s the continuation from "I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage":
---
I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage this would cause me. Upon learning about the default judgment against me, I immediately met with the trustee at his office. One of his staff told me that they would settle the case for $*,*, which I could not afford, being insolvent at the time. Despite this, Mr. D'Orio met with my lawyer regarding the judgment and its impact on my case against my partners in Superior Court. During this meeting, Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife, which he is now selling for a proposed $*,* to my partners.
Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”), which is owned and operated by my partners and financial advisor, to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The same financial advisor orchestrated the transfer of my business assets and shares under false pretenses, without fulfilling the promises made, thereby committing fraud upon the court.
- Under * U.S.C. § *, it is illegal to knowingly and fraudulently make a false statement or conceal property in relation to a bankruptcy case. My advisor's actions constitute a violation of this law, as he made fraudulent promises to manipulate my actions for his personal gain.
- Additionally, during the bankruptcy case, I have documents that do not show that creditors were paid.
REQUEST FOR RELIEF:
Given the substantial evidence of fraud, bad faith, and procedural violations

see above

Sure! Here’s the continuation from "I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage":
---
I did not understand the implications or the damage this would cause me. Upon learning about the default judgment against me, I immediately met with the trustee at his office. One of his staff told me that they would settle the case for $*,*, which I could not afford, being insolvent at the time. Despite this, Mr. D'Orio met with my lawyer regarding the judgment and its impact on my case against my partners in Superior Court. During this meeting, Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife, which he is now selling for a proposed $*,* to my partners.
Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”), which is owned and operated by my partners and financial advisor, to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The same financial advisor orchestrated the transfer of my business assets and shares under false pretenses, without fulfilling the promises made, thereby committing fraud upon the court.
- Under * U.S.C. § *, it is illegal to knowingly and fraudulently make a false statement or conceal property in relation to a bankruptcy case. My advisor's actions constitute a violation of this law, as he made fraudulent promises to manipulate my actions for his personal gain.
- Additionally, during the bankruptcy case, I have documents that do not show that creditors were paid.
---
REQUEST FOR RELIEF:
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 Judgment: I request

from *. Motion to Vacate Judgment: I request and what if any exhibits do I need?

Sure, here's the final version of your motion with the request for relief and without the need for additional exhibits:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
---
BACKGROUND
*. On February *, *, Classic Display, Inc. (the “Debtor”) filed a voluntary petition for relief under Chapter * of the Bankruptcy Code (the “Code”). On July *, *, Joseph M. DiOrio was appointed Chapter * trustee.
*. By Order dated September *, *, the Trustee sold the assets of the Debtor pursuant to § * of the Code to Ralph Grieco, James Michael Cronan, and James Tiernan or their nominee.
*. On November *, *, the Case was converted to Chapter * and DiOrio was appointed Chapter * trustee.
*. On May *, *, the Trustee filed adversary proceedings against the Debtor’s principal, James Cronan (“J. Cronan”), and Cronan’s ex-wife, Karen Cronan (“K. Cronan”), seeking to recover funds the Debtor fraudulently transferred to them.
*. On November *, *, the Trustee obtained the Judgment.
*. At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, including a promissory note and the sale of the business from me to Ralph Grieco.
*. Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the

Please provide from *. down

Sure! Here’s the continuation from "*. Motion to Vacate Judgment: I request" and a note on the exhibits:
---
LEGAL GROUNDS
Excusable Neglect and Lack of Notice:
- Karen, my former wife, did not receive proper notice or does not recall receiving notice of the hearing, which led to the default judgment against us.
- I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage this would cause me. Upon learning about the default judgment against me, I immediately met with the trustee at his office. One of his staff told me that they would settle the case for $*,*, which I could not afford, being insolvent at the time. Despite this, Mr. D'Orio met with my lawyer regarding the judgment and its impact on my case against my partners in Superior Court. During this meeting, Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife, which he is now selling for a proposed $*,* to my partners.
Newly Discovered Evidence:
- Recently, Mr. DiOrio,Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”), which is owned and operated by my partners and financial advisor, to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The same financial advisor orchestrated the transfer of my business assets and shares under false pretenses, without fulfilling the promises made, thereby committing fraud upon the court.
- Under * U.S.C. § *, it is illegal to knowingly and fraudulently make a false statement or conceal property in relation to a bankruptcy case. My advisor's actions constitute a violation of this law, as he made fraudulent promises to manipulate my actions for his personal gain.
- Additionally, during the bankruptcy case, I

Does this case need to be opened again or is it automatically opened and pending becuae of the trustees motion?

Certainly! Here’s the continuation from "*. Motion to Vacate Judgment: I request" and addressing the exhibits:
---
*. Motion to Vacate Judgment: I request that the court vacate the default judgment entered against me due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the trustee's motion to sell the judgment and the fraudulent activities of my financial advisor, provides substantial grounds for relief that were not available during the initial proceedings.
*. Stay of Sale: I request that the court stay the sale of the judgment pending the resolution of this motion to vacate the judgment to prevent any further harm or injustice.
*. Further Relief: Given the serious harm caused by the fraudulent activities of my financial advisor and partners, I request any further relief that the court deems appropriate to ensure justice is served and to address the severe financial and personal damages I have suffered, as well as the financial damages suffered by the bankruptcy estate and the former creditors due to millions of dollars in both property value and shares of a business being fraudulently conveyed.
---
Respectfully submitted,
/s/ [Your Full Name]
[Your Full Name]
[Your Contact Information]
---

Exhibits:
- Exhibit A: PromissCertainly! Here’s the continuation from "*. Motion to Vacate Judgment: I request" and addressing the exhibits:
---
*. Motion to Vacate Judgment: I request that the court vacate the default judgment entered against me due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the trustee's motion to sell the judgment and the fraudulent activities of my financial advisor, provides substantial grounds for relief that were not available during the initial proceedings.
*. Stay of Sale: I request that the court stay the sale of the judgment pending the resolution of this motion to vacate the judgment to prevent any further harm or injustice.
*. Further Relief: Given the serious harm caused by the fraudulent activities of my financial advisor and partners, I request any further relief that the court deems appropriate to ensure justice is served and to address the severe financial and personal damages I have suffered, as well as the financial damages suffered by the bankruptcy estate and the former creditors due to millions of dollars in both property value and shares of a business being fraudulently conveyed.
---
Respectfully submitted,
/s/ [Your Full Name]
[Your Full Name]
[Your Contact Information]
---

Exhibits:
- Exhibit A: Promiss

Please provide me with the exhibits without the outline.

Sure, here are the exhibits without the outline:
Exhibit A: Promissory note and the sale of the business from me to Ralph Grieco.
Exhibit B: Share transfer document.
Exhibit C: Deed transferring the commercial property from the bankruptcy court to my advisor and James Tiernan.
Exhibit D: Documentation of the illegal foreclosure on my children's and former wife's home in Massachusetts using a usury rate of *% interest.
Exhibit E: Forensic accountant’s report and deposition.
Exhibit F: Curriculum Vitae of Lorraine A. Horton, CPA/CFF, CFE, CICA.
Exhibit G: Documentation of the lien placed on the Superior Court case by Mr. D'Orio.
Exhibit H: Motion for Approval of Sale of Judgments by the Trustee.

How do I get the copy of the lien? My attorney said that the trustee filed it. It should be in the docket of the case right?

Yes, you should be able to obtain a copy of the lien from the docket of the case. The lien would typically be filed as part of the bankruptcy court proceedings. You can access the docket through the PACER (Public Access to Court Electronic Records) system, which is the electronic public access service for federal court documents.
To get a copy of the lien:
*. Log in to your PACER account.
*. Search for your case using the case number or party names.
*. Look for the docket entry related to the lien filed by the trustee.
*. You can download a copy of the document directly from PACER.
Would you like more information on accessing PACER or need help with any other part of your case?

see above

Yes, the lien should be part of the case docket. You can obtain a copy by accessing your eFile account for the United States Bankruptcy Court for the District of Rhode Island and searching the case docket for any filings related to the lien placed by the trustee. If you have trouble finding it, you can request assistance from the court clerk's office.
Here’s the updated version of your motion with the exhibits listed:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
*. On February *, *, Classic Display, Inc. (the “Debtor”) filed a voluntary petition for relief under Chapter * of the Bankruptcy Code (the “Code”). On July *, *, Joseph M. DiOrio was appointed Chapter * trustee.
*. By Order dated September *, *, the Trustee sold the assets of the Debtor pursuant to § * of the Code to Ralph Grieco, James Michael Cronan, and James Tiernan or their nominee.
*. On November *, *, the Case was converted to Chapter * and DiOrio was appointed Chapter * trustee.
*. On May *, *, the Trustee filed adversary proceedings against the Debtor’s principal, James Cronan (“J. Cronan”), and Cronan’s ex-wife, Karen Cronan (“K. Cronan”), seeking to recover funds the Debtor fraudulently transferred to them.
*. On November *, *, the Trustee obtained the Judgment.
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, including a promissory note and the sale of the business from me to Ralph Grieco.
- Subsequently, we

Im confused. My efile wont have the docketing .right?

Your eFile account may not have direct access to all docketing information, but you can typically view recent filings and case updates related to your specific case. To obtain the lien document, you can:
*. Access PACER: Use the Public Access to Court Electronic Records (PACER) service to view the full docket and download copies of filings. PACER provides access to federal court documents, including bankruptcy cases.
*. Court Clerk's Office: Contact the Clerk's Office of the United States Bankruptcy Court for the District of Rhode Island. They can provide assistance in locating and obtaining a copy of the lien document filed by the trustee.
*. Request from Your Attorney: If your attorney mentioned that the trustee filed the lien, they might have a copy or can assist you in obtaining it.
Here’s the revised version of your motion with the exhibits listed:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
*. On February *, *, Classic Display, Inc. (the “Debtor”) filed a voluntary petition for relief under Chapter * of the Bankruptcy Code (the “Code”). On July *, *, Joseph M. DiOrio was appointed Chapter * trustee.
*. By Order dated September *, *, the Trustee sold the assets of the Debtor pursuant to § * of the Code to Ralph Grieco, James Michael Cronan, and James Tiernan or their nominee.
*. On November *, *, the Case was converted to Chapter * and DiOrio was appointed Chapter * trustee.
*. On May *, *, the Trustee filed adversary proceedings against the Debtor’s principal, James Cronan (“J. Cronan”), and Cronan’s ex-wife, Karen Cronan

Ok but this will delay filing this motion as I have all the other exhibits except the lien. What do you think ?

Filing your motion with the exhibits you currently have would still present a strong case. You can mention the lien in your motion and indicate that you are in the process of obtaining it. This way, the court is aware of its existence and significance, even if you don't have the document immediately at hand.
Here’s a suggestion on how to incorporate this into your motion:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
*. On February *, *, Classic Display, Inc. (the “Debtor”) filed a voluntary petition for relief under Chapter11 of the Bankruptcy Code (the “Code”). On July *, *, Joseph M. DiOrio was appointed Chapter * trustee.
*. By Order dated September *, *, the Trustee sold the assets of the Debtor pursuant to § * of the Code to Ralph Grieco, James Michael Cronan, and James Tiernan or their nominee.
*. On November *, *, the Case was converted to Chapter * and DiOrio was appointed Chapter * trustee.
*. On May *, *, the Trustee filed adversary proceedings against the Debtor’s principal, James Cronan (“J. Cronan”), and Cronan’s ex-wife, Karen Cronan (“K. Cronan”), seeking to recover funds the Debtor fraudulently transferred to them.
*. On November *, *, the Trustee obtained the Judgment.
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, including a promissory note and the sale of the business from me to Ralph Grieco.
- Subsequently, we opened a new business together, and he advised me to give

see above

If obtaining the lien document will significantly delay filing your motion, consider filing the motion without it and indicating that the document will be provided once obtained. You can mention the lien in your motion and state that supporting documentation will be filed as a supplement. This way, you can proceed without unnecessary delay.
Here’s the revised motion with a note about the lien:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
*. On February *, *, Classic Display, Inc. (the “Debtor”) filed a voluntary petition for relief under Chapter * of the Bankruptcy Code (the “Code”). On July *, *, Joseph M. DiOrio was appointed Chapter * trustee.
*. By Order dated September *, *, the Trustee sold the assets of the Debtor pursuant to § * of the Code to Ralph Grieco, James Michael Cronan, and James Tiernan or their nominee.
*. On November *, *, the Case was converted to Chapter * and DiOrio was appointed Chapter * trustee.
*. On May *, *, the Trustee filed adversary proceedings against the Debtor’s principal, James Cronan (“J. Cronan”), and Cronan’s ex-wife, Karen Cronan (“K. Cronan”), seeking to recover funds the Debtor fraudulently transferred to them.
*. On November *, *, the Trustee obtained the Judgment.
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, including a promissory note and the sale of the business from me to Ralph Grieco.
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in

From subsequently down

Certainly! Here’s the continuation from "Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in":
---
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the share transfer. I have the share transfer document (Exhibit B).
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building that was in my name as the title owner and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property. I have the deed transferring the commercial property from the bankruptcy court to my advisor and James Tiernan (Exhibit C).
- It was not in my best interest to move from Chapter * to Chapter *. I would have stayed in Chapter 13and taken other actions. Of course, who gives up valuable assets and gets nothing in return? No one.
- They subsequently executed an illegal self-help eviction by changing the locks to the building, stripping me of my business and property, and then illegally foreclosed on my children's and former wife's home in Massachusetts using a usury rate of *% interest. This action is pending in two court cases: one in Superior Court, Massachusetts, against the financial advisor, and one in Federal Court, Rhode Island, against the private lender, who is my partner in this bankruptcy case buying the judgment (Exhibit D).
- I filed a lawsuit against them in Superior R.I. court, but due to financial strain, the case is still pending.
- During the representation with my counsel, I hired a forensic accountant to report on the financials that the court required the defendants to submit to dissolve the partnership. The forensic accountant reported extensive commingling of funds, tax evasion, sham transactions, and other fraudulent practices. The forensic accountant's findings are detailed in PLAINTIFF’S ANSWER TO DEFENDANTS’ EXPERT INTERROGATORY, where Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively,

INTERROGATORY, where Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively,

the “Entities”) acted as the agent and alter ego of one another with disregard for their separate identities in corporate form (Exhibit E).
LEGAL GROUNDS
Excusable Neglect and Lack of Notice:
- Karen, my former wife, did not receive proper notice or does not recall receiving notice of the hearing, which led to the default judgment against us.
- I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage this would cause me.
- Upon learning about the default judgment against me, I immediately met with the trustee at his office. One of his staff told me that they would settle the case for $*,*, which I could not afford, being insolvent at the time. Despite this, Mr. D'Orio met with my lawyer regarding the judgment and its impact on my case against my partners in Superior Court. During this meeting, Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife, which he is now selling for a proposed $*,* to my partners (Exhibit G).
Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”), which is owned and operated by my partners and financial advisor, to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court (Exhibit H).
Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The same financial advisor orchestrated the transfer of my business assets and shares under false pretenses, without fulfilling the promises made, thereby committing fraud upon the court.
- Under * U.S.C. § *, it is illegal to knowingly and fraudulently make a false statement or conceal property in relation to a bankruptcy case. My advisor's actions constitute a violation of this law, as he made fraudulent promises to manipulate my actions for his personal gain.
-

from that down.

Certainly! Here’s the continuation from "INTERROGATORY, where Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively,":
---
INTERROGATORY, where Ms. Horton is expected to testify that The Classic Group, Inc. and * Fountain Street, LLC (collectively, the “Entities”) acted as the agent and alter ego of one another with disregard for their separate identities in corporate form.
LEGAL GROUNDS
Excusable Neglect and Lack of Notice:
- Karen, my former wife, did not receive proper notice or does not recall receiving notice of the hearing, which led to the default judgment against us.
- I did receive notice and informed my advisor, but he assured me that the trustee was wrong and did not take any further action. I did not understand the implications or the damage this would cause me.
- Upon learning about the default judgment against me, I immediately met with the trustee at his office. One of his staff told me that they would settle the case for $*,*, which I could not afford, being insolvent at the time. Despite this, Mr. D'Orio met with my lawyer regarding the judgment and its impact on my caseagainst my partners in Superior Court. During this meeting, Mr. D'Orio placed a lien on the Superior Court case for $*,* against me and $*,* against my former wife, which he is now selling for a proposed $*,* to my partners.
Newly Discovered Evidence:
- Recently, Mr. DiOrio, Trustee for the bankruptcy court, has filed a Motion for Approval of Sale of Judgments to * Fountain Street, LLC (the “buyer”), which is owned and operated by my partners and financial advisor, to purchase a $*,* judgment for $*,*, raising serious concerns about ongoing fraud and bad faith. This judgment originated from the bankruptcy trustee's actions against me, directly resulting from my financial advisor's accounting representation in the bankruptcy court.
Fraud Upon the Court:
- My financial advisor, who also served as President, Shareholder, Partner, and CPA of the companies, represented me in the bankruptcy court.
- While wearing these many hats, he made promises to me that he did not keep, subsequently filing fraudulent documents in the bankruptcy court.
- The same financial advisor orchestrated the transfer of my business assets and shares under false pretenses, without fulfilling the promises made, thereby

From - The same financial advisor orchestrated the transfer of my business assets and shares under false pretenses, without fulfilling the promises made, thereby

committing fraud upon the court.
- Under * U.S.C. § *, it is illegal to knowingly and fraudulently make a false statement or conceal property in relation to a bankruptcy case. My advisor's actions constitute a violation of this law, as he made fraudulent promises to manipulate my actions for his personal gain.
- Additionally, during the bankruptcy case, I have documents that do not show that creditors were paid.
REQUEST FOR RELIEF:
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 Judgment: I request that the court vacate the default judgment entered against me due to excusable neglect, lack of notice, and newly discovered evidence. The newly discovered evidence, including the trustee's motion to sell the judgment and the fraudulent activities of my financial advisor, provides substantial grounds for relief that were not available during the initial proceedings.
*. Stay of Sale: I request that the court stay the sale of the judgment pending the resolution of this motion to vacate the judgment to prevent any further harm or injustice.
*. Further Relief: Given the serious harm caused by the fraudulent activities of myfinancial advisor and partners, I request any further relief that the court deems appropriate to ensure justice is served and to address the severe financial and personal damages I have suffered, as well as the financial damages suffered by the bankruptcy estate and the former creditors due to millions of dollars in both property value and shares of a business being fraudulently conveyed.
Respectfully submitted,
/s/ [Your Full Name]
[Your Full Name]
[Your Contact Information]
---
Exhibits:
- Exhibit A: Promissory note and the sale of the business from me to Ralph Grieco.
- Exhibit B: Share transfer document.
- Exhibit C: Deed transferring the commercial property from the bankruptcy court to my advisor and James Tiernan.
- Exhibit D: Documentation of the illegal foreclosure on my children's and former wife's home in Massachusetts using a usury rate of *% interest.
- Exhibit E: Forensic accountant’s report and deposition.
- Exhibit F: Curriculum Vitae of Lorraine A. Horton, CPA/CFF, CFE, CICA.
- Exhibit G: Documentation of the lien placed on the Superior Court case by Mr. D'Orio (to be provided).
- Exhibit H: Motion for Approval of Sale

I have an efile rhode account can I file on a bankr case in it? Or is bankr cases just on pacer?

You can generally use your eFile Rhode account to file documents in Rhode Island state courts. However, for federal bankruptcy cases, such as the one you're dealing with, you will need to use the CM/ECF (Case Management/Electronic Case Files) system through PACER (Public Access to Court Electronic Records). Here's what you can do:
*. Check eFile Rhode: Verify if it supports federal bankruptcy filings, as some state systems may have integrated access to federal systems.
*. Register with PACER: If you don't have access, you'll need to register for a PACER account to file documents in federal bankruptcy court.
Would you like detailed steps on how to register for PACER and file your motion?

see above

Bankruptcy cases are generally accessed and filed through PACER (Public Access to Court Electronic Records). PACER is a separate system specifically designed for federal court documents, including bankruptcy cases. If you have a PACER account, you can file documents, view the docket, and obtain necessary filings, such as the lien document, through this service.
Here’s the updated version of your motion for clarity:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
*. On February *, *, Classic Display, Inc. (the “Debtor”) filed a voluntary petition for relief under Chapter * of the Bankruptcy Code (the “Code”). On July *, *, Joseph M. DiOrio was appointed Chapter * trustee.
*. By Order dated September *, *, the Trustee sold the assets of the Debtor pursuant to § * of the Code to Ralph Grieco, James Michael Cronan, and James Tiernan or their nominee.
*. On November *, *, the Case was converted to Chapter * and DiOrio was appointed Chapter * trustee.
*. On May *, *, the Trustee filed adversary proceedings against the Debtor’s principal, James Cronan (“J. Cronan”), and Cronan’s ex-wife, Karen Cronan (“K. Cronan”), seeking to recover funds the Debtor fraudulently transferred to them.
*. On November *, *, the Trustee obtained the Judgment.
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, including a promissory note and the sale of the business from me to Ralph Grieco.
- Subsequently, we opened a new business together, and he advised me to give

I have a Pacer account but is it by state ? I am unsure if my Pacer accountant is just for Massachusetts or I will be able to access Rhode Island bankr court too.

Your PACER account should provide you access to federal court records across all states, including bankruptcy courts. It is not limited by state. You should be able to access the United States Bankruptcy Court for the District of Rhode Island using your PACER account. If you encounter any issues, you can contact PACER support for assistance.

ok! I will confirm once filled.

Great! Filing your motion through PACER and obtaining the necessary documents should help strengthen your case. If you need further assistance at any point, feel free to reach out. Good luck with your filing!

In the Introduction section do I add the date or any other details, INTRODUCTION The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.

In the introduction section, you don't need to add the date. The current format is sufficient and clear. Here’s the finalized introduction:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
---
Would you like any further assistance or adjustments?

see above

No specific date is required in the introduction section, but you can include any relevant context or details to make it clearer. Here’s a refined version of the introduction:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me on [Insert Date of Judgment] pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
---
Would you like any further adjustments or assistance with any other part of your motion?

To clarify can i add this: - Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building, * Fountain Street, Rhode Island, that was in my name as the title owner Cronan Realty, LLC and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and, once the transfer was done, they would add my name back onto the title of the property. I have the deed transferring the commercial property from the bankruptcy court to my advisor and James Tiernan (Exhibit C).

Yes, you can certainly add that clarification. Here’s the updated version of your motion with the added clarification:
---
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF RHODE ISLAND
In re: Classic Display, Inc.
Case No. *:*-bk-*
Debtor, Chapter *
---
MOTION TO VACATE JUDGMENT PURSUANT TO RULE *(b) FOR FRAUD UPON THE COURT
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me on [Insert Date of Judgment] pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
*. On February *, *, Classic Display, Inc. (the “Debtor”) filed a voluntary petition for relief under Chapter * of the Bankruptcy Code (the “Code”). On July *, *, Joseph M. DiOrio was appointed Chapter * trustee.
*. By Order dated September *,*, the Trustee sold the assets of the Debtor pursuant to § * of the Code to Ralph Grieco, James Michael Cronan, and James Tiernan or their nominee.
*. On November *, *, the Case was converted to Chapter * and DiOrio was appointed Chapter * trustee.
*. On May *, *, the Trustee filed adversary proceedings against the Debtor’s principal, James Cronan (“J. Cronan”), and Cronan’s ex-wife, Karen Cronan (“K. Cronan”), seeking to recover funds the Debtor fraudulently transferred to them.
*. On November *, *, the Trustee obtained the Judgment.
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, including a promissory note and the sale of the business from me to Ralph Grieco.
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock

see above

Certainly! Here’s the updated section with your clarification:
---
INTRODUCTION
The Plaintiff, [Your Name], respectfully moves this honorable court to vacate the default judgment entered against me on [Insert Date of Judgment] pursuant to Rule *(b) of the Rhode Island Rules of Civil Procedure, due to fraud upon the court, excusable neglect, and newly discovered evidence.
BACKGROUND
*. On February *, *, Classic Display, Inc. (the “Debtor”) filed a voluntary petition for relief under Chapter * of the Bankruptcy Code (the “Code”). On July *, *, Joseph M. DiOrio was appointed Chapter * trustee.
*. By Order dated September *, *, the Trustee sold the assets of the Debtor pursuant to § * of the Code to Ralph Grieco, James Michael Cronan, and James Tiernan or their nominee.
*. On November *, *, the Case was converted to Chapter * and DiOrio was appointed Chapter * trustee.
*. On May *, *, the Trustee filed adversary proceedings against the Debtor’s principal, James Cronan (“J. Cronan”), and Cronan’s ex-wife, Karen Cronan (“K. Cronan”), seeking to recover funds the Debtor fraudulently transferred to them.
*. On November *, *, the Trustee obtained the Judgment.
- At the time of the lawsuit, my financial advisor, Ralph Grieco, formed a partnership with me and purchased my business assets through the bankruptcy court, including a promissory note and the sale of the business from me to Ralph Grieco.
- Subsequently, we opened a new business together, and he advised me to give my shares of that business to the third partner in the newly formed business, James Tiernan, to give him a tax shelter. He promised that he would return my name to the stock power documents the following year. He did not, and I never received any money for the share transfer. I have the share transfer document (Exhibit B).
- Throughout the partnership, the two partners continually made promises to me. They advised me to move from Chapter * on the commercial building, * Fountain Street, Rhode Island, that was in my name as the title owner Cronan Realty, LLC and part of the bankruptcy estate, to Chapter * to liquidate. They assured me they would buy the building from the court and

Do you think this is ok? It was not in my best interest to move from Chapter * to Chapter * in the abensence of unfufilled promises. I had a due process right to know that my partners had no intent to keep their promise. I would have stayed in Chapter 13and taken other actions. Of course, who gives up valuable assets and gets nothing in return? No one- I dont know if I like the last question. Can we enphasize the betrayal of a fudiciary dutis as partners, shareholders and my trusted personal advisor. That she not have title to my business and property. They should not rewarded and aided and abetted by this court to perpetuate the crime against not only myself but the bankruptcy estate asw well. Can you polish?

Sure, here’s a polished version of your statement:
---
It was not in my best interest to move from Chapter * to Chapter * in the absence of fulfilled promises. I had a due process right to know that my partners had no intent to keep their promise. I would have stayed in Chapter * and taken other actions. The betrayal of fiduciary duties by my partners, shareholders, and trusted personal advisor is evident. They should not have title to my business and property. They should not be rewarded and aided and abetted by this court to perpetuate the crime against not only myself but also the bankruptcy estate and its creditors. This court must recognize the severity of their fraudulent actions and ensure justice is served.
---
Would you like any further adjustments or assistance with any other part of your motion?

Could you please writin an urgent email/ To Ms. Carin Marley, The emial letter that i sent to you last night with my Motion and Exhibits fro A to J was rejected this morning becuase of technical errors which I will fix however to prevent delay I want you to know this as to serve the opposing counsel I have sent them the motion with the exhibits rather tahn wait for the eFile delay.

Sure, here’s a draft email you can use to inform Ms. Carin Marley about the situation:
Subject: Urgent: Resubmission of Motion and Exhibits Due to Technical Errors
Dear Ms. Marley,
I hope this email finds you well.
I am writing to inform you that the email I sent last night containing my Motion and Exhibits (A to J) was rejected this morning due to technical errors. I am working on fixing these issues. However, to prevent any delays, I wanted to let you know that I have already served the opposing counsel with the motion and the exhibits to ensure that they are aware of the filing.
I will resubmit the corrected email with the Motion and Exhibits as soon as possible. Thank you for your understanding and assistance in this matter.
Best regards,
[Your Full Name]
[Your Contact Information]
/s/ [Your Full Name]
Would you like any adjustments or additional details included in the email?

Rejected – Technical Submission Error Returned Comments The system was unable to read these documents. Please resubmit in 'Print to PDF' format and remove all hyperlinks, special characters and font

Sure, here’s a draft of the email you can send to Ms. Carin Marley:
---
Subject: Urgent: Correction of Technical Submission Error for Motion and Exhibits
Dear Ms. Marley,
I hope this email finds you well. I am writing to inform you that the Motion and Exhibits (A to J) I submitted last night were rejected this morning due to technical submission errors. The system was unable to read the documents, and I have been instructed to resubmit them in 'Print to PDF' format and remove all hyperlinks, special characters, and font issues.
To prevent any further delay, I have already served the opposing counsel with the motion and exhibits directly. I will correct the submission errors and resubmit the documents via eFile as soon as possible.
Thank you for your understanding and assistance in this matter. If you need any additional information or have any questions, please feel free to contact me.
Best regards,
[Your Full Name]
[Your Contact Information]
/s/ [Your Full Name]
---
Would you like any further adjustments or additional details included in the email?

Could you write an email to Mr. Kusinitz, Here follows a recent Motion and their exhibits (A to J). Thank you

Subject: Submission of Recent Motion and Exhibits (A to J)
Dear Mr. Kusinitz,
I hope this email finds you well. Attached, please find a recent Motion along with their exhibits (A to J) for your review.
Thank you.
Best regards,
[Your Full Name]
[Your Contact Information]
/s/ [Your Full Name]

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