On March 5, I completed the Proposed Record on Appeal and served it to opposing counsel. For context, the Record on Appeal is a highly structured document that includes every relevant filing, order, and transcript from the trial court, organized in a very specific way so the Court of Appeals can understand the full context of the case.
It’s not just paperwork—it’s the foundation of your entire appeal, and if anything is left out or misfiled, your appeal could be weakened or dismissed. Because I wasn’t given help or guidance, I downloaded multiple examples from other appeals just to figure out exactly how to format and compile it properly.
I served him through the Odyssey eFile and eServe system, which is allowed because the Proposed Record doesn’t actually get filed—it’s only circulated for review, and at this stage, jurisdiction remains with the trial court, not the Court of Appeals. Traditionally, people mailed these, but Odyssey is still relatively new, and I wasn’t about to pay to print and mail 200 pages when I’m already covering the cost to docket the appeal, post bond, and absorb all the other financial burdens of fixing this mess. That’s the whole point of having an electronic filing system.
I also sent him an email letting him know it had been served and that I was hoping to finalize the record efficiently—but honestly, I expected him to drag it out and object to everything, as usual.
You can read all about just how complicated under Rule 9 here: → NC Rules of Appellate Procedure
Also on March 5, the defendants’ responses to my Requests for Admission were filled with evasive denials, misleading characterizations, and outright falsehoods. Many of the admissions were denied under the guise of undefined terms or legal objections, despite those terms being well-understood (e.g., “Minimum Housing Code” or “habitability”).
Several responses blatantly misrepresented the record, such as denying that the City of Raleigh deemed the property unfit—even though the housing case ordered specific repairs and stated the fireplace should not be used. In one of the most glaring misstatements, they falsely claimed that I had not provided proper notice to vacate, even though I have proof of email and written notice.
They also denied contacting other landlords, while simultaneously admitting they submitted a housing verification form that instructed a management company not to accept my application. Nearly every denial was framed to dodge accountability while still hinting at facts that supported my claims.
And notably, none of the denials were verified under oath, which is required under Rule 36—making their entire submission procedurally invalid. This was yet another example of bad-faith litigation and obstruction during discovery, using denial and deflection instead of truth and compliance.