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…
Despite the case being under interlocutory appeal and discovery already being implicated in the review, opposing counsel served discovery responses that were riddled with boilerplate objections, irrelevant denials, and evasive answers. Nearly every interrogatory was met with blanket claims of irrelevance, undue burden, or privilege—without a proper privilege log—and in some cases, they objected and…
On January 30, 2025, Chief District Court Judge Eagles denied my motion to have the case designated as an exceptional civil case under Rule 2.1, stating that the claims weren’t complex and there weren’t enough parties to warrant the designation—even though this was the very same case where defendants were allowed to delay proceedings to…
On January 27, 2025, I filed an Emergency Motion to address the procedural disorder created by the defendants’ overlapping filings, failure to respond to discovery, and repeated violations of court rules.
With less than 30 days left before trial, the court had granted orders—like the extension to answer and the continuance of my Motion…
Frank decided to file another motion to continue on only my motions, but of course want to move forward with his. This is what the cover sheet looks like when you correctly file with it, but unfortunately the motion was procedurally flawed, lacked good cause under Rule 6(b), and failed to explain the…
With discovery being in a couple of days, specifically the interrogatories and documents. Instead of complying, defendants filed a Motion to Extend Discovery.
I filed an objection to the because they failed to provide any specific reason for the extension as required under Rule 6(b) of the North Carolina Rules of Civil Procedure. Their…
To ring in the New Year, I spent it writing up the Request for Admissions. These are formal statements that the opposing party must admit or deny under oath.
They are used to narrow the issues for trial by establishing certain facts as true ahead of time. If they fail to respond within the…
On Christmas Day (and my favorite holiday), I spent it writing up my request for discovery. I sent the Request for Documents and Interrogatories the next day. These are formal discovery tools used to gather evidence. The Request for Documents asks the opposing party to produce specific records, emails, or other materials related to the…