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Notice of Interlocutory Appeal

After filing a motion to strike the defective extension on admissions, I immediately requested a hearing for that same week so the admissions could be deemed admitted before the February 13 hearing. If granted, that would have effectively resolved the case since the admissions covered every claim. Although the court denied my request for an…

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Motion to Compel Answer & Objection to Withdrawal

This was my first formal attempt to correct the growing procedural misconduct in the case, objecting to the defendants’ failure to file an answer and exposing, through emails, that opposing counsel was playing deliberate games with disclosure about new counsel. It was clear even then that they were intentionally creating procedural confusion to delay the…

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