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Order to Extend Time to File Responsive Pleading and Motions

I wasn’t notified that the extension order had been entered; I only found out about it through Frank. It was suspicious that the order was issued the day after I filed a motion to compel an answer, yet it was entered without a hearing, without acknowledgment of my objection, and without any showing of…

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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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Motion to Strike Complaint & Objection

Instead of filing an answer like required, Frank McGraw, in a desperate move, filed a Motion to Strike under Rule 12(f) and tried to claim that doing so automatically extended their time to answer by 20 days — which is factually incorrect. Under the law, filing a Rule 12 motion only extends the deadline if…

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Motion & Objection to Extension of Time

Right around the time the defendants' answer was due in district court, the procedural games began. On January 9, Frank emailed me for the first time stating that Anna was looking for new counsel — without explaining why. He claimed she had been searching since December 16, but I didn't take it seriously. If she…

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