The very next day after I filed my Motion for Default Judgment, Frank submitted a Motion to Withdraw as Counsel — and this also violated procedure. As I noted in a previous filing, Rule 16 requires there to be justifiable cause for an attorney to withdraw from a case. This usually means there’s a serious…
On January 16, I should have won this case — it should have been over. When a defendant fails to file an answer by the deadline, the case moves into default, meaning I was entitled to default judgment under the rules. Frank’s Motion to Strike hadn’t been ruled on yet, and it was clearly procedurally…
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…
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…