Motion to: Determine Sufficiency of Defendant’s Answer and Objections

STATE OF MICHIGAN
IN THE 31st CIRCUIT COURT FOR THE COUNTY OF ST. CLAIR
Office of Clerk of Court
201 McMorran Blvd.
Port Huron, MI 48060
(810) 985-2031
 
 
Thursday, February 4, 2010

 
 

 
 

Dear Clerk of Court

:

 

Enclosed for filing, please find Plaintiff’s Motion to: Determine Sufficiency of Defendant’s Answer and Objections; For Entry of Order that the Matter is Admitted; and For an Order Compelling Discovery; Plaintiff Brief in Support; Plaintiff’s Ex Parta Affidavit in Support, and Proof of Service.
 
And please except my sincere thanks, in advance, for this portion of your attention, time, and most kind cooperation in the matter.
 
 
 
Respectfully,
 
__________________________

Mr. Arthur L. Lockett

Pro se Plaintiff
909 Stone St. Apt #1
Port Huron, Michigan 48060

(810) 985 – 9309

 

 
 
 
 
 
 
 
 
 
 
 

 

STATE OF MICHIGAN
IN THE 31st CIRCUIT COURT FOR THE COUNTY OF ST. CLAIR
Office of Clerk of Court

201 McMorran Blvd.
Port Huron, MI 48060
(810) 985-2031

Monday, May 10, 2010
Arthur L. Lockett,                                                                                                                       Hon. Judge: Daniel J. Kelly

                                     Plaintiff,                                                                                                     Case No.# 09.002175-PZ

v.
 
People of the City of Port Huron,

                                    Defendants.

_____________________________________/

 

Plaintiff’s Motion to:
Determine Sufficiency of Defendant’s Answer and Objections;
For Entry of Order that the Matter is Admitted; and
For Order Compelling Discovery
 

Now Comes,

Plaintiff, Mr. Arthur L. Lockett, in pro se, pursuant to MCR 2.119 (A)(2); MCR. 2.312 (C)(3); MCR. 2.313(A)(4) and also moves for entry of an addition order under MCR 2.313(A) with respect to an objection to and a failure to respond to the request for admissions in whole and in parts thereof, and, failure to product and permit inspection as requested, and moves the Court to:

1). Plaintiff has, in good faith, conferred and attempted to confer with the Defendant’s Counsel, T. Allen Francis, in an effort to secure disclosure without court action.
2). Plaintiff, who has requested discovery and filed Request for Admissions, move the Court, to determine the sufficiency of the answer and objections, and for entry of the appropriate orders concerning production.
3). Pursuant to MCR. 2.312 (C)(3), unless the court determines that an objection is justified, it shall order that an answer be served; If the court determines that an answer does not comply with the requirements of the rule, enter an order that the matter is admitted.
4). Plaintiff request that the court will not, in lieu of one of the orders, determine that final disposition of the request be made at a pretrial conference or at another designated time before trial.
5). The provisions of MCR 2.313(A)(5) apply and Plaintiff request it be awarded expenses incurred in relation to the motion for defendant’s failure to make disclosure.

6). Plaintiff contend Defendant’s response is a Evasive and Incomplete Answer. For purposes of this sub-rule an evasive or incomplete answer is to be treated as a failure to answer. MCR. 2.313(A)(4)

7). The Plaintiff alleges that the Defendant failed to respond to his discovery and production request and failed to adequately answer requests for admission regarding the number of people whom are also listed in the Request for Admission.
8). The Plaintiff asserts that the requested discovery material and information is necessary to support the Plaintiff’s motion for Relief from Judgment and his Fraud Upon the Court complaint.
9). The Defendant has not asserted that the requested discovery is unduly burdensome or would violate statutory confidentiality provisions.
10). For the following reasons, the Court should grant the Plaintiff’s motion to compel discovery and grant the Plaintiff’s motion for an order to deem requests for admission admitted and awarded expenses incurred.
Respectfully submitted,
__________________________

Mr. Arthur L. Lockett

Pro se Plaintiff
909 Stone St. Apt #1
Port Huron, Michigan 48060

(810) 985 – 9309
(810) 354 – 2021

 
 
 
 

STATE OF MICHIGAN
IN THE 31st CIRCUIT COURT FOR THE COUNTY OF ST. CLAIR
Office of Clerk of Court

201 McMorran Blvd.
Port Huron, MI 48060
(810) 985-2031

Monday, May 10, 2010
 
Arthur L. Lockett,                                                                                                                              Hon. Judge: Daniel J. Kelly

                                       Plaintiff,                                                                                                          Case No.# 09.002175-PZ

v.
 
People of the City of Port Huron,

                                    Defendants.

_____________________________________/

 

Brief In Support of Plaintiff’s Motion to:
Determine Sufficiency of Defendant’s Answer and Objections;
For Entry of Order that the Matter is Admitted; and
For Order Compelling Discovery

On August 17th 2009, Mr. Arthur L. Lockett ("Plaintiff") initiated this Action against the City of Port Huron ("Defendant"), by Motion for relief from judgment, alleging numerous violations of his Michigan and U.S. Constitutional rights, Fraud Upon the Court and a number of due process and other violations by the Defendant through its agents.

On September 28th 2009 the Plaintiff filed and served his request for discovery and for the production of documents and other needed admissible evidence. The Defendant has failed to respond to that request in any manner required by court rules or Plaintiff discovery rights. This lack of response necessitate an order compelling discovery.

On April 8th 2010 Plaintiff filed and served on the Defendant his requests for admission in Reference case ID: 07P00808OM.

Admission Requests. First Set.

Responding Party: Defendant, The City Of Port Huron; and attorney, T. Allen Francis; John Livesay; District Court Judge Cynthia S. Platzer; Kevin K. Kenaya

and of the witnesses that provided testimony to Lockett‘s criminal-trial jury, and from court appointed trial-counsel Margaret Kelly.

The Defendant has provided a response from only one of the persons listed, John Livesay.

As part of the initial requests for admission. The responding party may answer a request for admission by admitting the request, denying the request, objecting to the request, or explaining that it is unable to answer due to lack of information, within 28 days… Any failure to do so constitutes an admission on the part of the requested party. See also, Fed. R. Civ. P. 36.

The Plaintiff, requested, in addition to John Livesay; attorney, T. Allen Francis, The City of Port Huron, Judge Cynthia S. Platzer; Kevin K. Kenaya, attorney, Margaret Kelly and of the witnesses that provided testimony to Plaintiff‘s criminal-trial jury (police Officers and others) to admit to the truth of the underlining matters, however, received non of their responses or any references thereabout.

I. Legal Standard

A Parties may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter involved in the pending action. MCR 2.300 General Rules Governing Discovery. Specifically MCR. 2.302(B)(1) and Fed R. Civ. P. 26(b)(1). Rule 26(b)(1) of the Federal Rules of Civil Procedure explains that relevant information need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence. A party may request documents that are in the possession, custody, or control of the party upon whom the request is served. Fed. R. Civ. P. 34(a). The mere legal right to obtain the documents on demand" constitutes sufficient possession for the purposes of discovery.

The Sixth Circuit has noted that a "discovery request is generally unobjectionable ‘if the information sought appears reasonably calculated to lead to the discovery of admissible evidence.’" Marshall v. Bramer, 828 F.2d 355, 358 (6th Cir. 1987)(quoting Fed. R. Civ. P. 26(b)(1)). Rule 26 is to be liberally construed to permit broad discovery. See U.S. v. Leggett & Platt, Inc., 542 F.2d 655, 657 (6th Cir. 1976) (commenting that the "Federal Rules of Civil Procedure authorize ‘extremely broad’ discovery"). See In re Bankers Trust Co., 61 F.3d 465, 469 (6th Cir. 1995).

Rule 2.312 Request for Admission

Within the time for completion of discovery, Plaintiff served on Defendant a written request for the admission of the truth of a matter within the scope of MCR 2.302(B) stated in the request that relates to statements or opinions of fact or the application of law to fact, including the genuineness of documents described in the request. Copies of the documents where served with the request and they have been or are otherwise furnished or made available for inspection and copying to the Defendant.. Each matter of which an admission is requested must be stated separately. Rule 36(a) establishes, however, that a party "may not give lack of information or knowledge as a reason for failure to admit or deny unless the party states that the party has made reasonable inquiry and that the information known or readily ascertainable by the party is insufficient to enable the party to admit or deny." Id. The requesting party may move the district court to determine the adequacy of the answers provided. Pursuant to Rule 36(a), "If the court determines that an answer does not comply with the requirements of this rule, it may order either that the matter is admitted or that an amended answer may be served." Id.

Rule 2.313 Failure to Provide or to Permit Discovery; Sanctions

It appears that Defendant and its Counsel has taken the position that they have no duty to admit or deny admission requests. Nor respond to Requests for Production of Documents and Other Things; (The party on whom the request is served must serve a written response within 28 days after service of the request. Under this rule, a Parties may also petition the court for an order compelling disclosure or discovery. Rule 2.310 C)(2)

Rule 2.313 (A)(4) Evasive or Incomplete Answer

For purposes of this sub-rule an evasive or incomplete answer is to be treated as a failure to answer. See Fed. R. Civ. P. 37. Specifically, Rule 37(a)(2)(B) enables a court to enter an order "compelling an answer, or a designation, or an order compelling inspection in accordance with the request" for failure to respond to a Rule 33 interrogatory. Id. The rule also provides for sanctions against parties that do not cooperate with discovery. Id. For purposes of this rule, Rule 37(a)(3) instructs that an "evasive or incomplete" answer must be treated as a complete failure to answer. Id.

Rule 2.313 (A)(5) Award of Expenses of Motion

Plaintiff moves the Court to, if the motion is granted, after opportunity for hearing, require the party or deponent whose conduct necessitated the motion or the party or attorney advising such conduct, or both, to pay to the moving party the reasonable expenses incurred in obtaining the order, including attorney fees, unless the court finds that the opposition to the motion was substantially justified or that other circumstances make an award of expenses unjust.

II. Discussion

Plaintiff asserts a right to conduct discovery for the purposes of proving the allegation listed in his complaint. As noted above, parties may conduct discovery regarding any matter, not privileged, that is relevant to the case. The Plaintiff submitted requests for admissions to the Defendant on the issues regarding elements of the case.

Of the many specified individuals that were required to respond to Plaintiff’s request for admission, only John Livesay attempted the required sworn responses, of which, does not relieve defendant its obligation to make a reasonable inquiry into the answers sought. Defendant could have used any reasonable search mechanisms to respond to Plaintiff’s request for discovery and admissions but chose not to do so.

The Defendant could have allowed Plaintiff to personally inspect the Defendant’s computer system and records.

Plaintiff request, and court rule requires filing of discovery materials, requests, responses, depositions, and other discovery materials where, as here, the discovery materials are to be used at trial, it must be either filed or made an exhibit;

Defendant could have merely responded to the discovery request and had the other named persons listed respond to the request for admissions it did John Livesay, and thereby avoid the entire discovery dispute. Defendant however, chose not to…

MCR 2.312 like Rule 36 of the Federal Rules of Civil Procedure establishes that a party who is unable to admit or deny a request must "set forth in detail" the reasons why it cannot answer. Fed. R. Civ. P. 36.

In its responses to the Plaintiff’s requests for admission and discovery, Defendant after a reasonable inquiry of the information known, in its possession, custody, and control and are readily ascertainable, neither admitted nor denied the request. Or provided any discovery.

The Defendant, however, has produced no evidence or description of its attempt to engage in a "reasonable inquiry" to discover and produce the requested information, not even the general observation that finding the information might be difficult.

Rule 26(b)(2) of the Federal Rules of Civil Procedure permits parties to avoid certain discovery requests for electronically stored information that impose "undue

burden or cost." Fed. R. Civ. P. 26(b)(2). Even in such situations, however, "the court may nonetheless order discovery from such sources if the requesting party shows good cause," after weighing factors like the burden of discovery, importance of the information sought, and the availability of the requested materials from another source. Id. As noted above, the Plaintiff has provided good cause for his request for information from the Defendant for the purposes of his motion.. The Defendant, in response, selects and offer only a response from John Livesay. Whom, in turn, is assisting the continued concealment of evidence that would expose his and the defendant’s criminal conduct.

This Court should find the Sixth Circuit’s decision in Coleman inapposite because, in that case, the defendant had already produced "hundreds of interrogatory

responses, numerous depositions, and thousands of pages of documents" and the plaintiff’s discovery requests were excessively broad.

In this present case, the Plaintiff’s discovery request is narrowly tailored to the issue of the case and a limited number of individuals. This Court should conclude that the requested discovery is not unduly burdensome and that the Defendant has failed to carry its burden of showing that it made a reasonable inquiry to obtain answers to the Plaintiff’s requests.

The discovery requested is solely within the control of the Defendant and the Defendant has not produced any discovery. It appears from the record that Defendant is unwilling to admit or deny the Plaintiff’s requests for admission.

Even if the Plaintiff’s discovery requests pose a burden on the Defendant, this Court should finds that the importance of the issues involved (Fraud Upon The Court) outweighs any claim of inconvenience or cost. While not all of the information sought by the Plaintiff may be admissible at trial, the Court should conclude that it is relevant and reasonably calculated to lead to admissible evidence.

The Court should therefore find that the Defendant was not substantially justified in its responses to the discovery request and requests for admission.

The Court should find that the production or inspection of such records would not violate any statutory confidentiality provisions. The Court should note that parties are free to enter into a private confidentiality agreement with respect to disclosure of documents and information.

The Court could have also consider a defense motion to seal an individual document in the file or to afford confidentiality protections to certain information had that been requested by defendant.

At this point in the case, however, the Court should not believe that the basic discovery requested by the Plaintiff conflicts with any statutory confidentiality requirements.

III. Conclusion

For the above reasons, this Court should GRANT the Plaintiff’s motion to compel discovery and GRANT the Plaintiff’s motion for an order to deem the requests for admissions admitted as to Defendant, The City Of Port Huron; and attorney, T. Allen Francis; District Court Judge Cynthia S. Platzer; Kevin K. Kenaya and of the witnesses that provided testimony to Lockett‘s criminal-trial jury, and from court appointed trial-counsel Margaret Kelly. The Court should, therefore, order the Defendant to produce materials relevant to Requests for discovery and Admissions and Requests for Production. And if Defendant fails to immediately undertake a good faith effort to produce the information, the court should then order that Plaintiff will be permitted to inspect in a reasonable manner the Defendant’s files and records, including electronically stored information, on these issues.

The Court will also consider the imposition of sanctions should the Defendant fail to comply with its order.

Finally, Defendant and its counsel has not made any attempt to cooperate in pretrial discovery. The Court should encourage all case participants to try to minimize further needless frustration, time, and expense associated with the discovery process. In all other respects discovery practice is subject to the general restrictions imposed under the court rules. With the exception of requests for admission, discovery materials may not be filed unless the materials are used in connection with a motion, used as an exhibit at trial, or the court requires the material to be filed. MCR 2.302(H); MCR 2.312(F). Further, the Court reserves the discretion to issue protective orders, pursuant to MCR 2.302(C), to protect litigants from annoyance, embarrassment, oppression, or undue burden or expense.

Plaintiff retains, however, an unfettered choice to determine, pursuant to the court rule, what discovery methods they wish to utilize. Of the available methods of discovery permitted under the court rules, the request for admission is the most inexpensive, efficient and effective.

Admissions are sought, first to facilitate proof with respect to issues that cannot be eliminated from the case, and secondly, to narrow the issues by eliminating those that can be. … By encouraging admissions, the goal…[is to] expedite the pending action. The purpose of MCR 2.312 is to limit areas of controversy and save time, energy, and expense which otherwise would be spent in proffering proof of matters properly subject to admission. Radtke v Miller, Canfield, Paddock & Stone, 453 Mich 413, 419, 425; 551 NW2d 698 (1996); citations omitted.

Like other discovery mechanisms contained in the MCRs, requests for admission

operate extra-judicially within the time and manner set by MCR 2.312. For the same reason, routine or liberal exercise of judicial discretion is contrary to the language of MCR 2.312 and its underlying purpose. Janczyck v Davis, 125 Mich App 683, 689, 692;

337 NW2d 272 (1983); Medbury v Walsh, 190 Mich App 554; 476 NW2d 470 (1991). Court involvement only occurs on motion from the parties and is restricted to objections raised, requests to shorten or lengthen the time for response, or requests to amend or

withdraw a response. Admissions under MCR 2.312 are “judicial” admissions, operating as formal concessions in the pleadings or as stipulations that have the effect of withdrawing a fact from issue and dispensing the need for further proof. Radtke, supra at 420; citations omitted. MCR 2.312 (B) (1) plainly requires that a request for admission is deemed admitted unless the answering party files a written answer or objection within 28 days. In other words, a party’s failure to respond results in an admission regardless of whether a timely response would have been a denial or an objection. Janczyk, supra at 690.

Attorney T. Allen Francis and the City of Port Huron has provided an improper and evasive response to Plaintiff’s Requests for Admission, and the Court should hold that Plaintiff’s Requests for Admission are deemed admitted due to Attorney T. Allen Francis and the City of Port Huron failure to respond.

Respondents’ failure to respond was not inadvertent. Plaintiff called the office of T. Allen Francis regarding the requests for discovery on many different occasions, a fact which Respondent should not deny. Indeed, in its response to Plaintiff request for admission, Respondent through Livesay made no claim that it was unaware of the requests for discovery, but asserted instead a denial of having denied discovery.

Rather than file responses or objections, Attorney T. Allen Francis and the City of Port Huron; District Court Judge Cynthia S. Platzer; Kevin K. Kenaya and of the witnesses that provided testimony to Plaintiff‘s criminal-trial jury, and from court appointed trial-counsel Margaret Kelly, has failed to admit or deny the truth of the underlining matters or otherwise respond properly. The Court should find no prejudice to Defendant beyond what is clearly envisioned in MCR 2.312.

On the other hand, John Livesay responses to the first set of requests is a furtherance of the Fraud Upon the Court, necessitating discovery that Plaintiff otherwise would not have needed to pursue.

Plaintiff request the court to order discovery materials to be filed.

The Court need not address whether the deemed admissions were otherwise objectionable because such inquiry is irrelevant, untimely, and has not been requested.

Defendant, to whom the request was directed, made no reasonable inquiry and the information necessary to admit or deny the matter is readily obtainable to the Defendant. The response fails if the evidence does not show that the party did in fact make a reasonable inquiry. As a result, the response is necessarily inadequate.

The Plaintiff’s discovery attempts are totally frustrated. And as far as the document requests are concerned, this is clearly correct, because the defendants never responded to these requests at all. Although the defendants could have filed written responses to the production request, neither defendant nor its counsel served the required documentation or any sort of response upon the Plaintiff. Clearly, such incomplete responses prejudice the plaintiff’s ability to prepare its case and increase the difficulty of future discovery. There is also a potential for additional fraud and the loss of evidence after such a delay. See Berthelsen, 907 F.2d at 621. Accordingly, the Court should find that the plaintiff demonstrated a total frustration of its discovery attempts, which establishes prejudice. Abbe, 916 F.2d at 1079.

The Defendant simple refused to provide the needed answers to the request for admissions and the discovery material because to do so would show that the Defendant has no defense to the relief sought, damages, nor any justification for their misconduct.

WHEREFORE, Plaintiff pray this Hon. Court to deem the Request for Admissions under MCR 2.312 are “judicial” admissions, operating as formal concessions in the pleadings as to the non-responding listed respondents, followed by the appropriate orders.

Respectfully submitted,

__________________________

Mr. Arthur L. Lockett Friday, May 7, 2010

Pro se Plaintiff
909 Stone St. Apt #1
Port Huron, Michigan 48060

(810) 985-9309
(810) 354-2021

 

 

 
 
 
 
 

STATE OF MICHIGAN
IN THE 31st CIRCUIT COURT FOR THE COUNTY OF ST. CLAIR
Office of Clerk of Court


201 McMorran Blvd.
Port Huron, MI 48060
(810) 985-2031

 
Arthur L. Lockett,
                                                                                                                                               Hon. Judge: Daniel J. Kelly

                                               Plaintiff,                                                                                  Case No.: 09-2175-PZ

 
v.                                                                                                                                            Determine Sufficiency of Defendant’s
                                                                                                                                               Answer and Objections
                                                                                                                                               Entry of Order that the Matter is Admitted Order Compelling Discovery
 
People of the City of Port Huron,

                                             Defendants.

_____________________________________/

Proof Of Service

NOW COMES, pro se Plaintiff, Arthur L. Lockett, pursuant to

Title 28, Part V, Chapter 115 § 1746, and states: that I, Mr. Arthur L. Lockett, do declare (or certify, verify, or state) under penalty of perjury, under the laws of the United States Of America, as represented by my signature below, that I did cause, at or near _10_:_30__, AM., on this date of: May __15th__ 2010, to be served, by hand delivery, a copy of Plaintiff’s Request to Determine Sufficiency of Defendant’s Answer and Objections; Entry of Order that the Matter is Admitted; and an Order Compelling Discovery on the Defendants at the Attorney, T. Allen Francis‘, office, at:

Fletcher Fealko Shoudy & Moeller PC

522 Michigan St.
Port Huron, MI 48060
(810) 987-8444

 

Respectfully submitted:
 
______________________________

Mr. Arthur L. Lockett Friday, May 7, 2010

Pro se Plaintiff
909 Stone St. Apt #1
Port Huron, Michigan 48060

(810) 985-9309
(

810) 354-2021

 
 

STATE OF MICHIGAN
IN THE 31st CIRCUIT COURT FOR THE COUNTY OF ST. CLAIR
Office of Clerk of Court


201 McMorran Blvd.
Port Huron, MI 48060
(810) 985-2031

Arthur L. Lockett,                                                                                                                                                      Hon. Judge: Daniel J. Kelly

                                                                                                                                                                                      Plaintiff, Case No.: 09-2175-PZ

 
v.
 
 
People of the City of Port Huron,

Defendant.

_____________________________________/
 
Arthur L. Lockett’s

Ex Parte Affidavit in Support

NOW COMES, In pro se, Plaintiff, Arthur L. Lockett, pursuant to

Title 28, Part V, Chapter 115 § 1746, and states: that I, Mr. Arthur L. Lockett, declare (or certify, verify, or state) under penalty of perjury, under the laws of the United States Of America, as represented by my signature below, that the foregoing is true and correct to the best of my knowledge, information and belief, and, of which, includes statements made in, Plaintiff’s Motion to: Determine Sufficiency of Defendant’s Answer and Objections; For Entry of Order that the Matter is Admitted; and For an Order Compelling Discovery; Plaintiff Brief in Support; Plaintiff’s Ex Parta Affidavit in Support, and Proof of Service.

Respectfully submitted:

_________________________

Mr. Arthur L. Lockett Friday, May 7, 2010

Pro se Plaintiff
909 Stone St. Apt #1
Port Huron, Michigan 48060

(810) 985-9309 (810) 354-2021

Title 28, Part V, Chapter 115 § 1746:

Wherever, under any law of the United States or under any rule, regulation, order, or requirement made pursuant to law, any matter is required or permitted to be supported, evidenced, established, or proved by the sworn declaration, verification, certificate, statement, oath, or affidavit, in writing of the person making the same (other than a deposition, or an oath of office, or an oath required to be taken before a specified official other than a notary public), such matter may, with like force and effect, be supported, evidenced, established, or proved by the unsworn declaration, certificate, verification, or statement, in writing of such person which is subscribed by him, as true under penalty of perjury, and dated, in substantially the following form:

(2) If executed within the United States, its territories, possessions, or commonwealths: “I declare (or certify, verify, or state) under penalty of perjury that the foregoing is true and correct. Executed on (date). (Signature)”.

 

 

 

ADR

09-002175-PZ

JUDGE

KELLY

File

8/17/2009

Adj Date

Close

 

 

Num

Date

Judge

Chg/Pty

Event Description/Comments

Clerk

1

 8/14/2009

KELLY

MOTION FOR WAIVER OR SUSPEN-
SION OF FEES & COSTS

JJS

2

ORDER
GRANTING MOTION FOR WAIVER
OR SUSPENSION OF FEES & COSTS

JJS

3

 8/17/2009

AFFIDAVIT IN SUPPORT

JJS

4

DEMAND FOR TRIAL BY JURY

JJS

5

DEMAND FOR PRETRIAL CONF.

JJS

6

SUMMONS AND COMPLAINT
FRAUD ON THE CT INDEPENDENT
ACTION IN EQUITY

JJS

7  

8/19/2009

D 001

RETURN OF SERVICE
FILED 8/19/09 HAND DELIVERED

JJS

 

9/9/2009

D 001

ANSWER FILED
ATTORNEY: P-66160 FRANCIS
/AFFIRMATIVE DEFENSES/PROOF

JJS

9  

9/28/2009

DISCOVERY REQUEST

JJS

10

PLAINTIFFS EX PARTE AFFIDAVIT

JJS

11

PROOF OF SERVICE FILED

JJS

12  

1/11/2010

NOTICE SENT FOR: 1/26/2010 4:00 PM
"NO APPEARANCE NECESSARY"

BLD

13

NOTICE TO APPEAR

JJS

14

PRETRIAL STATEMENT & CASE SCHEDULING ORDER

JJS

15  

1/26/2010

PRE-TRIAL STATEMENT ISSUED

BLD

16

ALTERNATIVE DISPUTE RESOLUTION ORDERED

JMC

17

 1/28/2010

ADR NOTICE

JJS

18  

4/8/2010

REQ FOR ADMISSIONS
PROOF OF SERVICE
ARTHUR LOCKETTS EX PARTE
AFFIDAVIT IN SUPPORT

KAB

19

 5/5/2010

ANSWER TO RQST TO ADMIT/ADMISSIONS
/PROOF

 

About these ads

About loclock7

53 year old father of three and one grandchild SC4 Student
This entry was posted in Judge Platzer's Court. Bookmark the permalink.

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s