Axe215!!!

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About Axe215!!!

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  1. Thanx bmc100; they never have tried to establish a breach of contract, but I am picking up what you are putting down. This is an easy fix; for the most part, I used my opposition motion to their MSJ to create this document. Like a fool, I cut out the section headings when I created the 'new' document.
  2. Much appreciated, Shell. In this case, Discovery is over...I made a point to ask at the Motion To Set Aside and Vacate Judgement hearing last week. I guess the gray area would be contained in their numerous responses in the interrogatories where they stated they would produce certain documents 'on receipt'. The thing is, they should have had the documents in the first place when they filed the suit. Also, I've amended the motion and brief, this also involves MCR 2.116 © (8), which states that "the opposing party has failed to state a claim upon which relief can be granted".
  3. And here is the brief: BRIEF IN SUPPORT OF DEFENDANT’S MOTION FOR SUMMARY DISPOSITION PURSUANT TO MCR 2.116 © (10) Now comes Defendant Beefer Real, Pro Se, for his Motion for Summary Disposition pursuant to MCR 2.116 © (10) states unto this Honorable Court as follows: FACTS AND LAW This matter is based upon what Plaintiff is alleging as a stated account arising from a credit card agreement allegedly entered into by Defendant with Chase Bank USA and subsequently procured by Plaintiff at auction (see Plaintiff’s supplied Assignment, affidavits, and billing statements, attached hereto and incorporated by reference). Defendant’s earliest contact from Plaintiff occurred on or about November 2, 2012 via U.S. Mail, which Defendant dismissed as junk mail. Subsequent contacts with law firms representing Plaintiff occurred from Xxxxx xxxx until Xxxxx xxxx, and that was when Plaintiff brought forth the court action. Since Xxxxx xxxx when the personal contacts with the various law firms began, Defendant has denied having an account and any outstanding balance with Plaintiff and/or Chase Bank USA. Furthermore, Plaintiff failed to attach written instruments to the complaint as required per Michigan Rules of Civil Procedure 2.113 (f) to support its claim. Furthermore, in subsequent discovery interrogatories, Plaintiff has stated that it does not possess any documentation with the Defendant’s signature, any original written agreement between the Defendant and Chase Bank, or a complete history of the alleged account that establishes the legitimacy of the balance sought. Plaintiff has stated in the interrogatories that it “is not the original creditor and does not currently possess all of the documents associated with the account. Plaintiff has requested additional information and will supplement this response upon receipt” (see ‘Plaintiff’s Answers to Defendant’s Interrogatories…”, attached hereto and incorporated by reference). MCR 2.113(F) requires that, when a claim is based on a written instrument, the instrument must be attached to the pleading: (1) If a claim or defense is based on a written instrument, a copy of the instrument or its pertinent parts must be attached to the pleading as an exhibit unless the instrument is (a) A matter of public record in the county in which the action is commenced and its location is stated in the pleadings; ( In possession of the adverse party and the pleading so states; © Inaccessible to the pleader and the pleading so states, giving the reason; (d) Of nature that attaching the instrument would be unnecessary or impractical and the pleading so states, giving the reason. Plaintiff did not attach a copy of any contract to its complaint. Plaintiff's failure to produce the contract on which its claim is based, as required by MCR 2.113(F), "warrants dismissal of the contract claim without prejudice." English Gardens Condominium, LLC v Howell Twp, 273 Mich App 69, 81; 729 NW2d 242, 250 (2006). Accord: Woodward Nursing Home v Medical Arts, 2006 Mich App LEXIS 207 (Mich Ct of App 2006). Plaintiff's failure to attach a copy of the real contract to its complaint is fatal to its claim. In addition to the requirements of the court rule, the contract is necessary to support plaintiff's claims. Without the real contract, Plaintiff cannot demonstrate that Defendant agreed to pay any particular rate of interest, late charges, or other fees, and it appears that much of the amount Plaintiff claims is comprised of late fees and interest. The Truth in Lending Act requires that a card issuer show that the use of the credit card was authorized. "In any action by a card issuer to enforce liability for the use of the credit card, the burden of proof is upon the credit card issuer to show that the use was authorized..." 15 USC § 1643( . In this case, Plaintiff fails to carry that burden. Even if the purported statements attached to plaintiff's motion were admissible, which they are not, those statements do not show that anyone authorized any charges at all on the credit card. Furthermore, statements provided by Plaintiff are not authenticated by the credit card employee in a way of testimony or sworn affidavit as per MRE 902(11). Also, Plaintiff did not attach a copy of the original credit card agreement, even the Truth in Lending Act separates billing statements and credit card agreement. Even if the documents submitted by Plaintiff were admissible, Plaintiff would still not be entitled to judgement based on theory of an account stated. To prove an account stated, a party must show that the other party agreed he owes the amount claimed. "An account stated means a balance struck between the parties on settlement." Watkins v Ford (syllabus) 69 Mich 357 quoted in Kaunitz v Wheeler, 344 Mich 181, 185; 73 NW2d 263 (1955). In Kaunitz’ case, the court held that trial court erred in granting plaintiff's summary judgment. Even the defendant's acknowledgment of indebtedness letter was not sufficient to show that defendant admitted it owed plaintiff the amount claimed. "The conversion of an open account into account stated, is an operation by which the parties assent to a sum as the correct balance due from one to the other, and whether this operation has been performed or not, in any instance, must depend upon the facts. That it has taken place, may appear by evidence of an express understanding, or of words and acts, and the necessary and proper inferences from them. When accomplished, it does not necessarily exclude all inquiry into the rectitude of the account." White v Campbell, 25 Mich 463, 468. Unlike Kaunitz, the present plaintiff does not show that defendant ever acknowledged he owes the plaintiff anything and there has been no acknowledgment by defendant that he owes the plaintiff the amount claimed as per defendant's claim. Merely sending a bill does not create account stated. There must be some acknowledgement by the party billed that he admits owing the debt and that he further admits that the amount claimed is accurate. The Michigan Court of Appeals has reaffirmed the necessity of proving the assignment, and announced requirements for doing so in Brown Bark, II LP v Bay Area Floorcovering & Design, 2011 Mich App LEXIS 1003, (May 31, 2011). The court held that the documents submitted to prove the assignment of the debt were insufficient for several reasons, including the fact that the plaintiff did not produce the entire assignment agreement, while the allonge was presented as evidence at trial, it was not attached to the note; nor did plaintiff include the agreement referenced in the allonge as evidence, citing privilege as its reason for failing to do so. Because the trial court did not have an opportunity to review the referenced agreement, and consequently could not determine what limitations might exist, the trier of fact could not reasonably conclude that half-page document constituted documentation of National City Bank's intent to transfer all of its rights related to the defaulted loan without any power of revocation. In the present case, Plaintiff has clearly not produced the entire agreement by which it allegedly acquired the debt, and there is no evidence that any amount or even the alleged account was in fact included in whatever accounts were included in the "Bill of Sale". In fact the only page showing the alleged account number has been printed by Midland Credit Management, Inc. as stated on the bottom of the page, and not by Chase Bank USA, N.A. Therefore plaintiff fails to show proper assignment. The amount that Plaintiff claims as damages is not supported by competent evidence. Attached to Plaintiff's motion is an affidavit of ‘Ida Nawtexist’ who states she is “employed as a Legal Specialist and has access to pertinent account records for Midland Credit Management, Inc. ("MCM")”. Affidavits must be made on personal knowledge and state in particularity facts admissible as evidence establishing the grounds stated in the motion. MCR 2.119( (1). If the affidavit refers to any papers, sworn or certified copies of those papers must be attached. MCR 2.116( (2). Plaintiff's affidavit signer does not attach the data on which her testimony is based, and as an employee of the assignee rather than the original creditor, lacks the requisite personal knowledge to support plaintiff's claim. The affiant makes unsupported statements that are based on hearsay. Defendant objects to The Declaration on these grounds. Defendant requests the court that it be stricken from the record. Courts have frequently held that an employee of the assignee of debt does not have personal knowledge necessary to testify about events or documents pertaining to the original creditor. See: Martinez v Midland Credit Management, 250 SW2d (Tex Ct of Ap. 2008), Ex 2; Asset Acceptance v Lodge, 325 SW3d 525, (MO App 2010) Finally, the affidavit has to be made within 10 days preceding the filing of the complaint or issuance of the writ (summons). MCL 600.2145. If the affidavit is made prior to that 10 day period, the affidavit does not serve as Prima Facie evidence and the court cannot put weight of evidence towards that affidavit. In this case the date on the affidavit shows Xxx xx, xxxx and complaint was filed Xxxx xx, xxxx. And, Plaintiff’s witness declaration of Ima Fakepersontoo from Chase Bank is not valid or admissible in Court and should be excluded and struck. Nowhere in the affidavit or its attached “Bill of Sale” is defendant’s name, personal information, or alleged account number as it relates to Plaintiff’s claim as outlined in the pleadings. The witness states that she is "aware of the process of the sale and assignment of electronically stored business records." That is the only background she gives as foundation for her testimony. Later she says "I am not aware of any errors in these accounts." However, I could easily say the same thing and I know nothing about Chase's record keeping practices. The witness does not set forth facts demonstrating that she WOULD know if there had been errors in the accounts. General familiarity with assignment of electronic records has nothing to do with account data entry and reconciliation. That statement should not be admitted. In the case of both declarations, Plaintiff attempts to include hearsay evidence in the proceedings without the ability of the trier of fact to evaluate the credibility of the witness. CONCLUSION Plaintiff has failed to meet its burden of proof. Midland LLC has failed to show an account stated exists or existed at any time. Plaintiff has not itemized the total sum upon which the complaint is based, including the date of each item or transaction; a description of the services, materials or goods supplied or other considerations rendered; and the price or charge made for each item or transaction. The documentation supporting the alleged Bill of Sale from the original creditor to Midland DOES NOT CONTAIN OR REFERENCE ANY PERSONAL INFORMATION PERTAINING TO THE DEFENDANT NAMED IN THIS SUIT. Based upon Michigan and other cited case law, Defendant is entitled to a Summary Disposition and judgement as a matter of law. WHEREFORE, Defendant respectfully requests that this Honorable Court grant judgement in Defendant’s favor and dismiss this suit with prejudice. Dated: Xxxxxx xx, xxxx _____________________________ Beefer Real Defendant, In Pro Per
  4. Hi gang, this is my next item on the agenda as I continue to battle Midland. Last week was my opposition to Midland's 'Motion to Vacate Judgement and Set Aside' (Look for that post elsewhere on the forum; just the fact that I am now preparing a Motion for Summary Disposition is a clue as to how last Friday's events turned out). The trial date is set for a few weeks down the road; in the meantime I am going to hit them with a MSJ (it's actually a MSD in Michigan). This'll be a two-parter; first comes the motion, then comes the brief. I followed the exact form that Plaintiff followed when they filed their own MSJ on me last August. DEFENDANT’S MOTION FOR SUMMARY DISPOSITION PURSUANT TO MCR 2.116 © (10) Now comes Defendant Beefer Real, Pro Se, for his Motion for Summary Disposition pursuant to MCR 2.116 © (10) states as follows: 1) That on or about June 20, 2013, Plaintiff filed his action, and Defendant was properly served. 2) The action filed by the Plaintiff was related to a credit card account that Plaintiff alleges belonged to the Defendant and was allegedly procured by Plaintiff from Chase Bank. 3) Defendant sent Request for Discovery via certified mail with return receipt to Plaintiff’s council on Xxxxxx xx, xxxx. Defendant received Plaintiff’s answers on or about Xxxxx xx, xxxx. 4) That Plaintiff, after an adequate period of discovery, has not been able to produce, and will not be able to produce, evidence sufficient to allow the trier of fact to find that Defendant is indebted to the Plaintiff. 5) The Plaintiff has used hearsay statements in the pleadings of this case. 6) That an examination of the attached documentation originally provided by Plaintiff, along with Plaintiff’s responses to interrogatories during discovery, has left Plaintiff with a lack of standing. Without standing, the case cannot be ruled in Plaintiffs favor. WHEREFORE, Defendant respectfully requests that this Honorable Court grant judgement in Defendant’s favor and dismiss this suit with prejudice. Dated: Xxxxxx xx, xxxx _____________________________ Beefer Real
  5. Latest update: the judge ruled in favor of their motion to set aside the verdict. He did order that they pay me $100 for my lost time from work along with time spent preparing for the motion, so I guess there was a little payback anyways. I am half tempted to contact them and say that I'll forget about the hundred bux if they drop the case and save themselves further embarrassment. In the meantime, I will spend this weekend getting a Motion for Summary Disposition ready to go so I can file first thing Monday morning. The main point of contention is that they have no Bill of Sale showing my name or information, along with the usual hearsay affidavits from both Midland and Chase.
  6. Okay, here is the Opposition as it was submitted to the court. And yep bmc100, it is double-spaced and typed in 12 pt font in the Word document: MEMORANDUM IN OPPOSITION TO PLAINTIFFS MOTION TO VACATE DEFAULT JUDGEMENT 1. Statement of Facts: 1. Plaintiff filed his action on xxxx xx, xxxx and Defendant was properly served. 2. The action filed by the Plaintiff was related to a credit card account that Plaintiff alleges belonged to the Defendant and was allegedly procured by Plaintiff from Chase Bank. 3. The original trial date was set for xxxxxxx xx, xxxx. At that proceeding, Plaintiff requested and received a new trial date of xxxxxxx xx, xxxx in order to allow for discovery by both parties. 4. On xxxxxxx xx, xxxx the trial was held and Plaintiff failed to appear. A default judgement was entered against Plaintiff. 5. On xxxxxxx xx, xxxx Plaintiff filed a Motion to Set Aside Dismissal and Reinstate on the grounds of MCR 2.612©(1)(a), which states that ‘On motion and on just terms, the court may relieve a party or a legal representative of a party from a final judgement, order, or proceedings on the following grounds: (a) Mistake, inadvertence, surprise, or excusable neglect. ARGUMENT I. Dismissal should not be set aside under MCR2.612©, because it was through mistake, inadvertence, surprise or excusable neglect. Plaintiff’s motion cites “inadvertence” as the claim agent relating to MCR 2.612©. Plaintiff does not supply a declaration as to why the inadvertence occurred other than the statement in Paragraph 4 of Plaintiff’s motion that ‘Plaintiff’s attorney failed to properly calendar the adjourned trial date and failed to appear for the trial scheduled on xxxxxxx xx, xxxx at 2:00.’ A review by the court will find that Plaintiff’s attorney, xxxxxx xxxxx, originally requested the adjournment from the court in person on the original trial date of xxxxxxx xx, xxxx and received the rescheduled date of xxxxxxx xx, xxxx from this honorable court at the same time that the Defendant received it. It should be further noted that the original trial date of xxxxxxx xx, xxxx has been the only court date so far that one of Plaintiff’s attorneys named in the court documents have been present, while the Defendant in this case, representing himself Pro Se, has not missed a single date during the court proceedings for this trial, up to and including the Civil Pre-Trial, a Motion for Summary Judgement that was brought by Plaintiff, the original trial date of xxxxxxx xx, xxxx, and the rescheduled trial date of xxxxxxx xx, xxxx. The intent of MCR 2.612© is to provide relief from errors by the court, improper service, or Acts of God, not a party forgetting to show up with proper notice (and especially if the party requested the new date in the first place). MCR 2.612 ( c)(1)(a) governs motions for relief from judgment and provides that "[o]n motion and on just terms, the court may relieve a party or the legal representative of a party from a final judgment, order, or proceeding" on the basis of "[m]istake, inadvertence, surprise, or excusable neglect." "Mistake" for purposes of MCR 2.612 (c )(1)(a), may be that of the trial court. Fisher v Belcher, 269 Mich App 247, 262; 713 NW2d 6 (2005), citing Altman v Nelson, 197 Mich App 467, 477; 495 NW2d 826 (1992). This Court has also held that relief from a judgment will generally only be granted in extraordinary circumstances and where the failure to grant the relief would result in a substantial injustice. Gillispie v Bd of Tenant Affairs of the Detroit Housing Comm, 145 Mich App 424, 427-428; 377 NW2d 864 (1985). In Farm Bureau Mut. Ins. Co. of Mich. v. Buckallew, 471 Mich. 940, 940 (2004), the insurance agency agreed to settle a wrongful death action of the defendant for $300,000. However, after the defendant dismissed the case, "plaintiff refused to pay the agreed settlement amount because it exceeded its no-fault policy limit for the underlying accident, a fact that neither party realized when they settled." The MI Supreme Court ruled that that "Plaintiff's mistake in understanding its own policy is not a mistake or excusable neglect that can be a basis for relief under MCR 2.612 (c )(1)(a). Plaintiff had access to all the necessary information, and its error is not excused by its own carelessness or lack of due diligence.” And since, in this current case, the plaintiff's attorney is the one who requested an adjournment of the first trial, he should have been especially aware of the next trial date. In addition, Defendant has attached as Exhibit 1 the Michigan Supreme Court decision regarding Banta vs. Serban in 1963 that is very relevant to this honorable court’s decision to not grant Plaintiff’s motion. Defendant reminds the court that Plaintiff, by their own admission, consider themselves “one of the nation’s biggest buyers of unpaid debt. Midland Funding LLC purchases accounts with an unpaid balance where consumers have gone at least 180 days without making a payment, or paid less than the minimum monthly payment.”(Quoted from: Midland Funding LLC home page website http://www.midlandcreditonline.com). Defendant raises this point in his opposition motion because it is well known that buyers of unpaid consumer debt, AKA “junk debt buyers” generally survive by taking “Default Judgments” from the consumers they file suit. Any quick research will show that it is a generally accepted fact that junk debt buyers, thru their satellite law firms, file for default judgments in 90%-95% of the cases they bring, based on the defendant’s in those cases failing to answer the complaints on time. Furthermore, it is the Defendant’s supposition that this ‘inadvertence’ by Plaintiff occurred mainly because Plaintiff is stalling for time. Plaintiff admitted during discovery that several key documents have not been procured from the alleged original creditor and that Plaintiff ‘has requested additional information and will supplement (these) response(s) upon receipt’. Summary and Conclusion The court should see the poetic justice in that the Plaintiff whose monetary success is determined on a daily basis against the number of default judgments it receives, is here motioning the court to vacate the entry of default, against the Defendant. Defendant believes this court should deny the Motion as it is not complete, it is missing a copy of the answer or other pleading pursuant to the Michigan Civil Procedure2.612© it is being brought. Plaintiff’s motion fails to prove mistake, inadvertence, surprise, or excusable neglectand should be dismissed. Defendant feels that Plaintiff is merely stalling for time, and should have known the trial date, since Plaintiff was the entity that requested the new date in the first place. Respectfully submitted, Dated:_____________, 2013 By_______________________
  7. True that k-krab; I had not thought of it in that way, but I did bring it up in a roundabout way in my opposition brief by mentioning that I think Midland is stalling because they do not have requested documents together yet (Hello? Bill of Sale?). Also, this is the same judge that denied their MSJ back in August. If given the chance I will reiterate it during the time the motion is being heard. Even if the judge grants their request to set aside the verdict, there will be a sound argument for requesting that Midland re-file the suit.
  8. The last few posts in the thread have given me some excellent case law to cite and have moved the Limbach case to the back of the line; I've pulled it out of the response. I am now citing from three different posts: the Farm Bureau case, the 1963 Michigan Supreme Court Case, and the cases cited in debtzapper's post. But the Limbach case was a great place to start; the other cases springboarded from it after it was posted. Y'all are a bunch of bloodhounds, I am just figuring out how to best navigate Google Scholar.
  9. It is an excellent example. One would think that it would be cited in later cases. But then again, in reading the document, the reason that more recent cases are hard to find is spelled out: " Very few cases have been presented to this Court for review of dismissals for failure of plaintiffs to respond to trial calls, and perhaps the infrequency of such appeals would justify our conclusion that such dismissals rarely occur. That they should rarely occur is obvious".
  10. OK gang, here is my opposition to their motion, I intend on filing it no later than Tuesday morning: MEMORANDUM IN OPPOSITION TO PLAINTIFFS MOTION TO VACATE DEFAULT JUDGEMENT 1. Statement of Facts: Plaintiff filed his action on xxxxxxx and Defendant was properly served. The action filed by the Plaintiff was related to a credit card account that Plaintiff alleges belonged to the Defendant and was procured by Plaintiff from Chase Bank. The original trial date was set for xxxxxxx. At that proceeding, Plaintiff requested and received a new trial date of xxxxxxx in order to allow for discovery by both parties. On xxxxxxx the trial was held and Plaintiff failed to appear. A default judgement was entered against Plaintiff, and on xxxxxxx Plaintiff filed a Motion to Set Aside Dismissal and Reinstate on the grounds of MCR 2.612©(1)(a), which states that ‘On motion and on just terms, the court may relieve a party or a legal representative of a party from a final judgement, order, or proceedings on the following grounds: (a) Mistake, inadvertence, surprise, or excusable neglect. ARGUMENT I. Dismissal should be set aside under MCR 2.612©, because it was through mistake, inadvertence, surprise or excusable neglect. Plaintiff’s motion cites “inadvertence” as the claim agent relating to MCR 2.612©. Plaintiff does not supply a declaration as to why the inadvertence occurred other than the statement in Paragraph 4 that ‘Plaintiff’s attorney failed to properly calendar the adjourned trial date and failed to appear for the trial scheduled on December 3, 2013 at 2:00.’ A review by the court will find that Plaintiff’s attorney, XXXXXXX, originally requested the adjournment from the court on the original trial date of xxxxxxx and received the rescheduled date of xxxxxxx from this honorable court at the same time that the Defendant received it. It should be further noted that the original trial date of xxxxxxxx has been the only court date so far that one of Plaintiff’s attorneys named in the court documents have been present, while the Defendant in this case, representing himself Pro Se, has not missed a single date during the court proceedings for this trial, up to and including the Civil Pre-Trial, a Motion for Summary Judgement, the original trial date of xxxxxxxx, and the rescheduled trial date of xxxxxxxx. The only way for Plaintiff to challenge a judgment once it is entered in the court record is to prove they were not served process or that the court lacked subject matter jurisdiction, fraud was involved, or matters beyond their control occurred such as a medical incident, traffic mishap, etc.. Plaintiffs motion does nothing to prove lack of process, lack of subject matter jurisdiction, fraud, or matters beyond their control. The intent of MCR 2.612© is to provide relief from errors by the court, improper service, or Acts of God, not a party forgetting to show up with proper notice (and especially if the party requested the new date in the first place). In Limbach v. Oakland Bd. of Road Com'rs 226 Mich App 389, 573 N.W.2d 336 (1997), the court ruled that MCR 2.612©(1)(a), was not "designed to relieve counsel of ill-advised or careless decisions". Lark v. Detroit Edison Co, 99 Mich. App. 280, 283, 297 N.W.2d 653 (1980). Defendant reminds the court that Plaintiff, by their own admission, considers themselves “one of the nation’s biggest buyers of unpaid debt. Midland Funding LLC purchases accounts with an unpaid balance where consumers have gone at least 180 days without making a payment, or paid less than the minimum monthly payment.” (Quoted from: Midland Funding LLC home page website http://www.midlandcreditonline.com). Defendant raises this point in his opposition motion because it is well known that buyers of unpaid consumer debt, AKA “junk debt buyers” generally survive by taking “Default Judgments” from the consumers they file suit. Any quick research will show that it is a generally accepted fact that junk debt buyers, thru their satellite law firms, file for default judgments in 90%-95% of the cases they bring, based on the defendant’s in those cases failing to answer the complaints on time. Furthermore, it is the Defendant’s supposition that this ‘inadvertence’ by Plaintiff occurred mainly because Plaintiff is stalling for time. Plaintiff admitted during discovery that several key documents have not been procured from the alleged original creditor and that Plaintiff ‘has requested additional information and will supplement (these) response(s) upon receipt’. Summary and Conclusion The court should see the poetic justice in that the Plaintiff whose monetary success is determined on a daily basis against the number of default judgments it receives, is here motioning the court to vacate the entry of default, against the Defendant. Defendant believes this court should deny the Motion as it is not complete, it is missing a copy of the answer or other pleading pursuant to the Michigan Civil Procedure 2.612© it is being brought. Plaintiffs motion fails to prove mistake, inadvertence, surprise, or excusable neglect and should be dismissed. Defendant feels that Plaintiff is merely stalling for time, and should have known the trial date, since Plaintiff was the entity that requested the new date in the first place. Respectfully submitted, Dated:_____________, 2013 By_______________________
  11. BV80, let me take this time to tell you "Thank you". Many were the nights when I sat at the computer drawing inspiration from your threads, along with several other posters. No, they are not citing (f). They are citing (1)(a): Mistake, inadvertence, surprise, or neglect. 'Inadvertence' is flat-out mentioned in their motion, they are saying that 'Plaintiff's attorney failed to properly calendar the adjourned trial date'. Which is simply amazing; since he is the one that requested the adjournment in the first place.
  12. Semper Fi, BTO429! My daughter is currently at Lejeune undergoing her Advanced Combat Training! Regarding your post, can you bust that down into plainer English, or point me in the direction of a couple of threads that refer to it? I am going to begin wordsmithing the document that skippy1960 attached in his reply.