|Sleazy Court Tactics on PTOI:|
So Seneca files this motion stating the company is out of money....blah blah blah.....And what is his motive pray tell?
Why to scare any potential investors of course, and to drive the SP down............and WHY does he do that?
Cause his blackmailing attempts FAILED.
What a sleaze ball.
Now here's some actual documentation to prove this:
Response to so called Discovery papers that were NEVER SENT.
2. On July 30, 2014, I received an email from Plaintiff's counsel, Rebecca Fuller,
transmitting Plaintiffs request for production, request for admissions, and first set of
interrogatories. (A copy of that email is attached to Plaintiff's motion [D.E. 33-5]) This was the
first time I, or anyone else at Carlton Fields Jorden Burt, P.A., learned that Plaintiff had issued
written discovery in this matter.
3. As a result, on July 31, 2014, I caused to be reviewed every fax transmission
received by Carlton Fields Jorden Burt, P.A.'s Miami office on June 26, 2014, which are
maintained on Carlton Fields Jorden Burt, P.A.'s network, and can confirm that no fax was
received from or on behalf of Plaintiff on June 26, 2014. (Due to the sensitivity of the June 26,
2014 faxes reviewed, they are not attached to this declaration.)
4. I also caused to be reviewed the electronic file maintained for this matter, and can
confirm that Plaintiff s June 26, 2014 discovery requests were also not received at Carlton Fields
Jorden Burt, P.A.'s Miami office by U.S. mail. It is Carlton Fields Jorden Burt, P.A.'s regular
Case 0:13-cv-61809-RLR Document 35-2 Entered on FLSD Docket 08/28/2014 Page 1 of 2
business practice to image all incoming mail and load it to the corresponding electronic file.
Based on my understanding of this business practice, the absence of any record from the
electronic file indicates that the discovery requests had not been received by U.S. mail.
5. In fact, as of the date this declaration is being signed, neither I nor anyone else at
Carlton Fields Jorden Burt, P.A. have ever received Plaintiff's discovery requests by fax or U.S.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct based on information in my possession and information provided to
LYING response of attys that 'supposedly' sent these Discovery Papers.....
My question is....instead of 'recovering the transmission reports'........why didn't they just INCLUDE them in this response?
You know why they're not included.............cause they DO NOT EXIST:
While we are certain that the discovery requests in question were sent to your office on June 26, 2014, and are recovering
the transmission reports to indicate the same, we are willing to agree to an additional 30 days to respond, until August 30,
2014; provided, however, that we will schedule mediation in this matter for mid-September of 2014.