TSINAH’s lawyer comes out HARD against epah’s MTD sham complaint
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Poast new message in this thread
Date: August 31st, 2022 12:14 PM Author: Glittery prole mad-dog skullcap
Wait. So EPAH filed a second motion to dismiss with what I assume is a rambling 42 page declaration. Then later that day the plaintiff filed a second amended complaint, mooting EPAH's lengthy second MTD. And because Florida doesn't have the common sense rule that you can only amend once without leave, the plaintiff can just keep amending and making EPAH move to dismiss again and again?
180 rooting for you EPAH. Did you draft the 42 page declaration on the beach stream of consciousness all in one go?
(http://www.autoadmit.com/thread.php?thread_id=5183119&forum_id=2#45098900) |
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Date: September 2nd, 2022 6:20 PM Author: hot old irish cottage
Epah's "erratic thinking" put on BLAST (but the court said "nah let's just do Zoom"):
Your Honor:
This letter shall serve as a summary of the reasons why the Court should deny Defendant [epah]’s request to conduct these proceedings via Zoom.
As a threshold matter, Mr. [epah]’s Motion to Strike the First Amended Complaint as a Sham Pleading; or in the Alternative to Dismiss is moot. During this litigation, Mr. [epah] emailed the undersigned no fewer than two motions for sanctions pursuant to section 57.105, Florida Statutes. They are attached hereto as Exhibits A and B. By filing the Second Amended Complaint, Plaintiff has availed himself of the “last clear chance” that Mr. [epah] extended to Plaintiff to correct some of minor issues that he complained of pursuant to Florida Rule of Civil Procedure 1.190(a). See Ex. B.at Bates No. 000010.
Second, given the evidentiary and fact intensive analysis required by the motions that Mr. [epah] has reflexively filed, these hearings must be conducted in person. Plaintiff intends to examine Mr. [epah] under oath, along with others, to oppose his motions. Further, without getting too deep into the weeds, Plaintiff insists on these hearings being held in person because Mr. [epah] has already materially misled the Court on matters pertaining to personal jurisdiction over him, e.g., his client [cigar co.'s] corporate citizenship. See Ex. C at Bates No. 000001 (demonstrating that [cigar co's] principal address is [address in Florida]).
Third, from the onset of this litigation, Mr. [epah]’s behavior has been abhorrent, and he has already engaged in bizarre conduct which merits this Court’s close supervision and scrutiny. The mootness and evidentiary issues aside, Mr. [epah]’s reflexively threatened motions for sanctions brought pursuant to section 57.105, Florida Statutes—along with the threat of a meritless suit for malicious prosecution—were lodged in bad faith, are designed to harass Plaintiff and his counsel, and are sanctionable themselves under the Court’s inherent authority and section 57.105, Florida Statutes, itself. See Ex. A at Bates No. 000001.
Indeed, in his first 57.105 motion, it is apparent that Mr. [epah] has, and continues to, cyberstalk the undersigned in violation of section 784.048, Florida Statutes. Specifically, he included my social media information in a footnote for no other reason than to harass and intimidate me. See Ex. A at Bates No. 000012, n.4.
Further, Mr. [epah] erratically thinks that he can continue to tortiously interfere with Plaintiff’s and his lawyer’s attorney-client relationship without facing consequences. He has yet again interjected himself into their attorney-client relationship by contacting United States District Judge Robert Pitman’s chambers via email to accuse them of “attempting to perpetuate a fraud on th[is] Florida court[.]” Ex. D at Bates No. 000003. Plaintiff is in the process of drafting a petition for a preliminary injunction to stop this outrageous conduct.
In sum, Plaintiff believes that the relief sought by way of the requested hearing is moot. Second, given the fact intensive and evidentiary nature of the motions—the Court must conduct traditional in-person hearings. And third, Mr. [epah]’s own conduct throughout this nascent litigation has already demonstrated that close Court supervision and scrutiny is required to control his erratic behavior. As the Court knows, our Supreme Court’s motto is Sat Cito Si Recte, which means “Soon enough if done rightly.” Given Mr. [epah]’s scorched earth litigation tactics, we must do this one right. For these reasons, Plaintiff requests that all hearings be conducted in person for the duration of the litigation.
(http://www.autoadmit.com/thread.php?thread_id=5183119&forum_id=2#45111718)
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Date: September 2nd, 2022 7:14 PM Author: hot old irish cottage
"e.g., his client [cigar co.'s] corporate citizenship. See Ex. C at Bates No. 000001"
For this he cited a 2015 doc on file with the *Oregon* SOS (because the SOS for Florida in 2016 says cigar co is HQed in CA).
Thoughts?
(http://www.autoadmit.com/thread.php?thread_id=5183119&forum_id=2#45111966) |
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Date: September 3rd, 2022 7:12 PM Author: cyan trip private investor
To be fair,
Extremely gay and retarded.
In other words: "Based."
(http://www.autoadmit.com/thread.php?thread_id=5183119&forum_id=2#45116009) |
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