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ZZZ files motion to DISQUALIFY backwater FL judge who canceled him

To paraphrase: "No impartial judge could fail to see t...
Ungodly Purple Hospital Travel Guidebook
  06/06/23
I don't get it. You have to call "minimum contacts&quo...
odious business firm
  06/06/23
Please post the text of the last ruling and the text of this...
Fishy Lay Cuck
  06/06/23
It's too long and would require too many edits but it's all ...
Ungodly Purple Hospital Travel Guidebook
  06/06/23
180 if he really did this
Naked clown theater
  06/06/23
get a real job you stupid ass bitch
aphrodisiac snowy really tough guy therapy
  06/06/23
Hi RT. How have you been?
Naked clown theater
  06/06/23
...
Peach Pungent Base Place Of Business
  06/06/23
...
drab kitchen
  06/07/23
are Meatball Ron's associations with this crew gonna come to...
Peach Pungent Base Place Of Business
  06/06/23
I've already had one inquiry from a freelancer trying to fin...
Ungodly Purple Hospital Travel Guidebook
  06/06/23
180
Peach Pungent Base Place Of Business
  06/06/23
*Bozo Rising*
Razzle burgundy toaster
  06/07/23
...
Sienna Cracking Ceo
  06/07/23
oh man, despite our different viewpoints politically, i thin...
Translucent theater stage
  06/07/23
...
Talented yapping pistol people who are hurt
  06/07/23
Lol
Ruby crusty library
  06/08/23
LMAO
Sienna Cracking Ceo
  06/07/23
wait are they still trying to fight this shit case?
swashbuckling ivory state
  06/07/23
RT has a theory that an EJ win for >$1,000 will mean that...
Ungodly Purple Hospital Travel Guidebook
  06/07/23
Wow. It's like watching two drunks swinging at each other in...
Razzle burgundy toaster
  06/07/23
what did your ultimate verdict against him come to with fees...
Topaz Stock Car
  06/07/23
Haven’t filed for fees yet. First his JMOL has to get ...
Ungodly Purple Hospital Travel Guidebook
  06/07/23
Complete text: Plaintiff respectfully moves this Court to...
Sienna Cracking Ceo
  06/07/23
this is an absolutely brilliant piece of legal writing, and ...
Naked clown theater
  06/07/23
Fe Fi Fo Fum This Judge is Unfit to Wipe My Bum
Glittery Jap
  06/07/23
...
swashbuckling ivory state
  06/07/23
...
Sienna Cracking Ceo
  06/07/23
...
Talented yapping pistol people who are hurt
  06/07/23
LOL
Fighting shrine
  06/07/23
HOLY FUCK, the “useful guidance” this retard is ...
Ungodly Purple Hospital Travel Guidebook
  06/07/23
this was written by CHATGPT, your honor
Sienna Cracking Ceo
  06/07/23
I have $100 says that’s what he did. It’s otherw...
Ungodly Purple Hospital Travel Guidebook
  06/07/23
...
Sienna Cracking Ceo
  06/07/23
which florida county is this case in so i can find it?
vibrant nighttime whorehouse
  06/07/23
I forget what it’s called but it has Gainesville in it...
Ungodly Purple Hospital Travel Guidebook
  06/07/23
alachua
Glittery Jap
  06/07/23
ty. i realized i had searched before when i saw the bizarre...
vibrant nighttime whorehouse
  06/07/23
Seems like sanctionable and referrable conduct.
Supple location
  06/07/23
Motions to disqualify in FL are granted almost automatically...
Up-to-no-good party of the first part haunted graveyard
  06/07/23
“ Motions to disqualify in FL are granted almost autom...
curious black locale
  06/07/23
ZZZ is a terrible lawyer
Sienna Cracking Ceo
  06/07/23
doesnt really seem like this motion meets this low bar
Glittery Jap
  06/07/23
This is just a guess, but I think that’s the standard ...
Ungodly Purple Hospital Travel Guidebook
  06/07/23
Shit, this ZZZ sounds like an asshole. Any chance he's right...
Hairraiser abnormal forum azn
  06/07/23
No idea it’s not my case
Ungodly Purple Hospital Travel Guidebook
  06/07/23
in FL, you can do it anytime
Up-to-no-good party of the first part haunted graveyard
  06/07/23
Yeah, I’m gonna go ahead and suppose that my instinct ...
Ungodly Purple Hospital Travel Guidebook
  06/07/23
dude just check some case law
Up-to-no-good party of the first part haunted graveyard
  06/07/23
Obv you could be right, but does it vacate the past orders t...
Ungodly Purple Hospital Travel Guidebook
  06/07/23
I'm not part of this case, but it doesn't matter because you...
Up-to-no-good party of the first part haunted graveyard
  06/07/23
Thought you were in "privity" with ZZZ?
Aromatic swollen dopamine legal warrant
  06/07/23
Before a judge with chambers next to the last one? You and ...
Ungodly Purple Hospital Travel Guidebook
  06/07/23
Remember you are arguing with TSINAH, a failed shitlawyer wh...
Talented yapping pistol people who are hurt
  06/07/23
TSINAH is a community account. I’m guessing that ZZZ ...
Sienna Cracking Ceo
  06/07/23
What did you mean by this? http://www.autoadmit.com/threa...
Up-to-no-good party of the first part haunted graveyard
  06/07/23
is that sp?
Naked clown theater
  06/07/23
...
Aromatic swollen dopamine legal warrant
  06/07/23
"Motions to disqualify in FL are granted almost automat...
vibrant nighttime whorehouse
  06/07/23
it's literally true
Up-to-no-good party of the first part haunted graveyard
  06/07/23
unbelievable, def not the case in CA
Hairraiser abnormal forum azn
  06/07/23
...
vibrant nighttime whorehouse
  06/07/23
38.10 Disqualification of judge for prejudice; applicat...
Up-to-no-good party of the first part haunted graveyard
  06/07/23
"Motions to disqualify in FL are granted almost automat...
bull headed violent filthpig coldplay fan
  06/07/23
>"the judge ruled against me and i don't trust the j...
Up-to-no-good party of the first part haunted graveyard
  06/07/23
this is pretty close: "the party reasonably fears th...
bull headed violent filthpig coldplay fan
  06/07/23
Some states (a lot of them, actually) allow peremptory excus...
Cerebral school
  06/07/23
really? that is insane.
Naked clown theater
  06/07/23
*only* the first motion to disqualify. You can't just move t...
Up-to-no-good party of the first part haunted graveyard
  06/07/23
is there any chance this motion succeeds? he said that 1. th...
Naked clown theater
  06/07/23
Because you take the sworn facts as gospel in evaluating a m...
Up-to-no-good party of the first part haunted graveyard
  06/07/23
even if taken as true, no i don't
Naked clown theater
  06/07/23
enjoy the petition for a writ of prohibition!
Up-to-no-good party of the first part haunted graveyard
  06/07/23
explain like i'm not a shitlawyer brother. i'm not folliwng ...
Naked clown theater
  06/07/23
yes, actually
Up-to-no-good party of the first part haunted graveyard
  06/07/23
i would like to hear your reasoning. if you are right, then...
Naked clown theater
  06/07/23
TSINAH is one of the leading legal minds of Florida AND Mich...
Sienna Cracking Ceo
  06/08/23
FL rule: (e) Grounds. A motion to disqualify shall set fort...
bull headed violent filthpig coldplay fan
  06/07/23
does whether this happens post-Answer have any effect on thi...
vibrant nighttime whorehouse
  06/07/23
no
Up-to-no-good party of the first part haunted graveyard
  06/07/23
The sole basis of the "impropriety" is that you th...
Khaki Histrionic Rehab
  06/07/23
lol Candy Ride
marvelous red nursing home
  06/07/23
...
razzle-dazzle macaca
  06/08/23
Why does he include pages and pages of block quotes? Ive nev...
Sienna Cracking Ceo
  06/07/23
Why does Kareem keep doing that skyhook? I've never seen ba...
vibrant nighttime whorehouse
  06/07/23
...
Glittery Jap
  06/07/23
...
Sienna Cracking Ceo
  06/07/23
...
Cerebral school
  06/07/23
...
henna abode internal respiration
  06/07/23
...
racy affirmative action mad-dog skullcap
  06/08/23
Why is ZZZ doing all this? This seems crazy that he would ke...
curious black locale
  06/07/23
He’s desperate for clients
Sienna Cracking Ceo
  06/07/23
cq
Peach Pungent Base Place Of Business
  06/08/23
All of this hoopla over an Audi Q5
Sienna Cracking Ceo
  06/07/23
I love the jurisprudential stand-off ITT EPAH: That would...
racy affirmative action mad-dog skullcap
  06/07/23
...
Sienna Cracking Ceo
  06/07/23
...
henna abode internal respiration
  06/07/23
Guys after all these years of seeing me and TSINAH’s r...
Ungodly Purple Hospital Travel Guidebook
  06/08/23
...
razzle-dazzle macaca
  06/08/23
Let's see what happens with a petition for a writ of prohibi...
Up-to-no-good party of the first part haunted graveyard
  06/08/23
Lol jfc TSINAH never not doubling down
racy affirmative action mad-dog skullcap
  06/08/23
he's literally DONE here
vibrant nighttime whorehouse
  06/08/23
This reminds me that I'm a pretty good legal writer. Too bad...
Poppy Wonderful Dilemma
  06/07/23
https://circuit8.org/wp-content/uploads/JudgeWalker_NewPic10...
Up-to-no-good party of the first part haunted graveyard
  06/07/23
That is the face of someone who likes to have her competence...
racy affirmative action mad-dog skullcap
  06/07/23
cr, this will end very well for zzz
Naked clown theater
  06/07/23
180
drab kitchen
  06/08/23
She has.to.go back
Hyperventilating Old Irish Cottage National
  06/07/23
It’s fine (slightly less ghetto than most of LA), but ...
Misanthropic address stain
  06/08/23
Thanks
Ungodly Purple Hospital Travel Guidebook
  06/08/23
...
henna abode internal respiration
  06/08/23
...
Glassy floppy main people hunting ground
  06/08/23
looks like ZZZ is dun here
Naked clown theater
  06/08/23
He was done the moment he took on these garbage cases.
Fishy Lay Cuck
  06/08/23
literally Plaintiff’s motion is hereby DENIED as le...
vibrant nighttime whorehouse
  06/08/23
Candy Ride free thread. odd case 🤔
marvelous red nursing home
  06/08/23
Super odd. TBF not in here either. Odd.
Fighting shrine
  06/08/23
very strange
marvelous red nursing home
  06/08/23
lmao at tsinah's posts itt. zzz MIGHT be able to get this j...
Titillating Piazza
  06/08/23
What? That would actually be a legally insufficient motion t...
Up-to-no-good party of the first part haunted graveyard
  06/08/23


Poast new message in this thread



Reply Favorite

Date: June 6th, 2023 7:36 PM
Author: Ungodly Purple Hospital Travel Guidebook

To paraphrase: "No impartial judge could fail to see that jurisdiction is like a bankshot in basketball, and therefore with the utmost respect we respectfully ask the judge to recuse herself from future matters that me and EJ may file against EPAH and RK."

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46397009)



Reply Favorite

Date: June 6th, 2023 8:10 PM
Author: odious business firm

I don't get it. You have to call "minimum contacts" before you shoot?

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46397112)



Reply Favorite

Date: June 6th, 2023 7:39 PM
Author: Fishy Lay Cuck

Please post the text of the last ruling and the text of this motion.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46397024)



Reply Favorite

Date: June 6th, 2023 7:43 PM
Author: Ungodly Purple Hospital Travel Guidebook

It's too long and would require too many edits but it's all very stupid

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46397040)



Reply Favorite

Date: June 6th, 2023 7:53 PM
Author: Naked clown theater

180 if he really did this

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46397068)



Reply Favorite

Date: June 6th, 2023 7:57 PM
Author: aphrodisiac snowy really tough guy therapy

get a real job you stupid ass bitch

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46397078)



Reply Favorite

Date: June 6th, 2023 8:06 PM
Author: Naked clown theater

Hi RT. How have you been?

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46397091)



Reply Favorite

Date: June 6th, 2023 8:09 PM
Author: Peach Pungent Base Place Of Business



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46397101)



Reply Favorite

Date: June 7th, 2023 4:23 PM
Author: drab kitchen



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400353)



Reply Favorite

Date: June 6th, 2023 8:10 PM
Author: Peach Pungent Base Place Of Business

are Meatball Ron's associations with this crew gonna come to light in the 2024 campaign?

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46397105)



Reply Favorite

Date: June 6th, 2023 8:14 PM
Author: Ungodly Purple Hospital Travel Guidebook

I've already had one inquiry from a freelancer trying to find a home for his story on this. In responding to his questions, I mocked, but I neither defamed nor threatened.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46397124)



Reply Favorite

Date: June 6th, 2023 8:16 PM
Author: Peach Pungent Base Place Of Business

180

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46397127)



Reply Favorite

Date: June 7th, 2023 4:14 PM
Author: Razzle burgundy toaster

*Bozo Rising*

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400316)



Reply Favorite

Date: June 7th, 2023 4:20 PM
Author: Sienna Cracking Ceo



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400338)



Reply Favorite

Date: June 7th, 2023 5:50 PM
Author: Translucent theater stage

oh man, despite our different viewpoints politically, i think you'd be awesome to hang with sometimes

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400634)



Reply Favorite

Date: June 7th, 2023 6:42 PM
Author: Talented yapping pistol people who are hurt



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400764)



Reply Favorite

Date: June 8th, 2023 9:58 AM
Author: Ruby crusty library

Lol

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46402661)



Reply Favorite

Date: June 7th, 2023 4:09 PM
Author: Sienna Cracking Ceo

LMAO

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400290)



Reply Favorite

Date: June 7th, 2023 4:10 PM
Author: swashbuckling ivory state

wait are they still trying to fight this shit case?

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400294)



Reply Favorite

Date: June 7th, 2023 4:33 PM
Author: Ungodly Purple Hospital Travel Guidebook

RT has a theory that an EJ win for >$1,000 will mean that EJ doesn’t owe RK $3.4M because of the balance of equities.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400384)



Reply Favorite

Date: June 7th, 2023 4:44 PM
Author: Razzle burgundy toaster

Wow. It's like watching two drunks swinging at each other in some 4th tier arena

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400416)



Reply Favorite

Date: June 7th, 2023 5:29 PM
Author: Topaz Stock Car

what did your ultimate verdict against him come to with fees etc

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400574)



Reply Favorite

Date: June 7th, 2023 7:58 PM
Author: Ungodly Purple Hospital Travel Guidebook

Haven’t filed for fees yet. First his JMOL has to get denied on June 16. I expect we’ll get around $800k in fees

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46401008)



Reply Favorite

Date: June 7th, 2023 4:13 PM
Author: Sienna Cracking Ceo

Complete text:

Plaintiff respectfully moves this Court to disqualify the Honorable Gloria

Walker (the "Trial Judge") from this case pursuant to Florida Rule of General

Practice and Judicial Administration 2.330. In support of this Motion, Plaintiff states:

1. THE FACTS AND REASONS UPON WHICH THE MOVANT RELIES AS THE GROUNDS FOR DISQUALIFICATION

.1 Florida Rule of General Practice and Judicial Administration 2.330 allows a

party to seek disqualification of the assigned trial judge where the party feels he will not receive a fair trial or hearing because of a specifically described prejudice

or bias of the judge. The Rule provides that, upon receipt of a legally sufficient motion to disqualify, "the judge shall immediately enter an order granting

disqualification and proceed no further in the action."

]

"2022 CA 003042" 174571608 Filed at Alachua CountyClerk 06/05/2023 10:19:24AM EDT

2. The facts constituting the grounds for this Motion were discovered on May 31, 2023, at the hearing on Defendant's Motion to Dismiss (the "Hearing"). They are

being presented to the Court for an immediate ruling. Thus, this motion is timely

filed.

3. This Motion is filed with all due respect to the Court and Trial Judge. Under the

circumstances as outlined below, Counsel, has an ethical responsibility as advocate to seek the remedy of disqualification.

4. Plaintiff fears he will not receive a fair hearing, because of the Court's continuing demonstrable prejudice stemming from Defendants' ex parte communications

with the Trial Judge and prejudice against him at the Hearing of May 31, 2023 manifesting in a the Trial Judge's accusation that Plaintiff is "forum shopping," and the Trial Judge's stated intention of entering an order enjoining Plaintiff from

filing suit against Defendants or refiling this case in another county. 5. Florida Rule of Judicial Administration 2.330(h) states that:

The judge against whom an initial motion to disqualify under subdivision (el is directed may determine only the legal sufficiency ofthe motion and shall not pass on the truth ofthe facts alleged. Ifa n y motion is legally insufficient, an order denying the motion shall immediately be entered. No other reason for denial shall be stated, and an order of denial shall not take issue with the motion. If the motion is legally sufficient, the judge shall immediately enter an order granting disqualification and proceed no further in the action.

6. A recitation of the facts forming the basis for this fear will demonstrate this fear is well-founded.

7. Plaintiff reasonably believes the Trial J u d g e is prejudiced against him. The Trial Judge has taken on the role of advocate for the Defendants, and is no longer an

2

impartial arbitrator in this matter. The actions of the court in (1) inquiring into

an attorneys'work product and decision making, (2) sua sponte, without a notice

hearing or motion of any Party, declaring an its intention to enjoin and otherwise bar Plaintiff from filing another lawsuit against Defendants or refiling this case in another county, (3) directing Defendants to put into the written record by way of proposed orders that Plaintiffis allegedly "forum shopping," and (4) receiving and otherwise reviewing ex parte communications, i.e., attorneys fee logs and records, transmitted from Defendants to the Trial Judge. Thus, the Plaintiff fears that he will not receive a fair hearing is well-founded, objective, and reasonable.

8. "When a judge enters into the proceedings and becomes a participant or an

advocate, a shadow is cast upon judicial neutrality." R.O. v. State, 46 So. 3d 124,

126 (Fla. 3d DCA 2010); see also Williams v. State, 160 So. 3d 541, 544 (Fla. 4th DCA 2015). Trial judges must studiously avoid the appearance of favoring one party in a lawsuit, and suggesting to counsel or a party how to proceed strategically constitutes a breach of this principle. See Chastine v. Broome, 629 So.2d 293 (Fla. 4th DCA 1993) (holding that a trial judge's provision of strategic advice to a party during a trial demonstrated impermissible bias); see also J.F. v. State, 718 So.2d 251 (Fla. 4th DCA 1998) (disapproving a trial judge who assisted with a delinquency prosecution by requesting the production of additional State's evidence).

9. "Prejudice of a judge is a delicate question to raise, but when raised as a bar to the trial of a cause, if predicated on grounds with a modicum ofreason, the judge against whom raised should be prompt to recuse himself." Livingston v. State,

3

441 So.2d 1083, 1085 (emphasis added). Where there is any legally sufficient basis, whether factually accurate or not, for a founded fear of possible prejudice to exist in the mind of a [party], recusal is mandated. See, e.g., Management Corporation of America, Inc. v. Grossman, 396 So.2d 1169 (Fla. 3rd DCA 1981).

10. In the instant case, a reasonably prudent person, would be in fear that the Court, because of the Trial Judge's prejudice or bias deprived him of fair and impartial treatment.

II. THE FACTS AND REASONS UPON WHICH THE MOVANT RELIES AS THE GROUNDS FOR DISQUALIFICATION

1. On May 31, 2023, at the Hearing, the Trial Judge stated that she received "attorneys fee" logs and other communications from the Defendants. Such logs, records, and communications were not served in a contemporaneous manner on Plaintiff and constitute ex parte communications with the Trial Judge.

12. As a result of Defendants' ex parte communications with theTrialJudge Plaintiff reasonable questions the impartiality of the Trial Judge.

13. On May 31, 2023, at the Hearing, after the Trial Judge sua sponte inquired why this case was filed in Alachua County, the Trial Judge expressed her opinion that Plaintiff was allegedly "forum shopping." As a result of the Trial Judge's statement, Plaintiff reasonably questions the impartiality of the Trial Judge.

14. At the Hearing, after the Trial Judge sua sponte stated her opinion that Plaintiff was forum shopping, she declared her intention to enter an order to bar or otherwise enjoin Plaintiff from filing suit against Defendants in another venue in the State ofFlorida.

4

15. Even fi the Trial Judge ultimately does not use the words "temporary injunction" in its order, an order barring Plaintiff from filing suit is effectively an order

imposing a temporary injunction. See Leposky v. Ego, 348 So. 3d 1160, 1162 (Fla. 4th DCA 2022). "To be entitled to a temporary injunction, a party must prove that: (1) irreparable harm will result fi the temporary injunction is not

entered; (2) an adequate remedy at law is unavailable; (3) there is a substantial likelihood of success on the merits; and (4) entry of the temporary injunction will serve the public interest. The party seeking the injunction has the burden to provide competent substantial evidence, and the court's order must contain clear, definite, and unequivocally sufficient factual findings to support each of the four elements." Leposky v. Ego, 348 So. 3d 1160, 1162 (Fla. 4th DCA 2022) (cleaned up).

16. The Trial Judge violated Plaintiff's right to the due process of law when it did not allow him to testify or present countervailing evidence of why a temporary

injunction should not issue, and over Plaintiff's counsel objection, stated remarks to the effect of that the Court has made its ruling, and to file a motion

fi Plaintiff disagreed with it. See Hinners v. Hinners, 312 So. 3d 938, 942 (Fla. 4th DCA 2021) (recognizing that the entry of a temporary injunction without an evidentiary hearing violates due process); Platinum Coast Fin. Corp. v. Farino's, Inc., 662 So. 2d 724, 724 (Fla. 2d DCA 1995) (reversing a temporary injunction where the trial court "failed to permit the appellants to present countervailing evidence of why a temporary injunction should not issue"). Leposky, 348 So. 3d at 1162.

5

17. Further, the Trial Judge violated Florida Rule of Civil Procedure 1.610, which states:

(1) A temporary injunction may be granted without written or oral notice to the adverse party only if:

(A) it appears from the specific facts shown by affidavit or verified pleading that immediate and irreparable injury, loss, or damage will result to the movant before the adverse party can be heard

in opposition; and

(B) the movant's attorney certifies in writing any efforts that have been made to give notice and the reasons why notice should not be required.

(2) Every temporary injunction granted without notice shall be endorsed with the date and hour of entry and shall be filed forthwith

in the clerk's office and shall define the injury, state findings by the court why the injury may be irreparable, and give the reasons why the order was granted without notice if notice was not given. The

temporary injunction shall remain in effect until the further order of the court.

18. Defendants have not shown by affidavit or verified pleading that they would

suffer an immediate and irreparable injury, loss, or damage will result unless the Court entered an injunction or that there is not an adequate remedy at law.

Further, there are no findings by the Trial Judge as to why any purported and speculative injuries to Defendants are "irreparable" or why this injunction was

granted without a properly noticed hearing. Nor could it because even fi Plaintiff were to ultimately file another lawsuit against Defendants in another venue (and Plaintiff were to somehow by liable to Defendants), a sum of money or damages would be appropriate recompense (a lawsuit seeking monetary damages is unmistakably an action at law). State Farm Mut. Auto. Ins. Co. v. Green, 579 So.

2d 402, 403 (Fla. 5th DCA 1991). Moreover, there is no discussion why Defendants would have a «substantial likelihood of success on the merits" or

why an order enjoining him from suing a debt collector and creditor that threatened him and his family would "serve the public interest."

19. Second, the Trial Judge did not require Defendants to post a bond as required by Florida Rule of Civil Procedure 1.610(b). See Shir Law Grp., P.A. v. Carnevale, 317 So. 3d 211, 214 (Fla. 3d DCA 2021) (reversing temporary injunction because

"the order failed to contain sufficient factual findings to support each prong of

the four-part injunction test, and the lower court failed to set an appropriate

bond"); see also Fla. R. Civ. P. 1.610(b) ("No temporary injunction shall be entered unless a bond is given by the movant in an amount the court deems

proper, conditioned for the payment of costs and damages sustained by the

adverse party if the adverse party is wrongfully enjoined.").

20. Third, setting aside the issues stemming from the fundamental requirements of

law, ie, a violation of Plaintiff's constitutional right to due process or an entitlement to bond, the form of the Trial Judge's injunction violated Florida Rule

of Civil Procedure 1.6.10(c) by prohibiting Plaintiff from filing suit against Defendant for facts that gives rise to the Complaint in this case in venue outside

of Alachua County. The Rule states that "[e]very injunction shall specify the reasons for entry, shall describe in reasonable detail the act or acts restrained without reference to a pleading or another document." The incorporation by reference to the Complaint in this action plainly renders the

injunction defective.

21. There has not been a properly noticed evidentiary hearing on any injunction-

let alone on whether Plaintiff should be enjoined from filing other lawsuits

against Defendants or refiling this case in another county. Rule 1.610(a)(2) requires reasonable notice, which is "defined as notice that provides a meaningful opportunity to prepare and defend against the allegations of the

motion or complaint. It means the ability to offer evidence and to secure a record of the proceedings." Harrison v. Palm Harbor MRI, Inc., 703 So.2d 1117 (Fla. 2d DCA 1997). In Harrison, the court held that seven days was sufficient under that standard. See Nelson Tree Serv., Inc. v. Gray, 978 So. 2d 198, 200-01 (Fla. Ist DCA 2008). Plaintiff and his counsel only learned that the Court was considering whether to enter an injunction against him when the Trial Judge announced from the bench it had already decided that it was taking such action against Plaintiff. After Plaintiff's counsel objected to that, the Trial Judge told Plaintiff that she had made her ruling and that Plaintiff could "file a motion."

22. Further, there has been no motion filed by any Party to this case moving the Court for an injunction. The Trial Judge sua sponte issued it thereby entering

the litigation as a party. See R.O. v. State, 46 So. 3d 124, 126 (Fla. 3d DCA 2010); see also Williams v. State, 160 So. 3d 541, 544 (Fla. 4th DCA 2015). When counsel for Plaintiff objected to the Trial Judge's inquiry and injunction against Plaintiff, the Trial Judge stated words to the effect that she had made her decision and to "file a motion." The Trial Judge's failure to afford Plaintiff with either notice or a fair opportunity to be heard deprived him of his constitutional right to the due process of law under the United States and Florida Constitutions, statutory rights under Florida Statutes, and violated the Florida Rules of Civil Procedure and Judicial Administration.

8

23. Further, the Trial Judge's accusation a n d determination that Plaintiff allegedly

"forum shopped" by availing himself of his statutory rights to choose the county

to file suit against nonresidents Defendants under section 47.011, Florida Statutes, "is simply inappropriate in the context of the venue statutes." Houchins v. Florida E. Coast Ry. Co., 388 So. 2d 1287, 1291 (Fla. 3d DCA 1980); § 47.011, Fla. Stat. ("Actions shall be brought only in the county where the defendant resides, where the cause of action accrued, or where the property in litigation is located. This section shall not apply to actions against nonresidents."). As the

Third District observed, a "court cannot give the defendant greater rights than the legislature has seen fit to grant in this statutory scheme by pejoratively describing the plaintiff's exercise of his statutory right to choose a forum as

forum shopping." Id. It wrote:

If a defendant seeks to be relieved from the plaintiff's choice of

forum, his exclusive remedy lies in demonstrating his entitlement to transfer under Chapter 47, Florida Statutes. Sage v. Travelers Indemnity Company of Hartford, 239 So.2d 831 (Fla. 4th DCA 1970). If a defendant, as here, fails in that showing, the plaintiff's choice of forum controls. A court cannot give the defendant greater rights than the legislature has seen fit to grant in this statutory scheme by

pejoratively describing the plaintiff's exercise of his statutory right to choose a forum as "forum shopping." The use of the phrase "forum shopping" is simply inappropriate in the context of the venue statutes.

***

We do not overlook that under Section 47.122, Florida Statutes (1979), a court may transfer a case in "the interests ofjustice." But "interests of justice" is merely an alternative ground for transfer

under established principles of law, not a panacea for ailing motions or the erroneously perceived injustice of "forum shopping." See, e. g. Carborundum Corporation, Pollution Control Division U.

Bay Fabricators, Inc., 461 F.Supp. 437 (D.Tenn. 1978) (transfer to a

9

forum where the defendant could compel the attendance of live

witnesses to offset an otherwise unfair advantage to the plaintiff); Aguacate Consolidated Mines, Inc. v. Deeprock, Inc., 566 F.2d 523 (5th Cir. 1978 (transfer to forum where action not limitations

barred); Vaughn v. American Basketball Association, 419 F.Supp. 1274 (S.D.N.Y.1976) (transfer to forum where law of state within the federal district would require interpretation); Smithline Corp. v. Sterling Drug, Inc., 406 F.Supp. 52 (D.Del.1975); and Continental Grain Co. v. Barge FBL-585, 364 U.S. 14, 80 S.Ct. 1470, 4 L. Ed.2d 1540 (1960) (transfers to forum in which related case involving identical issue pending). But see Ashland Oil, I nc. v. Florida Department of Transportation, supra (holding that the convenience of the court is not a ground for transfer).

Houchins, 388 So. 2d at 1291.

24. Indeed, "i]t is well established that where venue is proper in more than one

county, the choice of forum rests with the plaintiff. See Taylor v. Dasilva, 401

So.2d 1161 (Fla. 3d DCA 1981); Houchins v. Florida E.C. Ry. Co., 388 So.2d 1287

(Fla. 3d DCA 1980). PV Holding Corp. v. Tenore, 721 So.2d 430 (Fla. 3d DCA 1998).

25. Moreover, even if lawfully permitted, the Trial Judge could not make such a finding that Plaintiff "forum shopped" because that conclusion was not supported by competent substantial evidence in the record. The Trial Judge

cannot rely on the unsworn unverified argument of counsel or a party as evidence. See e.g., State v. Brugman, 588 So. 2d 279 (Fla. 2d DCA 1991) (a court, nor anyone "can make a factual determination based on an attorney's unsworn statements.").

26. As a result of the Trial Judge's unsupported statements and opinion that Plaintiff was "forum shopping," and her stated intention of entering an order enjoining Plaintiff from filing suit against Defendants--or refiling this case in

10

another county-Plaintiff reasonable questions the impartiality of the Trial Judge and reasonably fears that he will not be able to get a fair hearing or trial in this cause.

27. Regarding the issue of disqualification alone, it's important to explain that the motion is legally sufficient, because the facts articulated therein (if assumed true) objectively establish an absolute basis for disqualification. Absent argument from the Defense raising the issue of "forum shopping" it's wholly inappropriate for the trial court to opine sua sponte. M.D. Parker Assocs. U. Connor, 339 So. 3d 375 (Fla. 4th DCA 2022) provides some further guidance: Of equal importance, however, is also a longstanding, well-established Florida Supreme Court rule that provides a trial judge may not address the truth of the facts alleged in a motion to disqualify:

Regardless of whether [the trial judge] ruled correctly in denying the motion for disqualification as legally insufficient, our rules clearly provide, and we have repeatedly held, that a judge who is presented with a motion for his disqualification "shall not pass on the truth of the facts alleged nor adjudicate the question of disqualification."

When a judge has looked beyond the mere legal sufficiency of a suggestion of prejudice and attempted to refute the charges of

partiality, he has then exceeded the proper scope of his inquiry and on that basis alone established grounds for his disqualification. Our disqualification rule, which limits the trial judge to a bare determination of legal sufficiency, was expressly designed to prevent what occurred in this case-the creation of "an intolerable adversary atmosphere" between the trial judge a n d t h e litigant.

MacKenzie v. Super Kids Bargain Store, Inc., 565 So.2d 1332, 1339 (Fla. 1990) (quoting Bundy, 366 So.2d at 442).

The trial judge should have succinctly ruled on the motion in a few

words or less, communicated nothing further and moved on. But that didn't happen and the trial judge chose to take issue with Parker's sworn suggestions of bias by then irreparably entering a

detailed, three-page point-by-point written order applying individual scrutiny to each of Parker's allegations:

11

First, in the motion to disqualify, Parker asserted that thetrial judge

denied her motion to depose an expert witness because the trial

judge, in open court, agreed with and adopted Parker's opponent's position that Parker's request to depose the expert was "dilatory." In

the order denying the motion to disqualify, the trial judge took issue with and contradicted Parker's allegation and in an apparent

attempt to correct Parker, indicated that the judge had simply determined that "Parker had not shown good cause to take the disposition, given the late date and closeness to the trial period."

Second, in Parker's motion to disqualify, Parker alleged that the trial judge refused to issue a ruling on Parker's motion to continue and

kept it pending because, Parker swore, the trial judge believed that Parker's motion for continuance was "being sought for purely

strategic reasons" and was "wholeheartedly subscribing to [Parker's opponent's unfounded assertions of intentionally dilatory conduct."

M.D. Parker Assocs. v. Connor, 339 So. 3d 375 (Fla. 4th DCA 2022).

28. Accordingly, because this motion to disqualify is legally sufficient, the Court

must grant it and disqualify the Trial Judge.

III. DATES OF ALL PREVIOUSLY GRANTED MOTIONS TO DISQUALIFY FILED UNDER THIS RULE

29. There have been no dates of any previously granted motions to disqualify filed under this rule in the case because no parties have requested such relief.

30. There have been no dates of the orders granting those motions to disqualify filed under this rule in the case because no parties have requested such relief.

CONCLUSION

WHEREFORE, Plaintiff respectfully moves this Court to disqualify the Trial Judge.

IV.



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400314)



Reply Favorite

Date: June 7th, 2023 4:36 PM
Author: Naked clown theater

this is an absolutely brilliant piece of legal writing, and i predict the judge will not only be removed from the case, but possibly the bench.

i just have one question: why is the word "if" misspelled throughout the document as "fi"?

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400390)



Reply Favorite

Date: June 7th, 2023 4:37 PM
Author: Glittery Jap

Fe Fi Fo Fum

This Judge is Unfit to Wipe My Bum

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400393)



Reply Favorite

Date: June 7th, 2023 4:51 PM
Author: swashbuckling ivory state



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400441)



Reply Favorite

Date: June 7th, 2023 6:02 PM
Author: Sienna Cracking Ceo



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400661)



Reply Favorite

Date: June 7th, 2023 6:44 PM
Author: Talented yapping pistol people who are hurt



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400771)



Reply Favorite

Date: June 7th, 2023 5:48 PM
Author: Fighting shrine

LOL

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400629)



Reply Favorite

Date: June 7th, 2023 4:56 PM
Author: Ungodly Purple Hospital Travel Guidebook

HOLY FUCK, the “useful guidance” this retard is citing (Parker) is the DISSENTING opinion: https://casetext.com/case/md-parker-assocs-v-connor

Lmao. TSINAH your response?

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400457)



Reply Favorite

Date: June 7th, 2023 5:00 PM
Author: Sienna Cracking Ceo

this was written by CHATGPT, your honor

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400466)



Reply Favorite

Date: June 7th, 2023 5:02 PM
Author: Ungodly Purple Hospital Travel Guidebook

I have $100 says that’s what he did. It’s otherwise too coherent for a ZZZ brief

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400469)



Reply Favorite

Date: June 7th, 2023 5:02 PM
Author: Sienna Cracking Ceo



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400473)



Reply Favorite

Date: June 7th, 2023 5:03 PM
Author: vibrant nighttime whorehouse

which florida county is this case in so i can find it?

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400475)



Reply Favorite

Date: June 7th, 2023 5:05 PM
Author: Ungodly Purple Hospital Travel Guidebook

I forget what it’s called but it has Gainesville in it iirc

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400486)



Reply Favorite

Date: June 7th, 2023 5:06 PM
Author: Glittery Jap

alachua

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400492)



Reply Favorite

Date: June 7th, 2023 5:09 PM
Author: vibrant nighttime whorehouse

ty. i realized i had searched before when i saw the bizarre captcha.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400499)



Reply Favorite

Date: June 7th, 2023 7:00 PM
Author: Supple location

Seems like sanctionable and referrable conduct.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400816)



Reply Favorite

Date: June 7th, 2023 4:41 PM
Author: Up-to-no-good party of the first part haunted graveyard

Motions to disqualify in FL are granted almost automatically, so long as they are legally sufficient (i.e., movant claims some reasonable basis for the belief of impropriety & swears under penalty of perjury that they've read the motion and aver the facts it contains are true)

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400408)



Reply Favorite

Date: June 7th, 2023 4:46 PM
Author: curious black locale

“ Motions to disqualify in FL are granted almost automatically, so long as they are legally sufficient (i.e., movant claims some reasonable basis for the belief of impropriety & swears under penalty of perjury that they've read the motion and aver the facts it contains are true)”

Great then we can all expect the motion to be granted given how incredibly low the standard is.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400419)



Reply Favorite

Date: June 7th, 2023 4:58 PM
Author: Sienna Cracking Ceo

ZZZ is a terrible lawyer

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400463)



Reply Favorite

Date: June 7th, 2023 4:48 PM
Author: Glittery Jap

doesnt really seem like this motion meets this low bar

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400430)



Reply Favorite

Date: June 7th, 2023 4:49 PM
Author: Ungodly Purple Hospital Travel Guidebook

This is just a guess, but I think that’s the standard BEFORE the judge rules against you. You can’t act like a dipshit and get sanctioned and have SJ against 90% of your case then say, “this judge is biased I want a new one.”

At least that’s the way it is in CA, where you have the automatic right to veto a judge upon initial assignment.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400434)



Reply Favorite

Date: June 7th, 2023 5:03 PM
Author: Hairraiser abnormal forum azn

Shit, this ZZZ sounds like an asshole. Any chance he's right?

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400477)



Reply Favorite

Date: June 7th, 2023 5:06 PM
Author: Ungodly Purple Hospital Travel Guidebook

No idea it’s not my case

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400490)



Reply Favorite

Date: June 7th, 2023 5:05 PM
Author: Up-to-no-good party of the first part haunted graveyard

in FL, you can do it anytime

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400487)



Reply Favorite

Date: June 7th, 2023 5:08 PM
Author: Ungodly Purple Hospital Travel Guidebook

Yeah, I’m gonna go ahead and suppose that my instinct on this one is more accurate than your expertise in FL law but we’ll see what unfolds

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400496)



Reply Favorite

Date: June 7th, 2023 5:09 PM
Author: Up-to-no-good party of the first part haunted graveyard

dude just check some case law

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400500)



Reply Favorite

Date: June 7th, 2023 5:11 PM
Author: Ungodly Purple Hospital Travel Guidebook

Obv you could be right, but does it vacate the past orders the judge entered, because that’s what you guys need on this one.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400508)



Reply Favorite

Date: June 7th, 2023 5:15 PM
Author: Up-to-no-good party of the first part haunted graveyard

I'm not part of this case, but it doesn't matter because you can always file a motion for rehearing/reconsideration.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400528)



Reply Favorite

Date: June 7th, 2023 5:16 PM
Author: Aromatic swollen dopamine legal warrant

Thought you were in "privity" with ZZZ?

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400530)



Reply Favorite

Date: June 7th, 2023 5:18 PM
Author: Ungodly Purple Hospital Travel Guidebook

Before a judge with chambers next to the last one? You and ZZZ are some unrivaled legal strategists.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400540)



Reply Favorite

Date: June 7th, 2023 6:58 PM
Author: Talented yapping pistol people who are hurt

Remember you are arguing with TSINAH, a failed shitlawyer who told us that based on his "vast defense experience" that the prosecutor in the Murdaugh case looked like a complete clown when he cross examined the defendant and that Murdaugh would be acquitted almost immediately. He loves offering his opinion on subjects where he doesn't know shit. I know almost nothing about Florida law, but I also find it difficult to believe that you can disqualify a judge who has ruled against you for no reason other than that they ruled against you. Maybe TSINAH is right and Florida is really that stupid, but I'm going to need more than TSINAH's word before I believe that.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400810)



Reply Favorite

Date: June 7th, 2023 7:01 PM
Author: Sienna Cracking Ceo

TSINAH is a community account. I’m guessing that ZZZ is using it today

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400818)



Reply Favorite

Date: June 7th, 2023 8:42 PM
Author: Up-to-no-good party of the first part haunted graveyard

What did you mean by this?

http://www.autoadmit.com/thread.php?thread_id=1860379&forum_id=2#19862381

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46401149)



Reply Favorite

Date: June 7th, 2023 8:52 PM
Author: Naked clown theater

is that sp?

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46401189)



Reply Favorite

Date: June 7th, 2023 5:16 PM
Author: Aromatic swollen dopamine legal warrant



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400529)



Reply Favorite

Date: June 7th, 2023 5:04 PM
Author: vibrant nighttime whorehouse

"Motions to disqualify in FL are granted almost automatically, so long as they are legally sufficient"

I can't imagine this is true. Never granting MTD is one thing, but to "always" grant an affirmative request like this would be insane.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400483)



Reply Favorite

Date: June 7th, 2023 5:09 PM
Author: Up-to-no-good party of the first part haunted graveyard

it's literally true

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400498)



Reply Favorite

Date: June 7th, 2023 5:18 PM
Author: Hairraiser abnormal forum azn

unbelievable, def not the case in CA

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400542)



Reply Favorite

Date: June 7th, 2023 5:20 PM
Author: vibrant nighttime whorehouse



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400548)



Reply Favorite

Date: June 7th, 2023 5:54 PM
Author: Up-to-no-good party of the first part haunted graveyard

38.10 Disqualification of judge for prejudice; application; affidavits; etc.—Whenever a party to any action or proceeding makes and files an affidavit stating fear that he or she will not receive a fair trial in the court where the suit is pending on account of the prejudice of the judge of that court against the applicant or in favor of the adverse party, the judge shall proceed no further, but another judge shall be designated in the manner prescribed by the laws of this state for the substitution of judges for the trial of causes in which the presiding judge is disqualified. Every such affidavit shall state the facts and the reasons for the belief that any such bias or prejudice exists and shall be accompanied by a certificate of counsel of record that such affidavit and application are made in good faith. However, when any party to any action has suggested the disqualification of a trial judge and an order has been made admitting the disqualification of such judge and another judge has been assigned and transferred to act in lieu of the judge so held to be disqualified, the judge so assigned and transferred is not disqualified on account of alleged prejudice against the party making the suggestion in the first instance, or in favor of the adverse party, unless such judge admits and holds that it is then a fact that he or she does not stand fair and impartial between the parties. If such judge holds, rules, and adjudges that he or she does stand fair and impartial as between the parties and their respective interests, he or she shall cause such ruling to be entered on the minutes of the court and shall proceed to preside as judge in the pending cause. The ruling of such judge may be assigned as error and may be reviewed as are other rulings of the trial court.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400642)



Reply Favorite

Date: June 7th, 2023 5:17 PM
Author: bull headed violent filthpig coldplay fan

"Motions to disqualify in FL are granted almost automatically, so long as they are legally sufficient"

=====

well, ALL motions are granted if they are legally sufficient, right? but that doesn't address what counts as "legally sufficient."

"the judge ruled against me and i don't trust the judge" isn't legally sufficient anywhere outside of FL. is it sufficient in FL?

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400538)



Reply Favorite

Date: June 7th, 2023 5:29 PM
Author: Up-to-no-good party of the first part haunted graveyard

>"the judge ruled against me and i don't trust the judge" isn't legally sufficient anywhere outside of FL. is it sufficient in FL?

no, that is not legally sufficient in FL

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400576)



Reply Favorite

Date: June 7th, 2023 5:31 PM
Author: bull headed violent filthpig coldplay fan

this is pretty close:

"the party reasonably fears that he or she will not receive a fair trial or hearing because of specifically described prejudice or bias of the judge;"

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400582)



Reply Favorite

Date: June 7th, 2023 6:51 PM
Author: Cerebral school

Some states (a lot of them, actually) allow peremptory excusals of judges, so I could see this working.

But like EPAH said, not once the judge is already issuing rulings and clearly developed an on-the-merits dislike of your case. Of course (as tsinah responds) you "can raise" DQ anytime, but there's just no way it's a virtual auto-grant mid-case.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400795)



Reply Favorite

Date: June 7th, 2023 5:10 PM
Author: Naked clown theater

really? that is insane.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400504)



Reply Favorite

Date: June 7th, 2023 5:14 PM
Author: Up-to-no-good party of the first part haunted graveyard

*only* the first motion to disqualify. You can't just move to disqualify every judge in the jurisdiction. The second one needs to be a bit more robust, i.e., the subsequent judges would need to make a factual finding that they are in fact not fair or impartial in the case.

https://casetext.com/rule/florida-court-rules/florida-rules-of-general-practice-and-judicial-administration/part-iii-judicial-officers/rule-2330-disqualification-of-trial-judges

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400524)



Reply Favorite

Date: June 7th, 2023 5:18 PM
Author: Naked clown theater

is there any chance this motion succeeds? he said that 1. the defendant had an ex parte communication b/c he sent stuff to the judge and didn't copy plaintiff (this is not within the judge's control - D sent it, not the judge), and 2. that the judge criticized him (she said the P appeared to be forum shopping).

he then points out that her order was effectively a TRO and she got the law wrong, but that can't possibly be a basis to disqualify, so set that aside.

how the fuck does this meet even the lowest bar for disqualification?

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400544)



Reply Favorite

Date: June 7th, 2023 5:40 PM
Author: Up-to-no-good party of the first part haunted graveyard

Because you take the sworn facts as gospel in evaluating a motion to disqualify for legal sufficiency. If any of those are true, would you think that the movant reasonably fears that he or she will not receive a fair trial or hearing?

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400601)



Reply Favorite

Date: June 7th, 2023 6:16 PM
Author: Naked clown theater

even if taken as true, no i don't

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400695)



Reply Favorite

Date: June 7th, 2023 6:21 PM
Author: Up-to-no-good party of the first part haunted graveyard

enjoy the petition for a writ of prohibition!

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400704)



Reply Favorite

Date: June 7th, 2023 6:31 PM
Author: Naked clown theater

explain like i'm not a shitlawyer brother. i'm not folliwng you.

do you think either of the things noted above justifies disqualification?

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400730)



Reply Favorite

Date: June 7th, 2023 7:59 PM
Author: Up-to-no-good party of the first part haunted graveyard

yes, actually

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46401013)



Reply Favorite

Date: June 7th, 2023 11:50 PM
Author: Naked clown theater

i would like to hear your reasoning. if you are right, then you can pretty much get a judge recused for any reason at all. that doesn't seem right.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46401775)



Reply Favorite

Date: June 8th, 2023 6:20 AM
Author: Sienna Cracking Ceo

TSINAH is one of the leading legal minds of Florida AND Michigan and you should heed his counsel

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46402217)



Reply Favorite

Date: June 7th, 2023 5:20 PM
Author: bull headed violent filthpig coldplay fan

FL rule:

(e) Grounds. A motion to disqualify shall set forth all specific and material facts upon which the judge's impartiality might reasonably be questioned, including but not limited to the following circumstances:

(1) the party reasonably fears that he or she will not receive a fair trial or hearing because of specifically described prejudice or bias of the judge; or

in CA, that ground works but only if you raise it before the judge decides a matter bearing on the merits. so in FL you can submit on the merits, get a ruling, and then say "in my view the judge doesn't like me"?



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400547)



Reply Favorite

Date: June 7th, 2023 5:22 PM
Author: vibrant nighttime whorehouse

does whether this happens post-Answer have any effect on this analysis?

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400552)



Reply Favorite

Date: June 7th, 2023 5:37 PM
Author: Up-to-no-good party of the first part haunted graveyard

no

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400594)



Reply Favorite

Date: June 7th, 2023 6:39 PM
Author: Khaki Histrionic Rehab

The sole basis of the "impropriety" is that you think the judge made a premature and procedurally improper ruling.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400760)



Reply Favorite

Date: June 7th, 2023 4:59 PM
Author: marvelous red nursing home

lol Candy Ride

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400464)



Reply Favorite

Date: June 8th, 2023 9:30 AM
Author: razzle-dazzle macaca



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46402561)



Reply Favorite

Date: June 7th, 2023 5:12 PM
Author: Sienna Cracking Ceo

Why does he include pages and pages of block quotes? Ive never seen briefing like this before

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400512)



Reply Favorite

Date: June 7th, 2023 5:23 PM
Author: vibrant nighttime whorehouse

Why does Kareem keep doing that skyhook? I've never seen basketball playing like that before.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400556)



Reply Favorite

Date: June 7th, 2023 5:26 PM
Author: Glittery Jap



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400564)



Reply Favorite

Date: June 7th, 2023 6:01 PM
Author: Sienna Cracking Ceo



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400658)



Reply Favorite

Date: June 7th, 2023 6:53 PM
Author: Cerebral school



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400802)



Reply Favorite

Date: June 7th, 2023 7:41 PM
Author: henna abode internal respiration



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400947)



Reply Favorite

Date: June 8th, 2023 10:42 AM
Author: racy affirmative action mad-dog skullcap



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46402897)



Reply Favorite

Date: June 7th, 2023 5:41 PM
Author: curious black locale

Why is ZZZ doing all this? This seems crazy that he would keep laying down in the tracks for a guy like RT or EJ

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400603)



Reply Favorite

Date: June 7th, 2023 6:02 PM
Author: Sienna Cracking Ceo

He’s desperate for clients

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400659)



Reply Favorite

Date: June 8th, 2023 10:46 AM
Author: Peach Pungent Base Place Of Business

cq

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46402917)



Reply Favorite

Date: June 7th, 2023 6:06 PM
Author: Sienna Cracking Ceo

All of this hoopla over an Audi Q5

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400669)



Reply Favorite

Date: June 7th, 2023 6:35 PM
Author: racy affirmative action mad-dog skullcap

I love the jurisprudential stand-off ITT

EPAH: That would be retarded

TSINAH: But Florida

Please bump with result

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400747)



Reply Favorite

Date: June 7th, 2023 7:02 PM
Author: Sienna Cracking Ceo



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400820)



Reply Favorite

Date: June 7th, 2023 7:42 PM
Author: henna abode internal respiration



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46400949)



Reply Favorite

Date: June 8th, 2023 9:18 AM
Author: Ungodly Purple Hospital Travel Guidebook

Guys after all these years of seeing me and TSINAH’s relative legal successes, it shouldn’t have been hard to predict who was right:

ORDER DENYING MOTION TO DISQUALIFY

THIS CAUSE comes before the Court on Plaintiff’s First Verified Motion to Disqualify Pursuant to Rule 2.330. Upon consideration of the motion and the record, and being otherwise fully advised in the premises, it is

ORDERED AND ADJUDGED that:

Plaintiff’s motion is hereby DENIED as legally insufficient. DONE and ORDERED on Thursday, June 8, 2023.

DAT legal sufficiency can be an insurmountable bar for bitchboi lawyers

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46402526)



Reply Favorite

Date: June 8th, 2023 9:30 AM
Author: razzle-dazzle macaca



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46402564)



Reply Favorite

Date: June 8th, 2023 9:59 AM
Author: Up-to-no-good party of the first part haunted graveyard

Let's see what happens with a petition for a writ of prohibition. I think the order is improper.

Also, aren't you also about to get sanctioned to the tune of about $20M?

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46402663)



Reply Favorite

Date: June 8th, 2023 10:42 AM
Author: racy affirmative action mad-dog skullcap

Lol jfc TSINAH never not doubling down

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46402892)



Reply Favorite

Date: June 8th, 2023 11:55 AM
Author: vibrant nighttime whorehouse

he's literally DONE here

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46403188)



Reply Favorite

Date: June 7th, 2023 8:14 PM
Author: Poppy Wonderful Dilemma

This reminds me that I'm a pretty good legal writer. Too bad law makes me want to kill myself.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46401063)



Reply Favorite

Date: June 7th, 2023 8:39 PM
Author: Up-to-no-good party of the first part haunted graveyard

https://circuit8.org/wp-content/uploads/JudgeWalker_NewPic10x14.jpg

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46401137)



Reply Favorite

Date: June 7th, 2023 11:15 PM
Author: racy affirmative action mad-dog skullcap

That is the face of someone who likes to have her competence and integrity questioned

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46401670)



Reply Favorite

Date: June 7th, 2023 11:47 PM
Author: Naked clown theater

cr, this will end very well for zzz

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46401771)



Reply Favorite

Date: June 8th, 2023 9:30 AM
Author: drab kitchen

180

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46402563)



Reply Favorite

Date: June 7th, 2023 11:55 PM
Author: Hyperventilating Old Irish Cottage National

She has.to.go back

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46401786)



Reply Favorite

Date: June 8th, 2023 9:52 AM
Author: Misanthropic address stain

It’s fine (slightly less ghetto than most of LA), but not worth the cost to live there. If you’re considering Pasadena, it makes a lot more sense to just live further east in Claremont or something.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46402643)



Reply Favorite

Date: June 8th, 2023 9:54 AM
Author: Ungodly Purple Hospital Travel Guidebook

Thanks

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46402647)



Reply Favorite

Date: June 8th, 2023 11:32 AM
Author: henna abode internal respiration



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46403085)



Reply Favorite

Date: June 8th, 2023 11:51 AM
Author: Glassy floppy main people hunting ground



(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46403171)



Reply Favorite

Date: June 8th, 2023 9:56 AM
Author: Naked clown theater

looks like ZZZ is dun here

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46402657)



Reply Favorite

Date: June 8th, 2023 10:51 AM
Author: Fishy Lay Cuck

He was done the moment he took on these garbage cases.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46402937)



Reply Favorite

Date: June 8th, 2023 5:27 PM
Author: vibrant nighttime whorehouse

literally

Plaintiff’s motion is hereby DENIED as legally insufficient. DONE and ORDERED on Thursday, June 8, 2023.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46404887)



Reply Favorite

Date: June 8th, 2023 11:37 AM
Author: marvelous red nursing home

Candy Ride free thread. odd case 🤔

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46403097)



Reply Favorite

Date: June 8th, 2023 11:40 AM
Author: Fighting shrine

Super odd. TBF not in here either. Odd.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46403114)



Reply Favorite

Date: June 8th, 2023 5:57 PM
Author: marvelous red nursing home

very strange

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46404956)



Reply Favorite

Date: June 8th, 2023 11:38 AM
Author: Titillating Piazza

lmao at tsinah's posts itt.

zzz MIGHT be able to get this judge disqualified from a future court case next time he sues a dentist, not the current one jfc

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46403102)



Reply Favorite

Date: June 8th, 2023 7:03 PM
Author: Up-to-no-good party of the first part haunted graveyard

What? That would actually be a legally insufficient motion to disqualify. You don't get to disqualify a judge in a new case because they fucked up in a previous one.

(http://www.autoadmit.com/thread.php?thread_id=5351486&forum_id=2#46405158)