This document is a plaintiff's opposition to a proposed order granting a motion to dismiss filed by the defendant Gap International. The plaintiff makes 5 issues/arguments in opposition: 1) There was an observed violation of ex parte rules in the courtroom where the judge acknowledged reviewing defendant's documents without providing them to plaintiff. 2) The proposed order tries to make defendants appear innocent but excludes key evidence. 3) Evidence of a second theft of plaintiff's property was excluded. 4) Defendants continued registering plaintiff's stolen property for 6 years. 5) No law would allow defendants' actions and the dismissal prevents the truth from being determined at trial. The plaintiff believes further investigation is warranted.
Objection To Third Proposed Order Granting Dismiss Gap Gerard Ange Win-Tv vs ...Gérard Angé
First, I am not an Attorney. I was ordered into “Pro Se” against my will, by The Honorable John M. True, III. I am here because I am a victim of crimes against my two corporations and myself. I have come here to find Justice.
30757 2019 e_board_of_managers_of_t_v_board_of_managers_of_t_decision___order...Tom Nelson
This document is a court order from the Supreme Court of the State of New York, County of Bronx, appointing a referee to handle the foreclosure case regarding a property located in the Bronx. The order discontinues the case against some defendants, amends the caption to add additional defendants, and refers the case to a referee to investigate the amounts owed, the ability to sell the property as a single parcel, and to file a report with the court.
This document is a judicial subpoena ordering witness testimony. It commands that the recipient and others set aside all business and excuses to attend court proceedings in County to testify as a witness for the plaintiff. Failure to comply is punishable as contempt of court with penalties up to $50 and damages from noncompliance. The subpoena is signed by a justice of the court.
The Court of Appeals affirms the lower court's granting of summary judgment to CitiMortgage in a foreclosure action. Maria Potvin argued she was entitled to relief under the Home Affordable Modification Program and that foreclosure was inequitable, but the court found the mediation was non-binding and she did not sign the modification agreement or make payments. The court also found the affidavit from CitiMortgage in support of summary judgment met evidentiary rules for records of regularly conducted business activities. Therefore, the appeals court denied all of Potvin's assignments of error and upheld the foreclosure.
Sample motion for consolidation of cases in CaliforniaLegalDocsPro
This sample motion for consolidation of multiple cases in California is filed pursuant to Code of Civil Procedure section 1048(a) to request consolidation of two or more cases. The motion is used by a party who is requesting that a Court consolidate two or more cases on the grounds that consolidation of the cases is warranted in that all of the cases arise out of the same set of operative facts and contain common issues and further that consolidation of all of the cases will avoid unnecessary duplication of evidence and procedures in all of the actions; avoid the risk of inconsistent adjudications and avoid many of the same witnesses testifying on common issues in all actions as well as promote judicial economy and convenience. The sample on which this preview is based can be easily modified for use in cases where complete consolidation is requested or where consolidation is requested only for purposes of trial and is 19 pages including brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration, proof of service by mail and proposed order. The author is an entrepreneur and freelance paralegal who has worked in California and Federal litigation since 1995 and has created over 250 sample legal documents for sale.
This document contains Plaintiff Traian Bujduveanu's objections to a report and recommendations regarding Defendants' motion to dismiss. The Plaintiff objects on several grounds: (1) that the judge did not properly consider all documents submitted and failed to acknowledge admissions by Defendants; (2) that the Fourth Amendment protects third parties from searches of their property; (3) that requests for religious accommodation were denied; and (4) that conditions at the halfway house violated the Eighth Amendment's prohibition on cruel and unusual punishment. The Plaintiff argues these objections demonstrate the complaint should not be dismissed.
Objection To Third Proposed Order Granting Dismiss Gap Gerard Ange Win-Tv vs ...Gérard Angé
First, I am not an Attorney. I was ordered into “Pro Se” against my will, by The Honorable John M. True, III. I am here because I am a victim of crimes against my two corporations and myself. I have come here to find Justice.
30757 2019 e_board_of_managers_of_t_v_board_of_managers_of_t_decision___order...Tom Nelson
This document is a court order from the Supreme Court of the State of New York, County of Bronx, appointing a referee to handle the foreclosure case regarding a property located in the Bronx. The order discontinues the case against some defendants, amends the caption to add additional defendants, and refers the case to a referee to investigate the amounts owed, the ability to sell the property as a single parcel, and to file a report with the court.
This document is a judicial subpoena ordering witness testimony. It commands that the recipient and others set aside all business and excuses to attend court proceedings in County to testify as a witness for the plaintiff. Failure to comply is punishable as contempt of court with penalties up to $50 and damages from noncompliance. The subpoena is signed by a justice of the court.
The Court of Appeals affirms the lower court's granting of summary judgment to CitiMortgage in a foreclosure action. Maria Potvin argued she was entitled to relief under the Home Affordable Modification Program and that foreclosure was inequitable, but the court found the mediation was non-binding and she did not sign the modification agreement or make payments. The court also found the affidavit from CitiMortgage in support of summary judgment met evidentiary rules for records of regularly conducted business activities. Therefore, the appeals court denied all of Potvin's assignments of error and upheld the foreclosure.
Sample motion for consolidation of cases in CaliforniaLegalDocsPro
This sample motion for consolidation of multiple cases in California is filed pursuant to Code of Civil Procedure section 1048(a) to request consolidation of two or more cases. The motion is used by a party who is requesting that a Court consolidate two or more cases on the grounds that consolidation of the cases is warranted in that all of the cases arise out of the same set of operative facts and contain common issues and further that consolidation of all of the cases will avoid unnecessary duplication of evidence and procedures in all of the actions; avoid the risk of inconsistent adjudications and avoid many of the same witnesses testifying on common issues in all actions as well as promote judicial economy and convenience. The sample on which this preview is based can be easily modified for use in cases where complete consolidation is requested or where consolidation is requested only for purposes of trial and is 19 pages including brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration, proof of service by mail and proposed order. The author is an entrepreneur and freelance paralegal who has worked in California and Federal litigation since 1995 and has created over 250 sample legal documents for sale.
This document contains Plaintiff Traian Bujduveanu's objections to a report and recommendations regarding Defendants' motion to dismiss. The Plaintiff objects on several grounds: (1) that the judge did not properly consider all documents submitted and failed to acknowledge admissions by Defendants; (2) that the Fourth Amendment protects third parties from searches of their property; (3) that requests for religious accommodation were denied; and (4) that conditions at the halfway house violated the Eighth Amendment's prohibition on cruel and unusual punishment. The Plaintiff argues these objections demonstrate the complaint should not be dismissed.
The decision by the U.S. District Court for the Southern District of Ohio. EQT had leased land from Alex Cooper, et al with an initial five-year term. The lease provided for a five-year extension. It also required EQT to drill at least one well on/under the property during the first five-year lease. EQT failed to drill a well in the first term but instead elected to extend the lease for an additional five years. The federal judge found that EQT has the right to extend the lease even if they didn't drill a well during the first term.
This affidavit provides information in support of a motion for summary judgment. It describes the plaintiff's criminal conviction and sentence, his transfer to Dismas Charities halfway house, and the rules he agreed to follow. It states that the plaintiff drove himself to Dismas and had an unauthorized cell phone, violating the rules. As a result, his personal items were confiscated and he was returned to prison to complete his sentence.
This document is a motion filed by the defense attorney Ruth C. Rose seeking pre-trial discovery from the prosecution related to two police officers - Deputy Clotworthy and Sergeant Smith - who were involved in the arrest of the defendant Belvin Pugh. The motion requests access to complaints against the officers, any discipline imposed as a result of investigations into complaints, and any other exculpatory or impeaching evidence within the meaning of Brady v. Maryland. It also seeks information from any civil service commission hearings involving the officers related to the alleged misconduct. The motion is made on the grounds that the defendant denies the version of events described in the police report and contends the officers falsified probable cause, and this discovery could provide impeach
Sample California complaint for breach of contract and common countsLegalDocsPro
This sample California complaint for breach of contract also includes causes of action for common counts including open book account, account stated and goods sold and delivered. The sample on which this preview is based is 6 pages and includes brief instructions. The sample document is sold on scribd.com by LegalDocsPro.
MDFL - Order Denying Motion to Dismiss Trade Secret & Fraud ClaimsPollard PLLC
In this order, the United States District Court for the Middle District of Florida, Tampa Division, denies the defendants' motions to dismiss claims for breach of contract, theft of trade secrets in violation of the Defend Trade Secrets Act, 18 USC 1836 et. seq., fraud and aiding and abetting fraud.
In relevant part, the Court rejects the defendants' efforts to impose a summary judgment like burden at the pleading stage. Notable holdings include: (1) The question of whether information constitutes a trade secret is a question of fact normally resolved by a jury after full presentation of evidence. (2) A claim for misappropriation may exist not only where the defendant itself is alleged to have stolen trade secrets, but where the defendant is alleged to have obtained the trade secrets while knowing that they were acquired by improper means. (3) The allegation that a defendant induced a plaintiff to enter an NDA with no intention of honoring it states a claim for fraud in the inducement that is not barred by the independent tort doctrine.
The plaintiff is represented by Fort Lauderdale, Florida based Pollard PLLC. The firm has extensive experience litigating complex non-compete, trade secret, trademark and unfair competition claims. Their office can be reached at 954-332-2380.
This document is Plaintiff Jamil Sharif's memorandum in opposition to Defendant Decatur Hotels, LLC's motion to set aside a default judgment. Sharif argues that service of process was properly perfected on Decatur Hotels. He also argues that Decatur Hotels' failure to respond to the lawsuit was willful, precluding a finding of excusable neglect, and that setting aside the default judgment would prejudice Sharif. Therefore, Sharif asserts that the default judgment should not be set aside under Rules 60(b)(4), 60(b)(6), or 60(b)(1) of the Federal Rules of Civil Procedure.
Motion to Dismiss Claims for Misappropriation of Trade Secrets and Tortious Interference under Florida law. Tampa, Florida. Hillsborough County Circuit Court - Complex Business Litigation Division.
Pollard PLLC
P. 954-332-2380
Caso de EliGio Cedeño contra Juan Felipe Lara FernándezInforme 25
This document is a summary order from the United States Court of Appeals for the Second Circuit regarding the case of Eligio Cedeño v. Castillo. The order affirms the district court's dismissal of Cedeño's RICO complaint against various defendants for failure to state a claim. Specifically, it finds that Cedeño's complaint alleges an extraterritorial violation of RICO that the statute does not reach based on insufficient domestic conduct. It also rejects Cedeño's arguments that his claims fit within RICO's domestic focus and that RICO incorporates extraterritorial predicate offenses. The court further finds that the district court did not abuse its discretion in denying Cedeño's request to amend his complaint.
This document is a court order denying a motion from defendants Alec and Mike Sou for attorneys' fees and expenses under the Hyde Amendment. It provides background on the criminal case against the Sous, including that they initially pled guilty but later withdrew their pleas after the court rejected their plea agreements. It then describes how the government dismissed all charges against the Sous after a witness testified inaccurately during trial about the legality of recruiting fees. The court applies the legal standard under the Hyde Amendment and denies the Sous' motion, finding that their arguments do not establish that the government's position was vexatious, frivolous, or in bad faith.
Sample notice of ruling for CaliforniaLegalDocsPro
This sample notice of ruling for California can be modified for use in any litigation case in California. The author is a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years.
This document summarizes the proceedings of an arbitration hearing between Chevron Corporation, Texaco Petroleum Company, and the Republic of Ecuador. The hearing addressed the tribunal's jurisdiction over claims related to an arbitration between the US and Ecuador concerning an investment treaty. Counsel for the respondent argued that the tribunal does not have jurisdiction unless the claimants can demonstrate that a 1995 release agreement extends to claims by third parties related to oil extraction operations in Ecuador. The respondent's counsel asserted that the claimants had not met their burden of proof regarding the scope of the release.
Dismissal of Power.com's Suit Against FacebookEric Eldon
This order grants Facebook's motion to dismiss Power Ventures' counter-complaint and strike affirmative defenses. The court found Power Ventures' pleading lacked specificity and factual allegations to support its antitrust and other claims. Power Ventures is given 30 days leave to amend its pleading. The hearing on the motions is vacated.
Sample california demand for copies of pleadingsLegalDocsPro
This sample demand for copies of pleadings in California is used when a party has just filed an appearance in a case, and wants to request that all oher parties, particularly all adverse parties, to serve them with copies of all pleadings, including motions and discovery requests and responses served in the case prior to their appearance. The demand is made pursuant to Code of Civil Procedure Section 465.
Motion for Summary Judgment by Kanawha Stone containing the deposition and re...Putnam Reporter
Motion For Summary Judgment with exhibit containing the depositions and resumes of the plaintiffs in the case of :
DOLORES HALBURN and MARK HALBURN,
Plaintiffs,
v.
CITY OF HURRICANE, WEST VIRGINIA,
a municipal corporation, BEN NEWHOUSE,
individually and in his capacity as City Manager
for the City of Hurricane, CLEVELAND
CONSTRUCTION, INC. dba Cleveland
Construction, Inc. Of Nevada, and KANAWHA
STONE COMPANY, INC.,
Defendants.
Putnam County WV Civil Action No. 07-C-298
This document is a subpoena issued by the United States Bankruptcy Court for the District of Colorado in the case of Cordillera Golf Club, LLC. It commands John L. Emmerling to appear for a deposition at the law offices of Ballard Spahr LLP in Denver on July 18, 2012 at 9:00am. It also commands him to produce certain requested documents by electronic transmission or delivery to Young Conaway Stargatt & Taylor, LLP in Wilmington, Delaware by July 16, 2012 at 5:00pm. The subpoena is signed by Travis G. Buchanan as counsel for the debtor.
The Supreme Court granted the petition seeking to reverse the orders of the trial court judge who acquitted the respondents of drug charges. The Supreme Court found that the trial court judge gravely abused his discretion in granting the demurrer to evidence filed by the respondents. The police officers directly witnessed the illegal drug sale that occurred during a buy-bust operation. The testimonies of the police officers established that the respondents were caught in flagrante delicto negotiating and carrying out the sale. The Supreme Court ruled the trial court ignored clear proof that the elements of the crime were established.
Opposition To Motion To Dismiss S Gerard Ange V Templer FGérard Angé
THE END GAME...
WHEN CORPORATIONS AND CEO'S CAN PAY TO SUBVERT THE FABRIC OF OUR CONSTITUTIONAL RIGHTS THAT PROTECT ALL CITIZENS. THEN... WE ALL LOSE.
THESE ARE THE OFFICIAL COURT TRANSCRIPTS & COURT DOCUMENTS:
After SIX YEARS and $100,000.00 in legal fees... OUR CASE DAMAGES WERE THROWN OUT BY A "SURPRISE SUBSTITUTED JUDGE" & ON A TRUMPED UP PHONY MISSING "Assignment of Claims" DOCUMENTS THAT WERE NEVER MISSING AT ALL.
READ THE SHOCKING OFFICIAL COURT TRANSCRIPTS AND THEN DECIDE FOR YOURSELF WHY OUR CONSTITUTIONAL RIGHT TO TRIAL WAS DENIED BY A SUBSTITUTED JUDGE.
http://www.win-tv.net/GAP_WINTV_Site/GAP_WIN-Tv_Website_Theft.html
B189989 gaggero/sulphur mountain v geraldine, somerset farms, john, maureen r...jamesmaredmond
This document summarizes a hearing in the Superior Court of Ventura County regarding Sulphur Mountain Land and Livestock Company's motion for attorneys' fees and the defendants' motion to tax costs. The defendants' attorney argued that the case should have been filed as a limited action in municipal court based on the amount in dispute. He also argued that the plaintiffs pursued the case unreasonably by not accepting the defendants' early $25,209 settlement offer, which included damages and attorneys' fees at that point, and instead drove up costs over the ensuing years.
This document is a letter from Plaintiffs' counsel opposing a motion to dismiss from Defendant Unigestion Holding. The letter argues that the complaint provides sufficient details about Unigestion's involvement in an alleged conspiracy to illegally impose fees on phone calls and money transfers to Haiti in violation of antitrust laws. The letter cites evidence from a New York Times article and videos showing an agreement was made between Unigestion and other defendants to fix prices. The letter also argues the complaint meets pleading standards and that dismissal would be improper at this stage.
FindLaw | Justice Dept. Motion to Dismiss Defense of Marriage Actguest8f8287
This document is the United States' motion to dismiss a lawsuit challenging the constitutionality of the Defense of Marriage Act (DOMA). It provides background on DOMA and the procedural history of the case. The motion argues that the plaintiffs lack standing to sue, that DOMA is a valid exercise of congressional authority, and that DOMA does not violate equal protection, due process, privacy, speech, or other constitutional rights. The motion requests that all claims against the United States be dismissed.
The decision by the U.S. District Court for the Southern District of Ohio. EQT had leased land from Alex Cooper, et al with an initial five-year term. The lease provided for a five-year extension. It also required EQT to drill at least one well on/under the property during the first five-year lease. EQT failed to drill a well in the first term but instead elected to extend the lease for an additional five years. The federal judge found that EQT has the right to extend the lease even if they didn't drill a well during the first term.
This affidavit provides information in support of a motion for summary judgment. It describes the plaintiff's criminal conviction and sentence, his transfer to Dismas Charities halfway house, and the rules he agreed to follow. It states that the plaintiff drove himself to Dismas and had an unauthorized cell phone, violating the rules. As a result, his personal items were confiscated and he was returned to prison to complete his sentence.
This document is a motion filed by the defense attorney Ruth C. Rose seeking pre-trial discovery from the prosecution related to two police officers - Deputy Clotworthy and Sergeant Smith - who were involved in the arrest of the defendant Belvin Pugh. The motion requests access to complaints against the officers, any discipline imposed as a result of investigations into complaints, and any other exculpatory or impeaching evidence within the meaning of Brady v. Maryland. It also seeks information from any civil service commission hearings involving the officers related to the alleged misconduct. The motion is made on the grounds that the defendant denies the version of events described in the police report and contends the officers falsified probable cause, and this discovery could provide impeach
Sample California complaint for breach of contract and common countsLegalDocsPro
This sample California complaint for breach of contract also includes causes of action for common counts including open book account, account stated and goods sold and delivered. The sample on which this preview is based is 6 pages and includes brief instructions. The sample document is sold on scribd.com by LegalDocsPro.
MDFL - Order Denying Motion to Dismiss Trade Secret & Fraud ClaimsPollard PLLC
In this order, the United States District Court for the Middle District of Florida, Tampa Division, denies the defendants' motions to dismiss claims for breach of contract, theft of trade secrets in violation of the Defend Trade Secrets Act, 18 USC 1836 et. seq., fraud and aiding and abetting fraud.
In relevant part, the Court rejects the defendants' efforts to impose a summary judgment like burden at the pleading stage. Notable holdings include: (1) The question of whether information constitutes a trade secret is a question of fact normally resolved by a jury after full presentation of evidence. (2) A claim for misappropriation may exist not only where the defendant itself is alleged to have stolen trade secrets, but where the defendant is alleged to have obtained the trade secrets while knowing that they were acquired by improper means. (3) The allegation that a defendant induced a plaintiff to enter an NDA with no intention of honoring it states a claim for fraud in the inducement that is not barred by the independent tort doctrine.
The plaintiff is represented by Fort Lauderdale, Florida based Pollard PLLC. The firm has extensive experience litigating complex non-compete, trade secret, trademark and unfair competition claims. Their office can be reached at 954-332-2380.
This document is Plaintiff Jamil Sharif's memorandum in opposition to Defendant Decatur Hotels, LLC's motion to set aside a default judgment. Sharif argues that service of process was properly perfected on Decatur Hotels. He also argues that Decatur Hotels' failure to respond to the lawsuit was willful, precluding a finding of excusable neglect, and that setting aside the default judgment would prejudice Sharif. Therefore, Sharif asserts that the default judgment should not be set aside under Rules 60(b)(4), 60(b)(6), or 60(b)(1) of the Federal Rules of Civil Procedure.
Motion to Dismiss Claims for Misappropriation of Trade Secrets and Tortious Interference under Florida law. Tampa, Florida. Hillsborough County Circuit Court - Complex Business Litigation Division.
Pollard PLLC
P. 954-332-2380
Caso de EliGio Cedeño contra Juan Felipe Lara FernándezInforme 25
This document is a summary order from the United States Court of Appeals for the Second Circuit regarding the case of Eligio Cedeño v. Castillo. The order affirms the district court's dismissal of Cedeño's RICO complaint against various defendants for failure to state a claim. Specifically, it finds that Cedeño's complaint alleges an extraterritorial violation of RICO that the statute does not reach based on insufficient domestic conduct. It also rejects Cedeño's arguments that his claims fit within RICO's domestic focus and that RICO incorporates extraterritorial predicate offenses. The court further finds that the district court did not abuse its discretion in denying Cedeño's request to amend his complaint.
This document is a court order denying a motion from defendants Alec and Mike Sou for attorneys' fees and expenses under the Hyde Amendment. It provides background on the criminal case against the Sous, including that they initially pled guilty but later withdrew their pleas after the court rejected their plea agreements. It then describes how the government dismissed all charges against the Sous after a witness testified inaccurately during trial about the legality of recruiting fees. The court applies the legal standard under the Hyde Amendment and denies the Sous' motion, finding that their arguments do not establish that the government's position was vexatious, frivolous, or in bad faith.
Sample notice of ruling for CaliforniaLegalDocsPro
This sample notice of ruling for California can be modified for use in any litigation case in California. The author is a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years.
This document summarizes the proceedings of an arbitration hearing between Chevron Corporation, Texaco Petroleum Company, and the Republic of Ecuador. The hearing addressed the tribunal's jurisdiction over claims related to an arbitration between the US and Ecuador concerning an investment treaty. Counsel for the respondent argued that the tribunal does not have jurisdiction unless the claimants can demonstrate that a 1995 release agreement extends to claims by third parties related to oil extraction operations in Ecuador. The respondent's counsel asserted that the claimants had not met their burden of proof regarding the scope of the release.
Dismissal of Power.com's Suit Against FacebookEric Eldon
This order grants Facebook's motion to dismiss Power Ventures' counter-complaint and strike affirmative defenses. The court found Power Ventures' pleading lacked specificity and factual allegations to support its antitrust and other claims. Power Ventures is given 30 days leave to amend its pleading. The hearing on the motions is vacated.
Sample california demand for copies of pleadingsLegalDocsPro
This sample demand for copies of pleadings in California is used when a party has just filed an appearance in a case, and wants to request that all oher parties, particularly all adverse parties, to serve them with copies of all pleadings, including motions and discovery requests and responses served in the case prior to their appearance. The demand is made pursuant to Code of Civil Procedure Section 465.
Motion for Summary Judgment by Kanawha Stone containing the deposition and re...Putnam Reporter
Motion For Summary Judgment with exhibit containing the depositions and resumes of the plaintiffs in the case of :
DOLORES HALBURN and MARK HALBURN,
Plaintiffs,
v.
CITY OF HURRICANE, WEST VIRGINIA,
a municipal corporation, BEN NEWHOUSE,
individually and in his capacity as City Manager
for the City of Hurricane, CLEVELAND
CONSTRUCTION, INC. dba Cleveland
Construction, Inc. Of Nevada, and KANAWHA
STONE COMPANY, INC.,
Defendants.
Putnam County WV Civil Action No. 07-C-298
This document is a subpoena issued by the United States Bankruptcy Court for the District of Colorado in the case of Cordillera Golf Club, LLC. It commands John L. Emmerling to appear for a deposition at the law offices of Ballard Spahr LLP in Denver on July 18, 2012 at 9:00am. It also commands him to produce certain requested documents by electronic transmission or delivery to Young Conaway Stargatt & Taylor, LLP in Wilmington, Delaware by July 16, 2012 at 5:00pm. The subpoena is signed by Travis G. Buchanan as counsel for the debtor.
The Supreme Court granted the petition seeking to reverse the orders of the trial court judge who acquitted the respondents of drug charges. The Supreme Court found that the trial court judge gravely abused his discretion in granting the demurrer to evidence filed by the respondents. The police officers directly witnessed the illegal drug sale that occurred during a buy-bust operation. The testimonies of the police officers established that the respondents were caught in flagrante delicto negotiating and carrying out the sale. The Supreme Court ruled the trial court ignored clear proof that the elements of the crime were established.
Opposition To Motion To Dismiss S Gerard Ange V Templer FGérard Angé
THE END GAME...
WHEN CORPORATIONS AND CEO'S CAN PAY TO SUBVERT THE FABRIC OF OUR CONSTITUTIONAL RIGHTS THAT PROTECT ALL CITIZENS. THEN... WE ALL LOSE.
THESE ARE THE OFFICIAL COURT TRANSCRIPTS & COURT DOCUMENTS:
After SIX YEARS and $100,000.00 in legal fees... OUR CASE DAMAGES WERE THROWN OUT BY A "SURPRISE SUBSTITUTED JUDGE" & ON A TRUMPED UP PHONY MISSING "Assignment of Claims" DOCUMENTS THAT WERE NEVER MISSING AT ALL.
READ THE SHOCKING OFFICIAL COURT TRANSCRIPTS AND THEN DECIDE FOR YOURSELF WHY OUR CONSTITUTIONAL RIGHT TO TRIAL WAS DENIED BY A SUBSTITUTED JUDGE.
http://www.win-tv.net/GAP_WINTV_Site/GAP_WIN-Tv_Website_Theft.html
B189989 gaggero/sulphur mountain v geraldine, somerset farms, john, maureen r...jamesmaredmond
This document summarizes a hearing in the Superior Court of Ventura County regarding Sulphur Mountain Land and Livestock Company's motion for attorneys' fees and the defendants' motion to tax costs. The defendants' attorney argued that the case should have been filed as a limited action in municipal court based on the amount in dispute. He also argued that the plaintiffs pursued the case unreasonably by not accepting the defendants' early $25,209 settlement offer, which included damages and attorneys' fees at that point, and instead drove up costs over the ensuing years.
This document is a letter from Plaintiffs' counsel opposing a motion to dismiss from Defendant Unigestion Holding. The letter argues that the complaint provides sufficient details about Unigestion's involvement in an alleged conspiracy to illegally impose fees on phone calls and money transfers to Haiti in violation of antitrust laws. The letter cites evidence from a New York Times article and videos showing an agreement was made between Unigestion and other defendants to fix prices. The letter also argues the complaint meets pleading standards and that dismissal would be improper at this stage.
FindLaw | Justice Dept. Motion to Dismiss Defense of Marriage Actguest8f8287
This document is the United States' motion to dismiss a lawsuit challenging the constitutionality of the Defense of Marriage Act (DOMA). It provides background on DOMA and the procedural history of the case. The motion argues that the plaintiffs lack standing to sue, that DOMA is a valid exercise of congressional authority, and that DOMA does not violate equal protection, due process, privacy, speech, or other constitutional rights. The motion requests that all claims against the United States be dismissed.
FindLaw | Justice Dept. Motion to Dismiss Defense of Marriage ActLegalDocs
This document is the United States' motion to dismiss a lawsuit challenging the constitutionality of the Defense of Marriage Act (DOMA). It provides background on DOMA and the procedural history of the case. The motion argues that the plaintiffs lack standing to sue, that DOMA is a valid exercise of congressional authority, and that DOMA does not violate equal protection, due process, privacy, speech, or other constitutional rights. The motion requests that all claims against the United States be dismissed.
Fall 2010 open memo assignment no doubt v. activision right of publicity cali...Lyn Goering
This document is a court order granting the plaintiff's application to remand a case back to state court from federal court. The plaintiff had filed a complaint against the defendant in state court for claims related to the use of the plaintiff's likeness in a video game. The defendant removed the case to federal court, arguing the claims were preempted by federal copyright law. The court analyzed the relevant legal standards for removal and copyright preemption. Applying a two-part test, the court determined the plaintiff's claims were not preempted as they involved misappropriation of the plaintiff's name and likeness beyond what was agreed to, rather than contesting the defendant's copyright. The court therefore granted the application to remand the case back to
This document is a stipulation to dismiss an adversary proceeding filed in bankruptcy court. It summarizes that the plaintiff filed a complaint against the defendant seeking to prevent discharge of a debt. The case was then stayed pending resolution of a related state court lawsuit. That state court lawsuit was then dismissed. The parties now wish to dismiss the adversary proceeding with prejudice, with each party bearing their own costs and fees. The court will retain jurisdiction to enforce the terms of the dismissal.
SDFL - Order Dismissing Various Claims - Jurisdiction - Trade SecretsPollard PLLC
The Plaintiff filed a 20 count lawsuit alleging, among other counts, theft of trade secrets, unjust enrichment, breach of fiduciary duty, trademark infringement, violations of the Computer Fraud Abuse Act and more.
This is the classic shock and awe, everything and the kitchen sink approach to litigation.
In this instance, that approach backfired spectacularly. The Court dismissed 17 of the counts on jurisdictional grounds -- holding they cannot be refiled in federal court but must be pursued, if at all, in state court.
The court also dismissed one count with prejudice. Denied the motion to dismiss with respect to one count. And granted leave to amend on one count--- but warned plaintiff and its counsel to mind Rule 11 if they decide to amend.
Think twice before you file a 20 count complaint in federal court where you are literally throwing everything at the wall and hoping something sticks.
RK Associates, Raanan Katz Were Alleged In Unlawful Ejectment In Miamirkcenters
Defendants do not dispute, that security guards threw Plaintiffs off the property and that RK Associates and MWI changed the locks on the bank branch's office doors. Furthermore, Plaintiffs allege conversion of their remaining personal property by RK Associates and MWI after they were escorted from the premises. Judging from the record, the Court finds that there is a possibility that Plaintiffs can establish a cause of action against the resident defendant. Triggs, 154 F.3d at 1287. At the very least, Plaintiffs have a possibility of stating a viable cause of action against the landlord RK Associates for conversion of their equipment and for unlawful ejectment. Defendants themselves note that joinder is deemed legitimate when such possibility exists.
This document appears to be a court ruling regarding a property dispute between a landlord and tenant. Some key details:
- The plaintiff (landlord) sued the defendant (tenant) for a declaration of title and ejectment to regain possession of the tenanted premises, claiming the tenant had become a trespasser.
- The defendant resisted, claiming to have acquired a prescriptive title to the property.
- The court notes the parties agreed the subject matter of the dispute was the same premises, identified by the same assessment number and boundaries.
- A key issue was whether the defendant, as a tenant since 1946, was estopped from disputing the plaintiff's title by executing a last will
This document is the transcript from a court hearing regarding Terry Gene Bollea (Hulk Hogan's) motion for a temporary injunction against Gawker Media. The plaintiff's lawyer argues that posting the sex tape was not constitutionally protected speech and was a violation of Florida's video voyeurism law. He cites several cases to support this position. The judge reminds both parties to maintain professionalism and civility in their filings.
Edwards v. snowden add hbo and academy awardsPublicLeaks
1. Plaintiff Horace Edwards sues Edward Snowden and others involved in the film Citizenfour, alleging they unlawfully acquired and disclosed classified national security information stolen by Snowden, in violation of secrecy agreements.
2. The complaint alleges Snowden intentionally stole classified information from the NSA and CIA while working for those agencies. He then provided that information to filmmaker Laura Poitras, who worked with others to make the film Citizenfour, revealing the stolen classified information.
3. Plaintiff claims the disclosure of stolen classified information in the film poses a substantial risk of serious injury to himself and others. He alleges insurance fraud related to the film and asserts claims including violations of the Antiterrorism Act. The plaintiff seeks
FindLaw | Madoff Bail Denied by Appeals CourtLegalDocs
This document is a summary order from the United States Court of Appeals for the Second Circuit regarding United States v. Madoff. It affirms the district court's denial of bail for Bernard Madoff pending his sentencing. The appellate court found that given Madoff's age (70), potential lengthy sentence (150 years), and the means and opportunity to flee, the district court did not clearly err in determining he posed a risk of flight and denying bail.
Opposition to a California summary judgment motionLegalDocsPro
This sample opposition to a motion for summary judgment in California was created by a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years.
This complaint alleges that the defendants breached a written contract and committed fraud related to a proposed $56 million media campaign to promote the 2012 Mexican presidential candidacy of Enrique Peña Nieto. The complaint claims that while the defendants secured funding from the Mexican government for the campaign, they converted the funds for their own personal use and failed to pay for the advertising as agreed, instead making false representations and threats. The plaintiffs, who own a television network, seek damages for breach of contract, fraud, RICO violations, and other claims.
The Lord of Law: Major Nourhaghighi's Factum before the Court of Appeal for O...nourhaghighi
The following is DRAFT of the Major Nourhaghighi's Winning Factum before the highest court in Ontario
in which Major Nourhaghighi won a case against
the most experience Law Firm, Deacon, Spears, Fedson, & Montizambert LLP,
specialist in the Ontario Condominium Act
with $1500.00 award of Costs to Major Nourhaghighi
Court File No: M 32976
COURT OF APPEAL FOR ONTARIO
BETWEEN:
MAJOR KEYVAN NOURHAGHIGHI
Applicant (Responding Party)
-and-
CABER MANAGEMENT SERVICES INC. JOHN BEDFORD, JOHN MORIELLI,
LISA BLAIR; METRO TORONTO CONDOMINIUM CORPORATION NO. 935
Respondents (Moving Parties)
Similar to Opposition To Proposed Order Granting Dismissal: Gerard Ange G.A.P. INTERNATIONAL & Win-Tv v. Gap International &,Templer et al (20)
Fbi case gap international & win tv theft 2011Gérard Angé
Gerard Ange is a victim of theft by Gap International, a Turkish/American company. Over six years, Gap International stole Ange's television broadcast businesses, destroying $50 million and ruining his finances and credit. When Ange sought legal justice, Judge John M. True III denied Ange his constitutional right to an attorney and ordered him to represent himself. This effectively denied Ange his right to a fair trial and justice under the law. Ange believes larger forces may have been involved in subverting his legal rights to protect corporate interests.
Kurdish Television Satellite Network Proposal /G.A.P. INTERNATIONAL Gérard Angé
This proposal from G.A.P. International outlines plans to launch a satellite television network called Kurdish Television North America to broadcast Kurdish programming via satellite to viewers in North America. The proposal is dated November 2000 and provides satellite services through G.A.P. International located in San Rafael, California.
Judge True followed through with his threat he made to us in June, and ruled to dismiss our case against the defendants. He explained that the reason he dismissed the case was because of his previous ruling on June 10, 2009: (When he moved forward to have a trial "without Plaintiff's attorney present"). Judge John M. True went on to say that because of his ruling on June 10th, that the Plaintiffs didn't have any damages or any case left to fight. He then ruled to dismissed all charges against the defendants. By doing that Judge John M. True III denied our Constitutional Right to a Trial for the crimes committed against us.
AN ADDITIONAL ACTION: A MONETARY JUDGEMENT WILL BE GRANTED AGAINST US:
Judge John M.True III had stated that; "He will be granting a judgement against us to pay for all the defendants legal expenses". (A figure after six years could very well be as high as $1 Million dollars.)
OUR FUTURE:
We are now seeking additional funding for an Appeal and for a complete formal investigation into the replacement of Judge Barbara Miller and the odd rulings and Judicial actions exhibited in the court by Judge John M. True III.
We were intentionally denied our rights to a Trial and to Justice for the crimes that were committed against us.
We not only ask for our Constitutional rights... We Demand them !
Thank you for taking the time to read about our pursuit for justice.
Gérard Angé
President, CEO,
G.A.P. International &
World Indigenous Network / WIN-Tv
(both California Corporations)
FIRST> GAP & WINTV FAXED & SIGNED CORPORATE ASSIGNMENTS 2005Gérard Angé
THE FIRST GAP & WINTV FAXED & SIGNED CORPORATE ASSIGNMENTS 2005 with prior attached email from Eric Schenk and copy of fax cover with signed assignments.
NO ONE IS OR WAS HIDING ANYTHING! ~ BECAUSE ~ WE LET THE FACTS SPEAK FOR THEMSELVES ~
Gap Pa Productions Of Documents Response Only And CoverGérard Angé
Gap PA Productions of Documents Response and Cover Letter. > Defendants total lack of production of documents.
The Plaintiffs produced over a thousand documents to the defendant Gap of PA But In return: Gap of PA only produced 64 documents to us! They refused 90% of the requests for documents things like board meeting minutes at the time of the theft and phone records related to the case. Of those sixty-four documents that they did produced= fifty of those documents were copies of documents that we gave to them. of the 14 documents left: included (9) Nine emails with the 90% of text deleted.
DEPOSITION OF DEFENDANT / JON GREENAWALT DIRECTOR OF WEB DEVELOPMENT GAP INT...Gérard Angé
DEPOSITION OF DEFENDANT / Jon Greenawalt DIRECTOR OF WEB DEVELOPMENT GAP INTERNATIONAL INC. 700 OLD MARPLE ROAD, SPRINGFIELD, PENNSYLVANIA
OTHER DEFENDANTS:
=========================
ANTHONY TEMPLER /
CURRENTLY RESIDING AT:
Zille Str. 69, 10575
BERLIN, GERMANY
LAST KNOWN USA ADDRESS: ANTHONY TEMPLER/
ATANDA WEB PRESENCE SERVICES
939 61ST STREET, SUITE #13
OAKLAND, CA 94608-1301
-------------------------------------------------------------
GAP INTERNATIONAL INC. 700 OLD MARPLE ROAD, SPRINGFIELD, PENNSYLVANIA
----------------------------------------------------------
MORE INFORMATION ON THE THEFT:
http://www.win-tv.net/GAP_WINTV_Site/GAP_WIN-Tv_Website_Theft.html
----------------------------------------------------------
MEMORANDUM OF POINTS &
AUTHORITIES IN SUPPORT OF
MOTION FOR SUMMARY
ADJUDICATION AS TO THE
ELEVENTH CAUSE OF ACTION
=========================
ANTHONY TEMPLER /
CURRENTLY RESIDING AT:
Zille Str. 69, 10575
BERLIN, GERMANY
LAST KNOWN USA ADDRESS: ANTHONY TEMPLER/
ATANDA WEB PRESENCE SERVICES
939 61ST STREET, SUITE #13
OAKLAND, CA 94608-1301
-------------------------------------------------------------
GAP INTERNATIONAL INC. 700 OLD MARPLE ROAD, SPRINGFIELD, PENNSYLVANIA
----------------------------------------------------------
MORE INFORMATION ON THE THEFT:
http://www.win-tv.net/GAP_WINTV_Site/GAP_WIN-Tv_Website_Theft.html
----------------------------------------------------------
STATEMENT OF UNDISPUTED FACTS.
=========================
ANTHONY TEMPLER /
CURRENTLY RESIDING AT:
Zille Str. 69, 10575
BERLIN, GERMANY
LAST KNOWN USA ADDRESS: ANTHONY TEMPLER/
ATANDA WEB PRESENCE SERVICES
939 61ST STREET, SUITE #13
OAKLAND, CA 94608-1301
-------------------------------------------------------------
GAP INTERNATIONAL INC. 700 OLD MARPLE ROAD, SPRINGFIELD, PENNSYLVANIA
----------------------------------------------------------
MORE INFORMATION ON THE THEFT:
http://www.win-tv.net/GAP_WINTV_Site/GAP_WIN-Tv_Website_Theft.html
----------------------------------------------------------
How I Founded G.A.P. International Broadcasting leading to Both TheftsGérard Angé
MORE INFORMATION ON THE THEFT:
http://www.win-tv.net/GAP_WINTV_Site/GAP_WIN-Tv_Website_Theft.html
----------------------------------------------------------------------
Gerard Ange'
President, CEO
G.A.P. International, (a California Corporation)
World Indigenous Network Corporation
3879 Magnolia Drive,
Palo Alto, CA 94306
Cell 415-717-8302
Gerard_Ange@win-tv.net
http://www.win-tv.net
http://www.linkedin.com/in/gerardange
=========================
THE DEFENDANTS:
ANTHONY TEMPLER /
CURRENTLY RESIDING AT:
Zille Str. 69, 10575
BERLIN, GERMANY
LAST KNOWN USA ADDRESS: ANTHONY TEMPLER/
ATANDA WEB PRESENCE SERVICES
939 61ST STREET, SUITE #13
OAKLAND, CA 94608-1301
-------------------------------------------------------------
GAP INTERNATIONAL INC. 700 OLD MARPLE ROAD, SPRINGFIELD, PENNSYLVANIA
----------------------------------------------------------
THEFT #2 .WIN-TV.COM our Web Site & Power PointGérard Angé
THEFT #2 The www.WIN-TV.COM Web Site & Power Point presentation was Stolen on December 07, 2003 three hours after we called Gap International and threaten legal action If the didn't return our property.
-------------------------------------
MORE INFORMATION ON THE THEFT:
http://www.win-tv.net/GAP_WINTV_Site/GAP_WIN-Tv_Website_Theft.html
----------------------------------------------------------------------
Gerard Ange'
President, CEO
G.A.P. International, (a California Corporation)
World Indigenous Network Corporation
3879 Magnolia Drive,
Palo Alto, CA 94306
Cell 415-717-8302
Gerard_Ange@win-tv.net
http://www.win-tv.net
http://www.linkedin.com/in/gerardange
=========================
THE DEFENDANTS:
ANTHONY TEMPLER /
CURRENTLY RESIDING AT:
Zille Str. 69, 10575
BERLIN, GERMANY
LAST KNOWN USA ADDRESS: ANTHONY TEMPLER/
ATANDA WEB PRESENCE SERVICES
939 61ST STREET, SUITE #13
OAKLAND, CA 94608-1301
-------------------------------------------------------------
GAP INTERNATIONAL INC. 700 OLD MARPLE ROAD, SPRINGFIELD, PENNSYLVANIA
----------------------------------------------------------
THEFT #2
Our WIN-TV First Round funding was destroyed all our investors and our email was stolen on December 07, 2003 three hours after we called Gap International and threaten legal action If the didn't return our property.
-------------------------------------
MORE INFORMATION ON THE THEFT:
http://www.win-tv.net/GAP_WINTV_Site/GAP_WIN-Tv_Website_Theft.html
-----------------------------------------------------------------------
WIN-TV Executive Summery/Gerard Ange' CEO
-------------------------------------
Gerard Ange'
President, CEO
G.A.P. International, (a California Corporation)
World Indigenous Network Corporation
3879 Magnolia Drive,
Palo Alto, CA 94306
Cell 415-717-8302
Gerard_Ange@win-tv.net
http://www.win-tv.net
http://www.linkedin.com/in/gerardange
=========================
THE DEFENDANTS:
ANTHONY TEMPLER /
CURRENTLY RESIDING AT:
Zille Str. 69, 10575
BERLIN, GERMANY
LAST KNOWN USA ADDRESS: ANTHONY TEMPLER/
ATANDA WEB PRESENCE SERVICES
939 61ST STREET, SUITE #13
OAKLAND, CA 94608-1301
-------------------------------------------------------------
GAP INTERNATIONAL INC. 700 OLD MARPLE ROAD, SPRINGFIELD, PENNSYLVANIA
----------------------------------------------------------
GAP INTERNATIONAL & WIN-TV TIMELINE INFORMATION ON BOTH THEFTS Gérard Angé
Gap International theft Time-Line of www.gapinternational.com WIN-Tv FBI CASE ICC # I05071411389175
=========================
THE DEFENDANTS:
ANTHONY TEMPLER /
CURRENTLY RESIDING AT:
Zille Str. 69, 10575
BERLIN, GERMANY
LAST KNOWN USA ADDRESS: ANTHONY TEMPLER/
ATANDA WEB PRESENCE SERVICES
939 61ST STREET, SUITE #13
OAKLAND, CA 94608-1301
-------------------------------------------------------------
GAP INTERNATIONAL INC. 700 OLD MARPLE ROAD, SPRINGFIELD, PENNSYLVANIA
----------------------------------------------------------
MORE INFORMATION ON THE THEFT:
http://www.win-tv.net/GAP_WINTV_Site/GAP_WIN-Tv_Website_Theft.html
----------------------------------------------------------
An astonishing, first-of-its-kind, report by the NYT assessing damage in Ukraine. Even if the war ends tomorrow, in many places there will be nothing to go back to.
Essential Tools for Modern PR Business .pptxPragencyuk
Discover the essential tools and strategies for modern PR business success. Learn how to craft compelling news releases, leverage press release sites and news wires, stay updated with PR news, and integrate effective PR practices to enhance your brand's visibility and credibility. Elevate your PR efforts with our comprehensive guide.
Here is Gabe Whitley's response to my defamation lawsuit for him calling me a rapist and perjurer in court documents.
You have to read it to believe it, but after you read it, you won't believe it. And I included eight examples of defamatory statements/
El Puerto de Algeciras continúa un año más como el más eficiente del continente europeo y vuelve a situarse en el “top ten” mundial, según el informe The Container Port Performance Index 2023 (CPPI), elaborado por el Banco Mundial y la consultora S&P Global.
El informe CPPI utiliza dos enfoques metodológicos diferentes para calcular la clasificación del índice: uno administrativo o técnico y otro estadístico, basado en análisis factorial (FA). Según los autores, esta dualidad pretende asegurar una clasificación que refleje con precisión el rendimiento real del puerto, a la vez que sea estadísticamente sólida. En esta edición del informe CPPI 2023, se han empleado los mismos enfoques metodológicos y se ha aplicado un método de agregación de clasificaciones para combinar los resultados de ambos enfoques y obtener una clasificación agregada.
Acolyte Episodes review (TV series) The Acolyte. Learn about the influence of the program on the Star Wars world, as well as new characters and story twists.
04062024_First India Newspaper Jaipur.pdfFIRST INDIA
Find Latest India News and Breaking News these days from India on Politics, Business, Entertainment, Technology, Sports, Lifestyle and Coronavirus News in India and the world over that you can't miss. For real time update Visit our social media handle. Read First India NewsPaper in your morning replace. Visit First India.
CLICK:- https://firstindia.co.in/
#First_India_NewsPaper
Opposition To Proposed Order Granting Dismissal: Gerard Ange G.A.P. INTERNATIONAL & Win-Tv v. Gap International &,Templer et al
1. 1 GERARD ANGE’ / PRO SE (IN PROTEST)
3879 Magnolia Drive,
2 Palo Alto, CA 94306
(415) 717-8302 - voice
3 (415) 962-4113 - fax
4 Attorney PRO SE for PLAINTIFF
and CORPORATIONS in QUESTION
5
6
7 THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
8
AND FOR THE COUNTY OF ALAMEDA
9
10
GERARD ANGE’ et al., )
11 ) CASE NO. RG05241337
Plaintiff, )
12 )
vs. ) PLAINTIFF’S OPPOSITION TO
13 )
) [PROPOSED] ORDER GRANTING GAP
ANTHONY TEMPLER,
14 )
) INTERNATIONAL PA MOTION TO
GAP INTERNATIONAL INC et al., )
15
) DISMISS ACTION
16 Defendants. )
) Hearing Date: July 20, 2009
17 Time: 3:00 P.M.
Dept.: 512
18 Judge: Honorable John M. True III
Trial Date:
19
20 The Motion to Dismiss Action of defendant Gap International, Inc. ("GAP International")
21 was set for hearing on July 20, 2009, at 3:00 p.m., in Department 512 of the above entitled
22 Court, the Honorable John M. True, III presiding. Plaintiff Gerard Ange’ appeared pro se
23 (in protest) and Maurice R. Mitts of Mitts Milavec, LLC and Mia S. Blackler of Buchalter
24 Nemer PC appeared for Gap International PA.
25
I Gerard Ange’ in observance of the proceedings and was witness to what took place in the
26
hearing on July 20. 2009 and, throughout the six years since the theft(s) were committed. I have
27
reviewed the Defendants [proposed] Order and feel that the Defendants creative and wishful words
28
are “again ” not in line with reality and the FACTS of this case.
PLAINTIFF’S OPPOSITION TO DEFENDANTS’ [Proposed] MOTION GRANTING DISMISS
-1-
2. 1 I HAVE FOUR ISSUES IN REGARDS TO THE DEFENDANTS [proposed] ORDER
and, ONE ISSUE / OBSERVATION IN THE COURT ROOM ON JULY 20, 2009.
2
3
ISSUE # 1 (OBSERVATION IN THE COURT ROOM ON JULY 20, 2009).
4
5
A clear violation of EXPARTE RULES was observed in the court room between the
6 Defendant attorneys and Judge John M. True III. Plaintiff observed a “Binder ” Identified as a
7 Binder from the Defendants. It was also stated from the bench by Judge John M. True III that he
8 acknowledged reviewing the contents of the Defendants binder. It was also noted is that Judge
9 True III also made suggestions from the bench to the content of that binder directly to the
10 Defendants. That advice for them to make changes in those documents and ONLY THEN…
11 to present a copy the Plaintiff.
12
13
14
CONCLUSION: By Judge True’s own statements in Court on July 20 2009: that (A) Judge
15
John M. True III took Possession of Defendants documents { at some point } before the hearing
16
date. (B) Judge John M. True III then took the liberty to examine and to read those documents
17
contained in that binder. Then (C) Judge John M. True III in the court room on July 20, 2009
18
contributes his input and critiques the contents of defendants Binder and makes suggestions to the
19
defendants towards modifications of the Defendants documents… All while knowing that the
20
documents he has in his possession have never been produced to the Plaintiff. Only after, Judge
21
True’s critique in the court room to the Defendants on July 20, 2009 that Judge True then adds:
22
that the defendants are to make sure that the [NEXT] version is presented to the Plaintiff… That,
23
24
is a clear violation to the EX PARTE RULE. And at the very least, is a sanction-able act. This also
25 clearly shows a continuing bias and continuing favoritisms towards the Defendants by Judge John
26 M. True III.
27
28
PLAINTIFF’S OPPOSITION TO DEFENDANTS’ [Proposed] MOTION GRANTING DISMISS
-2-
3. 1
2 ISSUE # 2
3 As much as the defendant would like to vindicate themselves from the charges pointed
4 towards them by the Plaintiffs for their acts. THE FACTS ARE STILL THE FACTS… THIS
5 CASE WAS NEVER WAS BEFORE A JURY, and was dismissed on technical grounds by
6 Judge John M. True III. But, regardless of these facts, the defendants still try to write into the
7 [proposed] ORDER to dismiss, As if the defendants were the victims as this dismissal is a
8 punitive action directed towards the plaintiffs for misdeeds. Their claims are baseless fictitious
9 based on fantasy and fabrication and not on facts or the truth. Much that same as their earlier
10 fabricated claim of the missing “Assignment of Claims Documents” That were never missing at
11 all. http://www.slideshare.net/gerardange/first-gap-wintv-faxed-signed-corporate-assignments-2005
12
The defendants can only give an “appearance of innocence”, and only if they
13
[exclude] the reality of solid damming evidence against them.
14
15
16 ISSUE # 3
17
Damming Evidence #1 : The theft of WIN-TV on December 07, 2007 (three hours after
18
the call to Jon Greenawalt of Gap International in Pennsylvania and after Plaintiff threatened
19
legal action) The second theft took place. Both Defendants refuse to acknowledge or to ever
20
talk about this [SECOND THEFT].
21
[THIS DOCUMENTED EVIDENCE WAS ALL, EXCLUDED AND REMOVED BECAUSE
22
IT CLEARLY SHOWED CRIMINAL INTENT BY THE DEFENDANTS.]
23
24
25 ISSUE # 4
26
Damming Evidence #2 : The [FACT] that after our WIN-TV.COM property was stolen
27
on DECEMBER 07, 2003 it was then continually RE-REGISTERED by The Defendants every
28
year for (SIX YEARS) up to one month ago.
PLAINTIFF’S OPPOSITION TO DEFENDANTS’ [Proposed] MOTION GRANTING DISMISS
-3-
4. 1 CONCLUSION: “If” Co-Defendant Templer supposedly was paid off in a dollar amount in
2
excess of (10 X OVER ) what Templer’s (self claimed bill) for services was [ WITH A
3
PAYMENT ] from the sale of our 1st property www.gapinternational.com. (embezzled)
4
5 Then, why three months after the first theft… What Legal Justification would give the
6 Defendants the right to; ABSCOND / STEAL / POSSESS our other Corporation’s Property
7
WIN-TV.COM?
8
9 [WHAT LAW] could the DEFENDANTS site to convert the corporate property of the
10
Plaintiff’s WIN-TV Corporation’s ? And then to continue to RE-REGISTER Plaintiffs
11
property in every year for SIX MORE YEARS ?
12
13 ( These acts are multiple violations of Federal Crime called “Cybersquating” ).
14
15 [WHAT LAW] could the Honorable Judge John M. True, III site that would allow the
16 defendants the legal right to commit multiple Theft(s) against Plaintiff’s other Corporate
17
property WIN-Tv ?
18
19
20 The Answer: There is no law he can site.
21
22
ISSUE # 5
23
THE BIG QUESTIONS…
24
(1) WHOM DID THE THEFT OF THE WIN-TV’s PROPERTY BENEFIT ?
25
(2) WHAT WAS THE MOTIVE BEHIND THOSE SECOND CRIMINAL ACTS?
26
(3) [WHAT LAW] do the defendants base their second theft on?
27
28
PLAINTIFF’S OPPOSITION TO DEFENDANTS’ [Proposed] MOTION GRANTING DISMISS
-4-
5. 1
The Defendants, continue to {TRY] to claim that they were a “Bonafide
2
Purchaser” to do that, they would have to change reality. As we can see in
3
4 the [ISSUES 2 -5] That any [Exclusion] of the evidence and the facts mentioned
5
above, changes Reality and creates Fantasy, Fiction and Fabrication. It also
6
7 creates victims!
8
“A blind man could see clearly what was and is going on here.”
9
10
11 FINAL CONCLUSION
12 “If” the Defendants were so innocent of crime, you would think that they would be more
13 than willing to go to trial and present their case and share all the their evidence with a
14 jury. Because, that would allow the Defendants to prove their claim of innocence. But,
15 that is not that case here. Documents and evidence have been [EXCLUDED] and
16 [REMOVED] and also [DELETED]. The final solution was stopping the trial from going
17 forward all together. Their bold act and motion to dismiss showing clearly that the
18 defendants action and intent was to stop the trial in an attempt to change reality.
19
20 THE FUTURE:
21 If any party thinks that after this “Technical Dismissal” that this is over and it is case closed…
22 and its business a usual again, then, your wrong. THIS IS ONLY THE BEGINNING. The
23 next phase has already started.
24 A FORMAL INVESTIGATION:
25 We have been asking for a formal investigation of all the past actions that transpired. (there
26 have been many irregularities). Starting with the transfer of our trial Judge: Judge Barbara
27 Miller from Department 512, and then the Assignment of Judge John M. True III to our case [for
28 all purposes]. and many other irregularities following that substitution.
PLAINTIFF’S OPPOSITION TO DEFENDANTS’ [Proposed] MOTION GRANTING DISMISS
-5-
6. 1
The plaintiff’s have been turning over all evidence to the FBI and it seems now…
2
that there is some new interest on that end. We will have to wait to see where
3
this new interest leads.
4
5
IN ADDITION: We also will be moving forward with our appeal.
6
7
I will now dedicate my life to continue to share my experience about the
8
thefts, corporate crime and, about our search for justice. It is important for
9
everyone to learn from what has happened to us, as we tried to do something good
10
in the world only to become a target of theft. And then watch as everything we
11
worked so hard for destroyed.
12
I will be making public appearances to share my experiences of the last six
13
years, to educate the public. In a world where a lack of integrity and greed are
14
thought of as “Break-Though-Performance”. Where the rule of law is looked at as
15
only a tool used to circumvent evidence and dance around the facts.
16
For the sake of education and the truth, it important that I share my story so
17
that all people can study and understand whom did what to whom and why. And
18
learn that integrity is the key to good business. One way or another the truth will
19
all come out… I will make certain of that..
20
21 DATED: JULY 27, 2009
22
23 Respectfully Submitted,
24 GERARD ANGE PRO SE (IN PROTEST)
25
26
27
Gerard Ange'
________________________________________________
28
Mr. Gerard Ange'
PLAINTIFF’S OPPOSITION TO DEFENDANTS’ [Proposed] MOTION GRANTING DISMISS
-6-