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support of his motions, respondent contends that initial attempts
to communicate with petitioner were met with “abject hostility,
including accusations of fraud and misconduct.” Respondent also
points out that petitioner refused to meet with respondent’s
employees or to discuss his cases by telephone. In addition,
petitioner’s correspondence to respondent and the Court contained
“insulting and false accusations of ‘unethical misconduct’ and
‘bad faith’”.
Respondent contends that petitioner filed numerous frivolous
motions or documents, such as: “Petitioner’s Motion to Strike
Designation of Place of Trial, Petitioner’s Motion to Dismiss and
For Costs, Petitioner’s Motion for Reconsideration, Petitioner’s
Request for Admissions, Petitioner’s Motion for Summary Judgment,
Petitioner’s Request for Stipulations, Petitioner’s Notice of
Refusal to Accept Service of Court’s Documents.” Petitioner’s
motions were denied and did not address the underlying merits of
respondent’s determinations. In most instances they were
collateral attacks on respondent’s or the Court’s employees.
Respondent contends, that petitioner has filed, in another
court, a “false and frivolous law suit against respondent’s
counsel * * * [and Judges] of this Court.” Respondent contends
that “Petitioner is using * * * [that] law suit as a basis for
this Court to ‘stay’ this proceeding.” It is for those reasons
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Last modified: March 27, 2008