Thank you, XXXXX XXXXX you excellent responses...I have few more questions:
1) Judge ruling against my summary judgement was totally against me...does that mean he is biased and will be against me in trial?
2) Based on she is claiming only negligent infliction of emotional distress, medical negligence, sexual battery, infliction emotional distress...if she could not prove damages in trial...or her deposition...can she still win money from me or punitive damages?
3) Is trial with jury better or trial by Judge only for physicians..as some jurors not very smart?
4) What do you suggest if he denies termination sanctions or issue sanctions and order evidenciary hearing only...do you suggest I continue trial...as she did not finish her psych exam and also we did not finish deposition of her docctors?
5) Her lawyer submitted expert testimony written declaration after date in january elapsed...but he stated I was under standard of care...she alleges I saw her records adn gave her one script for doctor I was covering and referred her to...there was no damage whatsoever...absolutely except for emotional distress she claims?
Plz help me and I will tip you next time...I am still anxious about trial here ...given Judge's so scared to terminate any case...I think Judge always affraid of appeal to him later if he terminates...please help
Thank you, XXXXX XXXXX few more last questions, then I will rate you excellent again and tip you....
1) Her lawyer sent an opposition on termination sanctions...I think he would say she was not happy with psychiatrist that was offered by us but approved by court on a previous court order.....could Judge give her more chance to go back to him or another psychiatrist...given cut date for discovery process is end of this week?
2) We have not had chance to depose her psychiatrists that treated her before in different places...not expert witnesses....so we are going to depose her first...but cut point soon...so do you think that it is important to continue trial and depose all of them to prove she is indeed crazy?
3) What is nominal or punitive damages without actual loss? and how she proves any false allegations with no admissable evidence?
4) If court continued, can I keep sending more interrogatories to her? Is deposition only 7 hours maximum?
5) How does court weighs damages as emotional distress and depression and loss of self esteem...and marital problems...when they had divorce before I even met this lady and her husband already dismissed the case...as she had mental illness, drug addiction and a boyfriend during her marriage...so can court comes back asking me to pay her money just based on her allegations of emotional distress?
I will rate you excellent and tips after this time ...thanks a lot
I replied by questions..I rate you excellent and paid twice...please answer in am if possible..Thanks
thank you...couple more questions if you please..
1) We took her depo...she stated most of questions..I don't know or I don't remember...she could not remember exactly how battery occurred..but stated tht there was sex and even no hotel room whatsoever...? can she change her words in court? or casue we had videotaped her...she cant
2) My depo was cancelled cause her lawyer did not show up...he sent another one that was not associate with him on the records...we opposed and refused...he may file an associate later...could we ask for monetary sanctions for that? he cancelle with no notice to us
3) If she shows up for psych exam...and her exam proves she is mentally ill and lying...could this be encouraging for judge to dismiss?
4) Court coming soon...I was not deposed yet...can we show up to court without my depo and without depo from psychiatry or better to continue and depose all her treating doctors?
Thanks a lot...Plz answer when you can
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