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Dimitry K., Esq.
Dimitry K., Esq., Attorney
Category: Legal
Satisfied Customers: 41221
Experience:  Multiple jurisdictions, specialize in business/contract disputes, estate creation and administration.
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Its a medical practice exact words from order . Petitioner

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Its a medical practice exact words from order . Petitioner shall make all books and financials available for viewing and copying at his office within 14 days.
The affidavit of AFFIDAVIT OF KRISTINA MCCLURE, having been duly swom upon oath, deposes and states as follows:
1.I believe this to be a true emergency as the trial date is quickly approaching and Respondent's rights are being prejudiced by the delay.
She is a partner in the firm. Acceptable?

Thank you for your follow-up. Please allow me to respond.

That does appear to be acceptable on the face of the order. However you can contest on a variety of grounds. First, you can point to that the other parties had an extensive amount of time obtaining this information, and it is no longer a 'prejudice' of rights, but simply a respondent who failed to timely obtain information that has existed and been made available in the past. Second is the issue with the information, you can request that they redact and not review confidential and personal information of patients. As for it being a true emergency, that likewise can be contested by stating that if past records were provided in the past, there is no emergency but an unreasonable attempt to delay the proceedings. Nothing fundamentally changed between this current request and past requests of a similar vein.

Hope that helps.

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Customer: replied 3 years ago.

Update. compromised on all motions, they did get extension for 2 more days. the attorney came to the scheduled meeting 1 hour 30 minutes late and she made up a number to use as my total income, totally incorrect, and off a web site called Thomson Reuters. What they then did is they sent this through a service called Zinbra, which made it seem like it appeared in my inbox at an earlier date than it actually was sent. I filed a motion of contempt, but that would delay the proceedings for 7 days, so I withdrew but submitted a motion for reduction of support. Moreoever, i got a court reported to record everything that was stated in court (that the judge allowed) so that they cannot be deceptive on these important last days.

Also, I am asking this question from here because justanswer is all glitchy for me right now, so I hope this doesnt cause any problems.

Now for my questions: I got a trial date, but I need help with a statement for the final pre-trial that would prove that they are lying about assets so that they cannot delay this anymore, and so that I have substantial evidence to make sure this goes to trial. Really, I need something strong to say as my statement to the judge to make sure this goes to trial. Later, I will need help proving her inaccurate statements and flase claims on her Tax returns, as well as prove her motive to commit fraud and prevent production. There's enough motive there for her have financial gain for it, right? If so, I would like help knowing if there are any cases on this that I can use to help support my claim.

Thank you for your follow-up, James.

Ugh, I am truly sorry to hear that the opposing side has resorted to such tactics. Before I answer, I must ask--did the judge believe their version of the facts, or did the judge take more of your side in this hearing? I am asking to see whether or not filing for contempt may still be a viable option. Please advise!
Customer: replied 3 years ago.

He believed me for sure , he asked the counsler how many days would he need to prepare, around 7 the counsler replied.

Dimitry we discussed this earlier, I dont want to extent the tria date of the 24th of June its the first solid date ever. In addition he allowed my mortion to lower the support as well as the court reporters transcription I pay for and just received.. She will be there tomorrow for my motion to decrease the support based on fact, However as i said i went to the court house and sure enough the time of 11 00 am is preceded by a 9 00am motion that I am was unaware of and its been brought bu the opposing attorneys I have a copy of the docket. that clearly shows its added with no motion attached and no notice.


I am now going to ask you another question but I want you to get paid over and over on each one, So You can reply to this and I am also working with Andrea, I am preparing my am mended memorandum with actual proof that clearly or at least 99 percent shows the lying, deceiving manipulating and fabricating to the court.

Can I use A person or persons will falsify documents or fail to produce base on a Financial Motive to commit Fraud ?




I do appreciate your facts. Let me first answer the initial concern so that I do not get confused with my responses. Then, when you are satisfied, I will move on to the next topic.

In terms of your statement to the court, it would help to use the 'active tone' to put forth your ideas. I will show the difference in this paragraph. The first sentence is passive tone since it discusses what you could do indirectly. The second is 'active' because it state what you will or will not accomplish.

Here is a great step-by-step approach--please review it, consider creating your own first draft, and then I will help you edit the work--I cannot create it for you but I can suggest different verbiage:

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