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Dimitry K., Esq.
Dimitry K., Esq., Attorney
Category: Legal
Satisfied Customers: 37618
Experience:  Multiple jurisdictions, specialize in business/contract disputes, estate creation and administration.
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Spasibo, Dimitry! I hope my payment with bonus came thru

Resolved Question:

Spasibo, Dimitry!

I hope my payment with bonus came thru - otherwise please let me know. I know about possible farther actions ("Abuse of process," "Malicious litigation") but it is not an issue here. I don't need her money. All this is about the custody of our son - following case the same day July1. She used taking out of context very broad words for prejudice in the underlying custody case; my goal is to use it against her. I still would like your help if you have time. (No more characters)
Submitted: 1 year ago.
Category: Legal
Expert:  Dimitry K., Esq. replied 1 year ago.
Nezhashto,Customer

Thank you very much, your payment with your bonus came through. I truly appreciate it. Sure thing, I would be happy to help. What can I do to assist you?
Customer: replied 1 year ago.

Hello again Dimitry! First I thought that "nezhashto" is Ukrainian and tried to remember what still remained in my head (I was born in Kiev but grew up in Moscow). By the way, Esquire is really your last name? Mine is Sichkin; you may remember my father Boris Sichkin - movie actor who played Buba Kastorsky in "Elusive avengers."


 


The matter is too serious for me because it concerns my 6 y. o. son so when everything looks pretty much obvious I wouldn't like to take chances relying on my "self-taught" legal knowledge and experience (extensive in traffic court and pathetic in civil). In 34 years I learned though that non-standard methods work the best (like instead of annoyingly and senselessly asking when the radar was checked and by what, accusing municipality or city in creation of illegal revenue, conspiracy and proving that as a criminal enterprise they fall under the Organized Crime Act and the office of District Attorney is giving a hand to criminal enterprise. Actually it is so - 85% road signs in US are posted illegally without engineering survey but nobody knows). So, the idea in this case is the same. The petitioner's case is very weak. Extracted paragraph is vague without any clear threats. In its entirety my email is explanation and response to the petitioner's email. There was no intent to harass. No imminent likelihood of danger - I was in Mexico where planned to stay another couple of months and my wife was in NY. All petitioner's emails directly contradict her allegation. And my actual threat (in 1st email that day) was to go to the Family Court asking custody of our son. But simply dismissed Family Offense case will not help me in custody case. So I tried to build my defense on offense. Quite possible with many weak spots. Quite possible many questions still can be objected (even without apparent ground - why not try with the lay man). So, if you could review my amateurish attempts and correct them/predict/prevent objections it would be great and I would feel confident. Like I said I could email them to you so you could estimate how much your time it would take.


 


Best regards,


 


Customer/p>
Expert:  Dimitry K., Esq. replied 1 year ago.
Customer

I remember those movies quite well as I also grew up with them, and it happens also in Kiev. Small world, indeed. Esquire is not my last name, it is my title, but Dimitry is my first name. For confidentiality purposes I do not disclose my last name at this time.

I also happen to agree that at times going through non-linear methods may prove to be successful. It can definitely confuse the other side and could limit objections or even blunt their strategy.

Having said that, I personally cannot receive emails though the system as it would violate site rules If you have any direct questions, please post them in your thread and I can try to assist, but I would not be able to work with you one on one offsite as it would violate my own agreement. Please let me know if that is sufficient, and if yes, I will begin evaluating your questions once I am back online.

Please advise.

Customer: replied 1 year ago.

Hello Dimitry,


 


Yes, I understand this. What I meant referred to your private practice but technically it is possible to ask questions here and pay for them here. Will the form of one general question like say, "What need to be corrected (or deleted) here and what objections it can produce?" with subsequent specific questions work? I guess it is the best to combine these questions "by topic" (there is one general topic but it is subdivided) and their volume may exceed the maximum amount of what I can pay on Just Answer but I can always ask you: "Do you think that leather mini skirts Alla Pugacheva likes so much emphasizing the benefits of her age and accentuate it?" and pay for your answer.


 


Please tell me if it will work.


 


Best regards,


 


Customer/p>

 

Expert:  Dimitry K., Esq. replied 1 year ago.
Customer

That sounds fine. I can also politely let you know if I feel that we reachd the end of the scope for each thread and can then ask you to open up another question. But truly, I want to help more than anything, so please post your concerns so I can answer.

As for ms. Pugacheva, different strokes for different folks as she managed to remain both pupular and relevant for so many years.

Good luck!
Customer: replied 1 year ago.

Hello Dimitry,


 


As for Pugacheva, she is on of the best that ever happened on Soviet "estrada." Besides the obvious talent she was sincere and she didn't try to comply with the regime. And she absolutely didn't need to pretend she was 16 y. o. one of those new "little stars" with the names of German Shepards (all those Alma, Zemfira and the like) - she was much above them.


 


Please don't be polite in your answers. If something deserves "No, tebe eshe dolgo poly natirat'" - it is perfectly fine. And please don't be polite about the new thread. Actually I don't know how Just Answer system works and how to pay (or make them pay you) despite of my obscure "free Premier" status.


 


So, as for the case. On March 7 I wrote 3 emails - 2 long and 1 short as Post Scriptum. In first I said that my wife totally neglects the health and happiness of our child and I wasn't going to tolerate it any longer. Then I said I had 2 choices - to stop financial support or to go to the court and concluded that I chose the second option. She replied saying it was me who deprived our son of his father and ended saying that relocation to another country was out of question. In my reply to her response I first said that it was my physical or psycho-somatic condition that didnn't let me to stay in NY for too long (very long part), then described in tiny details how difficult financially it would be to stay in NY (very long and boring part with a cost of printer paper), then wrote a short paragraph "in question" where I first bragged about some street fight when I was a teenager (third Margarita in restaurant was definitely extra), then said that I never stopped at extreme measures even in relatively innocent situations and asked "Do you think I'll stop at anything - anything at all - when it concerns our son?" I guess, this is what my adversary will try to squeeze most from. I ended this email with "At the moment your terms - anything you want. Try to become totally insolvent and you'll get different terms. Don't make mistakes in choosing." In third email I said that I will take our son "in October... November... December... March - at the first possibility" and that it may cause a break in school year. My wife responded the next day asking why did I think the court would let me take American citizen to another country.


 


Actual allegations are 2 sentences: "The Respondent sent me emails in which he threatened to take away our son out of the country without my permission. He also threatened to kill me if I try to stop him."


 


I guess it is enough for the first letter, so no particular questions here except how is appropriate my possible (arrogant) opening statement:


 


Your Honor, for a long time I could not understand what were the charges in this case. There was a long list of possible charges without any specifically marked. Many if not most of them I simply could not commit because for that my physical presence was required and at that time I lived in Mexico. Finally, by analyzing the allegations I came to the conclusion that it must be either harassment or aggravated harassment and the attorney of the other party verified it was so. Harassment and aggravating harassment is a "words war." Allegations resulted from words may be true and valid, they may be misunderstanding, they may be misinterpretation, they may be misrepresentation or they can can be a lie. In a course of this trial I am going with admissible evidences prove that there was no misunderstanding, there was no misinterpretation, maybe only a small part was misrepresentation but the major part of the allegation was a lie. I am going to prove with admissible evidence that it was intentional lie under the oath and the petitioner committed the crime of perjury that included all essential elements: oath; intent; falseness and materiality. Thank you you Honor.


 


(I understand that there are zero chances to prove the perjury but just for the unexpected - by my adversary - angle).


 


Best regards,


 


Customer/p>

 

Expert:  Dimitry K., Esq. replied 1 year ago.
Customer

I do agree with your point about the singers. But as I have not really been a part of that culture for a few years, the new 'talent' is no longer something I follow, which is likely no big loss.

For payments, each time you positively rate an answer, I get compensated by the site for my work.

Now, in terms of your argument:

I am sorry but I do not in any way see this as perjury. You made two comments by your own admission that can be considered both as a threat (even an indirect threat) against safety of others, or at least it can be construed that way, and a claim that you will remove the child at the earliest opportunity. Those are both valid claims, and neither of them appear to be false. They are obviously potentially taken out of context but that is not perjury, that is a different interpretation of your words. Furthermore, the message that governs is the one received and not the one sent, so if she can legitimately claim that this was a threat, her interpretation is as valuable as the one you intended to send out. I am not defending her, I am merely pointing out that attacking her for perjury will simply waste the court's time and may get the judge to disregard you subsequent valuable points as he will not take your claims seriously going forward.

A threat can be made even if you are not physically present--what governs is whether or not the other person reasonably believed that the threat was valid, actionable, or imminent, and whether the party could act upon that threat. Where your focus would need to be is validity, and showing that the other party was aware you were not serious or could not seriously perform the threat (if the courts find it to be a threat in the first place).

Good luck.
Customer: replied 1 year ago.

Thank you Dimitry,


 


First, please tell me how to get back to you after rating your service. I would do it right away but I was afraid I had to start all over again with sign in and all the procedure.


 


I was going to use a word "perjury" only in the opening statement. But I was going to attack her from the point she could not believe her allegations herself because of this and that (all her responses contradict the possibility she actually believed there was any danger except "legal" - custody case - danger). Again, I'd like that the goal of prejudice in custody case would reach the judge's head, settle there and that he wouldn't like the idea of dirty game. I guess I need to re-work my opening statement (or maybe I don't need it at all - I'll rely on your opinion); something like this:


 


Your Honor... so on up to "or they can can be a lie." In a course of this trial I am going with admissible evidences prove that there was no misunderstanding. There is a chance my words were misinterpreted, but I don't believe it. Unlike the honorable court I know Ms. Moiseeva for 11 years and I know the way she think and the way she acts. I am going to prove that she accused me with the only goal in mind - a prejudice in the custody case. Thank you you Honor.


 


Cross-examination


 


(not an attack yet, only getting needed information with predictable answers. If anything can result in objections or should be re-construed, please tell me)


 


(I am not sure if I need Preface at all but in case the questions/answers regarding reducting email are well-rehearsed, it may be appropriate later)

Preface

1. Ms. Moiseeva, did you discuss with your attorney either personally or over the phone, Internet or by any other communications questions he was going to ask you?

2. Did you rehearse these questions and answers?

3. Did your attorney suggested what answers you should give for this or that question?


Part 1.


1. Ms. Moiseeva, in your allegations you said "emails the respondent sent me on March 7, 2013." However, you presented as an evidence only one email. Why is that? What happened with the rest? (Following questions depend on answer)

2. Ms. Moiseeva, are these 3 emails I sent you on March 7, 2013 and your answer to the 1st one?

3. Is there any other email or emails I sent to you that day?

4. So, I wrote you the 1st email, you replied, I replied to your reply and then I wrote very short 3rd email, is it correct?

5. And the email you presented as an evidence was my reply to your reply, not my first email, is it correct?

6. The first long email consists 3 parts or paragraphs. In the first part I describe how you neglect the health, happiness, childhood and future of our son in exchange of your tiny social comfort. Is it correct?

7. Does this part contain any threats to kill you and kidnap our son?

8. In the second paragraph I said that I was tired of your destruction of our son's life and that I was going to change it. I said that I had two choices and described the first as a termination of financial support. Is it correct?

9. 7. Does this 2nd part contain any threats to kill you and kidnap our son?

10. In the 3rd and last part I said the another choice was to go to the court, to file the petition for custody and I ended this part and the whole letter saying I chose this option. Is it correct?

11. 7. Does this 3rd part contain any threats to kill you and kidnap our son?

12. On March 7, 2013 you wrote an answer saying it was me that deprived our son of his father by my strange ideas. Is it correct?

13. Same March 7, 2013 I answered your answer by another long letter. It started with "It is my inability to live in NYC that deprives Boris of his father." Is it correct?

14. Then I explained in details why I could not live in NYC, is it correct?

15. After that I also in tiny details described our financial situation from the perspective of staying in NY, is it correct?

16. Then I wrote the separate paragraph you presented the court as an evidence, that in the beginning said "If life in paradise with a happy child, who has both mom and dad is a bad option for you, than you have only option between bad and worse. And if one more time I hear some uncertain proposals in all-or-nothing tone which end with "It is out of question!" you will get the worst option at the full scale!" Is it correct?

17. Ms. Moiseeva, In your answer to my first email you said "It is out of question for me and all the more for Boris to relocate to another country." Is it correct?

18. When I said "And if one more time I'll here "Out of question" was it a reply to your "out of question" in your previous letter?

18 a. So, it was not a completely separate letter starting the completely new subject we did not discuss before?

19. Do you think your "out of question" made me angry and I wrote an angry answer?

19. After this paragraph I wrote the conclusion where I said "At the moment you terms are: "OK, but I want everything." Try to become totally insolent and you'll get different terms." Is it correct?


 


Best regards,


 


Customer/p>

 


 

Expert:  Dimitry K., Esq. replied 1 year ago.
Customer

Thank you for your follow-up. If you rate me and the question closes, simply start a new thread and title it "For Dimitry..."--I will be informed that you are seeking me out. Or you should be able to post a reply in this thread even after posting your rating.

1. Asking about her attorney communications is privileged (means she does not have to answer it). Who she spoke with or how she was advised is not something the courts would allow her to answer if her attorney objects. Similarly, asking about rehearsal is not permitted since it is not going to the facts of the hearing. An attorney is supposed to advise her how to communicate, it is non-issue, and obviously he would suggest proper responses for maximum effect.

Question 7 is somewhat prejudicial to your position. It may be wiser to soften the language and simply discuss it as threats rather than bring up killing or kidnapping--it then creates an assumption that those comments were brought up elsewhere in the communication, and it frankly gives her a great opportunity to respond in a damaging way-- "No, that email did not have threats of killing, but the next email did". And that is an unfavorable road to walk on and only go that route if you are sure she will not point to any parts of the email with such terminology.

Question 14 should be reworded--you provided her with your ideas of why you could not live in the US, not that those ideas were valid, accurate, or accepted by her as being correct. Question 16 could be based on pointing to evidence on record and asking her to read it (if you are demanding that the quote be fully entered). Only do so if the letter ends up being entered into evidence, otherwise referring to documentation that is not in evidence would be objected to and not granted.

18 will be objected to you--you are asking her to go into your sate of mind, not hers. She did not know what you were thinking when you wrote it, she will only reply as to how she interpreted it. Same with 19, she can only speculate as to her thoughts, not yours.
<br/Customer I strongly urge you to consider retaining counsel--if her attorney is halfway competent, with your questions he can attempt to make you look very ridiculous and threatening. That is my concern.



Dimitry K., Esq., Attorney
Category: Legal
Satisfied Customers: 37618
Experience: Multiple jurisdictions, specialize in business/contract disputes, estate creation and administration.
Dimitry K., Esq. and 6 other Legal Specialists are ready to help you
Customer: replied 1 year ago.

Dimitriy,


 


I rated but the system told me "Access denied." However, when I got back I saw that your answer was rated :Excellent service." In any case let me start it from the beginning so I could rate your every answer.


 


Best regards,


 


Customer/p>
Expert:  Dimitry K., Esq. replied 1 year ago.
Customer

Thank you kindly, your rating did go through. Please let me know if I can assist you in any other way.
Customer: replied 1 year ago.

I just posted the new question so I could rate you every time you answer. I hope you'll receive it. If not - in short what I said was that I already got the very professional attorney - you - and that I could not afford an attorney (plus there are just a few days left before the trial and I am 300 miles away from NY). Besides I spoke with two attorneys and I had serious doubts about their - not professional competence - but the way of thinking. For instance, one could not understand how (written) proposal of my wife to come to me in Mexico during school holidays could help my case even though it was so obvious that a few weeks after she filed a Petition she offered me exactly what she asked the court to protect her from - deliver the child exactly where the kidnaper wanted to take him and give herself in full mercy of the murderer in a strange country where no one could protect her. So, I would really prefer to have YOU on my side instead of an attorney (even if I could afford one) that knows how to object something on what ground but cannot understand why.


 


 


As for your corrections, I removed all "killing" but could not quite understand what and why should be corrected in ## XXXXX 16 and 19 - and how. This 2nd email is the only email my wife stated as a threat and only the small paragraph near the end of it (of course I can send you the entire email but I don't want to take so much of your time). First 2 parts are my condition in NYC and how I describe it; second - my description of the financial situation. The goal here is not my wife's admission anything of it as a fact and to show that my letter was an answer to her email without any intent to harass (no intent - no cause). Similarly, my question about "was it a response or I started a separated subject" has the same goal - to show it was a continuation of the conversation even though somewhere in the middle it contained some angry response to what my wife said. Response even angry is not equal to separate email or call started from "Listen you! I am going to get you" - it is a part of a legitimate conversation. Otherwise every married man and woman all over the world had to be arrested for harassment. Depends on the terms of marriage number of counts could be in millions...


 


Best regards,


 


Customer/p>
Expert:  Dimitry K., Esq. replied 1 year ago.
Customer

Please give me a moment and I will try to clarify--one second, please.
Expert:  Dimitry K., Esq. replied 1 year ago.
Customer

Sorry for the delay, this was a bit longer to clarify than I expected.

I just posted the new question so I could rate you every time you answer. I hope you'll receive it. If not - in short what I said was that I already got the very professional attorney - you - and that I could not afford an attorney (plus there are just a few days left before the trial and I am 300 miles away from NY). Besides I spoke with two attorneys and I had serious doubts about their - not professional competence - but the way of thinking. For instance, one could not understand how (written) proposal of my wife to come to me in Mexico during school holidays could help my case even though it was so obvious that a few weeks after she filed a Petition she offered me exactly what she asked the court to protect her from - deliver the child exactly where the kidnapper wanted to take him and give herself in full mercy of the murderer in a strange country where no one could protect her. So, I would really prefer to have YOU on my side instead of an attorney (even if I could afford one) that knows how to object something on what ground but cannot understand why.

I appreciate that. Just please be aware that while I can also think like you, or at least follow your line of reasoning, I am trying to estimate how a typical judge would hear your claims as well as opposing counsel. The problem with an 'aria' is that every note must match, you have to know when to lay the foundation with your oboes and violins, when to provide pacing with your percussion, and when to push with your trumpets and your lead players. This questioning must also work the same way, you must know when to put forth basic foundation, when to expand upon it, how to control the witness so she does not surprise you on the stand, and how to trumpet your point across.

 

 

 

 

As for your corrections, I removed all "killing" but could not quite understand what and why should be corrected in ## XXXXX 16 and 19 - and how.

Perhaps the better approach may be to use her own testimony to bolster your own. "You testified that my comments in the email threatened your or our son (etc...) is that correct?" Do you see such language in this portion of the email? How about this portion? What about this portion? Wasn't the subject matter the care for our child in those emails, yes or no?

 

This 2nd email is the only email my wife stated as a threat and only the small paragraph near the end of it (of course I can send you the entire email but I don't want to take so much of your time).

There you can focus on the threat itself, was it expressly stated (did I directly threaten to harm you or hurt you? Did I ever tell you directly that I would physically hurt you or our child?), (Has our son ever been exposed to any physical harm from me to your knowledge?--don't ask that if you ever spanked the child, it would permit her to answer in a way that may harm your case).

 

First 2 parts are my condition in NYC and how I describe it; second - my description of the financial situation. The goal here is not my wife's admission anything of it as a fact and to show that my letter was an answer to her email without any intent to harass (no intent - no cause).

Then do not directly ask her--build up to it, ask what the tone of the email was, what was the full subject matter, and whether you ever claimed to take the child without a court order attached to it, whether you ever took a child without her consent across state lines or to a different country).

 

Similarly, my question about "was it a response or I started a separated subject" has the same goal - to show it was a continuation of the conversation even though somewhere in the middle it contained some angry response to what my wife said.

Better way may be to ask if whether or not both parties in the email got heated or emotional about their conversation Once she admits to it, then you can point to her response.

 

Response even angry is not equal to separate email or call started from "Listen you! I am going to get you" - it is a part of a legitimate conversation. Otherwise every married man and woman all over the world had to be arrested for harassment. Depends on the terms of marriage number of counts could be in millions...

Unfortunately parsing words is what counts, so anything directly stated in such a manner can be used potentially against you.

 

Good luck.

Customer: replied 1 year ago.

Finally your answers appeared.


 


I cannot see any DIRECT threat even in taken in isolation paragraph (the whole evidence my wife used:


 


"


You don't understand two simple things. First – you are not asking anymore what is out of questions for you. If life in paradise with happy child that has both mom and dad is a bad option for you, than you only have a choice between bad and worse. And one more time I will hear “Out of questions” you will get the worst option at the full scale! You'd better think whom you are making mad. According to Ryvkin (our friends – Y. S.) “You are chatting too long.” But when I stopped chatting he stopped his fight and waited for the opportunity to grab me from behind whispering: “It's me. I know you can do a lot even in such position but please don't. And that's enough for the guy – he doesn't breathe.” Darling, I didn't stop at extreme measures even in innocent situations, do you think I'll stop at anything – whatever it is – when it is my son?


Your choice is limited by the time and the level of arrogance. Never in my life I did anything bad to you. But everything I did for you was perverted in perverted consciousness. “My husband is a crook and I don't want to be relevant to it.” Zero gratitude but a lot of claims. Seven years of paid any wish-list somehow are forgotten. Try to grow insolent utterly and you'll get different conditions. At the moment your conditions are: “OK, but I want everything.” If forced – depends on the level of my anger.


 


Do not mistake in choosing.")


 


But of course it can be interpreted many ways. Still, "you'll get worse or different conditions" doesn't mean cheaper coffin.


 


As for my few next cross-examination questions. These following questions I wrote assuming there will be only reducted evidence. If only the fact (and not reducted email itself) that reducted evidence existed will remain I'd still want to bring the fact of "unfair intent" to the court only then I will have to re-construct my questions (or one of them)



20. Ms. Moiseeva, this is the email you presented as an evidence. Is it exactly the same email you presented as an evidence to the police?

21. Is it exactly the same email you presented to the court when you filed Family Offense Petition and asked for Order Of Protection?

22. Ms. Moiseeva, but it is not the complete email I sent you on March 7, 2013. It is only the small paragraph taken from the middle of it. Here is the complete email. ( Or - Ms. Moiseeva, but you presented the police and the court only the small paragraph taken from the middle of the entire email. Could you explain the court by what miracle the very long part before this paragraph as well as the part after this paragraph disappeared? (I have a strong filling that this questionwill be objected).

23. So, since you could not alter anything in original email, you copied it, pasted in editor like Word or Office, left the caption so it would look legitimate, deleted everything you thought should not be read before and after the paragraph you needed and then saved this new email. Is it how you did it, correct? (Same filling)

24. Why didn't you print the entire email as I did with everything in it whether I liked it or not so that it would be the judge who decide what was important and what was not?

25. And you omitted my first email for the same reason? (Whatever the reason she will cal)

25 a. Ms. Moiseeva, you admitted that description of my feeling and condition when I am in NY, explanation of financial cituation if we will stay in NY as well as my entire 1st email that initiated our correspondence did not content any threats; is it correct?

25 d. And since my first email and everything before the short paragraph you used as an evidence doesn't fit in the theory of aggravated harassment and the entire email with all the preceeding short paragraph acquires different meaning, you decided it should be removed? (Strong filling - how to avoid objection?)



 


Thank you.


 


Customer/p>
Expert:  Dimitry K., Esq. replied 1 year ago.
Customer

Thank you for your follow-up. I will be happy to clarify.

22. Is leading. Ask whether it was full or not, simply stating that it was a part without her first admitting to it would be sustained as an objection and you would be forced to reword.

23 is likewise leading--consider splitting into multiple questions.

24. It is not a yes/no question--you really want to avoid that.

25 may be okay if you ask it right after she admits to placing only certain points--if she does. That may be a bad avenue.
Dimitry K., Esq., Attorney
Category: Legal
Satisfied Customers: 37618
Experience: Multiple jurisdictions, specialize in business/contract disputes, estate creation and administration.
Dimitry K., Esq. and 6 other Legal Specialists are ready to help you
Customer: replied 1 year ago.

Dimitry,


 


Tried to rate you but "Access denied" I will try again after this reply.


 


Probably you meant something else I didn't know by "leading:" otherwise it is not direct examination and I can ask leading questions. But your corrections were great. My original questions were too amorphous. As for not "yes" or "no" questions - I'd like to ask my wife such questions every time there no danger of "her fantasy is a limit" and a concrete answer is required. She is shy to answer inconvenient answers even in supermarket, she cannot think fast, never was in a court and everything without her attorney hugging her is scary. She can answer that it was her who assassinated president Kennedy. She can easily ruin her case answering even single 27 question. Are my questions look good now?



20. Ms. Moiseeva, this is the email you presented as an evidence. Is it exactly the same email you presented as an evidence to the police?

21. Is it exactly the same email you presented to the court when you filed Family Offense Petition and asked for Order Of Protection?

22. Ms. Moiseeva, did you present both the police and the court only one paragraph from my second email I wrote this day, yes or no? (She simply may confused what would be "yes" or "no" if I'll use "Isn't it a fact" form)

22 a. Did this one paragraph looked like a complete email with caption and a text underneath, yes or no?

22 b. In your allegations you used plural form "emails." Did you present both the police and the court all 3 emails I sent this day?

22 c. So, you admitted that you omitted my first email and presented both the police and the court only one paragraph from my answer to your response which was my second email and that looked as a one and only completed email. Could you explain the court by what miracle the very long part before this paragraph as well as the part after this paragraph disappeared?

23. You could not alter anything in original email in Yahoo, could you?

24. Did you copy the entire email, pasted it in editor like Word or Office, left the caption so it would look legitimate, deleted everything before and after the paragraph you needed and then saved this new email, did you?

25. (If she admitted) Ms. Moiseeva, you admitted that description of my feeling and condition when I am in NY, explanation of financial cituation if we will stay in NY as well as my entire 1st email that initiated our correspondence did not content any threats; is it correct?

26. Did't you show my first email, removed everything before the short paragraph in the second and everything after that because it contradicted your theory of harassment, yes or no? (Of course "no")

27. Then why didn't you print the entire email as I did with everything in it whether I liked it or not so that it would be the judge who decide what was important and what was not?


 


O, and if you read the accusations and didn't tell me anything because you though the bitter truth may hurt me, please don't afraid to say it. I doubt they wait for me in a court with flowers and champagne.


 


Thank you.


 


Customer
Expert:  Dimitry K., Esq. replied 1 year ago.
Customerbr/>
Much better. In 22(c) just be careful with open-ended questions--you are giving her license to answer the question in whatever capacity she chooses. This is why on cross yes/no is far beter because it controls the pace. There she can claim she saw the information as unrelated, or as the hearing is about threats since that had no threat in it, the judge didn't have to see it because it is not important.

As for the accusations and your email, sorry that my response was omitted, that was absolutely not by intention. I could sense strong emotion from the comments, specifically anger, which potentially may harm your claim. This is why it is suggested that you consider showing that both parties were emotional and heated with their exchange, and that you introduce her emails to point to her emotional comments (if any) so as to show that the comments were angry but they did not threaten. It is hard to not look at that comment and not see a threat, so it is far better to defuse it if possible and point to both parties using strong language than attacking her one selectively editing the email--that is also important but it is not solely important.

Good luck.
Customer: replied 1 year ago.

Thank you Dimitry,


 


Everything is getting clearer and clearer. Beginning was difficult for me because it was just "collecting information." Now I am closer on the point.


 


As usual I'll first reply and then rate to not do everything from the very beginning.


 


A small clarification about who reads quotations. I knew that: "Please read for the court..." but always thought it was only for emphasizing or for intimidating a witness. Are there are rules it must be this or that way? If so, should I underline what I need her to read and say "please read this to the court?"


 


O, please tell me "Don't you think people never sleep?" unless you are the same night bird as I am.


 


 


Part 3


1. Ms. Moiseeva, isn't it a fact that when I asked you to explain why you decided I was going to take our son out of the country illegally, you copied and sent me the 3rd March 7 email where I said "I will take Boris away in October, November, December... March... as soon as it will become possible" - yes or no?

1 a. Please read this to the court... (Or should I read it since it was my email and ask "did I write it, yes or no?) Did I clearly say that I was going to go to the court asking custody of our son, did I say that in my opinion the court should take my side because its decisions have to be based on the best interests of the child, did I?

2. So, despite I clearly said in my first email this day I was going to go to the court for a custody, despite I said it was a simple solution since the court must make a decision based on the best interest of the child, you still interpreted mentioning our son's school year and "I'll take Boris" as a threat to take him out of the country illegally?)

3. And in your opinion what so important possibilities or opportunities a kidnapper - me in this particular case - might need if he was going to wait for them as long as one year? I could simply say when you are not home: "Borya, let's get dressed, we are going on the beach" and in a couple of hours we would be on a plain. What are these opportunities?

4. Ms. Moiseeva, is the following quotation from my main 1st email on March 7 correct: "Borya will be living in Mexico. I assume that his mother will live there too, thus he will have both mother and father as well as everything else he is deprived of." Did I write it - yes or no?

5. Ms. Moiseeva, please tell the court how "he will have both mother and father" can be interpreted as an intention to kill the mother. Mexico is a tropical country and I could not keep the dead mother with us for too long. (Should I avoid my idiotic humor?)

6. Ms. Moiseeva, is the following quotation from my main 1st email on March 7 correct: "I'll try to implement my decision into the reality gently. Once upon a time you were a good girl and deserve gentleness." Did I write it, yes or no?

10. Ms. Moiseeva, please tell the court - do you think "gently" and "deserve gentleness" clearly means a promise to kill you quickly without preceding tortures?

11. Ms. Moiseeva, are the following quotations from my main 1st email on March 7 correct: "The second option. Asking the judge for Physical Custody (with Joint Legal Custody). With factual Joint Physical Custody but at the prime custodian's physical residence." And then: "I will not take away Boris' mama from him. Joint Physical Custody means that a child may live with mother, father, change between them and whatever. Everything is fine with me. You are in your cozy nest, Boris is with me; Boris is with you in your nest; Boris is wherever he wants to be today. However everything is in Mexico." And then: "The father does not have the slightest objection to the unlimited communication between mother and child including physical residence of the child at the mother's place of residence. However in human conditions." And then: "Also I will have to pay to the attorney, since I will be able to come only for hearing in court." Did I write these, yes or no?

12. Ms. Moiseeva, please tell the court what other interpretations of these qoutas besides intention to hire an attorney, going to court and assumption that you would prefer to live with our son if I won are possible?

13. Ms. Moiseeva, after you received my March 7 emails, on March 8 you wrote an answer. Is this your answer and you said: "How do you imagine the court will let you take an American citizen to Mexico due to the fact that you cannot reside in US because you are crazy? Very strange logic." Is this exactly what you wrote?

14. Ms. Moiseeva, you said I threatened to take our son illegally out of country and kill you if you would try to stop me. But in your response to these threats you did not respond to them. Instead you referred to the possible court's opinion. Please explain to the court why in your opinion the kidnapper and murderer would want to go to a court? To receive a license to kill?

15. Ms. Moiseeva, you wrote an email to our common friends Gary and Natasha where you said: "Dear Igor and Natasha, It became impossible to negotiate withCustomer I had to go to the court." Did you write this?

16. Please explain to the court what in your opinion is possible to negotiate with a person who is going to kill you and kidnap your son? Terms and conditions of these crimes? (Weak - call for speculations?)

17. When you stopped doing your job for my company, did you write to me saying: "I am not going to assist you in making money for an attorney against me?"

18. You said I was going to kidnap your son and kill you. How an attorney could assist me in this?


 

Expert:  Dimitry K., Esq. replied 1 year ago.
Customer

I happen to be a night owl. While I do sleep, I try to do it during the morning and avoid that period of time when everyone is torpid, slow, and cranky. If you are a night person, I will be here with you for at least a few hours.

In terms of 'reading for the court', the person must read from something that was already authenticated and entered into evidence. If you are asimply asking her to read something, what she reads does not enter into evidence, only her comments go on record. Reading omething does not make it true, authenticating documentation then makes the comments viable (if needed).

In the third question--do not call yourself anything negative as that is what the courts remember. It is not a kidnapper...an 'alleged kidnapper or 'alleged abductor'. Further--making such assumptions places you in a poor light. Asking if you had opportunity to take the child and didn't is like sufficient. Her statements must be made to be vivid and emotional, not yours. comments about you should likely be tempered and made 'tasteless' for all practical purposes--the ls attention to you and your comments, the less claim that you acted improperly.

5. Avoid tasteless humor, but a caustic spin may be fine--you could ask if you meant someone else to take the role of the mother or if you meant her.

10 is a very nice question. If worded properly, it may be a winner. Just be aware for an objection on relevance.

12 is a bad question Giving license again to answer whatever she wishes. Unwise.

14. Same issue...alleged, not actual.

15. Objection...relevance--don't see the need to interject it as it is not related to your case.

16. Asking why she would negotiate is better, not penalties--she is not a judge or jury.


Hope that helps.


Customer: replied 1 year ago.

All what somebody (me or her) will read of course will be in evidence - all of it in our emails that I translated and certified. (I'd love to ask her to read and explain what it means some case law - to the end of the second sentence she would go to the mental hospital but...) I just did not understand when I should ask her to read; when I ask should I underline what I need her to read and ask her to read this or these sentence(s), and when I can read. Say, # XXXXX is long and quotas are from different places - can I not her read it?

#3. Fully understood. Could be simply "What are so important opportunities or possibilities I might need to wait for them 7-12 months..." But I didn't understand should or shouldn't I mention a possibility. ("He just explained how simply he could do this. She should get Order of Protection for eternity!!!" or "He could do it at any moment but didn't - therefore he didn't intend" - what reaction it will produce?) If the second then "... when at any given moment when you are not home I could simply say: "Borya, let's get dressed, we are going on the beach" and in 2 hours be on the plain with him? What are these opportunities?

#10. I did not understand possibility of objection on the relevance ground. I am speaking about the case and the question/possible answer is material (People v Scarola,
71 N.Y.2d 769 (1988): "All relevant
evidence is admissible unless its admission violates some exclusionary rule. "Evidence is
relevant if it has any tendency in reason to prove the existence of any material fact, i.e., it makes
determination of the action more probable or less probable than it would be without the
evidence").

Same with # XXXXX She asked our mutual friends to serve me with Order "if they will have a chance to see me" and explained why - isn't her comments - why - are relevant to the case? She didn't say: "He became absolutely insane and threatened to kill me;" instead "impossibility to negotiate."

But - something clumsy in this # XXXXX question indeed. What did you mean when you said "worded properly?" If you can't re-phrase this particular question, can you give me an example?

## XXXXX and 14. I understand the point although my wife doesn't think like you do. She doesn't see opportunities to speculate. But why take chances? However, preceding ## XXXXX and 13 are important. There are endless "court, judge, attorney, both mother and father, our son lives with you, your Physical Custody" in # XXXXX - a lot direct words on the scale when on the other scale is only possible interpretation of emotions. And all of this contradicts possible interpretation. And in # XXXXX is unadequate to possible interpretation but 100% adequate to not illegal and "legal" threat response: "How you imagine the court..." Will it work if I'll re-phrase # XXXXX like:

Ms. Moiseeva, I was stating my real intentions and not some possible interpretations of emotions for a long time in this email. I used direct words. Are words and sentences "judge, Physical Custody, with Joint Legal Custody, attorney, with factual Joint Physical Custody, at prime custodian's physical residence, child may live with mother, physical residence of the child at the mother's place of residence" and their repetitions code words and they have double meaning, yes or no?

So, if they don't have any other meaning, did you think when reading this I was speaking about hiring an attorney, judge decision, who will get Physical custody, who Legal, will our son live with you or me and so on without speaking about anything else - yes or no?

More difficult to re-word #14 but unadequate petitioner's answer is important. Will the following work (then it will be #13) If needed all can be re-phrase as questions ("Do you agree that one part excludes another?"):

# XXXXX Ms. Moiseeva, in your allegations you referred to March 7 emails. You read all 3 of them. Small part of them are expressed emotions that you said you interpreted as a threat. Large part is dedicated to legal proceding. In a sense of intentions one part excludes another. Since one excludes another you could believe that only one of them is my true intentions. The next day you wrote an answer to these 3 emails. Is this your answer and you said: "How do you imagine the court will let you take an American citizen to Mexico due to the fact that you cannot reside in US because you are crazy? Very strange logic." Is this exactly what you wrote?

#14. Was it the answer to the part that was dedicated to the legal proceding or was it the answer to the part you interpreted as a threat?


 


#14 a. Ms. Moiseeva, you admitted that there were 2 parts or 2 subjects in my emails - concrete legal and emotional that you interpreted as a threat. You admitted that only one of them could be my true intent. You admitted that consequently you could believe that either this part was my true intent or that. You wrote an answer the next day. You admitted that it was an answer to my legal intentions. So, did you asked for Order of Protection to protect yourself from justice - yes or no? (Rhetoric question of course with predictable "no" but seems to be useful)


 


#16. Did not quite understand what you meant here:


 


"What would you negotiate with the person that was going to kill you and kidnap your son? Terms and conditions of these crimes?" Something like this?


 




Taking into the account all psychology and preciseness of words # XXXXX should be re-phrased too:

In your allegations you said I was going to take our son out of country and kill you if you try to stop me. How an attorney could assist me in this?


 


Best regards,


 


Customer/p>
Expert:  Dimitry K., Esq. replied 1 year ago.
Customer

As you wrote a very detailed response, I will attempt to respond in kind. Should you have any follow-up concerns, I will respond to them in the morning as I will be going to sleep after this post.
-----

All what somebody (me or her) will read of course will be in evidence - all of it in our emails that I translated and certified. (I'd love to ask her to read and explain what it means some case law - to the end of the second sentence she would go to the mental hospital but...) I just did not understand when I should ask her to read; when I ask should I underline what I need her to read and ask her to read this or these sentence(s), and when I can read. Say, # XXXXX is long and quotas are from different places - can I not her read it?
It appears that I was unclear. If you entered the emails into evidence, then you can ask her to read from them. But if you did not enter the emails, or you are asking her to read from a document that was never put into evidence, the other party would object.

 

#3. Fully understood. Could be simply "What are so important opportunities or possibilities I might need to wait for them 7-12 months..." But I didn't understand should or shouldn't I mention a possibility. ("He just explained how simply he could do this. She should get Order of Protection for eternity!!!" or "He could do it at any moment but didn't - therefore he didn't intend" - what reaction it will produce?) If the second then "... when at any given moment when you are not home I could simply say: "Borya, let's get dressed, we are going on the beach" and in 2 hours be on the plain with him? What are these opportunities?
I am not sure what you hope to win by mentioning other opportunities beyond cursory asking if you ever took the child without permission. If she says 'no', then you can state that her claim that you would take the child is unreasonable based on your past behavior as there was no history ever of such claims in the past.

 

#10. I did not understand possibility of objection on the relevance ground. I am speaking about the case and the question/possible answer is material (People v Scarola,
71 N.Y.2d 769 (1988): "All relevant
evidence is admissible unless its admission violates some exclusionary rule. "Evidence is
relevant if it has any tendency in reason to prove the existence of any material fact, i.e., it makes
determination of the action more probable or less probable than it would be without the
evidence").

That is because this isn't really a relevant question, it is an emotional one. You are asking for her opinion (which isn't fact) and that is why her opinion could be objected to, something you can potentially rebut by claiming that her opinion and concerns are at the heart of the matter and that is why her response should be permitted to be given.

Same with # XXXXX She asked our mutual friends to serve me with Order "if they will have a chance to see me" and explained why - isn't her comments - why - are relevant to the case? She didn't say: "He became absolutely insane and threatened to kill me;" instead "impossibility to negotiate."

This is a situation where it is again a relevance issue. Parties do not always share what occurs within their family unit with others, so the fact she simply stated that you are difficult to talk to does not take away from her anxiety--in fact going to third parties may bolster her case by arguing that she no longer felt safe or comfortable in communicating with you one-on-one so she asked others to intervene. This is why that is a potentially troubling road.

But - something clumsy in this # XXXXX question indeed. What did you mean when you said "worded properly?" If you can't re-phrase this particular question, can you give me an example?

Hmm, perhaps "...did you think that the comments in the letter (use the language) was some sort of abstract code to mean that you were threatened with death or severe injury?" It is not ideal, but it is better.


## XXXXX and 14. I understand the point although my wife doesn't think like you do. She doesn't see opportunities to speculate. But why take chances? However, preceding ## XXXXX and 13 are important. There are endless "court, judge, attorney, both mother and father, our son lives with you, your Physical Custody" in # XXXXX - a lot direct words on the scale when on the other scale is only possible interpretation of emotions. And all of this contradicts possible interpretation. And in # XXXXX is unadequate to possible interpretation but 100% adequate to not illegal and "legal" threat response: "How you imagine the court..." Will it work if I'll re-phrase # XXXXX like:

Ms. Moiseeva, I was stating my real intentions and not some possible interpretations of emotions for a long time in this email. I used direct words. Are words and sentences "judge, Physical Custody, with Joint Legal Custody, attorney, with factual Joint Physical Custody, at prime custodian's physical residence, child may live with mother, physical residence of the child at the mother's place of residence" and their repetitions code words and they have double meaning, yes or no?

That is better, you may also want to break that into multiple questions.

So, if they don't have any other meaning, did you think when reading this I was speaking about hiring an attorney, judge decision, who will get Physical custody, who Legal, will our son live with you or me and so on without speaking about anything else - yes or no?

More difficult to re-word #14 but unadequate petitioner's answer is important. Will the following work (then it will be #13) If needed all can be re-phrase as questions ("Do you agree that one part excludes another?"):

Not sure I follow, sorry.

# XXXXX Ms. Moiseeva, in your allegations you referred to March 7 emails. You read all 3 of them. Small part of them are expressed emotions that you said you interpreted as a threat. Large part is dedicated to legal proceding. In a sense of intentions one part excludes another. Since one excludes another you could believe that only one of them is my true intentions. The next day you wrote an answer to these 3 emails. Is this your answer and you said: "How do you imagine the court will let you take an American citizen to Mexico due to the fact that you cannot reside in US because you are crazy? Very strange logic." Is this exactly what you wrote?

The part I put in bold would be objected to--that is a conclusion that you are reaching for her. Consider reworking.

#14. Was it the answer to the part that was dedicated to the legal proceding or was it the answer to the part you interpreted as a threat?

 

 

 

#14 a. Ms. Moiseeva, you admitted that there were 2 parts or 2 subjects in my emails - concrete legal and emotional that you interpreted as a threat. You admitted that only one of them could be my true intent. You admitted that consequently you could believe that either this part was my true intent or that. You wrote an answer the next day. You admitted that it was an answer to my legal intentions. So, did you asked for Order of Protection to protect yourself from justice - yes or no? (Rhetoric question of course with predictable "no" but seems to be useful)

 

 

 

#16. Did not quite understand what you meant here:

 

 

 

"What would you negotiate with the person that was going to kill you and kidnap your son? Terms and conditions of these crimes?" Something like this?

I just see that as a poor question. Simply out there for shock value and I can see her attorney object on the fact it brings nothing useful to the proceedings.

 

 

 



Taking into the account all psychology and preciseness of words # XXXXX should be re-phrased too:

In your allegations you said I was going to take our son out of country and kill you if you try to stop me. How an attorney could assist me in this?

Customer: replied 1 year ago.

Good "morning" Dimitry,


 


I think that profession of attorney with all this preciseness of words is a great preparation for a Russian jail with their "Otvet' za slovo." Have you ever considered a career of "vor v zakone?"


 


Either I missed your answer or you missed my technical question: do I have to put anything in Stipulation of Facts in Statement of Readiness? Well, it is also custody case the same day. If the attorney's evidence in Exhibit will be reducted, do I have to object it there or tell to the judge?


Finally, if he will present the entire email and "will forget" about reducted version how to bring the fact the case originated with reducted evidence and there was nothing else? In the best (worst for the petitioner) light of course?


 


Probably it was I who was not clear. Some particular email IS in evidence. I need to quota one or several sentences from it. Do I HAVE TO ask the petitioner to read it/them? Can I read them myself instead and ask her "Did I/you say it - yes or no?" If for one or another reason it is she that has to read, do I have to underline (put a line by hand in the copy of email under the sentences) this or these sentences and ask her to read them? When I need to quota several sentences from different part of email it will look silly ("Good, and now read from here... OK, stop... where the next?.. O, here it is")


 


# XXXXX Actually I asked this question only because I asked her once (not for the trial and in our real "private" correspondence: "I can see you still insisting on "kidnapping" of Borya. Please show me where I wrote this and I'll say that I should drink less Margaritas. And if you will be not able to show, please say: "Excuse me, I've got something wrong." She sent me this short email. Later, since it was the last email I wrote same day March 7, I thought that she may use it as an evidence. That's why I was going to ask this question showing the evidence was unreasonable. But I don't think it will bring me any points. However, it seems to me your corrections opened a door for a great opportunity. I can ask:


 


Ms. Moiseeva, is it true that I first offer you to relocate to Mexico about a year ago? ("Yes")


 


 


Is it true that I offered you this many times, was very persistent, tried to convince you, often I was angry but you always said "no?" ("Yes")


 


Ms. Moiseeva, did we live together in the same apartment with our son? ("Yes")


 


Could I without all the drama you put in your allegations when you were not home simply say "Boris, let's get dressed - we are going on the beach" and in 2 hours be with him on the plane? (Uncertain "yes" most likely)


 


During the past year did I have many such opportunities?


 


So, unless it was the court order I was talking throughout our correspondence that day, what are those opportunities I mentioned in my email and why they are so important I was going to wait for them 7-12 months?


 


 


 


 


# XXXXX "That is because this isn't really a relevant question, it is an emotional one. You are asking for her opinion (which isn't fact) and that is why her opinion could be objected to, something you can potentially rebut by claiming that her opinion and concerns are at the heart of the matter and that is why her response should be permitted to be given."


 


Isn't this exactly what her attorney is going to do during direct examination? Asking her interpretation of this and that, what she thought it meant, etc.? This emotional statement is not really suitable even for inference - it's all about what she thought, did it harass her and if it was my intent to harass. May I object his questions/her answers on the same relevance ground - asking for opinion/opinion is not a fact? Actually the whole case is opinions and my opinion all was intentional lie as valid as her opinion it was a clear threat. Nothing clearly proves one or the other. By the way, if my objection on this ground will be overruled, than it will be very difficult for the opponent to bring the same objection on the same ground.


 


 


#10. Thank you for re-phrasing this. One problem. Would you ask slesarya-vodoprovodchika iz Saratova: "Vam ne kazhetsya, chto v vashem suzhdenii prisutstvuet nekotory immanentny dualizm?" Same thing. She will not understand "some sort of abstract code" but will not say it and can answer God knows what. This is rhetoric question though. However - it seems to me it is virtually the same from the emotional/relevance point of view only without sarcasm (quick death


without preceding tortures).


 


Will # XXXXX work like this:


 


 


13. Ms. Moiseeva, in your allegations you referred to March 7 emails. You read all 3 of them. Small part of them are expressed emotions that you said you interpreted as a threat. Large part is dedicated to legal proceding. Do you agree that in a sense of intentions one part excludes another? (It will be difficult to her to understand)


 


Since you agreed one part excludes another, do you agree that you could believe I intended to do either one part or another?


 


The next day you wrote an answer to these 3 emails. Is this your answer and you said: "How do you imagine the court will let you take an American citizen to Mexico due to the fact that you cannot reside in US because you are crazy? Very strange logic." Is this exactly what you wrote?


 


#14. Was it the answer to the part that was dedicated to the legal proceding or was it the answer to the part you interpreted as a threat?


 


#14 a. Ms. Moiseeva, you admitted that there were 2 parts or 2 subjects in my emails - concrete legal and emotional that you interpreted as a threat. You admitted that only one of them could be my true intent. You admitted that consequently you could believe that either this part was my true intent or that. You wrote an answer the next day. You admitted that it was an answer to my legal intentions. So, did you asked for Order of Protection to protect yourself from justice - yes or no? (Rhetoric question of course with predictable "no" but seems to be useful)


 


You clearly explain the weakness of other questions so they went to my big box with proud name "Junk" on it.


 


Best regards,


 


Customer/p>

 


 

Expert:  Dimitry K., Esq. replied 1 year ago.
Customer good 'morning' to you as well. I will do my best to respond here.

Good "morning" Dimitry,

 

I think that profession of attorney with all this preciseness of words is a great preparation for a Russian jail with their "Otvet' za slovo." Have you ever considered a career of "vor v zakone?"

Taking the 5th on that one. I also think I have a better dental plan.

 

Either I missed your answer or you missed my technical question: do I have to put anything in Stipulation of Facts in Statement of Readiness? Well, it is also custody case the same day. If the attorney's evidence in Exhibit will be reducted, do I have to object it there or tell to the judge?

You would need to object on-site. As for putting something in the stipulation, is there anything you wish to revise? If not, I am unclear as to what you wish to enter as additional facts in this case.

 

Finally, if he will present the entire email and "will forget" about reducted version how to bring the fact the case originated with reducted evidence and there was nothing else?

You don't. You were out-maneuvered you you go on.

 

In the best (worst for the petitioner) light of course?

IT's a non issue if they enter the full email.

 

Probably it was I who was not clear. Some particular email IS in evidence. I need to quota one or several sentences from it. Do I HAVE TO ask the petitioner to read it/them?

No, you do not. But if they are in evidence, it would be more foreceful to have the words be read.

 

Can I read them myself instead and ask her "Did I/you say it - yes or no?"

You can, but it would better for the witness to do it.

 

If for one or another reason it is she that has to read, do I have to underline (put a line by hand in the copy of email under the sentences) this or these sentences and ask her to read them?

No, you do not.

 

When I need to quota several sentences from different part of email it will look silly ("Good, and now read from here... OK, stop... where the next?.. O, here it is")

 

 

 

# XXXXX Actually I asked this question only because I asked her once (not for the trial and in our real "private" correspondence: "I can see you still insisting on "kidnapping" of Borya. Please show me where I wrote this and I'll say that I should drink less Margaritas. And if you will be not able to show, please say: "Excuse me, I've got something wrong." She sent me this short email. Later, since it was the last email I wrote same day March 7, I thought that she may use it as an evidence. That's why I was going to ask this question showing the evidence was unreasonable. But I don't think it will bring me any points. However, it seems to me your corrections opened a door for a great opportunity. I can ask:

 

Customer good 'morning' to you as well. I will do my best to respond here.

Good "morning" Dimitry,

 

I think that profession of attorney with all this preciseness of words is a great preparation for a Russian jail with their "Otvet' za slovo." Have you ever considered a career of "vor v zakone?"

Taking the 5th on that one. I also think I have a better dental plan.

 

Either I missed your answer or you missed my technical question: do I have to put anything in Stipulation of Facts in Statement of Readiness? Well, it is also custody case the same day. If the attorney's evidence in Exhibit will be reducted, do I have to object it there or tell to the judge?

You would need to object on-site. As for putting something in the stipulation, is there anything you wish to revise? If not, I am unclear as to what you wish to enter as additional facts in this case.

 

Finally, if he will present the entire email and "will forget" about reducted version how to bring the fact the case originated with reducted evidence and there was nothing else?

You don't. You were out-maneuvered you you go on.

 

In the best (worst for the petitioner) light of course?

IT's a non issue if they enter the full email.

 

Probably it was I who was not clear. Some particular email IS in evidence. I need to quota one or several sentences from it. Do I HAVE TO ask the petitioner to read it/them?

No, you do not. But if they are in evidence, it would be more foreceful to have the words be read.

 

Can I read them myself instead and ask her "Did I/you say it - yes or no?"

You can, but it would better for the witness to do it.

 

If for one or another reason it is she that has to read, do I have to underline (put a line by hand in the copy of email under the sentences) this or these sentences and ask her to read them?

No, you do not.

 

When I need to quota several sentences from different part of email it will look silly ("Good, and now read from here... OK, stop... where the next?.. O, here it is")

 

 

 

# XXXXX Actually I asked this question only because I asked her once (not for the trial and in our real "private" correspondence: "I can see you still insisting on "kidnapping" of Borya. Please show me where I wrote this and I'll say that I should drink less Margaritas. And if you will be not able to show, please say: "Excuse me, I've got something wrong." She sent me this short email. Later, since it was the last email I wrote same day March 7, I thought that she may use it as an evidence. That's why I was going to ask this question showing the evidence was unreasonable. But I don't think it will bring me any points. However, it seems to me your corrections opened a door for a great opportunity. I can ask:



Ms. Moiseeva, is it true that I first offer you to relocate to Mexico about a year ago? ("Yes")

 

Is it true that I offered you this many times, was very persistent, tried to convince you, often I was angry but you always said "no?" ("Yes")

Don't bring up your own anger. State the communication was emotional or heated. You do not want to make yourself look bad.

 

Ms. Moiseeva, did we live together in the same apartment with our son? ("Yes")

 

Could I without all the drama you put in your allegations when you were not home simply say "Boris, let's get dressed - we are going on the beach" and in 2 hours be with him on the plane? (Uncertain "yes" most likely)

 

During the past year did I have many such opportunities?

 

So, unless it was the court order I was talking throughout our correspondence that day, what are those opportunities I mentioned in my email and why they are so important I was going to wait for them 7-12 months?

Split in two--you have two questions in one.

 

# XXXXX "That is because this isn't really a relevant question, it is an emotional one. You are asking for her opinion (which isn't fact) and that is why her opinion could be objected to, something you can potentially rebut by claiming that her opinion and concerns are at the heart of the matter and that is why her response should be permitted to be given."


Isn't this exactly what her attorney is going to do during direct examination? Asking her interpretation of this and that, what she thought it meant, etc.? This emotional statement is not really suitable even for inference - it's all about what she thought, did it harass her and if it was my intent to harass. May I object his questions/her answers on the same relevance ground - asking for opinion/opinion is not a fact?
Yes, you can.

Actually the whole case is opinions and my opinion all was intentional lie as valid as her opinion it was a clear threat. Nothing clearly proves one or the other. By the way, if my objection on this ground will be overruled, than it will be very difficult for the opponent to bring the same objection on the same ground.
I agree with you, just showing you where he may object and if you arne't ready for it, you could lose the objection.

#10. Thank you for re-phrasing this. One problem. Would you ask slesarya-vodoprovodchika iz Saratova: "Vam ne kazhetsya, chto v vashem suzhdenii prisutstvuet nekotory immanentny dualizm?" Same thing. She will not understand "some sort of abstract code" but will not say it and can answer God knows what. This is rhetoric question though. However - it seems to me it is virtually the same from the emotional/relevance point of view only without sarcasm (quick death

 

without preceding tortures).

I get your point, but you do not want to appear overly intellectual either--she has to understand the questions that you are posing to her.

 

Will # XXXXX work like this:

 

13. Ms. Moiseeva, in your allegations you referred to March 7 emails. You read all 3 of them. Small part of them are expressed emotions that you said you interpreted as a threat. Large part is dedicated to legal proceding. Do you agree that in a sense of intentions one part excludes another? (It will be difficult to her to understand)

It still difficult for me to understand. One part does not exclude the other, and it is not a wise approach. You cannot exclude a threat, it is either a threat or it is not.

 

Since you agreed one part excludes another, do you agree that you could believe I intended to do either one part or another?I do not see her agreeing. This is a problematic line of thinking.

 

The next day you wrote an answer to these 3 emails. Is this your answer and you said: "How do you imagine the court will let you take an American citizen to Mexico due to the fact that you cannot reside in US because you are crazy? Very strange logic." Is this exactly what you wrote?

#14. Was it the answer to the part that was dedicated to the legal proceding or was it the answer to the part you interpreted as a threat?

Better.

 

#14 a. Ms. Moiseeva, you admitted that there were 2 parts or 2 subjects in my emails - concrete legal and emotional that you interpreted as a threat. You admitted that only one of them could be my true intent. You admitted that consequently you could believe that either this part was my true intent or that. You wrote an answer the next day. You admitted that it was an answer to my legal intentions. So, did you asked for Order of Protection to protect yourself from justice - yes or no? (Rhetoric question of course with predictable "no" but seems to be useful)

What justice? From whom? What does that mean? My apologies, I do not see this as a valid retelling.

 

You clearly explain the weakness of other questions so they went to my big box with proud name "Junk" on it.

Good to hear!

 

Good luck to you!



 

Customer: replied 1 year ago.

Hello Dimitry,


 


Small clarifications and next questions ( 2 more portions left and everything starting to acquire a structure - thank you very much!)


 


"Object on site" - exactly when? Before the trial starts; at the moment when the attorney will give the judge the evidence, some other time?


 


"Out-maneuvered" also means that there were no evidence at all when the petitioner went to the police and then to the court - the entire email could be printed and certified only after June 20. It also means that my opponent had no evidence (since there are no other evidence) at the original trial date June 20. Obviously I want to "chew and put in judge's head" that originally the evidence was intentionally fabricated (even if "intentionally fabricated" is impossible to prove and not wise to mention). Will I be able to squeeze something useful with my previous questions we discussed:


 


20. Ms. Moiseeva, this is the email you presented as an evidence. Is it exactly the same email you presented as an evidence to the police?

21. Is it exactly the same email you presented to the court when you filed Family Offense Petition and asked for Order Of Protection?

22. Ms. Moiseeva, did you present both the police and the court only one paragraph from my second email I wrote this day, yes or no? (She simply may confused what would be "yes" or "no" if I'll use "Isn't it a fact" form)


 


We a bit stuck with #13 but it seems to be important as she herself refers to "legal threat" without mentioning any other threats right after she said she was threatened. So, will it work like this:


 


 


 


13. Ms. Moiseeva, in your allegations you referred to March 7 emails. You read all 3 of them. Small part of them are expressed emotions that you said you interpreted as a threat. Large part is dedicated to legal proceeding. One part you interpreted as an intent to take our son out of the country illegally. Do you agree that another part where I said I was going to hire an attorney and to go to the court for the custody of our son expresses intent to proceed legally?

OK. So there are two theoretically possible intents. One of them is to proceed legally - to go to the court. Another to proceed illegally - illegally take our son out of the country. Do you agree that whatever the real intent was, it could be only one intent, not both of them at the same time? (Hopeful "yes")

So, if it could be only one intent, you could believe that I had only one intent whatever it was - is it so?

The next day you wrote an answer to these 3 emails. Please read this: "How do you imagine the court will let you take an American citizen to Mexico due to the fact that you cannot reside in US because you are crazy? Very strange logic." (Is this exactly what you wrote?)

#14. Was it the answer to the part that was dedicated to the legal proceeding or was it the answer to the part you interpreted as a threat?

(Better.)


 


If it's OK I don't know if I should push it farther or leave for a while to bring everything at the very end.


 


 


 


Next.


 


 


19. Ms. Moiseeva, where were you and were was I on March 7, 2013?

20. Did I go to Mexico by plain, boat or car?

21. Is it true that the trip to the place I was in Mexico by car takes approximately a week - it is about 3,700 miles trip?

22. Did we communicate via email and/or Skype between March 7 and March 11 when you filed a Family Offense Petition discussing usual business matters like who received or didn't received the item, where you could buy an adapter for Nintendo I gave to our son and the like?

23. Do you think it is the usual routine when after announcement of upcoming crime, criminals and their future victims start to discuss insignificant details like these? "OK, so I will kill you the next Thursday. Meanwhile, did you buy AA batteries for the camera?" Is it usual in your opinion, yes or no?

24. Was there anything in our emails and other communications that told you I was going back to NY immediately? If yes - please show the court the email where I said so.

25. Ms. Moiseeva, I cannot understand. Even with extremely frivolous interpretation of "I'll take Boris in October, November, March" the potential kidnapper said he was going to do this in 7 to 12 months from now. He is in another country 37,000 miles away from you. (He had initial plans to stay there for another 2 months - if she will say she knew) and nothing told you he changed his mind. You and him continue to communicate the regular way. What did produce the fear of immediate danger so that you went to the Family Court and asked for an Order Of Protection?

26. So, whether it was justified or not you feared I could take our son out of the country and kill you if you would try to stop me - is it what you are saying?

27. Ms. Moiseeva, is this your email you wrote on April 2, 2013?

28. Please read this sentence: "I will gladly agree everything was a misunderstanding" Did you mean you would agree in the court everything was a misunderstanding?

28 a. Please read "However I demand the full custody (Legal and Physical). Under these conditions I guarantee your maximum participation in Boris' life, any kind of communication possible if you are not in the country, at any time. Our visits to you during the time of school holidays. You can oblige me to it through court order. Maybe it will be make easier for me to take time off from work. However, without my presence, he will be able to travel to you and with you only, when he reaches at least 14 years of age." (Did you write this?)

30. Ms. Moiseeva, another thing I cannot understand. Even though the potential violator was in another country, even though he had no intentions to come back to NY within next 2 month, your fear he could kidnap your son and kill you was so horrible that despite of the absence of the real threat (I left this on purpose knowing in advance you will object. She however not "vor v zakone" and will miss it. Can her attorney object "absense of the real danger?"), despite of the absence of any imminent danger you went to the court and asked for an Order of Protection. But then you offered the kidnapper to voluntarily bring your son exactly where he wanted to take him and to give yourself to the murderer in another country where you would be in his whole mercy and nothing could stop him from killing you. To simplify, you offered exactly what you asked the court to protect you from. Could you explain the court this contradiction?


 


 


I am going to cashier now.


 


Thank you in advance.


 


Customer/p>
Expert:  Dimitry K., Esq. replied 1 year ago.
Customer

I am sorry but I was having difficulty posting a response to your initial. Could you please shorten your posts?
Customer: replied 1 year ago.

O, sorry Dimitry, I didn't know you had character limitation. I'll just split it in two.


 


 


"Object on site" - exactly when? Before the trial starts; at the moment when the attorney will give the judge the evidence, some other time?


 


 


 


"Out-maneuvered" also means that there were no evidence at all when the petitioner went to the police and then to the court - the entire email could be printed and certified only after June 20. It also means that my opponent had no evidence (since there are no other evidence) at the original trial date June 20. Obviously I want to "chew and put in judge's head" that originally the evidence was intentionally fabricated (even if "intentionally fabricated" is impossible to prove and not wise to mention). Will I be able to squeeze something useful with my previous questions we discussed:


 


 


 


20. Ms. Moiseeva, this is the email you presented as an evidence. Is it exactly the same email you presented as an evidence to the police?

21. Is it exactly the same email you presented to the court when you filed Family Offense Petition and asked for Order Of Protection?

22. Ms. Moiseeva, did you present both the police and the court only one paragraph from my second email I wrote this day, yes or no? (She simply may confused what would be "yes" or "no" if I'll use "Isn't it a fact" form)


 


 


 


We a bit stuck with #13 but it seems to be important as she herself refers to "legal threat" without mentioning any other threats right after she said she was threatened. So, will it work like this:


 


 


 


 


 


 


 


13. Ms. Moiseeva, in your allegations you referred to March 7 emails. You read all 3 of them. Small part of them are expressed emotions that you said you interpreted as a threat. Large part is dedicated to legal proceeding. One part you interpreted as an intent to take our son out of the country illegally. Do you agree that another part where I said I was going to hire an attorney and to go to the court for the custody of our son expresses intent to proceed legally?

OK. So there are two theoretically possible intents. One of them is to proceed legally - to go to the court. Another to proceed illegally - illegally take our son out of the country. Do you agree that whatever the real intent was, it could be only one intent, not both of them at the same time? (Hopeful "yes")

So, if it could be only one intent, you could believe that I had only one intent whatever it was - is it so?

The next day you wrote an answer to these 3 emails. Please read this: "How do you imagine the court will let you take an American citizen to Mexico due to the fact that you cannot reside in US because you are crazy? Very strange logic." (Is this exactly what you wrote?)

#14. Was it the answer to the part that was dedicated to the legal proceeding or was it the answer to the part you interpreted as a threat?

(Better.)


 


If it's OK I don't know if I should push it farther or leave for a while to bring everything at the very end.

Expert:  Dimitry K., Esq. replied 1 year ago.
Customer

Thank you for your follow-up:

"Object on site" - exactly when? Before the trial starts; at the moment when the attorney will give the judge the evidence, some other time?

When the evidence is attempted to be entered. Then you can seek an objection and move o have the full email entered as evidence.

 

 

 

 

 

 

"Out-maneuvered" also means that there were no evidence at all when the petitioner went to the police and then to the court - the entire email could be printed and certified only after June 20. It also means that my opponent had no evidence (since there are no other evidence) at the original trial date June 20. Obviously I want to "chew and put in judge's head" that originally the evidence was intentionally fabricated (even if "intentionally fabricated" is impossible to prove and not wise to mention). Will I be able to squeeze something useful with my previous questions we discussed:

Sorry, I do not see it, I only see this as useful if you fail to get your emailed entered and the judge permits the redacted emails instead.

 

 

 

20. Ms. Moiseeva, this is the email you presented as an evidence. Is it exactly the same email you presented as an evidence to the police?

21. Is it exactly the same email you presented to the court when you filed Family Offense Petition and asked for Order Of Protection?

22. Ms. Moiseeva, did you present both the police and the court only one paragraph from my second email I wrote this day, yes or no? (She simply may confused what would be "yes" or "no" if I'll use "Isn't it a fact" form)

 

 

 

We a bit stuck with #13 but it seems to be important as she herself refers to "legal threat" without mentioning any other threats right after she said she was threatened. So, will it work like this:

 

 

 

 

 

 

 

 


13. Ms. Moiseeva, in your allegations you referred to March 7 emails. You read all 3 of them. Small part of them are expressed emotions that you said you interpreted as a threat. Large part is dedicated to legal proceeding. One part you interpreted as an intent to take our son out of the country illegally. Do you agree that another part where I said I was going to hire an attorney and to go to the court for the custody of our son expresses intent to proceed legally?
Much better. Now you are clearly showing what you are trying to ask. Before the question was very theoretical and not direct enough--this is better.

OK. So there are two theoretically possible intents. One of them is to proceed legally - to go to the court. Another to proceed illegally - illegally take our son out of the country. Do you agree that whatever the real intent was, it could be only one intent, not both of them at the same time? (Hopeful "yes")
Bad question. Both of those can be done concurrently. Asking to open yourself up to testimony you did not expect.

So, if it could be only one intent, you could believe that I had only one intent whatever it was - is it so?
could be both, a person can kidnap a child AND move for emergency custody at the same time.

The next day you wrote an answer to these 3 emails. Please read this: "How do you imagine the court will let you take an American citizen to Mexico due to the fact that you cannot reside in US because you are crazy? Very strange logic." (Is this exactly what you wrote?)

#14. Was it the answer to the part that was dedicated to the legal proceeding or was it the answer to the part you interpreted as a threat?
Good, easier to under.

Good luck!

Customer: replied 1 year ago.

Dimitry,


 


Thank you. When the evidence is attempted to be entered - technically first it will be entered in Statement Of Readiness. Did you mean - when attempted to be physically presented to the court/judge?


 


That #13. Well, she is not you; not even me. She never heard about sophistic and cannot implement it. Most likely she would agree there could be only one intent. But of course you are right and I don't want to risk getting into the discussion what's possible and what's not. Any ideas how still make her admit there is either one or another possibility?


 


 


Part 2 of the split message (then only one portion left):


 


 


 


19. Ms. Moiseeva, where were you and were was I on March 7, 2013?

20. Did I go to Mexico by plain, boat or car?

21. Is it true that the trip to the place I was in Mexico by car takes approximately a week - it is about 3,700 miles trip?

22. Did we communicate via email and/or Skype between March 7 and March 11 when you filed a Family Offense Petition discussing usual business matters like who received or didn't received the item, where you could buy an adapter for Nintendo I gave to our son and the like?

23. Do you think it is the usual routine when after announcement of upcoming crime, criminals and their future victims start to discuss insignificant details like these? "OK, so I will kill you the next Thursday. Meanwhile, did you buy AA batteries for the camera?" Is it usual in your opinion, yes or no? (I am not sure I need this question at all)

24. Was there anything in our emails and other communications that told you I was going back to NY immediately? If yes - please show the court the email where I said so.

25. Ms. Moiseeva, I cannot understand. Even with extremely frivolous interpretation of "I'll take Boris in October, November, March" potential violator said he was going to do this in 7 to 12 months from now. He is in another country 37,000 miles away from you. (He had initial plans to stay there for another 2 months - if she will say she knew) and nothing told you he changed his mind (or Nothing told you he was going back to NY). You and him continue to communicate the regular way. What did produce the fear of immediate danger so that you went to the Family Court and asked for an Order Of Protection?

26. So, whether it was justified or not, you feared I could take our son out of the country and kill you if you would try to stop me (or ... or not, you still had a great fear) - is it what you are saying?

27. Ms. Moiseeva, is this your email you wrote on April 2, 2013?

28. Please read this sentence: "I will gladly agree everything was a misunderstanding" Did you mean you would agree in the court everything was a misunderstanding?

28 a. Please read "However I demand the full custody (Legal and Physical). Under these conditions I guarantee your maximum participation in Boris' life, any kind of communication possible if you are not in the country, at any time. Our visits to you during the time of school holidays. You can oblige me to it through court order. Maybe it will make easier for me to take time off from work. However, without my presence, he will be able to travel to you and with you only, when he reaches at least 14 years of age." (Did you write this?)

30. Ms. Moiseeva, another thing I cannot understand. Even though the potential violator was in another country, even though he had no intentions to come back to NY within next 2 month (if she will say she knew it), your fear he could kidnap your son and kill you was so horrible that despite of the absence of the real threat (I left this on purpose knowing in advance you will object. She however not "vor v zakone" and will miss it. Can her attorney object "absense of the real danger?"), despite of the absence of any imminent danger you went to the court and asked for an Order of Protection. But then you offered the kidnapper to voluntarily bring your son exactly where he wanted to take him and to give yourself to the murderer in another country where you would be in his whole mercy and nothing could stop him from killing you. To simplify, you offered exactly what you asked the court to protect you from. Could you explain the court this contradiction? (I remember that psychological thing - better call yourself Jesus Christ and not murderer but here I wanted to emphasize the contradiction. Also - yes, there are hundreds of ways to explain this contradiction. But... how to say it politely... can't even find English words.. Nazvat' za predelami bytovyh tem intellekt moego opponenta ravnym polenu oznachaet oskorbit' hvoynye lesa, smeshannye i polosu lesonasazhdeniy).


 


Best regards,


 


Customer/p>

 


Expert:  Dimitry K., Esq. replied 1 year ago.
Customer

Thank you. When the evidence is attempted to be entered - technically first it will be entered in Statement Of Readiness. Did you mean - when attempted to be physically presented to the court/judge?

Your welcome, and yes, exactly right.

 

 

That #13. Well, she is not you; not even me. She never heard about sophistic and cannot implement it. Most likely she would agree there could be only one intent. But of course you are right and I don't want to risk getting into the discussion what's possible and what's not. Any ideas how still make her admit there is either one or another possibility?

Forget me or you, you are talking to her, and to the judge--if the judge doesn't understand, or the attorney does not understand, it will alienate the judge. The trick in court is to speak so clearly that even a 5 year old can understand it--that is the standard that you are attempting to get to.

 

 

 

 

 

Part 2 of the split message (then only one portion left):

 

 

 

 

 

 

 

19. Ms. Moiseeva, where were you and were was I on March 7, 2013?

20. Did I go to Mexico by plain, boat or car?

Relevance. What's the point of this question to her claims against you? You can ask it, don't see the point.

21. Is it true that the trip to the place I was in Mexico by car takes approximately a week - it is about 3,700 miles trip?



22. Did we communicate via email and/or Skype between March 7 and March 11 when you filed a Family Offense Petition discussing usual business matters like who received or didn't received the item, where you could buy an adapter for Nintendo I gave to our son and the like?

23. Do you think it is the usual routine when after announcement of upcoming crime, criminals and their future victims start to discuss insignificant details like these? "OK, so I will kill you the next Thursday. Meanwhile, did you buy AA batteries for the camera?" Is it usual in your opinion, yes or no? (I am not sure I need this question at all)

Useless question, and again places you in the light of being a criminal.

24. Was there anything in our emails and other communications that told you I was going back to NY immediately? If yes - please show the court the email where I said so.

25. Ms. Moiseeva, I cannot understand. Even with extremely frivolous interpretation of "I'll take Boris in October, November, March" potential violator said he was going to do this in 7 to 12 months from now. He is in another country 37,000 miles away from you. (He had initial plans to stay there for another 2 months - if she will say she knew) and nothing told you he changed his mind (or Nothing told you he was going back to NY). You and him continue to communicate the regular way. What did produce the fear of immediate danger so that you went to the Family Court and asked for an Order Of Protection?

Long but a decent line of questioning.

26. So, whether it was justified or not, you feared I could take our son out of the country and kill you if you would try to stop me (or ... or not, you still had a great fear) - is it what you are saying?

27. Ms. Moiseeva, is this your email you wrote on April 2, 2013?

28. Please read this sentence: "I will gladly agree everything was a misunderstanding" Did you mean you would agree in the court everything was a misunderstanding?

Interesting line of questioning. Perhaps it needs to be expanded if you had further communication.

28 a. Please read "However I demand the full custody (Legal and Physical). Under these conditions I guarantee your maximum participation in Boris' life, any kind of communication possible if you are not in the country, at any time. Our visits to you during the time of school holidays. You can oblige me to it through court order. Maybe it will make easier for me to take time off from work. However, without my presence, he will be able to travel to you and with you only, when he reaches at least 14 years of age." (Did you write this?)


30. Ms. Moiseeva, another thing I cannot understand. Even though the potential violator was in another country, even though he had no intentions to come back to NY within next 2 month (if she will say she knew it), your fear he could kidnap your son and kill you was so horrible that despite of the absence of the real threat (I left this on purpose knowing in advance you will object. She however not "vor v zakone" and will miss it. Can her attorney object "absense of the real danger?"), despite of the absence of any imminent danger you went to the court and asked for an Order of Protection. But then you offered the kidnapper to voluntarily bring your son exactly where he wanted to take him and to give yourself to the murderer in another country where you would be in his whole mercy and nothing could stop him from killing you. To simplify, you offered exactly what you asked the court to protect you from. Could you explain the court this contradiction? (I remember that psychological thing - better call yourself Jesus Christ and not murderer but here I wanted to emphasize the contradiction. Also - yes, there are hundreds of ways to explain this contradiction. But... how to say it politely... can't even find English words.. Nazvat' za predelami bytovyh tem intellekt moego opponenta ravnym polenu oznachaet oskorbit' hvoynye lesa, smeshannye i polosu lesonasazhdeniy).

I understand, I am just concerned you are trying to be too sophisticated.

 

Good luck!

Dimitry K., Esq., Attorney
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  • http://ww2.justanswer.com/uploads/dkaplun/2009-05-17_173121_headshot_1_2.jpg Dimitry K., Esq.'s Avatar

    Dimitry K., Esq.

    Attorney

    Satisfied Customers:

    15975
    Multiple jurisdictions, specialize in business/contract disputes, estate creation and administration.