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2019-11-15_ENFORCEMENT - M1996076
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2019-11-15_ENFORCEMENT - M1996076
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Last modified
12/27/2024 2:14:16 PM
Creation date
11/15/2019 1:00:53 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M1996076
IBM Index Class Name
Enforcement
Doc Date
11/15/2019
Doc Name
Response to Motion
From
Law Offices of John R. Henderson, P.C.
To
DRMS
Email Name
ACY
Media Type
D
Archive
No
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decreed. This is an important and non-trivial issue, with potential major legal and financial <br /> consequences for Fontanari. <br /> Fontanari followed Rule 2.5 in stating its Motion/Petition for Declaratory Order. <br /> G. DRMS's ATTACK ON NEW COUNSEL HENDERSON AT SECTION IV. <br /> OF ITS MOTION TO STRIKE IS ILL-FOUNDED AND UN-JUSTIFIED <br /> As noted in excruciating detail in the Motion to Re-Open,attorney Beckwith <br /> revealed detailed information to DRMS and counsel both that he could not be <br /> present,and that Fontanari was interviewing various substitute counsel,neither of <br /> whom could be present on August 21 (Exhibit A to Motion to Re-Open). <br /> In Section IV of its Motion to Strike, DRMS points the finger at attorney <br /> Henderson for not being present on August 21, and that he"simply chose not to <br /> attend". DRMS had already been informed that neither of the counsel being <br /> interviewed could be present on August 21. Yet, DRMS apparently made no attempt <br /> to accommodate the schedules either of Beckwith or of substitute counsel. <br /> As a point of fact, Henderson stated to Division that he had been retained by <br /> e mail of August 22, 2019,the day after the hearing; this is contained in the August <br /> 22 a mail cited by DRMS. That same a mail also contains a statement to Mr. <br /> Henderson that he had left a phone message with Amy Yeldell the night before the <br /> hearing. Apparently,attempts by both Beckwith and soon-to-be counsel Henderson <br /> to avert a miscarriage of justice,and to have a fair hearing,are now to be used to <br /> attack Fontanari.This is unjustified, and un-called for. <br /> H. REQUEST TO COMBINE MOTIONS FOR PLACEMENT AND <br /> HEARING ON THE NOVEMBER BOARD AGENDA <br /> 12 <br />
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