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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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hearing". The DRMS was able to present a lengthy and well-prepared case,knowing <br /> that there would not be opposition by an attorney ready to counter their case,or <br /> even to protect Fontanari during cross examination. <br /> A realistic assessment of this situation requires a recollection that Fontanari <br /> is a septuagenarian with a lifetime of experience in minin and construction and the <br /> use of heavy equipment. Fontanari is most assuredly not an attorney,and lacks any <br /> training in the law,whether the Rules of Civil Procedure, the Rules of Evidence,the <br /> Administrative Procedures Act and administrative law practice generally.Yet, <br /> multiple objections raised by DRMS in its Motion to Strike assume that Fontanari <br /> had somehow voluntarily elected to proceed pro-se,with all the duties and <br /> obligations of an attorney.As a point of fact, DRMS dedicated Section III of its <br /> Motion (Motion to Strieke at Sections 19 through 24) to listing the caselaw related <br /> to the duties assumed of a pro-se litigant. <br /> As a point of fact,when a litigant in a criminal or civil proceeding elects to <br /> proceed pro-se,the presiding judge will conduct an advisement and will ask a series <br /> of probing questions designed to elicit a clear understanding by the pro-se litigant of <br /> the duties he is assuming,and a clear statement that his waiver of the right to <br /> counsel is knowing, considered and voluntary.The point here is not that no such <br /> advisement was conducted;the purpose of the advisement is to protect the trial <br /> record from a later attack that the litigant was deprived of due process by denying <br /> him a fundamental right: assistance of counsel. A review of Exhibit A to Fontanari's <br /> Motion to Re-Open clearly illustrates Beckwith's multiple attempts to get Fontanari <br /> 9 <br />
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