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Reargue to Vacate

Reargue to Vacate

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Published by WatsonFraud9892
Denied without any legtimate basis
Denied without any legtimate basis

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Published by: WatsonFraud9892 on Apr 08, 2010
Copyright:Attribution Non-commercial

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10/24/2012

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Whereby, defendant has µvery good cause¶ for his reargument to be granted, since without beinggranted a hearing for his chance to plead his side and affirm his position, a horrific injustice willresult and an irrevocable sever injury would result that can be prevented. Since, defendant¶slegitimate rights to possession of his home would be dispossessed by those who never gave hima nickel for his property and extracted over a million dollars of its equity. Then, the final injurywould be the court handing to them the opportunity to legally do on a massive basis what theyhave prior been doing illegally on a piece meal basis. Specifically, this is with trashing (or stealing many thousands of dollars of his personal property that was on the grounds and inhisgarage.In addition plaintiff¶s property manager,Camadelo, just told defendants agent that all thefurniture that was left in the red building was trashed. Yet, on two occasions when defendant hadsomeone with a truck to move out these valuable antique furnishings was prevented by plaintiffs, by them not showing up and refusing to provide the key as they promised. Now, at this time theGreenwich Police, Detective Sampten and Lt. Brown told defendant¶s agent, Hutchins, that theyconsider defendant¶s property abandoned and that plaintiff has the legal right to do whatever theywant with the property he abandoned and is forfeited to their ownership.The prevailing issue is that defendant is constitutionally entitled to plead his case before thecourt deprives him of possession to his property. Thereby,allowing defendant to havehis right toa hearing to bring forth the material issues of fact and law. Since, although defendant hadrepresentation, Mark Katz, the only party his lawyersadvocated was to affirm the legal interests
 
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of plaintiff. In fact, Katz neglected to provide any of the papers of the case and signed instead of defendant, who he kept in the dark about the case.A marker that can verify Katz¶a collusion with the opposition is that when plaintiff¶s lawyer Kaelin said they owned 100% of the property he did not contest. In addition to agreeing to theimmediate implication of the ³U&O´ as if it was matter of their legal right. Not to mention, Katzwas observed in a circle when Kaelin, Pecunies, and Elsie Peorinwhen Kaelin was discussing hislegal strategy; such as with discussing the pending foreclosure and telling Elsie Peorinhow hewanted her testimony to be. Noteworthy was Peorin¶s comment: ³I feel sorry for Del (defendant) I hope we get this squaredaway soon. Percunies told Peroin, ³you have really earned your commission.´As Peroin duringdefendants first eviction perjured herself by saying defendant drove away someone who came toher office to buy his properties. Thereby, to justify defendant being shut out from the sale process and not being allowed to continue to live on his property, due to his activity of drivingaway potential buyers."Actual conflict of interest" exists when aim or goal of trial counsel diverges from`interests of client.²Mercer v. Commissioner of Correction, 724 A.2d 1130, 51ConnApp. 638, certification denied 731 A.2d 309, 248 Conn. 907 (1999).³For purposes of obstruction of justice statute proscribing "corrupt" endeavors toobstruct justice, corrupt conduct is conduct that is motivated by improper purpose. 18U.S.C.A. § 1503(a) (
U.S. v. Triumph Capital Group, Inc
., 260 F.Supp.2d 470 Conn.(2003).

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