Do you honestly expect people to accept that you are too dense and unable to address the documented evidence here that this is your only thoughts or reaction and answer to what was posted?
What documented evidence? You didn't provide any, did you?
Apparently you are trying to explain how our subpoenas of December 6 and 12, 2007, really could be issued after the plaintiffs' motions of Dec. 18, 2007, and June 25, 2008. Lots of luck.
By the way, you quote above where Jerrie Hayes refers to a proposed protective order she submitted "as part of Plaintiffs’ 26(f) Report." Could you please provide a link to where one can actually read that document as it was sumitted to the court with that report? Hint: see Doc. 18 at
http://www.3abnvjoy.com/mad-07cv40098/. Then quote for us the actual text of that proposed order.
Hint: Jerrie never submitted any such proposed protective order with the 26(f) report.
If the state of Washington felt like it had to make sure that 3ABN wasn't deceiving it in regards to the charitable gift annuity debacle up there, then certainly we have been justified in maintaining that we must be allowed to challenge any document Danny or 3ABN produces.
What does that mean? That means we have to be allowed to get the documents from collateral sources, not just the dishonest plaintiffs. We have to be allowed to make sure that any bank statements given to us by Danny and 3ABN are the same as the ones MidCountry or any other bank has.
But back to the main point: Simpson explicitly stated, "Frustrated by delays they encountered as this Court considered what sort of protective order and limits on the scope of discovery would be appropriate, Defendants circumvented this Court and obtained subpoenas from sister courts in Minnesota, Illinois, Michigan ...."
- On December 12, 2007, when the court in Minnesota issued that second subpoena, the court in Massachusetts wasn't considering any such things, since the plaintiffs hadn't filed their motions yet.
- There were no delays at that point, other than the Rule 26(a)(1) materials, since Danny and 3ABN didn't respond to my requests to produce until January.
- Judge Saylor had already explicitly ruled that there would be no stay of discovery while such motions were being crafted, filed, and ruled upon.
- While the date of the first subpoena, Dec. 6, 2007, is important, it doesn't tell you how early we were thinking about going after the bank records.
In going through some correspondence, looks like I started giving thought to subpoenas by October 29, 2007, which would be before I went pro se. I had started drafting one by Nov. 12, 2007.
How much earlier do we need to go before you are convinced that Atty. Greg Simpson lied to the court on that point?