Don't thank me as I do not do you any favors, nor do I defend your cause or support even an iota of it . . . My heart and my effort belong to the Creator of the Universe, the one and only true God who judges us all. My words are not for your benefit, your defense, your use or my glorification - but for the defense of my Savior.
Once again you walk around the room thumping your chest, banging a gong, bellowing as loud as you can in an effort to distract the "listening" public so thy can't see the truth.
There is no license provided to you . . . only that which you have manufactured in your own dreams. In your head, relevance may be a nebulous thing and open to your interpretation - but that would only be in your delusional perspective. The Court is going to focus narrowly on the Complaint and limited you to those things that you can sufficiently argue are within the
original scope of the Complaint. You may think the Court is enamored of you and your pro se position - but the judge and the Court aren't going to buy your snake oil and aren't going to be entertained by your pro se approach. You may have a little paralegal training under you belt, but that is akin to a low single A pitcher going up against Alex Rodriguez.
Here you are wrong again . . . you want the issue to be "failure to produce" when in actuality you are going to be left holding an empty bag because Rule 26 is going to be your undoing. If you cold reign in your out of control partner you might be able to get a little glimmer of acknowledgment from the courts . . . but as it stands, the court is going to see the harassment, the effort to expand the case, the unreasonable demands and is going to shut you down like a bankrupt business . . . oops.
You love to banner wave, chest thump . . . but we all know what "goeth before a fall' . . . In the past you have been able to intimidate, threaten, cajole, manipulate, and subject to false accusations and hyperbole - but not this time. You actually have to stand in front of the Court and meet the letter of the law . . . and wanting you will be.
We'll deal with your abuse of Rule 34 next.
No need as the Court, more than likely, will require you to stick to the context of the Complaint. Again, you think you can manipulate the court and falsely assume you can operate outside the laws of the land the Federal Rules of Civil Procedure. Time to follow the letter of law Mr. Pickle.
Well, anyman, why doesn't 3ABN/Danny amend their complaint if they want to narrow discovery?
Thank-you Anyman for that clarification. Have you read the allegations? I'd say they have given us pretty broad scope and relevancy is almost anything. In fact, I would challenge you to give me an example of production that is not relevant to the claim. You can get a preview of the arguments that are dead ahead. PACER in advance...nothing too terribly secretive about it!!!
So, ANYMAN, me thinks the problem is FAILURE to Produce, not relevancy. But, I'd love to give you a shot at it!!!
Gailon Arthur Joy