Friday, September 16, 2016

MR. GAFFNEY’S ERRORS CONTINUE






MR. GAFFNEY’S ERRORS CONTINUE

Mr. Gaffney’s string of legal errors continues. He has misinterpreted or misheard or attempted to deceive the Defendant Davis when he stated that he would not provide Answers to Interrogatories because Judge Tucker delayed the Discovery process. The events proved Mr. Gaffney in error.

As reported in an earlier blog, the Court on August 6, 2016 ordered Mr. Gaffney to answer my Interrogatories regarding his income and his relationship to Turtleboy.  On August 10, 2016 Mr. Gaffney refused to provide a date by which he would answer the Interrogatories. In response I filed a Motion with the Court on August 11, 2016 to compel Mr. Gaffney to provide a definite date on which he would provide his Answers.  (Exhibit 1 below)

As a rule the Answers are due within 30 days of the Court Order.  On September 6, 2016 I telephone Mr. Gaffney that his 30 days allowed by Court rules to answer the Interrogatories had passed and the Answers were past due. He was now in contempt of Court. (Exhibit 2).

Incredibly Mr. Gaffney responded that the Judge did not want him to answer the questions until after the ruling on Defendant Tirella’s Motion to Dismiss.
I attended the Hearing on Defendant Tirella’s Motion. The Judge said that he would clarified the issue of the Turtleboy Deposition. He did not say that he wanted to delay the Discovery process for Mr. Gaffney.
 
On September 14, 2016 the Judge contradicted Mr. Gaffney and ordered to answer the Interrogatories on or before October 7, 2016.

The Judge has not ruled on the Motion to Dismiss by Ms. Tirella at this time.

TURTLE BOY

In other developments on September 13, 2016 the Judge ruled that Turtleboy would not get a protective order and there would be no restriction on the deposition of Turtleboy.

==========================================================
Exhibit 1
                                                                                                                                                                                                                                                                                                                                                                                      COMMONWEALTH OF MASACHUSETTS

                                                                                                                                                                     WORCESTER,          SS                                                          
SUPERIOR COURT                                                                                                                                                                                                                                                                                                        
                                                                                                      16-0288 B
                                                          
********************************                                                                                                                                      
Michael Gaffney, Plaintiff                      *
                                                                     * 
                             Vs.                                   * 
                                                                     *
Gordon T. Davis                                       *                                                                                            InCity Times                                                *
DEFENDANT GORDON T. DAVIS’ MOTION TO COMPLE PLAINTIFF TO PROVIDE A DATE CERTAIN OR ESTIMATED DATE FOR HIS ANSWER TO COURT SELECTED INTERROGATORIES

The Pro Se Defendant Gordon T. Davis respectfully requests this Court to compel the Plaintiff Mr. Gaffney to provide a date certain in compliance with the Court Order by Judge Tucker re-answering the allowed Interrogatories
Background
1.    Judge Tucker on July 28, 2016 has ordered the Plaintiff to answer the allowed Interrogatories (Exhibit 1)
2.   On August 10, 2016 the Defendant Gordon T. Davis met in person with the Plaintiff. The Plaintiff refused to provide any date for the Answers to the Court ordered found in Exhibit 1.
3.   At the same meeting when asking for a date certain from the Plaintiff, the Defendant was called a “petulant child”. This was witnessed by the Defendant’s wife and another witness.
4.   The Plaintiff Mr. Gaffney continued his inappropriate behavior by ridiculing and shaming the Pro Se Plaintiff by continuously saying “Do you know what you are doing?”
Argument

5.   The Plaintiff was served with Interrogatories on My 4, 2016. He had over 90 days to prepare his Answers.


6.   The Plaintiff has refused to provide a date certain or even an estimate for his provision of Answers.

The refusal to provide a certain date is adversely affecting the Defendant’s ability to conduct discovery and the preparation of his defense.
The Plaintiff being an officer of the Court should not be allowed to play fast and loose with the Court rules and orders.
7.   The Plaintiff as a Court officer has conducted himself in an inappropriate manner by name calling and ridiculing the Pro Se Defendant.


Conclusion and Relief
The Pro Se Defendant, Gordon T. Davis, respectfully asks the Court to order the Plaintiff to provide the Court ordered Answers.
The Pro Se Defendant, Gordon T. Davis, also requests that the Court caution the Plaintiff Mr. Gaffney (who is an attorney) about appropriate behavior in a Court proceeding.

 Respectfully submitted


Gordon T. Davis
Pro Se Plaintiff

=======================================================
Exhibit 2

-----Original Message-----
From: Michael Gaffney <michaelgaffneylaw@gmail.com>
To: Gordon Davis <standards2100@aol.com>
Sent: Tue, Sep 6, 2016 11:20 am
Subject: Re: 9C Conference Regarding Court Compelled Answers to Interrogatories.

As you are aware, Judge Tucker was pretty clear in court on August 25, 2016 when he advised the he would review the discovery motions after a determination on the Motion to Dismiss as the determination on the Motion to Dismiss would be dispositive.  In fact, he has scheduled a Hearing on the Protective Order after the due date for the Amended Complaint.


On Sat, Sep 3, 2016 at 7:37 PM, <standards2100@aol.com> wrote:
Dear Mr. Gaffney:

The Court ordered Answers to my Interrogatories are passed due. By your admission in your Opposition Memo to Motion to Compel a Date Certain for your Answers the Answers were due on September 2, 2016. You are now in contempt of Court.

 In accordance with Rule 9C I telephoned you on September 3, 2016 to discuss your failure to provide Answers in a timely manner and a manner ordered by Court. Please return my call with about your Answers. I am considering contempt of Courts sanctions. 

 The Answers are due forthwith. 

Regards, 

Gordon T. Davis

Pro Se Defendant

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