Is Mr. Gaffney's Affidavit An Attempt to Deceive the Court?

An Intentional Deception or Just Sloppiness?

NOT LEGAL ADVICE


In July 2016 Mr. Gaffney filed a Motion to Amend his Complaint. In accordance with Rule 9a, Mr. Gaffney is required to provide a copy of his Motion to Amend to the Defendant. He did provide a copy to me. I made Mr. Gaffney aware of the missing document by email on June 4, 2016

Even though I made him aware of the missing document, Mr. Gaffney never responded to the email nor did he send a copy of the missing document. Instead Mr. Gaffney provided the Court an Affidavit stating he never recieved my Opposition Memo.

He did not tell the Court he never sent a copy of his Motion to Amend to me. This could be construed to be a deception of the Court. I made the Court aware of the issue in my Opposition Memo which was sent separately from Mr. Gaffney's filing. See below.

Mr. Gaffney actions are evidence of either deception or sloppiness. This evidence can be used to show to a Jury the quality of Mr. Gaffney's work as a lawyer.  This can be used in the determination of whether Mr. Gaffney's suit for one million dollars is frivolous.

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                                                                                                                                                                                                                                                                                                            COMMONWEALTH OF MASACHUSETTS

                                                 WORCESTER,          SS                                                    SUPERIOR COURT                                                         16-0288 B

                                                          

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Michael Gaffney, Plaintiff                      

                                                                  

                             Vs.                                 

                                                                  

Gordon T. Davis                                                                                                             InCity Times                                          

Rosalie Tirella                                       

Defendants                                                                                                                                                                                                            

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DEFENDANT GORDON T. DAVIS’ OPOSITION MEMO TO PLAINTIFF’S MOTION TO COMPLAINT

Now comes the Defendant Gordon T. Davis and he respectfully requests that this honorable court deny Plaintiff’s Motion to Amend his complaint. The Plaintiff failed to comply with Rule 9a and 9c.

Background

1.     The Plaintiff failed to provide a copy of his Motion to Amend his Complaint in a timely manner. He filed his Motion without the Defendant’s Opposition Memo, a violation of Rule 9a.

2.     The Defendant informed the Plaintiff of the missing copy of the Motion to Amend by email on July 2, 2016. (Exhibit 1).

3.     The Plaintiff did not respond to the Defendant’s email notification. The Plaintiff did not seek a Rule 9c conference to resolve the issue of the missing copy of the Plaintiff’s Motion to Amend. As noted this is a violation of Rule 9c.

4.     The Plaintiff has written a deceptive Rule 9a Affidavit implying that the Defendant did not respond to the Plaintiff’s Motion. (Exhibit 2).

Argument

     The Plaintiff has failed to comply with Court Rules for the filing of a Motion to Amend his Complaint. The Defendant was not provided an opportunity to write an Opposition Memo.

     The Plaintiff wrote a deceptive Rule 9a Affidavit implying that the Defendant made no response to the Plaintiff’s Motion to Amend. The Defendant asks the Court to make note of this deception and possible attempt to unfairly take advantage of a Pro Se Defendant.

When notified of the missing document the Plaintiff made no attempt to resolve the issue as required by Rule 9c. The Plaintiff has not filed a Rule 9c Certificate.

Conclusion

Defendant Mr. Davis respectfully ask the Court to deny the Plaintiff’s Motion as it is not in compliance with Court Rules.

Respectfully submitted,

Gordon T. Davis

Pro Se Defendant

Deposing Turtleboy About Mr. Gaffney

                                               

DEPOSING TURTLEBOY SPORTS AND AIDEN KEARNEY

This is not legal advice

Mr. Gaffney has refused to answer questions in discovery. Although there is a motion before the Court to compel him to answer, there are other ways to get the informaiton.

One of the ways is to subpeone witnesses. In this case Turtleboy Sports and Aiden Kearney are witnesses. For Turtleboy Sport there is a Duces Tecum  which compels it to provide relavent documents.  At the deposition I can ask questions about the documents.

For Mr. Kearney there will be a depostion by oral examination about his conversations with Mr. Gaffney. At some later point I will depose Mr. Gaffney and compare testimonies of the two.

Mr. Gaffney has sworn under oath that his wife was affected by the alleged defamation. This has openned the door for her deposition and taking of her medical records.

A copy of the Notice of Depostion to Turtleboy Sports is seen below.

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                                        COMMONWEALTH OF MASACHUSETTS

                                                                                               WORCESTER,          SS                                                     SUPERIOR CIVIL COURT                                                                                 C.A. 16-0288 B

                                                           

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Michael T. Gaffney,

 Plaintiff                                                                                     

                             Vs.                                   *                                                                 

Gordon T. Davis,

and                                                              *                                                                                                    

InCity Times                                                            

Rosalie Tirella                                            *

Defendants                                                 *   

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                        NOTICE OF TAKING OF DEPOSITION (DUCES TECUM)

To            Turtleboy Digital Marketing LLC.

                 c/o Aiden Kearney

     116 Brookline St.

     Worcester MA 01603

Please take notice that at 10:00 a.m. on Wednesday, August 10, 2016 the Defendant, Gordon T. Davis, will take the Deposition of the Keeper of the Records of Turtleboy Digital Marketing LLC (hereafter referred to as “Turtleboy”) in pursuit to the Massachusetts Rules of Civil Procedures. The Deposition will be taken at the office of Real Time Court Reporting, Hammond St. Worcester MA.

The Deposition will be taken before a Notary Public in and for the Commonwealth of Massachusetts or by some other officer authorized by law to administer oath.

The exam will continue until completed.

The Deponent is required to bring the following records.

1.   All correspondence between Turtleboy and the Plaintiff, Michael T. Gaffney (hereinafter referred to as “Mr. Gaffney”). Please include invoices and receipts.

2.   All correspondence between any Massachusetts agency and Turtleboy regarding Mr. Gaffney.

3.   A copy of the article dated December 9, 2015, “Mosaic Mafia Family Structure”

4.   A copy of any and all publications regarding the people whom Turtleboy claimed was in the Mosaic Mafia Family. The time period for these publications are from December 10, 2015 through present.

5.   The names of the authors and photographers each publication found in Item 4 above.

6.   A copy of Turtleboy’s incorporation documents.

7.   The names of the present officers of Turtleboy.

You are invited to attend and cross-exam.

                                                            Sincerely,

                                                            Gordon T. Davis

                                                            

Cc: Robert Scott, Esq.

       Office of Hector Pinero

       807 Main St.

       Worcester MA 01610

                        CERTIFICATE OF SERVICE

I, Gordon T. Davis Pro Se Defendant, hereby certified that I have this day served the foregoing Notice of Taking Deposition by mailing it via first class prepaid postage to the following:

Turtleboy Digital Marketing LLC

c/o Aiden Kearney

116 Brookline St.

Worcester MA 01603

Margaret M. Melican, Esq.

2 Foster St.

Worcester MA 01608

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 Gordon T. Davis                                     Date

A Perry Mason, Mr. Gaffney Is Not,

Mr. Gaffney Is Not Perry Mason

One of Mr. Gaffney complaints is that I caused him one million dollars in damages, including harm to his business as a lawyer. A defense to such a claim is that Mr. Gaffney does not now and is unlikely in the future to be a one million dollar man.

The evidence for this are the court documents written by Mr. Gaffney.  There are conceptual errors of the meaning of the law, errors in the interpretation of the Court rules, documents have the wrong dates, words are misused, and there are some grammatical and typographical mistakes.

Of course to be fair, I also make errors and mistake. However I am visually disabled and I am not a lawyer.

This evidence will be presented to the Court and to the jury as a defense against Mr. Gaffney’s complaint.

The first error Mr. Gaffney made was in the misinterpretation of Rule 33a.  The rule clearly states that Interrogatories are allowed to be served against the Plaintiff at the beginning of the action. Mr. Gaffney argued the Interrogatories could only be served after the service of the Complaint.

“(1) In General. Any party may serve upon any other party written interrogatories to be answered by the party served or, if the party served is a public or private corporation or a partnership or association or governmental agency, by any officer or agent, who shall furnish such information as is available to the party. Interrogatories may, without leave of court, be served upon the plaintiff after commencement of the action and upon any other party with or after service of the summons and complaint upon that party”

The second mistake made by Mr. Gaffney was in his request for documents. He mistakenly asked for documents related to an “accident” when he meant “incident. Mr. Gaffney wrote:

            “Copies of any and all statements regarding the alleged accident;…”

Of course in a defamation suit there are no relevant “accidents”.

For want of a better word Mr. Gaffney’s carelessness continued when he wrote his opposition to my codefendant’s Motion to Dismiss. The Defendant’s Motion is dated in July 2016. Mr. Gaffney response Opposition Memo is dated incredibly in April 2016. A possible explanation is that Mr. Gaffney plagiarized his Opposition Memo and forgot to change the date.

In the same document Mr. Gaffney asks the Court to “Dismiss” the Defendant’s Motion to Dismiss. The  State Courts do not “dismiss” motions. The Courts “deny” motions.  Such a misuse of the wording of Court procedures could make a person wonder how many Opposition Memos Mr. Gaffney has written.

Everyone can make minor mistakes. However there is a curious mistake that Mr. Gaffney has made that might call into question his ability as a lawyer. That mistake is found in his so called Amendment to the Complaint. He has asked the Court to add to the Complaint, the allegation that the Defendants were “angry” about Mosaic.

Mr. Gaffney should know, being a licensed attorney, that state of mind is not actionable.  Being “angry” might be evidence as motive, but it is certainly not anything that caused him any harm. A case can not be amended based on new evidence. It can be amended based on new or newly known actions.

Given the above evidence of the quality of his practice, a jury will likely see that Mr. Gaffney is not Perry Mason.

Complaint to Board of Overseers Against Mr. Gaffney

Mr. Gaffney conduct before and after his filing of the case may rise to the level of professional misconduct. In this letter I am making a complaint to the Board of Overseers for lawyers practicing in Massachusetts.

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Attorney and Consumer Assistance Program                                                                     Office of the Bar Counsel                                                                                                                            99 High Street
Boston, Massachusetts 02110 

Re: Michael T. Gaffney, BBO #651957

Dear Sir or Madam:

I am writing to complain about Michael T. Gaffney. Esquire. His BBO number is seen above.

Mr. Gaffney has engaged in conduct involving dishonesty, fraud, deceit or misrepresentation. He has engage in conduct that is prejudicial to the administration of justice. He has engage in any other conduct that adversely reflects on his or her fitness to practice law.

Mr. Gaffney has continually engaged in intimidating and overly aggressive litigation tactics His tactics are those of a bully and rule breaker.

Because Mr. Gaffney is a lawyers holding public office, he assumes legal responsibilities going beyond those of other citizens. His misconduct could suggest an inability to perform his responsibilities as a lawyer.

Background

I am a writer. I wrote about the efforts by Mr. Gaffney to close down a community center in a Black neighborhood. A blogger, Turtleboy, supported what I consider Mr. Gaffney’s racist efforts.  Turtleboy libeled me by calling me “mentally unbalance” and I sued him on February 12, 2016. A week late Mr. Gaffney sued me in retaliation..

Misconduct by Mr. Gaffney

1.     On February 19, 2016 Mr. Gaffney misused the Court system and sued me for libel based on my opposing his efforts to close a Black community center, Mosaic. (Exhibit1)

2.     This is misconduct as Mr. Gaffney’s Complaint is frivolous and intended as retaliation. Mr. Gaffney published that he was supporting Turtleboy against me. This is evidence of his retaliation. (Exhibit 2)

3.     In June 2016 Mr. Gaffney told my employer that I should be fired from my job. My continued employment is not relevant to the claims found in Mr. Gaffney’s Complaint; it is not related to any relief that is sought by him. His attempt to have me terminated is evidence of his retaliation and bullying. (Exhibit 3)

4.     Mr. Gaffney claimed that his business, mental health, and political capital were harmed. He claims one million dollars in damages. (Exhibit 1)

5.     When served with Interrogatories, Mr. Gaffney dishonestly objected to the questions about his business, income, mental health, and political capital. The pretext for his objections is that such questions would not produce any evidence that could be used in the Defendant’s defense. (Exhibit 4)

Mr. Gaffney being a lawyer knew that his statements were dishonest as the very basis of his claims are income, mental anguish, and political capital. These deceitful statements are intended to be prejudicial to the administration of justice.

Conclusion

     There is sufficient evidence for the Board of Overseers to investigate Mr. Gaffney’s actions as dishonest and prejudicial to the administration of Justice. His actions are retaliatory and those of a bully trying to stifle political discussion. He has conducted himself in a manner that adversely reflects on his profession.

   I respectfully ask that Mr. Gaffney be investigated for this misconduct.

Respectfully submitted,

Gordon T. Davis                                                                                                                                                                                               

Cc: Michael T. Gaffney, Esq.

Mr. Gaffney's Case Unravelling

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Not Legal Advice

Because Mr. Gaffney has refused to answer the Interrogatories, a Motion to Compel Answers is being sent to the Court. The Motion explains how the Interrogatories are relevant to the case. See below.

Although Mr. Gaffney has claimed damage to his business, he has not provided any evidence of any daamage. He claims that he suffered mental anguish, but he has not answered any question about his medical or mental health. Mr. Gaffney claims that his " political capital" was damaged, yet he has not answered the question about what is political capital.

If Mr. Gaffney can not or will not provide evidence of damage or harm, then his case falls apart and could be determined to be frivolous.
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COMMONWEALTH OF MASSACHUSETTS

WORCESTER, ss. SUPERIOR COURT

           C. A. NO. 2016-00288 B

_______________________

MICHAEL T. GAFFNEY

Plaintiff,

V.

INCITY TIMES

ROSALIE TIRELLA

GORDON T. DAVIS

Defendants.

_______________________

DEFENDANT GORDON T. DAVIS’ REQUEST FOR MOTION TO COMPEL PLAINTIFF TO PROVIDE CRITICAL ANSWERS TO INTERROGATORIES.

Defendant Gordon T. Davis (Davis) respectfully requests the Court to compel

Plaintiff Michael T. Gaffney (Gaffney) to answer critical interrogatories in the

Defamation lawsuit (Exhibit 1)

On May 4, 2016 the Defendant served the Plaintiff with two sets of Interrogatories.

(Exhibit 2).

Those Interrogatories included the following which were not answered by the

Plaintiff.

INTERROGATORY NO. 2

Please identify each and all persons who has knowledge of any fact relating in any manner of the events, transactions or occurrences that are described in the Complaint and in any pleading setting forth a claim or defense or counterclaim in this action, and for each such person state:

a.      Name, address and telephone number

b.    Describe to the best of your knowledge the subject matter and facts about which they have knowledge and in what capacity or circumstance they acquired such knowledge;

c.      State whether or not you or any of your agents, attorneys, servants or employees know of the existence of, have taken or have in your or their possession a statement (as defined in Mass.R.Civ.P. 26(b)(3) made by or taken from such a person concerning this action or its subject matter; and

d.    Indicate whether or not you intend to call the person as a witness at trial.

The Plaintiff has failed to provide an answer regarding who has knowledge of the event. The Plaintiff references several documents in his response to Interrogatory No. 16. He does not indicated from whom he obtained these documents nor the names of witnesses with knowledge of the facts.

INTERROGATORY NO. 4

Please describe the nature and date of all illnesses, accidents or injuries from which you have suffered up to and including the present date.

Please include any treatment for Mental Anguish and any other mental illness or condition

The Plaintiff is claiming “mental anguish” as harm done to him. The Plaintiff has failed to answer questions about his health, mental health or condition, nor pain and suffering. The Defendant is entitled to this information as material facts in his defense.

INTERROGATORY NO. 5

Please state the identity of any and all clients who engaged you as an “attorney” in the past five years, including in your answer the address of any such person, the date any such person hired you as an “attorney”, the purpose of your legal counsel and the forum in which you practiced in the interest of any such person.

     The Plaintiff is claiming his business has been harmed by the Defendant. The Plaintiff has not provided information about his business and the likelihood that the Plaintiff’s business could generate one million dollars in income. This information is needed in order for the Defendant to compare year to year income and services. This would be material facts in whether the Defendant caused any loss of business.

INTERROGATORY NO. 6

For any legal counsel described in your answer to Interrogatory No. 5, please state (a) whether you had a fee agreement with your legal counsel client, (b) the date of any such fee agreement, (c) the amount of any fee received from any such advocacy client and (d) the amount due from each such legal counsel client.

The Plaintiff is claiming his business has been harmed by the Defendant. The Plaintiff has not provided information about his business and the likelihood that the Plaintiff’s business could generate one million dollars in income. This information is needed in order for the Defendant to compare year to year income and services. This would be material facts in whether the Defendant caused any loss of business. The Plaintiff has not provided any evidence that the Plaintiff has suffered any loss or harm.

          INTERROGATORY NO. 7

For any legal counsel client described in your answer to Interrogatory No. 5, please state whether any legal counsel client terminated your employment or engagement based upon statements made by the Defendants.

     The Plaintiff is claiming his business has been harmed by the Defendant. The Plaintiff has not provided information about his business and the likelihood that the Plaintiff’s business could generate one million dollars in income. This information is needed in order for the Defendant to compare year to year income and services. This would be material facts in whether the Defendant caused any loss of business. The Plaintiff has not provided any evidence that the Plaintiff has suffered any loss or harm.

INTERROGATORY NO. 8

If your claim is that you have been denied employment or engagement as an attorney by any person based solely upon statements allegedly made by either one or all Defendants, please state:  (a) the name of any such potential client for advocacy service, (b) the date or dates on which you believe you would have served as an attorney for any such potential client, (c) the amount of income you could reasonably have expected to have received from any such potential client.

     The Plaintiff is claiming his business has been harmed by the Defendant. The Plaintiff has not provided information about his business and the likelihood that the Plaintiff’s business could generate one million dollars in income. This information is needed in order for the Defendant to compare year to year income and services. This would be material facts in whether the Defendant caused any loss of business. The Plaintiff has not provided any evidence that the Plaintiff has suffered any loss or harm

INTERROGATORY NO.  9

If your services as an “attorney” have ever been terminated or declined for reasons other than statements made by the Defendants, please state (a) the date or dates on which you have been so terminated or declined for service as an advocate, (b) the exact reason for your having been terminated, (c) the name and address of any client who has terminated your services, and (d) the amount of income lost by any such termination.

The Plaintiff is claiming his business has been harmed by the Defendant. The Plaintiff has not provided information about his business and the likelihood that the Plaintiff’s business could generate one million dollars in income. This information is needed in order for the Defendant to compare year to year income and services. This would be material facts in whether the Defendant caused any loss of business. The Plaintiff has not provided any evidence that the Plaintiff has suffered any loss or harm.

INTERROGATORY NO. 10

If you referred legal counsel clients to attorneys, please state:  (a) the name and address of any attorney to whom you have referred advocacy clients, (b) the date or dates on which you have referred advocacy clients to each such attorney, (c) whether you have a referral agreement with any such attorney whereby you continue to render advocacy services after referral and (d) the amounts paid to you by any client or attorney after referral to an attorney.

      The Plaintiff is claiming his business has been harmed by the Defendant. The Plaintiff has not provided information about his business and the likelihood that the Plaintiff’s business could generate one million dollars in income. This information is needed in order for the Defendant to compare year to year income and services. This would be material facts in whether the Defendant caused any loss of business. The Plaintiff has not provided any evidence that the Plaintiff has suffered any loss or harm.

INTERROGATORY NO. 11

Please identify in detail all losses and damages claimed in your complaint, including in your answer the exact nature of any such loss or damage, date or dates any such loss or damage was incurred, the amounts of any such loss or damage and the method by which any such valuation of damages was calculated.

     The Plaintiff is claiming his business has been harmed by the Defendant. The Plaintiff has not provided information about his business and the likelihood that the Plaintiff’s business could generate one million dollars in income. This information is needed in order for the Defendant to compare year to year income and services. This would be material facts in whether the Defendant caused any loss of business. The Plaintiff has not provided any evidence that the Plaintiff has suffered any loss or harm.

INTERROGATORY NO. 12

Please describe your complete employment history, stating as to each job:  (a) the dates of your employment, (b) the name and address of your employer, (c) your job title, (d) your hourly, weekly or monthly rate of compensation and actual earnings received and (e) your reason for separation from this employment.

     The Plaintiff is claiming his business has been harmed by the Defendant. The Plaintiff has not provided information about his business and the likelihood that the Plaintiff’s business could generate one million dollars in income. This information is needed in order for the Defendant to compare year to year income and services. This would be material facts in whether the Defendant caused any loss of business. The Plaintiff has not provided any evidence that the Plaintiff has suffered any loss or harm.

          INTERROGATORY NO. 14

Please state the name, current address of each person who was a witness to or has any knowledge of any occurrence, event, fact, circumstance or discoverable matter upon which your claim is based or founded, specifying each occurrence, event, fact, circumstance or discoverable matter each such person was a witness to or had knowledge.

     The Plaintiff has failed to provide an answer who has knowledge

of the events. The Plaintiff references several documents in his response to Interrogatory No. 16. He does not indicated how he obtained these documents nor the names of witnesses with knowledge of the facts.

INTERROGATORY NO. 17

Please describe your relationship(s) with Turtleboy Sports or any of its employees, whether it was business, quid pro quo, or any other.

    The answer to this question is related to two of the Defendant’s affirmative defenses. The Second Affirmative Defense is that the Plaintiff reputation was so tarnished that the Defendant could not have tarnished it further. The Third Affirmative Defense is that the Plaintiff filed this instant frivolous lawsuit as a mean to retaliate against the Defendant for Davis’s legal actions against Turtleboy Sports and Aiden Kearney.

          INTERROGATORY NO. 18

 Did you in any manner correspond with Turtle Boy Sports or any its employees before filing your instant Complaint?

     The answer to this question is related to two of the Defendant’s affirmative defenses. The Second Affirmative Defense is that the Plaintiff reputation was so tarnished that the Defendant could not have tarnished it further. The Third Affirmative Defense is that the Plaintiff filed this instant frivolous lawsuit as a mean to retaliate against the Defendant for Davis’s legal actions against Turtleboy Sports and Aiden Kearney.

INTERROGATORY NO. 19

Please describe any and all investigations by Massachusetts Ethic Commission and/or OCPF into any of your professional practices.  Please include the accusations/charges and findings.

     This answer is related to the Defendant’s Second Affirmation Defense which is that the Plaintiff’s reputation was so tarnished that the Defendant could not have tarnished it more.

          INTERROGATORY NO. 20

 Did Turtleboy Sports or Aiden Kearney provided informational to you regarding Mosaic Cultural Center located 41 Piedmont St. Worcester MA? If so what was the information it provided to you?

     The answer to this question is related to two of the Defendant’s affirmative defenses. The Second Affirmative Defense is that the Plaintiff reputation was so tarnished that the Defendant could not have tarnished it further. The Third Affirmative Defense is that the Plaintiff filed this instant frivolous lawsuit as a mean to retaliate against the Defendant for Davis’s legal actions against Turtleboy Sports and Aiden Kearney.

          INTERROGATORY NO. 21

Have you or any of your friend, acquaintances, family, coworkers, campaign staff used racial or other pejoratives? If please provide the names of those people including the actual pejoratives such as “nigger”, “spic”, faggot, “bitch”.  Please provide the name and relationship to you of each person using the pejorative and the pejorative used.

     This answer is related to the Defendant’s Second Affirmation Defense which is that the Plaintiff’s reputation was so tarnished that the Defendant could not have tarnished it more.

         

INTERROGATORY N. 22

 Please provide a legal definition or financial definition of “political capital”.

     Gaffney claims that he was harmed by his loss of “political capital”. The plaintiff failed to provide a legal or any definition for the term. This answer is critical in order for the Defendant to rebut and evaluate the claim. There has been no evidence what “political capital” is, how it is evaluated, or whether the Plaintiff loss any due to the action of the Defendant.

                   INTERROGATORY NO. 26

26. Please indicate everyone and all people who attended any and all of your fundraising events for any and all of your candidacies for City Council of Worcester MA.    

 The event that the Plaintiff claims is libelous took place at a Plaintiff fundraiser. A witness or the actual perpetrator of the alleged event is likely amount the campaign donors or guest. This answer is critical in the determination of the truth of the claim.

27.  Please provide everyone and all people who contributed anything to your campaigns for City Councillor. Please include contributors of money and in kind contributions.

     The event that the Plaintiff claims is libelous took place at a Plaintiff fundraiser. A witness or the actual perpetrator of the alleged event is likely amount the campaign donors or guests. This answer is critical in the determination of the truth of the claim.

INTERROGATORY NO. 28

28.Please refer to Worcester Magazine stories attached to instant Questions. Did you author any of the social media posts with your name appearing in the reference Worcester Magazine stories?

The answer is related to the Defendant’s Second Affirmative Defense. The Plaintiff reputation is so tarnished that it could not have been further tarnished by Defendant’s actions.

RELIEF SOUGHT

The Defendant respectfully asks the Court to compel the Plaintiff to answer the Defendant’s Interrogatories and to cooperate in a good faith and professional manner during Discovery.  The Plaintiff is suing the Defendant for one million dollars. The Plaintiff should provide the answers, documents and evidence to support his claims. The Defendant is deserving of the evidence to be found in Discovery to defend himself from what could be a ruinous matter .

Respectfully Submitted

By the Pro Se Defendant

                                               

Gordon T. Davis