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<blockquote data-quote="Deset Gled" data-source="post: 8835578" data-attributes="member: 7808"><p>Lanasa's NY legal team responded to Tenkar's filing. Formatting and emphasis mine:</p><p></p><p>----</p><p>Your Honor:</p><p></p><p>This law firm represents the Plaintiffs in the above-captioned action.</p><p></p><p>By this letter I would respectfully request permission to respond to Attorney Schneider’s</p><p>Letter Motion of November 21, 2022 (ECF No. 14), until Monday, November 28, 2022, before</p><p>the Court makes any ruling on the Motion.</p><p></p><p>This Letter Motion merits being directly addressed on a number of bases including, but</p><p>not limited to:</p><p> a. <strong>the failure to confer with opposing counsel before the filing of the motion</strong>;</p><p> b. direct violation of the previously entered into Stipulation; and</p><p> c. <strong>late filing of the Letter Motion</strong>.</p><p></p><p>Attorney Schneider has arbitrarily (and <strong>discourteously and unprofessionally</strong>) set a</p><p>number of dates in his Letter Motion, without even bothering to confer with Plaintiffs’ counsel.</p><p><strong>Furthermore, the Letter Motion contains a number of libelous statements that need to be</strong></p><p><strong>addressed, that Attorney Schneider has seen fit to make, under the protection of immunity</strong></p><p><strong>conferred by judicial filings.</strong></p><p></p><p>I request this additional time within which to respond (and make any other applications</p><p>under the Rules) due to my current schedule, the upcoming holidays.</p><p>Your attention to this request is greatly appreciated.</p><p></p><p>Respectfully submitted,</p><p>Bernard V. Kleinman, Esq.</p><p>Attorney for Plaintiffs</p><p>-----</p><p></p><p>My summary:</p><p></p><p><img src="https://media2.giphy.com/media/Wvo6vaUsQa3Di/200.gif" alt="Tantrum Crying GIF" class="fr-fic fr-dii fr-draggable " style="" /></p><p></p><p>IANAL, so someone can correct me if I'm wrong here, but</p><ul> <li data-xf-list-type="ul">The defendant (Tenkar) has no obligation to negotiate with their attacker (Lanasa) before filing a response.</li> <li data-xf-list-type="ul">The defendant is allowed to make a defense, and Lanasa's blatant and unwavering bigotry is allowed to be part of that defense.</li> <li data-xf-list-type="ul">The "late filing" was preceded by a request for time extension, which Lanasa didn't respond to.</li> <li data-xf-list-type="ul">Throwing around ad hominems like Tenkar's lawyer being "discourteous and unprofessional" really only make Lanasa look even more like a bully. Hopefully the judge sees it that way, too.</li> </ul><p></p><p>We'll have to wait until November 28th to get the real meat of Lanasa's full legal response, but I'm predicting a nothingburger.</p><p></p><p>On a final note, I want to acknowledge that [USER=15047]@tenkar[/USER] is a member here and I don't want to be posting behind his back, but I also completely understand that he can't comment on this litigation.</p></blockquote><p></p>
[QUOTE="Deset Gled, post: 8835578, member: 7808"] Lanasa's NY legal team responded to Tenkar's filing. Formatting and emphasis mine: ---- Your Honor: This law firm represents the Plaintiffs in the above-captioned action. By this letter I would respectfully request permission to respond to Attorney Schneider’s Letter Motion of November 21, 2022 (ECF No. 14), until Monday, November 28, 2022, before the Court makes any ruling on the Motion. This Letter Motion merits being directly addressed on a number of bases including, but not limited to: a. [B]the failure to confer with opposing counsel before the filing of the motion[/B]; b. direct violation of the previously entered into Stipulation; and c. [B]late filing of the Letter Motion[/B]. Attorney Schneider has arbitrarily (and [B]discourteously and unprofessionally[/B]) set a number of dates in his Letter Motion, without even bothering to confer with Plaintiffs’ counsel. [B]Furthermore, the Letter Motion contains a number of libelous statements that need to be addressed, that Attorney Schneider has seen fit to make, under the protection of immunity conferred by judicial filings.[/B] I request this additional time within which to respond (and make any other applications under the Rules) due to my current schedule, the upcoming holidays. Your attention to this request is greatly appreciated. Respectfully submitted, Bernard V. Kleinman, Esq. Attorney for Plaintiffs ----- My summary: [IMG alt="Tantrum Crying GIF"]https://media2.giphy.com/media/Wvo6vaUsQa3Di/200.gif[/IMG] IANAL, so someone can correct me if I'm wrong here, but [LIST] [*]The defendant (Tenkar) has no obligation to negotiate with their attacker (Lanasa) before filing a response. [*]The defendant is allowed to make a defense, and Lanasa's blatant and unwavering bigotry is allowed to be part of that defense. [*]The "late filing" was preceded by a request for time extension, which Lanasa didn't respond to. [*]Throwing around ad hominems like Tenkar's lawyer being "discourteous and unprofessional" really only make Lanasa look even more like a bully. Hopefully the judge sees it that way, too. [/LIST] We'll have to wait until November 28th to get the real meat of Lanasa's full legal response, but I'm predicting a nothingburger. On a final note, I want to acknowledge that [USER=15047]@tenkar[/USER] is a member here and I don't want to be posting behind his back, but I also completely understand that he can't comment on this litigation. [/QUOTE]
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