Seeking For Legal Advocacy

 3. Discovery / Requests to Admit

   Discovery requests and Requests to Admit were served. To my knowledge, responses were not timely served within the applicable response periods.

I am attempting to determine:

- the procedural impact of the lack of response;
- whether relief should be sought or preserved at hearing;
- whether additional filings are strategically advisable;
- and how best to address the issue without unnecessarily burdening the Court or over-litigating the docket.

4. Procedural Documentation
   I have maintained extensive documentation including:

- emails to opposing counsel;
- certificates of service;
- sheriff service receipts;
- filed notices;
- hearing notices;
- Rule 201(k) certifications;
- screenshots of docket entries and ROA history;
- and communications relating to counsel appearances and litigation status.

5. Strategic Concerns
   One of my primary concerns is proceeding strategically and professionally without:

- flooding the docket with repetitive filings;
- damaging credibility with the Court;
- or mishandling procedural issues that may have significance later in the litigation.

I am seeking counsel who can:

- review the procedural posture of both cases;
- evaluate discovery and Rule 201(k) issues;
- assess pending motions and deadlines;
- advise regarding Requests to Admit and potential admissions issues;
- determine whether sanctions or procedural remedies are appropriate;
- and potentially assist with representation, appearance, motion practice, or hearing preparation.

I can provide:

- docket screenshots;
- ROA summaries;
- email correspondence;
- service documentation;
- filed motions and exhibits;
- and additional supporting materials immediately upon request.

If you are available to discuss representation or limited-scope assistance, please let me know your availability, consultation process, and any materials you would like me to forward in advance.

Thank you for your time and consideration.

Sincerely,

CHRISTOPHER LAWRENCE MCGOLDRICK TRUST
:Christopher-Lawrence; .McGoldrick:-Trustee
(779) 208-6096
christophermcgoldricktrust@gmail.com

Don’t wait for judges to rule.
Set your Motions for Hearing,first and foremost.

Study the class on Motions & Hearings.

Jurisdictionary, is your best "set of eyes".

The motions were all set for April 9th 2026 that court date came and past .. during that proceeding /-hearing I articulated that I have motions, specifically five motions motion to dismiss the EV case, motion to deem rfas admitted, motion to compel discovery, motion to deposit occupancy on to the court registry, And motion for sanctions were already on record and submitted into the docket with proper notice and share of service and due process... During said court date previously I had representation and submitted a rebuttal to the counterparties motion to dismiss however, unfortunately because I had representation at that point, it was stricken during the April 9th court date hearing it was brought back up that that motion to dismiss was not yet responded to. I was given 14 days to properly rebut and I rebutted within the first 3 days. The counter party was given 14 days to respond to the rfas and failed to do so as well as 14 days to respond to my motion to dismiss they did do with their amended motion to dismiss which I rebutted within 72 hours of receiving that. From what I recently gathered from the counterparties associate who sent me a screenshot of a text message between him and my counterparty. Counterparties council will be submitting a response to my rebuttal probably tomorrow.. of which the next hearing is on May 18th 2026 so I intend to rebuttal whatever their points of interest are point for point and beyond that go into the May 18th hearing properly. Rebutted to all of their points which in effects moves the court to the motions that are already on file that I filed, especially since the deadline to respond to the rfas has came and went.. but with those five motions pending unrulled on as well as the sixth motion being my response to their amended motion to dismiss and odds are likely a seventh motion being my response to their response. I'm not trying to flood the docket they're already over there court ordered time and deadlines procedurally speaking

I'm going to definitely read every bit that I can, especially since I do have all the information that jurisdictionary so keenly and astutely put on their website regarding motions for hearings because moving the court is definitely the smart thing to do. I'm not just going to sit idle-handed. Dr. Graves is definitely right

You must study my tactics, sir.
All of them, please.

Make CLEAR in the court record that you will win on appeal if the trial level judge rules against you! Make CERTAIN you can get a certified transcript of every word spoken in the courtroom!

Dr. Graves,

I wanted to respectfully update you regarding where I currently stand procedurally and how I have been applying the Jurisdictionary teachings concerning motions, hearings, record preservation, and moving the court.

At present, I have multiple pending motions already filed into the record with proper notice and certificates of service. My objective has been to avoid allowing the case to remain dormant and instead actively move the court toward enforceable rulings and orders, exactly as your teachings emphasize.

The motions currently pending include:

1. Motion to Dismiss
2. Motion to Deem Requests for Admissions Admitted
3. Motion to Determine Sufficiency of Responses
4. Motion to Compel Discovery
5. Motion for Sanctions
6. Rebuttal/Response to opposing party’s amended motion to dismiss
7. Anticipated reply/rebuttal to opposing counsel’s forthcoming response

During the April 9th hearing, I made certain the record reflected that these motions existed and remained unresolved. I articulated directly to the court that the motions had been filed, noticed, and procedurally pending. The court granted briefing deadlines, and I complied within the first few days rather than waiting until the final deadline.

The opposing party was likewise given deadlines to respond to both the RFAs and my motion to dismiss. Those deadlines have now substantially passed, which is part of why I moved forward with the motions concerning deemed admissions and insufficiency of responses.

What I have been trying to apply from your teachings is the principle that motions alone accomplish nothing unless the court is moved toward a hearing and ruling. I fully understand now that filing paperwork is only part of litigation practice; controlling the movement of the case and preserving the record is equally important.

I have also been studying and applying your concepts regarding:

- moving the court to enter orders rather than merely “requesting” relief
- preserving objections and appellate posture
- ensuring motions are properly set and noticed
- keeping detailed procedural records
- rebutting only newly raised arguments
- making certain the record clearly reflects unresolved issues
- using concise factual and legal arguments tied directly to controlling authority
- maintaining professionalism and composure despite opposition tactics

One of the most important concepts I took from your materials is that courts generally do not act unless a litigant actively moves the case forward. That concept completely changed how I view litigation strategy.

I am now actively preparing for the May 18th hearing and intend to address opposing counsel’s arguments point-for-point while maintaining focus on the actual procedural posture, deadlines, discovery failures, and pending motions already before the court.

I also understand now the importance of:

- hearing scheduling,
- proper notices,
- preserving transcripts,
- making a complete appellate record,
- and ensuring every material issue is spoken clearly into the record.

I genuinely appreciate the education your materials have provided because they helped me begin understanding litigation as procedural warfare centered around motions, hearings, records, and enforceable orders rather than emotion or rhetoric.

Any additional insight you may have regarding my current procedural posture or strategic direction would be sincerely appreciated.

Respectfully,

Christopher McGoldrick

Whenever possible, Christopher set your motions for hearing, and of course it’s always best if you have one hearing for one motion, so it doesn’t become a complicated gobbling Gook that judges sometimes aren’t smart enough to understand and that attorneys use an opportunity to create their smoking mirrors game. Hope this is helpful. Thank you for the praise. We appreciate it. We’re waiting for everyone else to learn what you are learning thank you bye.

2 summons, 1 was listed at $5,000.00 and the 2nd one incorporated an additional amount and totaled $13,000.00.