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 t...