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As I was saying.... On (twosday) February 22, 2022 we received this pacakge from the Santos' lawyer, Harvey D Rogers PA. So, at first glance I was not at all impressed by the package that he sent, and much less impressed by the fact that he didn't send it registered mail, but affixed 9 US "forever" postage stamps —some dating back to 2015— on a large brown envelope that has a number 10 envelope, taped to the front of it, that bears our address and his return address. It appears that the envelope was a used envelope that has suffered some tears as it travelled through the Postal System.

So, my conclusion here is that; the large envelope did not fit in his printer and instead of addressing it by hand, or at the very least, use mailing labels —which I guess he does not possess— he used a number 10 envelope as a mailing label. And, even that, was not printed properly. Needless to say, his presentation and his first impression to me, is not indicative of a good lawyer. Regardless of his circumstances, his professsionalism leaves much to be desired, based on the fact that he would send out such a pathetic looking correspondence. I had advised the Witch to retain a good —I mean, a really good— lawyer. Base on the impression presented here, I guess they opted for whatever they could get.

I Googled him and found tons of consumer complaints against him. It seems that he takes client's money, and keeps building cases for his bill to mount up, but does not deliver good results. In fact some claim to have suffered disastrous results. I will have links to the numerous complaint sites shortly.

Click on the image to enlarge

So this package that we received contained various notices & motions, some filed, some to be filed. The cover letter as well as all the content of the package was on copy paper. I'm assuming that we are not worthy of a pre-printed letterhead stationary or, perhaps this lawyer cannot afford standard printed stationary; just an assumption.

As I read through this bombardment of notices, motions, and all that legal jargon and case law citing, I wonder about his formal education. The grammar is just awful, and there are way too many typos for a legal professional. The extent of his motion to dismiss, which is more like BLAH, BLAH, BLAH.... than anything facts, with tons of irrelevant case law citings, will put you to sleep. Most lawyers don't have a clue about Malicious Prosecution; much less this lawyer. In his motion to dismiss, he sounds like a used car salesman, trying to pressure the court into a quick dismissal, with all of his repetitious, and ambiguous facts.

In his cover letter —printed on copy paper, because....? Are we not worthy of printed stationary?— he is threatening us with sanctions if we do not voluntarily dismiss our case at once. Ha! NOT HAPPENING! In addition, he claims that we are in violation of our injunction agreement as it relates to the child. I THINK NOT! He needs to read and understand the terms of our agreement, before making such claim. He is wanting me to take down posting made online concerning the child, and pay them some $2500 in attorney's fees..... Apparently, they —the Bozo & the Witch— are wanting me to take down my story about The Family From Hell. That's also NOT HAPPENING! His cover letter is posted below.

Click to see his Cover Letter

Also included in the "Package" is a DEFENDANTS MOTION FOR SANCTIONS. Wow! Starting to feel like Putin, with all of these sanctions, LOL. The motion is 4 pages long and his Statement of Facts includes 16 facts as to why we should be subjected to sanctions. Well, he's a little premature, I would say. All of these facts —just like all the facts in his MOTION TO DISMISS— are just a lot of Hoopla, trying to intimidate or impress in some way, a novice litigant to dismiss his claim. To me, it's all BLAH, BLAH, BLAH. I think that if he had IRONCLAD, undeniable facts proving our wrongdoing, the motion could be justified, BUT, he does not. That motion is posted below.

Click to see his Motion for Sanctions


And, finally:

Again, 9 pages, 9 numbered facts, 5 memorandum of more blah, blah, blah, where it appears to me that he does not have a clue and grossly misrepresents our claim. That particular motion, looks like a sales pitch —like the motion for sanctions— to either sell the judge on an unjustified, immediate dismissal or to intimidate us into thinking that we don't have a case. I BEG TO DIFFER! In the statement of facts where his grammar is horrible, with tons of typos, one wonders about his practice of law. He is citing numerous other OLD cases (some up to 20 years old) that are all irrelevant to and do not compare to THIS case. At first glance I doubt that any of these cited case relate to an injunction for sexual abuse on a minor child. He's even STATING that our allegations are

" impertinent, immaterial, irrelevant, scandalous, malicious and fabricared".

Ha! It seems that he is using wordage from our allegations against us. Morever, while he is STATING that our claim lacks any documentations, exhibits to support the claim, he has included OUR exhibits renumbered as his, with his motion. I think that this man is just blowing a lot of Hot Air. I have attached 9 material exhibits to my complaint. I don't understand how he could have missed these exhibits, as they are filed with the court. And, since new discovery has surfaced, I will be adding many more exhibits to prove my claim. At the end of the day, it is for a judge to decide the merits of the case; not this clown.

Disclaimer: Based on the contents of the motion, this lawyer impresses me as a real clown; a used car salesman, discrediting my comlaint without basis; like a dirty politician. That is strictly my opinion; not a statement of facts.

For your entertainment, I am posting his MOTION TO DISMISS —It's such a JOKE— so you can see for yourselves, what I am talking about.


Click to see his Motion to Dismiss

Here are some links to complaints & reviews of this lawyer. According to most of the complaints, Harvey D Rogers is a Money Hungry theif, that likes to drag out court cases to run his bill way up. I guess our defendants are about to be taken for a wild ride. This is an assumption; not a stated fact. Hope they've been working real hard and saved all their money, they're going to need it. Oh Welll....

Complaints Board

Merchants Circle

Yelp

Avvo.com

Lawyer.com


I will be filing a response to his motion to dismiss in the next few day (today is 02/28/22) and post it here as well.... I want to document every aspect of this trial, to publish here and possibly include in my planned Documentary of the Family From Hell. Stay tuned!

Well, today I filed —e-filed actually— my Opposition to Motion to Dismiss, as well as my E-Mail designation. I then e-mailed him a letter, notifying him of that Opposition and asked him to explain to me, about a claim in his cover letter that I violated our agreement with the child, and that he want me to pay some $2500 for his legal fees.

He responded in an ambiguous & sarcastic way. Pretty much the way that the Witch would have answered. Instead of telling me exactly what the issue was, he said, "You have continued to post patent improper posting on line and I don't need to bring it to your attention since you know about that." So, that kind of annoyed me. The fact that I have pictures of the child in my documentary, on my site, that, is not withing the scope of our agreement.

The agreement Names 5 Specific Social Media Sites, —Facebook, Twitter, Instagram, TIK TOK, or Snapchat— where I agreed not to post photos of the child. I guess, he didn't read that. So, my reponse created an e-mail battle, that went back & forth until I mentioned to him that I document everything about The Famiy From Hell which he is now a part of, that everything he says or does would be included in my documentary. That ended that battle for now.

Click to see My Opposition to his Motion to Dismiss

Our E-mail battle. This lawyer work on the "Imtimidation Principle" trying to take advantage of novice litigator. I have no respect whatsoeve for this man. Anyway, here are the emails. The first email contained only the attachment

Click to see my first E-mail Attachement

Click to see the E-mails


Update: Motion to Dismiss, March 15th, 2022

Motion to dismiss
Well, so the Motion to Dismiss Zoom Court sesssion came & went on the 15th. I didn't fare so well. It was not on the lack of merit of the complaint, but on the technicality of the termination of the original injunction. He claimed that it was not a bona fide termination in my favor. And, as much as I tried to convince the judge otherwise, she was Hell bent on the fact that because there was an agreement, the termination was not in my favor. Even though, the injunction was vacated. However, I had read a case law Doss v Bank of America where there was an agreement, and it did not negate the bona fide nature of her termination.

We must have argued back & forth for 20 minutes, but it was futile. Like talking to a brick wall. So, I have to do much more research to find where our agreement does not invalidate a bona fide termination in my favor. If I can find a concrete workaround, I will absolutely appeal. I have 30 days to do so. Check back for more updates. Bummer!

So, the Motion to Dismissed was granted by the young, black female judge, whom I had argued with so much that my termination was bona fide. She had a one way mind, and didn't seem to consider the fact that the underlying suit was totally bogus as it was all fabricated lies. It seems that bought into all the lies and opinions as it related to matter of law, that the defense was presenting in his motion. I also strongly felt that we were being discriminated against because we were Pro Se litigants. She did however give me 15 days to amend my complaint. However disappointing the outcome, it is not the end of the story!

A few days later, I was on Avvo (a lawyer site that answers questions) wondering if anyone could help me fight this. There I posted a link to whatnow.html which detailed my predicament. A day later, I received an email from a lawyer (Alan Grossman) who claimed that he could help. So, I retained him. My retainer was $2500. Bummer! More money to defend those Evil, fabricated lies.

In the following days, Alan started drafting an amended complaint. We emailed back & forth discussing all the facts of the case. Time was running out, I was getting really concerned. He finally emailed me the draft on the last day late in the afternoon for me to verify. I didn't see the email until around 6:00pm, but still I proof read it and found several inaccurate facts. I sent him the corrections, but it was too late. Needless to say, I was not too impressed by Alan.

In the amended complaint, he had incorporated new elements: Abuse of Process and Conspiracy. The abuse of process is similar to Malicious prosecution, but a bit different. It's more of a way to file suit against someone to extort. I never thought it was the appropriate action as it related to my case, hence I file Malicious Prosecution. The conspiracy, I found interesting though. And, I can pretty much prove conspiracy from many facts surrounding the injunction that they filed against us.

Defense however, had an absolute ball with these new allegations. I wonder how much time he spent (at whatever rate he charges) to do case search, and argue every aspect of these new allegations. On May 3rd, 2022 he filed a whole new Motion to Dismiss the amended complaint. It's 16 pages long, plus exhibits. But, he didn't stop there. On May 9th, he filed a 6 page long, Motion for Sanctions. It's objective being that if we don't dismiss the Amended Complaint, and the judge rules in the defendants favor, my lawyer & I will be responsible to pay all of their legal fees.

At the very beginning, his cover letter mentioned dismissing our Malicious Prosecution, and paying some $2500 in legal fees. All he had done so far was file a Motion to Dismiss. Having given the matter some serious consideration, and as reluctant as I was to give in, to these Butt Wipes, we offered to pay the $2500. He replied that he was away, but the he would consult with his clients and get back to us. He later came back with a reponse for a $7500 settlement..... We laughed! So, Given all of the motions filed by defense trying to suck the life out of us I can only imagine that the Santos' legal fees must be through the roof! OMG!!! They must be at $10,000 to $15,000 and counting. Well, they asked for it.

And, we're not finished; it seems! As if all of these motions that are not even adjudged yet, aren't enough, they're filing more actions. Holy Shit! These people went off the deep end. So, on May 12th, my lawyer received a letter from Harvey (their counsel) stating that he was going to file an action against me, for the car. Do you believe this shit! He claims that because the car was used as collateral on the $2000 loan to the BOZO, that by selling the car that they had given back to Yolanda, my loan was satisfied and now, they are asking that I return the car.... What a fucking (excuse my French) joke! I won't elaborate on the case as it supposedly coming up for litigation. You can read the letter Here and my response to him. Ironically, I received the letter from Alan on Friday the 13th!

Click on the image to enlarge

I don't understand the mentality of the Santos in filing more frivolous actions against us, almost 3 years after they moved out. I can only imagine that they have not gotten their revenge yet, and they are so desperate to hurt us because they have NOTHING on us. We (specially Yolanda) only did good for them, yet they shit all over us. Still, they want blood; these Low Life Maggots. So, we will let it play out and see where this goes.

More to come soon

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