Conferring with HCA Lawyers re Intended Filings
Originally Published: Jan 20, 2023 | Republished: Jan 20, 2023
From Plaintiff’s conversation with Court Reporter, @HCAhealthcare held an EX PARTE discussion with Judge Reeder, immediately followed by monetary sanctions motion threats, designed so Plaintiff will stand down. It is a dastardly action, but one which fails to intimidate Plaintiff https://t.co/LTHHSVVIXv pic.twitter.com/siSklAmDLP
— lawsinusa (@lawsinusa) January 20, 2023
January 20, 2023
Mr. Hamel
Considering yesterday’s email as an opening to confer, and in light of my prior submission this week pertaining to PLAINTIFF’s FIRST REQUESTS FOR ADMISSIONS & PRODUCTION FOR MADISON J. ADDICKS, I would like to advise of my intention to submit the following requests, and now seek to confer as to whether you object or seek any clarification on the requests.
Please respond by close of business, Friday, 20 January, or I will assume you are opposed;
PLAINTIFF’s FIRST REQUESTS FOR ADMISSIONS & PRODUCTION FOR NICOLE G. ANDREWS;
PLAINTIFF’s FIRST REQUESTS FOR ADMISSIONS & PRODUCTION FOR BENJAMIN “BEN” HAMEL;
PLAINTIFF’s FIRST REQUESTS FOR ADMISSIONS & PRODUCTION FOR JOHN S. SERPE;
PLAINTIFF’s FIRST REQUESTS FOR ADMISSIONS & PRODUCTION FOR MARGARET L. LAYRISSON
and also;
PLAINTIFF’s and COUNTER-DEFENDANT’s MOTION FOR LEAVE TO DESIGNATE RESPONSIBLE THIRD PARTIES related to your current counterclaim.
Cheers,
Mark Burke
doctor
