Judge Martini – Motion
DR. MAX DENIS ANTOINE, PRO SE VICTIM
P.O. BOX 3393
JERSEY CITY, NEW JERSEY 07303
TEL. (202) 000-0000 ENCRYPTED
E-MAIL: ACSGLOBALMAX@YAHOO.COM
JANUARY 28, 2010
UNITED STATE DISTRICT COURT FOR
THE DISTRICT OF NEW JERSEY
HON. JUDGE WILLIAM MARTINI, U.S.D.J.
50 WALNUT STREET
NEWARK, NEW JERSEY 07102
RE: DR. MAX D. ANTOINE, ACS, ET AL
V. VALLEY FORGE INSURANCE, ET AL
FEDERAL CASE DOCKET NO. 09-CV-5568
NEW JERSEY STATE DOCKET NO. ESX-L-8526-09
MOTION REQUESTING FOR MORE TIME TO REFUTE
AND REBUT DEFENDANTS BOGUS MOTION FOR
PREMATURE SUMMARY JUDGMENT
Dear Hon. Beloved Judge Martini,
I am just in receipt of these defendants bogus motion for summary judgment. The Post Office has just delivered me the package late today, January 28, 2010 with certified mail return receipt. Ironically defendants have also requested Oral argument before your honor on this Monday, February 1st, 2010. There is practically no way that plaintiffs can timely oppose, prepare and submit a rebuttal in less than two business days.
Therefore, we are requesting under Federal Court Rules 56 (d), (e), (g), also under 621 F.2d 169, Federal Rule 26 (f), and In Re Rodstad, 126 F.3d 1224 ( 9th Cir. 1997 ) that you either deny the defendants bogus motion under the Bad Faith Doctrine, or in the alternative that you grant the plaintiffs at least thirty ( 30 ) days to timely oppose, refute and accordingly rebut the aforesaid prejudicial motion for summary judgment.
I am further updating this Court per copy of my letter previously addressed to Hon. Judge Mark Falk that this lawsuit is now being amended to include numerous additional defendants and supplemental counts including Assistant Prosecutor Robert Grady, the Essex County Prosecutors Office at Large, The Bloomfield Police Dept., Detective Richard Mcgoldrick, Detective David Sanabria, Police Officer Yessenia Jessee Aponte aka “Lucille Castillo”, the Belleville Municipal Court, the New Jersey State Police, the Essex County Jail, and numerous other classified conspirators as our CONSTITUTIONAL investigation is BROADLY unfolding.
Respectfully requested,
Dr. Max Denis Antoine
Plaintiff-Injured Victim
Cc: United States Court of Appeals for the Third Circuit, In Vestum Notices…!!
David M. Kupfer, Esquire for Above Defendants
Ivan Sutherland, Chief Criminal Defense Attorney for Dr. Max D. Antoine
Hon. Beloved Judge Michael Ravin, Essex County Criminal Court Judge
All Potential Forensic Witnesses & Facts Experts for Dr. Max D. Antoine
All Classified Investigators for Dr. Max D. Antoine, www.jlsecurity.biz