MOHAMMAD HAMED, byhisauthorized agent WALEED HAMED,

Plaintiff/Counterclaim Defendant,

vs.

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDSDIVISION OF ST. CROIX

)FATHI YUSUF and UNITED CORPORATION,)

)Defendants/Counterclaimants, )

vs.

WALEED HAMED, WAHEED HAMED,MUFEED HAMED, HISHAM HAMED, andPLESSEN ENTERPRISES, INC.,

Additional Counterclaim Defendants.

))))))

UNITED CORPORATION,

Plaintiff,

v.

\ilAHEED HAMED(alWa V/illy Hamed),

Defendant.

CNIL NO. SX.12-CY-370

ACTION FOR DAMAGES,INJUNCTIVE RELIEFAND DECLARATORY RELIEF

JURY TRIAL DEMANDED

))))))))))))))))))))I

DU

AND

'1000

St Thom 56

REPLY TO OPPOSITION TO MOTION TO CONSOLIDATE CASES

Fathi Yusuf ("Yusuf'), âs the Liquidating Partner of the Plaza Extra Partnership,

respectfully submits this Reply to "Defendant Waheed Hamed's Opposition to Plaintiff

United's Motion to Consolidate with SX-12-CV-370" filed in the captioned cases on April 4,

2016 (Case 3701) and April 1,2016 (Case 101) (the "Opposition"). It is noteworthy that the

Opposition does not dispute a single allegation or representation set forth in the Motion

CTVIL NO. ST-I 3-CV-OOOOI OI

Action for Damages

JURY TRIAL DEMANDED

I All capiølized terms not otherwise defined in this Reply shall have the meaning provided for in Yusuf s Motionto Consolidate Cases filed on March l7,2016 (the "Motion").

Hamed v. Yusuf, et al.Civil No. SX-12-CV-370Page2

including the statement that "all the claims asserted in Case 101 may be treated as claims for

resolution in the liquidation process of the Partnership pursuant to the Plan adopted in Case

370."

In describing the factual and procedural background of Case 101, the Virgin Islands

Supreme Court stated:

United filed a complaint against Hamed in the Superior Court of theVirgin Islands on March 5,2013. In its complaint, United alleged thatin 1992, while Hamed was the manager of its Plaza Extra grocery storeon St. Thomas, he used United's inventory to secretly operate acompeting business. United also alleged that in 1995, Hamed used$70,000 of United's funds for an unauthorized purpose through acashiers check United's complaint sought damages againstHamed for breach of fiduciary duties, conversion, and breach ofcontract, and a full accounting of the funds allegedly misappropriatedby Hamed.

United Corporation v. Hamed,2016 V .1. Supreme LEXIS l-*2 (Jan. 12,2016).

Waheed Hamed ("Vy'aheed") has myopically fixated on the fact that after Case 101 was

filed, Yusuf conceded the existence of a Partnership with Mohammad Hamed and, pursuant to a

summary judgment entered in Case 370 on November 7, 2014, the Court declared that a

Partnership was formed in 1986 by the oral agreement between Hamed and Yusuf for the

ownership and operation of the Plaza Extra Stores, with each partner having a 50o/o ownership

interest in all of the Partnership assets and profits, and a 50% obligation as to all losses and

liabilities.

The Supreme Court gave short shrift to Waheed's argument "asserting that United lacks

standing to bring this action in the first place because it never had an ownership interest inPlaza

Extra." Id .at *4. Of course, this is the same argument Waheed is now reserving in the motion

DUDLEY, TOPPEB

AND FEUERZEIG, LLP

1000 Frederiksberg Gade

P.O Box 756

St. Thomas, U.S. Vl. 00804-0756

(34O\ 774-4422

Hamed v. Yusuf, et al.Civil No. SX-12-CV-370Page 3

for summary judgmont attached as an exhibit to his Opposition. The Supreme Court roundly

criticized Waheed for making this argument:

However, Hamed cites none of this controlling authority [cited in thepreceding paragraphl in making his standing argument, despite beingrequired to do so under this Court's rules. V.I.S.CT.R. l5(b) ("[I]naccordance with ethical standards, any attorney who . does notpresent otherwise controlling contrary law, will be subject to sanctionsas the Court deems appropriate."); Hamed v. Hamed, S.Ct. Civ. No.2014-0008, _D.I. . 2015 V.I. Supreme LEXIS 21, at * 5 n.7 (V.I. July 20, 2015); Percival v. People,62V.l.477,49l (V.I. 2015).And despite the fact that we denied the motion to dismiss on the groundthat standing is not a jurisdictional doctrine in the Virgin Islands,Hamed reasserted his standing argument at oral arguments before thisCourt.

We, therefore, take this opportunity to reaffirm that "standing" - as

that concept is understood in federal constitutional law - does not existin any form in the Virgin Islands Courts.

Id. at* 7-8.

Waheed claims that Case 101 is already subject to a dispositive motion for summary

judgment, attached as an exhibit to his Opposition, "in which the following issues are

undisputed:

1. United admitted that never has been the owner of the PlazaExtra Stores.2

2. United admitted that a partnership between Hamed and Yusuf existed.

3. Thus, the only real party in interest is Fathi Yusuf - alrcAfly¿Ìarty here.

4. Thus, Yusufs claims are already before this Court without

consolidation."

Opposition atp.2 (emphasis in original).

DUDLEI TOPPER

AND FEUERZEIG, LLP

1000 Frederiksberg Gâde

P.O Box 756

St. Thomas, U S. V.l 00804-0756

l34O) 774-4422

2 Neither the Opposition nor the motions for summary judgment attached as exhibits bother to point to any suchadmission.

Hamed v. Yusuf, et al.Civil No. SX-12-CV-370Page 4

Although Waheed may have attached copies of motions for summary judgment as

exhibits to his Opposition, those motions are clearly noncompliant with LRCi 56.1(a)(l) in that

they are devoid of a supporting brief, affidavits and a statement of material facts about which

the movant contends there is no genuine issue. Since Waheed did not include the required

separate statement of material facts, he also failed to comply with the requirement that he "affix

to the statement copies of the precise portions of the record relied upon as evidence of each

material fact." ^See LRCi 56.1(a)(1). Even if Waheed's summary judgment motion was

compliant with LRCi. 56.1, it simply raises the same lack of standing argument already rejected

by the trial court in Case 101 and twice rejected by the Supreme Court. Clearly, this half baked

motion attached as an exhibit to the Opposition provides no impediment to consolidation.

Incredibl¡ Waheed claims that "the only real party in interest is Fathi Yusuf - already a

parW herq." Vy'aheed's claim that Yusuf is already a party to Case 101 is demonstrably false.

See docket sheet attached as Exhibit 1. Accordingly, his additional claim that "Yusufs claims

are already before this Court wÍthout consolidation" is also demonstrably false.

United's claims against V/aheed in Case 101 were obviously asserted before any

concession or determination regarding the Partnership's ownership of the Plaza Extra Stores.

The real party in interest now is the Partnership from which Waheed is alleged to have

misappropriated funds and assets. Yusuf as the Liquidating Partner of the Partnership "with the

exclusive right and obligation to wind-up the Partnership pursuant to this Plan and the

provisions of the V.I. Code Ann. tit. 26, ç 173(c), under the supervision of the Master," has

determined that the Partnership's "claims asserted in Case 101 may be treated as claims for

resolution in the liquidation process of the Partnership pursuant to the Plan adopted in Case

DUDLEY, TOPPER

AND FEUERZEIG, LLP

1000 Frêderiksberg Gads

PO. Box 756

St. Thomas, U.S. Vl 00804-0756

(34O) 774-4422

Hamed v. Yusuf, et al.Civil No. SX-12-CV-370Page 5

370." Motion at tf 5. Nothing Waheed has presented to this Court in the Opposition or the

exhibits to the Opposition establishes otherwise. Since Case 370 and Case 101 clearly "involve

a common question of law or fact," see Fed. R. Civ. P. 42(a), these cases are unquestionably

suited for consolidation.

For all of the foregoing reasons, as well as the reasons set forth in the Motion, Yusuf

respectfully requests this Court to consolidate Case 101 with Case 370 for final disposition.

Respectfu lly submitted,

DATED:April 15,2016

DUDLEY' TOPPER

AND FEUERZEIG, LLP

1000 Freder¡ksberg Gade

P.O Box 756

St. Thomas, U S. Vl. 00804-0756

(s4o\ 774-4422

DUDLEY,

Gregory H.,tþdgés fflt Bar No. 174)I 000 Frederiksberg GadeP.O. Box 756St. Thomas, VI 00804Telephone: (3a0) 7 15-4405Telefax: (340) 715-4400E-mail : ehodees@dtfl aw.conl

Attorneys for Fathi Yusuf, the Liquidating Partner

Flamed v. Yusuf, et al.Civil No. SX-l2-CV-370Page 6

CERTIFICATE OF SERVICE

I hereby certify that on this 15th day of April, 2016,I caused the foregoing Reply ToOpposition To Motion To Consolidate Cases to be served upon the following via e-mail:

Joel H. Holt, Esq. Carl Hartmann, III, Esq.LA\il OFFICES OF JOEL H. HOLT 5000 Estate Coakley Bay,#I-62132 Company Street Christiansted, VI00820Christiansted, V.I. 00820 Email: carl@carlhartmann.comEmail: holtvi@aol.com

Mark V/. Eckard, Esq. Jeffrey B.C. Moorhead, Esq.Eckard, P.C. C.R.T. BuildingP.O. Box 24849 1132 King StreetChristiansted, VI 00824 Christiansted, VI00820Email: markfÒmarkeckard.com Email: jeffreymlaw@yahoo.com

The Honorable Edgar A. RossEmail:çdeg@

DUOLEY TOPPER

AND FEUERZEIG, LLP

1000 Freder¡ksberg Gade

PO. Box 756

St. Thomas, U.S. Vl. 00804-0756

(340ì. 774-4422

R:\DOCS\6254\3\DRFTPLDC\ I 615322.DOC

UNITED coRPoRATloN Plaíntiff)

)Vs' )

)

)

)

SUPERIOR COURT OF THE VIRGIN ISLANDSDIVISION OF

PÂRTY NAME.

EGKARD, ESQ., MARKW.

UN¡TED CORPORATION ,

DEWOOD,.NIZARA¡

WAHEED HAMED (A/K/AW|LLY, W|LLY HAMED ) ,

CIVIL DOCKET

cAsE NO! ST-201 3€V-00001 01

FILING DATE: March 05, 2013

JUDGE: Hon, MichaelC, Dunston

CASE TYPE: DAMAGES. CIVIL

SECONDARY NUII

PETITION

PARTY-TYPE

ATTORNEY FOR OE.TENDANT ORRESPONDENT

PLAINTlFF

ATTORNEY FOR PLAINTIFF ORPETITIONER

DEfENDANT

uflG4N1,

f0oo

P001

P001

D001

Page I of6

þ0Dg

exHleffI

DOCKET DATE

04101t2016

03t23t2016

03123120'16

03fi812016

03t17t2016

02t05t2016

02103t2016

01t1212016

DEFENDANT WAHEED HAMED'S OPPOSITION TO PAINTIFF UNITED'S MOTION TOCONSOLI DATE WITH SX-l 2-CV-370SUBMITTÊD BYCARL HARTMANN III, ESQ,

DEFENDANT WAHEED HAMED'S MOTION AND MEMORANDUM FOR SUMMARY JUDGMENTALONG WITH EXHIBIT 1 AND 2

NOTICE OF FIL¡NG IN OTHER DIVISIONBY MARKW. ECI(ARD, ESQ.

FEE RECEIVED 9.OO

RECEIPT#- 00154364

MOTION TO CONSOLIDATE CASES FILED BYATTY. GREGORY HODGES WITHPROPOSED ORDER

NOTICE OF APPEARANCE FOR DEFENDANT FILED BY MARCK ECKARD, ESQ,

SUPREME COURT'S MANDATE ENTERED

SUPREME COURT'S ORDER OF THE COURTAND OPINION OF THE COURT ENTEREDRE: ORDERÉD THATTHE SUPERIOR COURT.S JUNE 24. 2013 ORDER ISREVÊRSED;ORDERED THAT THE SUPERIOR COURTS SEPTEMBER 2,2014 ORDER ISREVERSED.ORDERED THATTHIS CASE IS REMANDED TO THE SUPERIOR COURT OFR FURTHERPROCEEDINGS CONSISTENT WITH THE ACCOMPANYING OPINION.

FEE RECEIVED 1O3.OO

RECEIPT# - 00145098

FEE RECEIVED 6,00RECETPT#- 00144858

PURSUANTTO SUPREME COURT'S SCHEDULING ORDER ENTERED MARCH 10, 2OI5IN THEABOVE NOTED CASE. WHICH REQUIRES THIS OFFICE TO FILE THEE.RECORD ON OR BEFORE MARCH 20,2015

UPDATED CERTIFIED DOCKET FORWARDED TO SUPREME COURT

SUPREME COURT'S SCHEDULING ORDER ENTERËDRE: ORDERED THAT PURSUANT To SUPREME coURT RULES 11 (b) AND 40.3û)THE CLERK OF THE SUPERIOR COURT SHALL FILE THE E-RECORD ON ORBEFORE MARCH 20,2015.

PURSUANT TO SUPREME COURT'S DOCKETING ORDER ENTERED FEBRUARY 24,2015, PLËASE FIND INDEXWITH RËQUIRED DOCUMENTS

CERTIFIED DOCKET FORWARDED TO SUPREME COURT

NOTICE OF FILING DOCUMENTS IN THË OTHËR DIVISION, NOTICE OF FILINGAPPEALSUBMITTED BY CARL HATMANN, III, ESQ.

NOTICE OFAPPEAL FILED IN THE SUPREME COURT.

DOCKËTING ORDËR ENTER€DRE: ORDERED THATAPPELLANT'S NOTICE OFAPPEAL BE DOCKETEDAS S .

cT. ctv, No.2015-0021

Page 2 of 6

DOCKETS ENTERED ON'THIs:CASE:

DESCRIPTION

04t17t2015

04t1312015

03t2012015

0312012015

03t1012015

AMOUNT

02t2612015

02t2612015

02t2st2015

02t24t2015

02t24t2015

11107t2014

1011612014

10t1012014

10t06t2014

REPLY TO BRIEF IN SUPPORT OF UNITED CORPORATIONS'S MOTION FORRECONSIDERATION FILED BY NIZAR A. DEWOOD, ESQ

DEFENDANT WAHEED (',WtLLtE") HAMED'S OppOSlÏON TO Pl.AtNTIFF UNITED'SMOTION FOR RECONSDIERATION FILED BY CARL J. HARTMANN. III, ESQUIRELETTERATTACHED

PLAINTIFF UNITED'S MOTION TO STAY FILING OF RESPONSES TO DEFENDANT'SBILL OF COSTS Ff LED BY NIZAR A, DEWOOD, ESO PROPOSED ORDER ATTACH

NOTICE OF ENTRY OF ORDER't0105t2014CARL J. HARTMANN, ËSOU|RE (STX)NlzARA, DEWOOD, ESOUTRE (STX)

AMENDED CERTIFICATE OF SERVICE RECEIVEDSUBMITTED BY NIZAR DEWOOD, ESQ.

ORDER SIGNED BY JUDGE MICHAEL C. DUNSTON, THAT DEFENDANT SHALL RESONDTO THE MOTION BY OCTOBER27,2014, AND PLAINTIFF MAY REPLY BYNOVEMBER 7,2014,

PLAINTTFF',S RULE 59(E) MOTION FOR RECONSTDERATION AND TOALTER ORAMEND JUDGEMENT FILED BY NIZARA. DEWOOD, ESQ UNITED'S BRIEF INsuPPoRT OF ITS RULE 59(E) MOTTONATTACH

MOTION AND MEMORANDUM AS TO B]LL OF COSTAND ATTORNEYS FEES FILED BYCARLJ, HARMANN ¡II, ESO PROPOSED ORDERATTACH

MOTION & MEMORANDUM AS TO BILL OF COSTAND ATTORNEYS FEES FILED BYCARL HARTMAN, ESQ,

NOTICE OF ENTRY OF MEMORANDUM OPINIONAND ORDER09102t2þ14GARL J. HARTMANN ilt, ESQUTRE (STX)NtzARA. DEWOOD, ESQUTRE (STX)

MEMORANDUM OPINION SIGNED BY JUDGE MICHAEL C. DUNSTON.

ORDER SIGNED BY JUDGE MICHAEL C, DUNSTON, THAT PLAILNTIFF'S AMENDEDCOMPLAINT IS DISMISSED WITH PREJUDICE IN ITS ENTIRELY. ORDERED THATDEFENDAT;S APRIL 28,2014, MOTION TO DISMISS FOR LACK OF STANDINGIS DENIEDAS MOOT.

NOTICE OF ENTRY OF ORDER05t12t2014CARL J. HARTMANN, III, ESQ.NIZAR DEWOOD, ESQ.

ORDER SIGNED BY JUDGE MICHAEL C. DUNSTON

NOTICE OF ENTRY OF ORDER04t2512014NIZAR DEWOOD, ËSQ.CARLJ. HARTMANN, III, ESQ.

DEFÊNDANT WAHEED HAMED'S RULE 12(c) MOTION TO DISMISS FOR LACK oFSTANDING FILED BY CARL J. HARTMANN, III, ESQ.

ORDER SIGNED BY JUDGE MICHAEL C. DUNSTON

DEFENDANT WAHEED HAMED'S REPLY WITH REGARD TO HIS MOTION FOR SUMMARYJUDGMENT FILED BY CARL J. HARTMANN III, ESQ.

MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S RESPONSE IN OPPOSITIONTO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT FILED BY NIZAR A. DEWOOD,ESQ.

Page 3 of 6

,t0106t2014

10105t2014

0912912014

09t24t2014

0st1812014

09t04t2014

09l0azaß

09t02t2014

05113t2014

05n2t2ß14

0412il2414

04t28t2014

0412612014

04t23t2014

0410712014

03t1212014

03112J2014

0310712014

03t0612014

02i1212014

NOTICE OF ENTRY OF ORDER03107t2014NIZAR DEWOOD, ESQ.CARLJ. HARTMANN, III, ESO.

NOTICE OF SERVICE OF DEFENDANT HAMED'S INTERROGATORY RESPONSES.RESPONSES TO REQUEST FOR PRODUCTION AND REQUESTS TOADMIT FILED BYCARLJ. HARTMANN III, ESQ.

ORDER SIGNED BY JUDGE MICHAEL C. DUNSTON

PLAINTIFF UNITED'S MOTION TO EXTEND TIME TO FILE TIS RESPONSE IN

OPPOSITION TO DEFËNDANT'S MOTION FOR SUMMARY JUDGMENT FILED BY NIZARA. DEWOOD, ESQ,

NOTICE OF ENTRY OF ORDER02111t2014NIZAR A. DEWOOD, ESQ.CARL J, HARTMANN, II, ESQ.

ORDER SIGNED BY JUDGE MICHAEL C, DUNSTON

DEFENOANT HAMED'S MOTION FOR SUMMARY JUDGMENT FILED BY CARL J.HARTMANN,III, ESQ.

DEFENDANT HAMED'S MEMORANDUM IN SUPPORT OF MOTION FOR SUMMARYJUDGMENTAS TO THE SOLE REMAIN¡NG CLAIM FILED CARL J. HARTMANN,il, ESQ,

JOINT STIPULATION FOR ENLARGEMENT OF TIME AS TO DISCOVERY FILED BY

NLZARA, DEWOOD, ESQ.

NOTICE OF SERV]CE OF PLAINTIFF UNITEDCORPORATION'SANSWER TODEFENDANTS (CORRECTED) FIRST SET OF INTERROGATORIESSUBMITÏED BY NIZAR DEWOOD, ESQ.

NOTIGE OF SERVICE OF PLAINTIFF UNITEDCORPORATIONS RESPONSES TODEFENDANT'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTSSUBMITTED BY NIZAR DEIJVOOD, ESQ,

NOTICE OF SERVICE OF PLAINIFF UNITED CORPORATION'S RESPONSES TODEFENDANT'S (CORRECTED) FIRST REQUEST FOR ADMISSIONSSUBMITTED BY NIZAR DEWOOD, ESQ.

DEFENDANT WAHEED HAMED'S TCORRECTED) FIRST INTERROGATORIES TOPLAINTIFF UNITED FILED BY CARL J, HARTMANN, III, ESQUIRE,..

DEFENDANT WAHEED HAMED',S ICORRECTED] FIRST,REQUESTS FOR ADMISSIONS

TO PLAINTIFF UNITED F¡LED BY CARL HARTMANN, III, ESQUIRE.,.

DEFENDANT WAHEED HAMED'S FIRST INTERROGATORIES TO PLAINTIFF UNITEDFILED BY CARL J. HARTMANN III, ESQUIRE.

DEFENDANT WAHEED HAMED'S FIRST REQUESTS FOR,ADMISSIONS TO PLAINTIFFUNTIED FILED BY CARL HARTMANN III, ESQUIRE.

DEFENDANT WAHEED HAMED'S FIRST REOUEST FOR THE PRODUCTION OFDOCUMENTS TO PLAINTIFF UNITED FILED BY CARL HARTMANN III, ESQUIRE.

LETTER ADDRESSED TO OFFICE OF THE CLERK FILED BY CARL J . HARTMANNSELF.DISCLOSURES PURSUANTTO RULE 26 ATTACHED

SELF-DISCLOSURES PURSUANTTO RULE 26 FILED BYATTY. CARL HARTMANN

ANSWER TO FIRSTAMENDED COMPLAINTFILED BY CARL J. HARTMANN III, ESQUIRE.

ANSWER TO FIRSTAMENDED COMPLAINTAND LETTERF]LED BY CARL J. HARTMANN III, ESQUIRE.

Page 4 of 6

oãfit2014

42106t12014

12t16t2013

10t10t2013

10/1012013

10t0812013

0911212013

09t1212013

09/09/20{ 3

09I09/20'13

09/09/2013

08t2312013

08t2312013

07t3012013

'0713012013

07t1812013

07t1812413

SCHEDULING AND MEDIATION ORDER SIGNEDAND ENTERED BY JUDGE DDUNSTON

NOTICE OF ENTRY OF ORDER DATED7t1812013NIZAR DEWOOD, ESQUIRECARL HARTMANN, 111, ESQUIRE

FILE FORWARDED TO JUDGE'S CHAMBER

PROPOSED STIPULATED SCHEDULING ORDER RECEIVED, FILED BY CARLHARTMANN, ESQ.

AMENDED COMPLAINT FILED BY NIZARA, DEWOOD, ESQUIRE

NOTICE OF ENTRY OF MEMORANDUM AND ORDER0612412013NIZAR DEWOOD, ESQ.CARL HARTMANN, III, ESQ.

NOTICE OF ENTRY OF ORDER06124t2013NIZAR DEWOOD, ESQ.CARL HARTMANN, III, ESQ.

MEMORANDUM OPINION AND ORDER SIGNED BY JUDGE MICHAEL C. DUNSTON;IT IS ORDERED THAT DEFENDANT'SAPRIL 15,2013 MOTION FOR JUDGMENT ON

THE PLEADINGS IS GRANTED IN PARTAND DËNIED IN PART WITHOUTPREJUDICE; AND lT lS ORDERED THAT THE PORTION oF PLAINTIFF'SCOMPLAINT RELATED TO AN ALLEGED CERTIFIED CHECK FOR SEVENTYTHOUSAND DOLLARS lS DISMISSED WITH PREJUDICE; ETC.

ORDER SIGNED BY JUDGE MICHAEL C. DUNSTON; IT IS ORDERED THAT BY

JULY 12. 2013, THE PARTIES SHALL CONDUCTA SCHEDULING CONFERENCEPURSUANTTO RULE 26(f)OF THE FEDERAL RULES OF CIVIL PROCEDUREANDSHALL SUBMIT TO THE COURT BY JUNE 19, 2013 AWRITTEN REPORT SETTINGFORTH A PROPSED DISCOVERY PLAN AND PROPOSED SCHEDULING ORDERAPPROVING THE SAME AND ADOPTING ITAS THE SCHEDULING ORDER IN THISCASE;

FILE FORWARDED TO JUDGE'S CHAMBER

DEFENDANT HAMED'S REPLYTO PLAINTIFF'S OPPOSITION TO THE MOTION FORJUDGMENT ON THE PLËADINGS RECEIVED, FILED BY CARL J. HARTMANN, III,

ESQ,

AMENDED CERTIFICATE OF SERVICE RECEIVEDSUBMITTED BY NIZAR DEWOOD, ESQ,

FILE RETURNED TO THE CLERK'S OFFICE

FILE FORWARDED TO JUDGE'S CHAMBERS

PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION FORJUDGMENT ON THE PLEADINGS F¡LED BY NIZAR DEWOOD, ESQUIRE.

FILE RETURNED TO THE CLERKS OFFICE

NOTICE OF ENTRY OF ORDER DATED:04129t2013CARL HARTMANN, ESQUIRE via EMAIL: carl@carlhartman,comNtzAR A. DEWOOD, ESQUIRE 888-398-84289(FAX)

07t1712013

07t16t201t

07t',5t2013

0612612013

06/25/2013

0Êt2412013

06it24,n413

08t1212013

06t04t2013

05t2a2013

05/13/2013

05,09/2013

0s/01,2013

04/30/2013

0413012013

Page 5 of 6

0412912013

04t2412013

0412312013

04t16t2013

0312012013

0310712013

03106/2013

03/06/2013

03/05/2013

03r0512013

0310512013

03105/2013

03r05r2013

0310512013

ORDER SIGNED BY JUDGE MICHAÉL C. DUNSTON.-ORDERED THAT PLAINTIFFSHALL RESPOND TO THE MOTION BY MAY 13,2 013, AND DEFENDANT MAY REPLYBYMAY 24,2013.

Ff LE FORWARDED TO JUDGE'S CHAMBER

NOTICE OFAPPEARANCE RECEIVED FROM JOSEPH DIRUZZO. ESOUIRE.

MOTION FOR JUDGMENT ON THE PLËADINGS, MEMORANDUM IN SUPPORT OF

MOTION FOR JUDGMENT ON THË PLEADINGS AND ORDERSUBMITTED BY CARL HARTMANN, ESQ.

ANSWER FILED BY CARL HARTMANN, ESQUIRE

CASE SENT FRON NON-JURYTO JURY

FEE RECEIVEDREGE|PT#- 00128993

RETURN OF SERVICE FOR 20 DAY SUMMONS FOR WAHEED.HAMED RETURNEDSERVED ON 3/5/13.

DIRECT JUDGE ASSIGNMENT HON, M|ChAEI C. DUNSTON MCD

COMPLAINTAND SUMMONS FILED BY NIZARA. DEWOODI ESQ.

FILING FEEASSESSED

CIVIL LITIGANT PERSONAL ÞATA FORMS FITED BY NIZARA. DEWOOD, ESQ.

20 DAY SUMMONS ISSUED

DOCKETING LETTER AND NOTICE OF JUDGE ASSIGNMENT PROCESSED BY ÇLERK

TOTAL NUMBER OF ENTRIES: 88

PREPARED BY: TEN]SHA LOWRY

fi*ùfiiEND OF REPoRT*******

75.00

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