Friday, November 27, 2009

KingCast replies to Sam Shaulson and Citibank on Motion to Compel and Motion to Strike.

Complainant's Reply Memorandum on my Motion to Compel:
The Documents are combined in one here at wepaper, I will embed later.

Despite clear and repeated warnings, Citibank has allowed for the spoliation of crucial video that would show my behavior at the bank to be exemplary and would show that they knew exactly who JRT is: In those videos one can see her get the paperwork and sit in the offices in order to open an account!

See MacLellan v. Shaw's Supermarket, Inc., 24 Mass. L. Rep. 317 (2008)

Plaintiffs filed a motion for sanctions against the supermarket for spoliation of evidence, alleging a failure to preserve a scissor lift, destruction of a surveillance video, improper documentation of the incident, and inadequate maintenance records……..

The same was true of the video tape. The court noted that the video which might have shown the sequence of events that resulted in the alleged injury was material and relevant evidence.

Despite clear and continual warnings to maintain video from all visits to the bank – including the time when their staff called me a “motherfucker” and extended their index fingers -- Citibank’s niggardly response is now to provide Respondent claims that I am “playing games” with the legal system for not providing them the full name of my girlfriend, the allegedly “unidentified woman” for whom Citibank most definitely opened a bank account. That is ludicrous as I provided her initials, and Citibank knows when she was at the bank (with Derrick Gillenwater and me) and it is a simple matter for them to see that they did indeed open a bank account for her.

From the Reply Memorandum on my Motion to Strike.

"...All grievances were DISMISSED. Even more interesting is that the Columbus Bar Association seems to be giving the Respondent more information than they gave me: When I asked for the information and disposition of anonymous complaints that came in from New Hampshire they refused to tell me who it was, only now I come to find out that the Columbus Bar Association freely shared that information with Respondent.

I never got the identity of the accusers that the Bar Association provided to Respondent at will. Fascinating. See Attachment 1.

Sam_Shaulson_Citibank_Motion_to_Compel_+_Motion_to_Strike_Rebuttal

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