34 thoughts on “PACER Fee to download full pleading – $37.10, Opportunity to expose the Goatherders – Priceless”
Receiving you FIVE BY FIVE. Actual Maxwell here. Whiskey Tango Foxtrot. I SAY AGAIN WHISKEY TANGO FOXTROT. Actual Maxwell requests confirmation this is Sierra Lima Alpha Bravo Bravo Echo Delta transmitting this frequency. Suspect Oscar November India Oscar November type interference with transmissions this channel. I say again, confirm identity as Sierra Lima Alpha Bravo Bravo Echo Delta and NOT Oscar November India Oscar November OVER
(background noise precedes the actual radio transmission,which sounds like scuffling and general confusion amongst an unruly group. After the transmission is complete the background noise continues, as if someone has seized the mic and is holding it keyed. The hubbub is then drowned out by Maxwell shouting WHISKEY TANGO FOXTROT WHISKEY TANGO FOXTROT IT’S ONLY MONDAY AND WHISKEY TANGO FOXTROT ALREADY providing additional emphasis to the general atmosphere. (The audience is perhaps intended to experience something which might be described as a feeling similar to confused beguilement, which had begun to teeter towards tedium and, which now is instead beginning to overshadow the fleeting sense of invigorating ennui produced by prior events.)
The Haspel name is synonymous with making beautiful ties in NOLA but I got to say that the above sharp,clean linsd “brief” is a very “able” fit and it is environmentally friendly as it allows for a lot of fresh air circulation into the “stinky” crack areas between the legs. So I can’t wait till Haspel adjudicates the entire “suit” and displays them especially in front of the highly critical eyes and ears of brief/suit expert, Ms.Morgan .
They should also be fabulous things to wear, to be seen worn, should make news within the industry and after it is modeled in the “big” show they could eventually be bought by others to wear when there is a “chilling effect” in the local journalistic air.
I’m sure certain others will be “leery” of the new airy “brief”, but the “brief” is ideally designed to prevent those embarrassing “goats in the garden” incidents which plague all men at times especially in hot areas of high humility.
Right on yo’ Haspel bros’, go true da’ motions and done sue it all up real soon, nice and pruddy.
Really a great pleading, in my humble opinion as a non-attorney. Logical, flowing and powerful.
Once Judge Morgan gets about 3 pages into Abel’s anticipated non-sensical, spleen-venting, “he hurt my fee-fees” (feelings)melodrama of a memorandum in opposition, she just might convulse.
Special Motion to Deport Alien Goats/Goatherders From A Community Garden
NOW INTO COURT, comes Doug Handshoe who respectfully states the following to this Honorable Court;
Handshoe alleges that alien goats and their goatherders have continually, persistently and arrogantly trampled in a community garden that he and others have worked post Katrina; all in an effort to remove insurance scam briers, political corruption weeds and other opportunistic parasites which seem to be also plaguing the entire Gulf South region.
First it was Sargent Duddley Do-Right of the Royal Canadian Mounted Police who trampled thereon trying to serve a Canadian SLAPP lawsuit, alleging hurtful feelings, on Handshoe in Wiggins, Mississippi.
Then a laughing joyful group, carrying a cheesy judgment from Canada based on sour allegations, again trampled Handshoe’s community garden but were soon run out by the Honorable District Court of Southern Mississippi. However,they ran still spitting and chewing the paper in their mouths straight to the Honorable U.S. Fifth to try to milk buckets of tears from those overworked honorable eyes on Camp Street.
Most recently, a local goatherder related in business to the original goatherders trampled still again and additionally inviting others to join him in attempting to trample,crush and even eat emerging seedlings of parody, hyperbole and many shoots of truth and justice.
Handshoe respectfully prays that after due process all alien, unwelcomed goats/goatherders be physically restrained,removed and deported allowing peace be to be rightfully restored to his purposeful,community garden.
There will be a hearing on The Special Motion concerning the goats’ “briefs” on April 10th and the goatherders will have their goat diapers or panties on:
FYI and for the bailiffs of the U.S.Eastern District Court of Louisiana on checking proper diaper application to goats courtesy of Claire, a shepardess out of Nova Scotia no less:
There’s even an illustrative and “ingredient” section for OnASteed aiding proper diaper/panty application for his “trusted” steed. Although OnASteed could be in Florida at that time resting comfortably, defending his “castle” with his “lance”(i.e. his words), gazing into ” Merlin’s crystal ball” and possibly a little “leery” of potential “dragon slayers” still lurking about.
Full docket text for document 24:
ORDER: Oral argument will be held as to [23] MOTION to Strike on 5/15/2013 10:00 AM before Judge Susie Morgan. The motion remains set for submission on 4/10/13. Accordingly, any written opposition shall be filed by 4/2/13. Signed by Judge Susie Morgan.(cbn)
Have you guys forgotten the DMR fiasco? Will Joe Zeigler and his brother-in-law get away scott free? Is anyone paying attention to that bunch? Who approved Baby Walker’s bulkhead on the property sold to the DMR? Come on fellas….you’ve done a great job on the NOLA group….get on top of the DMR crooks for a while and give the goatherders a short rest???
Charlene: We haven’t forgotten you Silkwooder, but Doug and da’ goatherders are joined at the hip in a hellish union via a few cheesy coital suits until death do they part.
That said, Doug did what you asked and done ” get on top” of the coastal crooks and got a few,big time pelvic thrusts in today observable in graphic X-rated detail from DMR’s secret,toy helicopter.
24,215 pages of DMR records posted by the Sun Herald to review, Feel Bryant naming the new DMR director tomorrow, and then there is that D’Iberville Ocean Expo MDEQ take back.
It’s the time of year when the weather forecast sometimes is for stormy weather.
Please tell me if I have this right (I’m not an attorney):
Daniel Abel filed his original lawsuit against you and AMV(B)in the Eastern District of Louisiana saying that the federal court had jurisdiction over the case because AMV(B) and you resided in a state other than Louisiana. Able has since filed an amended complaint in this suit which also says that the Eastern District has jurisdiction over the case for the same reasons.
To your knowledge, Abel has never filed suit against you in any Louisiana state court.
Now, Abel is asking the federal court to “remand” his case to some nebulus state court where he has never filed a suit? Is that procedurally possible? Is this forum shopping? Is the current case moving along too quickly for Abel and his supporters?
If remand is denied, do you think he may try to voluntarily dismiss this matter within minutes after filing a state court petition in the CDC?
In my personal, non-attorney opinion, Abel’s opposition to AMV(B)’s motion to dismiss is deja vu of his pattern and practice in other lawsuits I’ve looked into. It’s confusing, disjointed, irrelevant in many places, cut/paste, shotgun approach, thrown against the kitchen wall, all over the place conclusions and self-serving allegations.
I didn’t know he was a linguist-blog-comment-deciphering expert? Some of the language in his pleading makes me feel he is representing to the court that he can identify AMV(B) as whitmergate and others who comment on Slabbed by using what sounds a lot like something done by the guy used by Heebe to out Perricone via his writing styles.
Oh. He also “demands” discovery in connection with your motion to strike. I would hate for you to have to go through that cost and delay, but if the court does grant discovery, maybe Concrete Busters will ask to participate in some of the depositions, etc. since Able includes allegations about them in this suit.
Exactly NAAS. Even better though is Abel contacted Special Agent Cataldi at NOLA FBI. She tells me they had a brief conversation, a few days after which she was sent a memorandum prepared by Abel of the conversation that bears no relationship to their actual discussion. I imagine Abel’s memo will surface someplace like Canada if I had to guess.
That hole these Goatherders have dug for themselves is impressive.
I remember reading something in 1 of his pleadings about how the FBI or something the FBI said actually supported his claims in some way.
Would the FBI publicly confirm or deny their conversation with Abel? Was there any written response by the FBI to Abel’s memorandum?
I’m not a lawyer, so forgive my layman’s questions. If his comments or “claims” about the FBI are in response to AMV(B)’s motion to dismiss, can she do some discovery for the document since he is saying the FBI supports his side of things?
If he has lied about this FBI conversation in a pleading to the court, isn’t that a serious no no?
Anybody whose mantra is “tort reform” should be following this case.
Well, on second thought, Concrete Busters may not be helpful after all. I wonder if any kind of written settlement agreement exists between Concrete Busters, Smith & Fawer, Abel, etc.?
more technically correct would be to dismiss without prejudice to allow filing in state court. But then there’s the jurisdictional and venue issues – and a SJ on the SLAPP law.
Just have to wonder out loud if there’s the jurisdictional threshold present for diversity. Doug, that’s your queue line for the canned laughter.
The Honorable Court should sanction him by the page then turn his Kamikaze goat,paper eating butt over to the Interior Department to be paper- boarded( legal paper stuffed in mouth until breathless).
Unlike Haspel’s ultra-lite legal “briefs” these Fruit of the Loom “briefs” are heavy,baggy, can hold a lot of legal crap thereby cutting off sunshine and fresh air to the real “pricky” issues.
Correction: Misspell- “Pricky” issues in my above post should have read “prickly” issues. As in “prickly” heat which occurs when a crying babe doesn’t get their Fruit of the Loom,full of piss dribbles and crap, changed and in an Honorable Zone are exceeding the limit of SPB(sh*ts per brief.)
For “prickly” heat it is imperative to get the ” whining” babe to stop crying and then an abundance of Sanction Powder applied to its irritated,dwarf sized genitalia with every new “brief”.
NAAS: Seriously, isn’t there a Rule for page limits in a certain size font for briefs in U.S. District Court and has a motion to exceed same been filed? Where is the “brief” police ?
Receiving you FIVE BY FIVE. Actual Maxwell here. Whiskey Tango Foxtrot. I SAY AGAIN WHISKEY TANGO FOXTROT. Actual Maxwell requests confirmation this is Sierra Lima Alpha Bravo Bravo Echo Delta transmitting this frequency. Suspect Oscar November India Oscar November type interference with transmissions this channel. I say again, confirm identity as Sierra Lima Alpha Bravo Bravo Echo Delta and NOT Oscar November India Oscar November OVER
(background noise precedes the actual radio transmission,which sounds like scuffling and general confusion amongst an unruly group. After the transmission is complete the background noise continues, as if someone has seized the mic and is holding it keyed. The hubbub is then drowned out by Maxwell shouting WHISKEY TANGO FOXTROT WHISKEY TANGO FOXTROT IT’S ONLY MONDAY AND WHISKEY TANGO FOXTROT ALREADY providing additional emphasis to the general atmosphere. (The audience is perhaps intended to experience something which might be described as a feeling similar to confused beguilement, which had begun to teeter towards tedium and, which now is instead beginning to overshadow the fleeting sense of invigorating ennui produced by prior events.)
How does one translate “Bitch Slapped” into goatherdese?
The Haspel name is synonymous with making beautiful ties in NOLA but I got to say that the above sharp,clean linsd “brief” is a very “able” fit and it is environmentally friendly as it allows for a lot of fresh air circulation into the “stinky” crack areas between the legs. So I can’t wait till Haspel adjudicates the entire “suit” and displays them especially in front of the highly critical eyes and ears of brief/suit expert, Ms.Morgan .
They should also be fabulous things to wear, to be seen worn, should make news within the industry and after it is modeled in the “big” show they could eventually be bought by others to wear when there is a “chilling effect” in the local journalistic air.
I’m sure certain others will be “leery” of the new airy “brief”, but the “brief” is ideally designed to prevent those embarrassing “goats in the garden” incidents which plague all men at times especially in hot areas of high humility.
Right on yo’ Haspel bros’, go true da’ motions and done sue it all up real soon, nice and pruddy.
Very good, Doug, very good.
Motion for leave to file excess pages granted by Judge Morgan. You’d be amazed by the number of attorneys that never ask for such permission. 😉
Always a calculated gamble, Doug. You ned to know if the law clerk is lazy or actually wants to do the work.
Really a great pleading, in my humble opinion as a non-attorney. Logical, flowing and powerful.
Once Judge Morgan gets about 3 pages into Abel’s anticipated non-sensical, spleen-venting, “he hurt my fee-fees” (feelings)melodrama of a memorandum in opposition, she just might convulse.
Ha ha don’t you love the common notion and thought of it of Motion to strike and beat and bitch slap and etc…..
Special Motion to Deport Alien Goats/Goatherders From A Community Garden
NOW INTO COURT, comes Doug Handshoe who respectfully states the following to this Honorable Court;
Handshoe alleges that alien goats and their goatherders have continually, persistently and arrogantly trampled in a community garden that he and others have worked post Katrina; all in an effort to remove insurance scam briers, political corruption weeds and other opportunistic parasites which seem to be also plaguing the entire Gulf South region.
First it was Sargent Duddley Do-Right of the Royal Canadian Mounted Police who trampled thereon trying to serve a Canadian SLAPP lawsuit, alleging hurtful feelings, on Handshoe in Wiggins, Mississippi.
Then a laughing joyful group, carrying a cheesy judgment from Canada based on sour allegations, again trampled Handshoe’s community garden but were soon run out by the Honorable District Court of Southern Mississippi. However,they ran still spitting and chewing the paper in their mouths straight to the Honorable U.S. Fifth to try to milk buckets of tears from those overworked honorable eyes on Camp Street.
Most recently, a local goatherder related in business to the original goatherders trampled still again and additionally inviting others to join him in attempting to trample,crush and even eat emerging seedlings of parody, hyperbole and many shoots of truth and justice.
Handshoe respectfully prays that after due process all alien, unwelcomed goats/goatherders be physically restrained,removed and deported allowing peace be to be rightfully restored to his purposeful,community garden.
There will be a hearing on The Special Motion concerning the goats’ “briefs” on April 10th and the goatherders will have their goat diapers or panties on:
http://www.nannygoatsinpanties.com/2011/01/goat-thing-of-the-day-nanny-goats-in-diapers.html
We have the following minute entry hot off the PACER press:
FYI and for the bailiffs of the U.S.Eastern District Court of Louisiana on checking proper diaper application to goats courtesy of Claire, a shepardess out of Nova Scotia no less:
http://chooksiniowa.blogspot.com/2011/01/diapers-for-goat-kids-and-lambs.html
There’s even an illustrative and “ingredient” section for OnASteed aiding proper diaper/panty application for his “trusted” steed. Although OnASteed could be in Florida at that time resting comfortably, defending his “castle” with his “lance”(i.e. his words), gazing into ” Merlin’s crystal ball” and possibly a little “leery” of potential “dragon slayers” still lurking about.
Have you guys forgotten the DMR fiasco? Will Joe Zeigler and his brother-in-law get away scott free? Is anyone paying attention to that bunch? Who approved Baby Walker’s bulkhead on the property sold to the DMR? Come on fellas….you’ve done a great job on the NOLA group….get on top of the DMR crooks for a while and give the goatherders a short rest???
Charlene: We haven’t forgotten you Silkwooder, but Doug and da’ goatherders are joined at the hip in a hellish union via a few cheesy coital suits until death do they part.
That said, Doug did what you asked and done ” get on top” of the coastal crooks and got a few,big time pelvic thrusts in today observable in graphic X-rated detail from DMR’s secret,toy helicopter.
Read this recent Sun Herald story.
DMR required no formal bids for $5.8 million in work on reefs
24,215 pages of DMR records posted by the Sun Herald to review, Feel Bryant naming the new DMR director tomorrow, and then there is that D’Iberville Ocean Expo MDEQ take back.
It’s the time of year when the weather forecast sometimes is for stormy weather.
Doug:
Please tell me if I have this right (I’m not an attorney):
Daniel Abel filed his original lawsuit against you and AMV(B)in the Eastern District of Louisiana saying that the federal court had jurisdiction over the case because AMV(B) and you resided in a state other than Louisiana. Able has since filed an amended complaint in this suit which also says that the Eastern District has jurisdiction over the case for the same reasons.
To your knowledge, Abel has never filed suit against you in any Louisiana state court.
Now, Abel is asking the federal court to “remand” his case to some nebulus state court where he has never filed a suit? Is that procedurally possible? Is this forum shopping? Is the current case moving along too quickly for Abel and his supporters?
If remand is denied, do you think he may try to voluntarily dismiss this matter within minutes after filing a state court petition in the CDC?
In my personal, non-attorney opinion, Abel’s opposition to AMV(B)’s motion to dismiss is deja vu of his pattern and practice in other lawsuits I’ve looked into. It’s confusing, disjointed, irrelevant in many places, cut/paste, shotgun approach, thrown against the kitchen wall, all over the place conclusions and self-serving allegations.
I didn’t know he was a linguist-blog-comment-deciphering expert? Some of the language in his pleading makes me feel he is representing to the court that he can identify AMV(B) as whitmergate and others who comment on Slabbed by using what sounds a lot like something done by the guy used by Heebe to out Perricone via his writing styles.
Oh. He also “demands” discovery in connection with your motion to strike. I would hate for you to have to go through that cost and delay, but if the court does grant discovery, maybe Concrete Busters will ask to participate in some of the depositions, etc. since Able includes allegations about them in this suit.
Exactly NAAS. Even better though is Abel contacted Special Agent Cataldi at NOLA FBI. She tells me they had a brief conversation, a few days after which she was sent a memorandum prepared by Abel of the conversation that bears no relationship to their actual discussion. I imagine Abel’s memo will surface someplace like Canada if I had to guess.
That hole these Goatherders have dug for themselves is impressive.
I remember reading something in 1 of his pleadings about how the FBI or something the FBI said actually supported his claims in some way.
Would the FBI publicly confirm or deny their conversation with Abel? Was there any written response by the FBI to Abel’s memorandum?
I’m not a lawyer, so forgive my layman’s questions. If his comments or “claims” about the FBI are in response to AMV(B)’s motion to dismiss, can she do some discovery for the document since he is saying the FBI supports his side of things?
If he has lied about this FBI conversation in a pleading to the court, isn’t that a serious no no?
Anybody whose mantra is “tort reform” should be following this case.
Well, on second thought, Concrete Busters may not be helpful after all. I wonder if any kind of written settlement agreement exists between Concrete Busters, Smith & Fawer, Abel, etc.?
NotAtAll –
more technically correct would be to dismiss without prejudice to allow filing in state court. But then there’s the jurisdictional and venue issues – and a SJ on the SLAPP law.
Just have to wonder out loud if there’s the jurisdictional threshold present for diversity. Doug, that’s your queue line for the canned laughter.
And, looks like I can make it there on April 10, just a few blocks away. Trusting J. Morgan doesn’t recall me quickly on other matters.
I do not think anything will be happening on the 10th. Looks like May 15th is the day at this point.
Doug – (laughing out loud) – does this klown actually believe he has gotten the $75k threshold?
http://www.youtube.com/watch?v=otdHbA4GlSI
Empire: Here’s Shemp’s thres”hole” for his brain fart caught on fire:
http://www.youtube.com/watch?v=BLWIzZjc9_4
Just attempted to read the 55-page piece of cut/paste, nonsensical crap filed by Abel in alleged response to the court’s order.
On page 47 of said piece of crap:
“Regarding 37 & 38, as an attorney, Abel cannot ethically
It appears to be raining Kamikaze Goats. 😉
Set the alarms for May 15th.
NAAS:You gotta’ be legally sheeting me !! FIFTY-FIVE ?, FIFTY-FIVE ?, did you say FIFTY-FIVE pages with an inability to “satisfy the moment”?
http://youtu.be/HoxRFOr_sQ0
The Honorable Court should sanction him by the page then turn his Kamikaze goat,paper eating butt over to the Interior Department to be paper- boarded( legal paper stuffed in mouth until breathless).
Unlike Haspel’s ultra-lite legal “briefs” these Fruit of the Loom “briefs” are heavy,baggy, can hold a lot of legal crap thereby cutting off sunshine and fresh air to the real “pricky” issues.
Meantime over at the 5th Circuit…..
http://www.youtube.com/watch?v=ls2lC7DQFMI
Same song, second verse. I fucking hate whiny bitches!
Interesting he should cite that part of the ethics code. It brings back to mind a question I asked him here on Slabbed a few months ago:
Daniel G. Abel: have you self-reported to the ODC the 12/21/12 decision of the US 5th Circuit in the Martin/Fidelity matter?
Correction: Misspell- “Pricky” issues in my above post should have read “prickly” issues. As in “prickly” heat which occurs when a crying babe doesn’t get their Fruit of the Loom,full of piss dribbles and crap, changed and in an Honorable Zone are exceeding the limit of SPB(sh*ts per brief.)
For “prickly” heat it is imperative to get the ” whining” babe to stop crying and then an abundance of Sanction Powder applied to its irritated,dwarf sized genitalia with every new “brief”.
NAAS: Seriously, isn’t there a Rule for page limits in a certain size font for briefs in U.S. District Court and has a motion to exceed same been filed? Where is the “brief” police ?
He filed a motion for leave to exceed the page limit. He should have filed a motion to exceed the bullshit limit.