Attorney Rose [Toyota U.S.A. Albany Attorney] was just roused from a long winter's nap!
Since there is no simple recap for the KING OF CONFLICT and POSTPONEMENT,
this Dilly, Dally, Delay, Stall & Bill 'Em Attorney deserves a truly SPECIAL AWARD!
This Dilly, Dally, Delay, Stall & Bill 'Em King slumbers for months, days.....then is aroused, not pleasantly.
This is complicated legalese simplified:
Lemon Lady's Attorney requested Toyota U.S.A. to produce a witness to be deposed that met 20 qualifications.
Dilly, Dally, Delay, Stall & Bill 'Em King killed some more trees, submitted letter indicating 16 qualifications, SPECIFIED 5 DAYS TO OBJECT.
Lemon Lady's Attorney IMMEDIATELY OBJECTED, threatened court action to resolve.....we all know how anxious the Dilly, Dally, Delay, Stall & Bill 'Em King is to travel from Albany, NY for court appearances......
....to which the Dilly, Dally, Delay, Stall & Bill 'Em King insisted his DEEP POCKETED client wanted a TELEPHONE CONFERENCE!
In good faith, Lemon Lady's Attorney suggested dates, times.
Dilly, Dally, Delay, Stall & Bill 'Em King had CONFLICTS! Made one commitment he was forced to cancel the day before.
The Dilly, Dally, Delay, Stall & Bill 'Em King emailed:
THURSDAY OR FRIDAY
Then he ignored the Lemon Lady's Attorney's response........
THURSDAY AND FRIDAY come and go!
The Lemon Lady's Attorney circulated this in anticipation of a September 17th Pre-Trial:
Attached please find initial draft Pre-Trial Memorandum with Plaintiff’s Response to all items. I will accept Attorney Vieira’s in-court offer to coordinate all responses and signatures and to return an original to me so I can file it with the court pursuant to the Pre-trial Order.
The Dilly, Dally, Delay, Stall & Bill 'Em King who has unforeseen conflicts, snoozes for months on end, awakened:
I see no realistic way to do a consolidated pre-trial in light of the fact that we have not yet had depositions or a vehicle inspection***. Am I missing something here ?
There is a pretrial scheduled for September 17. Unless the parties intend on having the significant depositions completed by that time, then it would seem that pretrial date appears to be premature. I would agree that exchanging a pretrial memo without a meaningful list of expected witness is really useless for trial preparation. For me, I can easily complete my clients section of the document.
Daniel J. Vieira
*****After slumbering for months, the Dilly, Dally, Delay, Stall & Bill 'Em King woke up in March 2013, sent his lackey to court [who arrived LATE, chased other attorneys across the parking lot], forced the judge to return from elsewhere, insisting upon a 4 month DELAY.
The EXCUSE was that the LEMON LADY hadn't returned the INTERROGATORIES and DISCOVERY ONLY submitted the previous week.
In March, the Toyota U.S.A. lackey offered a rigid list of items:
First, INTERROGATORIES & DISCOVERY, then DEPOSITIONS for which the DILLY, DALLY, DELAY, STALL & BILL 'EM KING seems to have inordinate CONFLICTS, including the one he refused to disclose.
THEN, the BRAND NEW LEMON INSPECTION!
NOTE: NHTSA conducted an INSPECTION for which Toyota U.S.A. sent a GAGGLE of folks from California to freeze their butts in New England. [The DILLY, DALLY, DELAY, STALL & BILL 'EM KING was present, but might have forgotten as Part 2 explains.]
They RETRIEVED the COMPUTER CODES, participated in the INSPECTION on the premises of ROUTE 44 TOYOTA, filmed the FOLLY.
[The GAGGLE was sent the day before, remained the day of the INSPECTION, returned to California the following day. Even with discounted accommodations, the GAGGLE spent more than the value of the BRAND NEW LEMON TOYOTA.]
Toyota PTC [Pre-Trial Conference]
A Massachusetts woman....
2010 NHTSA Toyota Prius Complaints & SUA
Toyota: This Gets Betterer and Betterer! #3
Remember: This is only about a BRAND NEW LEMON TOYOTA and the ILLEGAL BUSINESS PRACTICES of ROUTE 44 TOYOTA.