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THE 2016 LETTER TO NM&F LAWYER

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The August 2016, 101 Page Letter I sent Certified Mail to Attorney Sarah Manning of Nutter McClennen & Fish, who authored the false Summary Judgment Memo signed February 1, 2011 by Attorney Manning. This document was filed on 6/14/11 (Docket Entry #18). The SAME day CCT admitted in CCT SOF #52 CCT had 2002 Bundles.

I probably spent the better part of a year putting this document together, then gathering the courage to send. I was in the middle of the NY trial, 10 trips in 2015, not counting Dana, or Brigham & Woman’s. But I wanted to legally place this lawyer on notice of the specific false statement she made in that document, as well as the more recent (2014) statements I can attribute to affidavits made by successor Counsel, Holland & Knight. This document was subject to Mass 56, the lawyer had to KNOW her facts, because a judge was going to believe them.

Manning won SJ in Barnstable by vouching for evidence proving CCT innocently thought up Bundles on Jan 9, 2003, 70 days after the p&s, so cannot be guilty of hiding them in 2002.
Yet Attorney Mitchell of Holland & Knight told the appeals court that “
Bundles were fully disclosed during 2002 negotiations”. The affidavits in the case for this lawyers are damning.

I have invested thousands of hours into this matter, not for profit, not because I was right, but because I was right and I knew I had proven it with their words and documents. Not close. I had created hour long videos, detailing every aspect of the crime, and of the obvious cover up. Everyday since the 2002 fraud then 2007 litigation, that I wasn't in a hospital, I worked on this.

The August 2016 Letter. Instead of correcting her affidavits, or those of successor counsel, as required by law, she had 2 Yarmouth Police cars come to my home.
*You can view this document out of the frame in new window Here.

Not willing to give up, I also didnt want any claimed statute of limitations to pass, and I knew Manning had a duty to the Court and the Bar, to give notice and or correct any false statement she or any other counsel had made to the courts.

As it stands, the conspiracy by client & counsel together to deceive the courts is something from which neither of them can hide. The duty to correct the statements continues.

And as I noted to Attorney Manning in the letter below:  ‘a decision produced by fraud on the court is not in essence a decision at all and never becomes final.’ Id. (quoting 11 Wright and Miller, federal Practice and Procedure § 2870 at 409 (1995)) (quoting Kenner v. Commissioner of Internal Revenue, 387 F.2d 689, 691 (7th Cir.1968)).

And as I also pointed out to Attorney Manning, the Appeals Court Judge who also ruled based on Your false statements that: “the agreement was executed, CCTimes began to sell internet advertising in a bundle with print advertising.”. But we know, Manning knows, Attorney Mitchell knows, That Is NOT and more true than when Barnstable found it to be fact.

THIS judge ruled in (Mt Ivy V Defonseca), that pro se litigants can commit fraud on the court, and should face consequences. So when she learns of the lies of these two firms! A 2nd Judge of the Three member Appeal Panel also heard the MT. Ivy case.

2 Rulings by 4 Judges state CCT’s Bundles came after the 2002 p&s, In January 2003.
But the record is replete with admissions and documents proving the 2002 Scheme.

$73,000 in 2002 Bundle revenue NM&F admitted to on 6/14/11 in CCT SOF #52. CCT had to Alter financials provided in Discovery to Hide ALL of it, to claim Jan 2003!

THESE JUDGES SIMPLY TRUSTED CCT LAWYERS, WHO BRAZENLY DECEIVED THEM!

As I pointed to Counsel in this voluminous document (as shown on right panel), Appeals Court Judge, the Honorable Justice Wolohojian, has held that even pro se litigants can be found guilty of Fraud Upon The Court, not only lawyers. Vindication to me would be having Her Honor ask Both Lawyers WHY SHE found “After” The sale CCTimes began Bundling..?