A week ago Attorney Beatman, who is trying to collect $21 million from the Goat, filed a motion to take the deposition of the Goat and also filed a motion to attach the Goat’s bank accounts. None of the Goat’s wet dream team of attorneys objected or even responded to the two motions. Attorneys Willie Dow, Willie the Ward, Davie Grudberg, the Sklarz boyz, and the token female Amanda Nugent, all took the Fifth Amendment and invoked their right to remain silent. The only sound you heard from this wet dream team of attorneys was the ka-ching sound of their cash registers cashing in coins made of goat gold.
The Goat filed a Motion for a New Trial, which Judge Shea has not yet ruled upon. The Goat may file an appeal. In the meantime, Attorney Beatman wants to start collection proceedings against the Goat, as Mirlis has a $21 million verdict, and the Goat is sleezier than his own wet dream team of attorneys. The Goat can stop Beatman’s collection activities by posting an insurance bond with the Court. An insurance bond is security in case the Goat loses his motion for new trial or loses his appeal. But no insurance company in the world would be stupid enough to back the Goat for $21 million. The Goat can file bankruptcy, which would also stop collection proceedings. The Goat already hired the Sklarz boyz, who specialize in bankrupting reprobates like the Goat.
Yesterday Judge Shea issued an order to show cause against the Goat, which is rarely done in the Federal courts. With an order to show cause Judge Shea gave the Goat’s wet dream team one last chance to respond to Beatman’s motions. The Goat and his wet dream team of limp noodle attorneys must either respond by August 21, or suffer the consequences. An attorney must do more for a client than just cash the client’s checks.
Here is a copy of Judge Shea’s full order:
ORDER TO SHOW CAUSE: Plaintiff has filed a 186 motion for order directing the clerk to issue the (ECF Nos. 174, 176) writs of execution. The 186 motion indicates that the “[j]udgment remains unsatisfied in full and the Defendants have paid nothing on the same.” (ECF No. 186 at 1.) Plaintiff has also filed a motion to take the deposition of Daniel Greer for the purpose of discovering information about his assets. (ECF No. 187). Also, pending before the Court is Defendants’ 172 motion under Rule 59 for a new trial or, in the alternative, for remittitur.
Rule 62 of the Fed. R. Civ. P. provides — absent two exceptions that are inapplicable here — an execution may issue on a judgment if more than fourteen days have elapsed since a judgment’s entry. Fed. R. Civ. P. 62(a) (“Except as stated in this rule, no execution may issue on a judgment, nor may proceedings be taken to enforce it, until 14 days have passed after its entry.”). Further, subsection (b) of Rule 62 provides that execution of the judgment may be stayed pending the resolution of a motion under Rule 59 but only “[o]n appropriate terms for the opposing party’s security.” Id. Typically, that standard “require[s] [a party] to post a bond sufficient to protect the prevailing party’s interest in the judgment.” Lawyers Title Ins. Corp. v. Singer, 2011 WL 1827268, at *1 (D. Conn. Mar. 7, 2011)(internal quotation marks and citations omitted)(citing cases). Nonetheless, a “[c]ourt may grant a stay without requiring the judgment debtor to post a bond if the judgment debtor can show that in the absence of standard security, the judgment creditor will be properly secured against the risk that the judgment debtor will be less able to satisfy the judgment after the disposition of the post-trial motions.” Id. (internal quotation marks and citations omitted)(citing cases).
In this case, more than 14 days have passed since the 163 judgment’s entry, and Defendants have not filed a motion to stay execution of the 163 judgment, posted a bond to protect plaintiff’s interest in the 163 judgment or shown that such bond is unwarranted because the Plaintiff’s interest in the judgment will be protected pending the disposition of their 172 motion. Therefore, on or before August 21, 2017, Defendants are ordered to show cause why the Court should not grant the relief prayed for in the 186 motion and in the 187 motion to take deposition of Daniel Greer.