The world is a scary place right now, so I decided to entertain myself. Remember this chucklehead? It has been three weeks since I sent that email. They have not responded. Maybe it’s because they are on vacation due to the holidays. I got an autoresponder saying they are out of the office until January 11. Good, everyone deserves some time off, even chuckhead lawyers.
But as I had not heard anything, and I have repeatedly asked for documents from them, I followed up today.
I hope you have at least a quarter of the fun reading this as I did writing it. Their office got CCd so they understand how I do.
And, opposing counsel, if you’re reading this: “Hi! I hope you enjoy your vacation and that it is someplace warm and delightful and full of tasty adult beverages. It is cold and miserable here in Philadelphia and the world is on fire“.
Greetings Mr [Tough Guy, Esq.], and Happy New Year.
I have not yet received the notice under the [redacted law] that your client is required to provide to my client regarding [redacted facts]. In fact, despite my requests, you have not indicated whether it even exists. If you do not respond to me indicating one way or another by the end of this week, I will take that as an admission that it does not exist. I understand that I am not a judge and do not get to set your responsive deadlines for court matters—however, as this is not a court deadline, I may draw conclusions from your behavior. Consider this an informal RFA. Without hearing from you, I will deem as admitted that you do not have it.
Regarding your curious venture into Common Pleas Court, I understand that you may have perfected service on my client’s mailing address recently via certified mail. Please confirm this is the case, and I will enter my appearance. Note that [client redacted] is not at this address currently, but I did receive word from his parents that they received a certified letter (Footnote: Your complaint also does not include a copy of the required notice. See, id. I was on Law Review. It taught me all of these neat citation tricks).
Hey, did you know I am a dungeon master? As I see it, you’re trying to play this game as a Human Barbarian (I am not sure of your alignment yet, but I would guess lawful evil, at this point, based on your behavior).
This is silly, and your “my clients are aggressive look at me I am so tough hahaha surprise lawsuit after you extended me a courtesy and did not require my appearance at an afternoon hearing on 12/23” tactic will not work on me.
In creating your character, you ought to have considered putting more of your stat points into Wisdom and Intelligence, rather than Strength.
When I litigate, I take on the spirit of a lawful evil Tiefling Warlock, and my patron is Óðinn (I told you a bit about him before), the chief god of the Norse, associated with wisdom, healing, death, royalty, the gallows, knowledge, war, battle, victory, sorcery, poetry, frenzy, and the runic alphabet. I think you understand my point. I was a fat theater/orchestra/academic team nerd as a kid, and was picked on mercilessly, and I have a lot of unresolved nerd rage for attorneys who act like you. I also work for myself and can dedicate endless hours to this case, if I feel like it. That’s the beauty of self-employment.
If you are more into Harry Potter than D&D, I’d say you’re a tough guy Hufflepuff. I am Slytheryn. My wand is elm, with a unicorn hair core, and unyielding flexibility, My patronus is a Thestral. I am not joking. Take this for what it is worth to you.
Also you are famous: https://phillylawblog.wordpress.com/2020/12/15/a-norse-take-on-randazzas-litigation-philosophy/. You can expect more of this from me in the future if you continue to be a chucklehead tough guy instead of a big-boy attorney who acts like a professional, as attorneys are supposed to be (in case you don’t know anything about my friend and mentor Marco [sic] Randazza, you can read more about him here: https://randazza.com/marc-j-randazza/).
In closing, you could have been nice, courteous, and professional to me, and I would have extended the same courtesies. Instead, you chose to be a jerk. Cool.
Well, as the unofficial Philadelphia motto goes, “fuck around and find out”. You fucked around.
(I am very professional).
Best for 2021,