Aspect 7.0 Discovery Before Trial and Trial

Aspect 7.0 Discovery Before Trial and Trial

The seventh part of the attack plan involves discovery in the context of the HEARING as well as before the trial, both before the same Judge, and hopefully done within one year. Upon the opposition to the initial filing, notices of deposition of officers and DEFENDANT EXPERTs should be filed in advance of the HEARING to be available at the HEARING as names are divulged. Those discovery notices can be prepared in advance with blank lines for real names when DEFENDANT EXPERT names are learned and officer and managers names are learned in opposition. This discovery by PLAINTIFFs would be expedited. This expedited discovery served as misdirections as well as setting up JPM. The expedited discovery will serve to keep the DEFENDANT COUNSEL distracted and misdirected. These expedited discover depositions will be scheduled before the HEARING, with an eye looking towards use at the hearing and any possible trial. The goal to precisely focus TEAM discovery of DEFENDANTS with rapid TEAM notices for discovery of vital points and facts only where it really matters and always done so in a cost effectively manner.

The DEFENDANT EXPERTs and key managers depositions with duces tecum should serve many purposes, one of which purpose is to humiliate the DEFENDANT EXPERTs, absolutely so, and, secondly to discover the name of key managers, for possible weak minded JPM traitors, of whom, for further depositions along with duces tecum for impeachment use at the HEARING. The expedited discovery by the TEAM will be launched at time of filing the complaint and at the time of opposition service for further misdirection of the DEFENDANT. After the hearing, if not settled quickly addition discovery will be had, but the case in chief should be by then well defined for rapid advance to trial. 

DEFENDANT COUNSEL will be inundated because of the discovery and filings served by PLAINTIFF and because of the legal norm of client seen coming and self serving ethical rules is to get really involved with each, thereby lessening the focus at the hearing in general, thereby causing JPM much expense while the TEAM misdirects the DEFENDANT COUNSEL. The key line of defense is simply to not robustly respond as expected to their production requests as largely typical unnecessary legal expense. The complaint and moving papers will set the stage for the trial, if trial ever reached, where damages are alleged in the complaint, but the case is really about enjoining JPM and not the dollar damages that should come during settlement. 

The discovery responses by the TEAM will be minimal, and thus placing reduced burdens on the PLAINTIFF COUNSEL, yet, the DEFENDANT COUNSEL must stand ready and are inclined to fully engage. Hear, the typical delay tactics are expected and will be pointed out to the Judge as the typical lawyer evasiveness, with light suggestions, so that the Judge can put two and two together, and thus, the PLAINTIFF will always plaint the DEFENDANT as not only the evil, but evading the truth, by using conventional lawyer tactics. The misdirection used is to play upon DEFENDANT COUNSEL inherent conventional tendencies to paint DEFENDANT COUNSEL as evasive and the DEFENDANT as evil and immoral. 

The goal is also to keep TEAM responses and production to a minimal. The robust complaint, and motions and discovery sought will help protect PLAINTIFFs from unnecessary burdens. Thus, up front consideration must be thought out to prefect DEFENDANT pleading hard ships in court for any relief which should be difficult for JPM having 1T$ capitalization. 

During the preparation phase, all PLAINTIFFs should assemble boxed production of only highly relevant materials, and it is better that such materials be placed under the care of a corporate document manager. TFMR and LMPC are two PLAITIFF service providers that should segregate personal documents and business documents. The business documents should be sent corporate managers and these documents should show correlation between price suppression and membership rolls for showing irreparable hard. Retailers and Wholesalers are large and should have a document manager for responding to production requests. This is about JPM not the PLAINTIFF, and thus the discovery should be more of PLAINTIFF discovery of JPM and not JPM discovery of PLAINTIFFs. Thus, the TEAM production should be made by corporate production managers through simple compliance.  The only expense after the complaint is filed, is the moving of some boxes to DEFENDANT rented copying space, where the DEFENDANT COUNSEL will probably have photocopy machines and much staff expecting the typical production load, but DEFENDANT should not get much, as the discover even by them will be a misdirection. PLAINTIFFs and EXPERTs are generally protected by Work Product and need not deliver documents, though support materials can be relevant, but only then offices opened up to one day inspection, if that. EXPERT production should be simple and will relieve the TEAM while DEFENDANT COUNSEL are distracted preparing at great expense for production that never comes in mass as they would normally expect. 

The TEAM and PLAINTIFF COUNSEL wont even look at PLAINTIFF produced documents as no screening of them will be had as they all are generally covered by a protective order in place filed when filing the initial filing. The moving paper will be against the DEFENDANTs conduct. PLAINTIFFs conduct will not largely irrelevant to the motions and hence discovery of PLAINTIFFs will be minimal.

The TEAM responsive discovery is kept to a minimum with low logistics, while the DEFENDANT COUNSEL stumbles about with copying machines and staff setting up for reviewing massive documents that will not be produced. PLAINTIFF COUNSEL hides behind Work Product, Speculative Damages, and Irreparable harm in the moving papers to minimize production. PLAINTIFF persons and corporation can produce a few documents showing possession of some AGE ASE coins on hand. PLAINTIFF service provider can produce attendance records over the time period 2009 through 2013, perhaps reasonably for example in months, boxed during preparation. 

PLAINTIFF EXPERTs may get deposed after the motion. REID shall interview PLAINTIFF EXPERTS in advance and early in the preparation phase before the complaint to define the system scope of DEFEDANT business and to get all the PLAINTIFF EXPERTs on the same page respecting the same, so as to defend any depositions of the PLAINTIFF EXPERTs may not ever occur but would before any trial. The preparation will be well done by REID, with focused discovery in a total one sided fashion, to the TEAM advantage, while wasting and misdirecting the resources of DEFENDANT and DEFENDANT COUNSEL and while humiliating the DEFENDANT EXPERTs, in depositions and on the stand. The totality is the planed set up of the DEFENDANT, for exposing its nefarious business plans, and crimes and immoral conduct.

The trial expectantly should never be reached, and the case would be largely developed by the time of the hearing, and thus PLAINTIFFs could move quickly to trial as added pressure upon the DEFENDANT who should have settled the case after the hearing long before any trial. The TEAM will be ready for and press for a quick trial if the injunction hearing fails. With minimal extra expense for TRIAL as a duplicate of the hearing, and the case would have been developed by the time of the hearing and effectively ready for trial. The TEAM would go into any trial fully ready as mostly a repeat of the hearing. Cost effective resolution of cases does not serve most greedy attorneys generally in our society, but here, such cost effectiveness favors this rapid dispute resolution. 

The TEAM will do the legal flip of the traditional attorney roles, with cost effectiveness pursuit of rapid resolution of the dispute by an injunction hearing shortly after filing the complaint. This is because of REID past history and success use of the legal flip with a 100% plaintiff success rate and 98% prosecution success rate, with low fees and rapid resolution, during the legal flip. 

Aspect 7.1 Plaintiff Communication Hubs

There will be three Communications Hubs. The first communications hub is the primary communications hub located at HQ with REID ever present there. The secondary communications hubs are at Chicago Law Firm where are the PRIMARY SECONDARY TERTIARY COUNSEL and the District Law Firm whereat is the PROXIMAL COUNSEL. The third communications HUBS are at TFMR and LMPC through on line servers accessed the DISSTAL COUNSEL. MURPHY and FERGUSON are bullion service providers with respective tertiary communication hubs to be used by DISTAL COUNSEL for finding need judicial notice URL video and document exhibits.

The primary communications HUB provides central communications to the remaining HUBS, Broadcasters, commentators, PLAINTIFF COUNSEL and PLAINTIFF EXPERTs. All three hubs can provide relay communications both internally and externally as desired. 

Aspect 7.2 US Justice Counsel Will Be Court Amici

The court record created will be a silver platter to US Justice. US Government attorneys are welcomed by the TEAM to monitor the case at any time, as much education of the bullion world will be had while they acquire an understanding of exactly how the DEFENDENTS uses the statue trading laws and trading compliance to commit the manipulations and crimes. 

Aspect 7.3 Plaintiffs Experts Consultants Commentators

There are many Gold Notables. PLAINTIFFs include service providers, retailers and wholesalers. Service providers provide URL cites with members who can regularly post comments as a private club of members. The two preferred service providers are TFMetalsreport and LemetropoleCafe. PLAINTIFFs preferably number six and have been identified in the dream team. Other unknown service providers can be listed as possible plaintiffs. Two retailers have been identified in the dream team. Other retailers can be listed possible plaintiffs. Two wholesalers have been identified in the dream team. Other wholesalers can be listed possible plaintiffs. 

There are nine listed PRIMARY SECONDARY TERTIARY EXPERTS. Other standby experts can be listed, and be used as replacement or supporting experts. Others in the field can be listed as consultants to the case and commentators to the case. These possible plaintiffs,  standby experts, consultants and commentators generally have specific expertise within the bullion field. Possible Plaintiffs and Standby Experts may be interviewed with supporting declarations prepared as supporting members of the TEAM and act as replacements or added TEAM members to add weight to the cause. Consultants are behind the scene supporting REID, out of the lime light, and their names and roles kept confidential, but can be used to provide input to support the case. Commentator will be in the lime light, but their roles kept confidential. 

List of Supporting TEAM members
Plaintiffs, named complainers of Record
Possible Plaintiffs, replacement Plaintiffs and Experts
Experts, named experts of Record
Standby Experts, replacement Experts and Supporting Experts
Consultants, Confidential Experts for Case Supports
Commentators, Confidential Experts for the Broadcasting
Plaintiffs, Counsel, and Experts share in any settlement 
only when officially made of record in the case.

Plaintiffs and Experts can be added, with individual shares prorated, and would be provided a reasonable rate and reimbursed for all expenses. Counsel would be provided a reasonable rate of pay plus expenses with a possible retainer as is customary.