File an APPEAL
One of the Directors claimed that the corporation NEVER received the Motion for Summary Judgment (MSJ) because neither the corporation nor the partnership had EVER used one of the addresses we sent it to and that the President/Director was "confused" about the need to respond to our Second Request for Admissions because of his bankruptcy and the fact that the corporation lost its charter for failure to pay franchise taxes and supposedly wasn't operating.
We PROVED the corporation DID receive it---the President/Director SIGNED the Return Receipt for it---then CHOSE to do NOTHING! And we found out that the lawyer/Director PAID for the corporation to file bankruptcy---using the VERY SAME ADDRESS they claimed the corporation NEVER used!!!
We PROVED that his bankruptcy status had ZERO effect on "confusing" him because neither he nor the defunct corporation were even IN bankruptcy at the time. His 2001 BR had been THROWN OUT for "Unreasonable Delay" for never filing anything except the initial B1 form and his 2004 ($6,600/mo to $30,000/mo) bankruptcy had not even started yet. BTW, we later found in his SWORN brankruptcy filings last August that he had made $300,000 in 2001 before claiming he was bankrupt on 12/28/2001.
They also SWORE they were NEVER on the radio promoting anything as we claimed. But, oops! I had TAPED THE BROADCAST---with THEIR VOICES ON IT!!! Every time they know I have the legal equivalent of "Monica's Blue Dress," THEY CHANGE THEIR STORY!!!
My version of the FACTS, on the other hand, has NOT changed even once during the entire 3-1/2 YEARS and they have not been able to prove ANYTHING that I have said is a lie---because it ISN'T!!!