Académique Documents
Professionnel Documents
Culture Documents
Plaintiffs
}
v. ) C IVIL ACT ION
3 FILE NO.: 1 :06-CV-00247-WSD
WACHUVIA BANK, NATIONAL }
ASSOCITAION, et al )
WACHOVIA SECU RITIES }
Defendants }
. . . . .?
which the Plaintiffs received a letter, two days afterward, Plaintiffs received
LR 16-2.
Case 1:06-cv-00247-WSD Document 18 Filed 04/04/2006 Page 2 of 15
1. Description of Case:
slander.
account with Mike Peoples at then First Union Bank, the Wesley
names .
2
Case 1:06-cv-00247-WSD Document 18 Filed 04/04/2006 Page 3 of 15
accounts even though the address the accounts were sent to since May
1997 was different than the address of Ms . Caffrey who still had a
Plaintiff s statements to the guardian, denying all access and info to the
the accounts were not frozen late June . Mr. Appel3uly 01, 2002 sent a
letter to Cindy Wall, Regional Manager, to insure and verify that the
Joyner, Mr. Lillig III agreed the accounts had belongedd to Mr . Stegeman and
(1) Pending Related Cases : There are none in The United States
Federal District Courts . The "Order" signed by Judge Hunter 02/22/2006 has
which Mr. Joyner v Mr. Stegeman 0209732-5 , settled out of Court which
4
Case 1:06-cv-00247-WSD Document 18 Filed 04/04/2006 Page 5 of 15
2 . This case is complex because it posses one (1) or more of the features
3. Counsel.
Plaintiffs: Pro Se
William J . Honey, II
Jodi Emmert Zysek
1500 Marquis Two Tower
5
Case 1:06-cv-00247-WSD Document 18 Filed 04/04/2006 Page 6 of 15
4. Jurisdiction:
there are multiple claims the Plaintiffs will identify and discuss separately the
(a) The following persons are necessary parties who have not been joined:
Wachovia Securities .
(c) The names of the following parties are either inaccurately stated or
(d) The parties have a continuing duty to inform the court of any
6
Case 1:06-cv-00247-WSD Document 18 Filed 04/04/2006 Page 7 of 15
Plaintiffs have failed to state a claim upon which relief can be granted .
Wachovia claims that is the reason for not answering the cqmplaint. The
Plaintiffs did state legally co izable claims . The Plaintiffs realize this is
Wachovia would have taken the time to read the complaint, the would
realize that the issues are clearly stated . Wachovia's numerous code
violations shows the malice and contempt for which fraud breach of
contract breach of du are necessary o have a claim for which relief can
7
Case 1:06-cv-00247-WSD Document 18 Filed 04/04/2006 Page 8 of 15
THIRTY (30) DAYS after the Joint Preliminary Report and Discovery
Plan is filed, or should have been filed, will not be accepted for filing,
All motions should be filed as soon as possible . The local rules set
specific filing limits for some motions . These times are restated below .
All other motions must be filed WITHIN THIRTY (30) DAYS after the
(b) Summary Judgment Motions : within twenty (20) days after the close
(c) Other Limited Motions.- Refer to Local Rules 7.2A; 7.2B, and 7.2E,
to expert testimony no later than the date that the proposed pretrial order is
8
Case 1:06-cv-00247-WSD Document 18 Filed 04/04/2006 Page 9 of 15
Fed.R.Civ .P.26. If any party object that initial disclosures are not
appropriate, state the party and basis for the party's objection .
Does any party request a scheduling conference with the court? If so,
please state the issues which could be addressed and the position of each
party-
The discovery period normally commences thirty (30) days after the
Cases in this Court are assigned to one of the following three (3)
discovery tracks : (a) zero (0)-months discovery period, (b) four (4)-
9
Case 1:06-cv-00247-WSD Document 18 Filed 04/04/2006 Page 10 of 15
.
Attorney Legal authority r documents disputing s . McDonald's
ownershi . The accounts titled Jean S . Caffre and James B . Ste eman
James B . Ste eman Joint Tenants With Rights of Survivorship . Who gave
forged acquisition documents where the came from . Where old Power
10
Case 1:06-cv-00247-WSD Document 18 Filed 04/04/2006 Page 11 of 15
pertaining to Mr. Jo ner and his Social Securi number as sole owner o f
like to reserve the option to add discovery aterial to include if and when
Wachovia answers.
under the Federal Rules of Procedure or Local Rules of this Court, and
first defendant b answer to the com Taint Wachovia Bank has re nested
that the discovery period not commence until ten 10 days after the Court
has ruled on Wachovia Bank's Motion to Dismiss the Complaint and The
Court has made an Order on Wachovia's r nest . The Plaintiffs have filed
The Plaintiffs have repeatedly brought this to the attention of the Courts
11
Case 1:06-cv-00247-WSD Document 18 Filed 04/04/2006 Page 12 of 15
asking that all Motions, etc be stopped until the Appeal has been decided .
Wachovia has suggested that the Appeal is not real, the Plaintiffs recently
supreme Court has been changed to The Court of Appeals . The fee
associated with such having been paid and Notice to This Court has been
filed. The Plaintiffs request that no other actions, motions, pet itions,
discovery, etc be had, filed, or decided until such time the Georgia Court
What other orders do the parties think that the Court should enter under
defendants .
settlement of this case: Prior to The Plaintiffs filing the complaint, the
12
Case 1:06-cv-00247-WSD Document 18 Filed 04/04/2006 Page 13 of 15
26(f) conference . The defendants are misleadin g This Court, March Ob,
meeting that went ignored . March 09, 20Q6 the Plaintiffs received
staring
g that the Plaintiffs refused to the conference . Wachovia
(b) The Plaintiffs do not consent to having this case tried before a
13
Case 1:06-cv-00247-WSD Document 18 Filed 04/04/2006 Page 14 of 15
Respectfully
821 Sheppard Rd
Stone Mountain, GA 30083
(770) 879-8737
Report and Discovery Plan are true and correct to belief and knowledge
of the Plaintiffs .
Subscribed to and,Sworn
Before me this -day
3
Of April, 2006 .
Notary Publ i c
My Commission Exp '
14
Case 1:06-cv-00247-WSD Document 18 Filed 04/04/2006 Page 15 of 15
CERTIFiCA,TE OF SERVICE
I hereby certify that this 3dday of April, 200 served a true and copy
of the foregoing PLAINTIFF'S PRELIMINARY REPORT AND
DISCOVERY PLAN upon the defendants in this matter by causing to be
deposited, in the U .S. Mail proper postage paid to thee defendants through
each attorney separately as listed on file as follows :
PARKER, HUDSON, RAINER, DOBBS, LLP
William J . Holley, 11
Jodi Emmert Zysek
1500 Marquis Two Tower
285 Peachtree Center Avenue, N.E.
Atlanta, GA 34303
821 Sheppard Rd
Stone Mountain, GA 30083
(770) 879-8737
Subscribed to aQwworn
Before me this 3 • clay
Of April, 2006 .
?" 110
My C ommission Expires : pob1c ' ~~ ~
J
l
fir. .n „w