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Case: Pending Nim Surname v. Vanguard National Bank (2025) CV 04

Your Honor,


The court set a 48-hour deadline for submitting witness lists, starting from Wednesday at 9:34 PM. The Plaintiff did not submit their request until Friday at 10:28 PM, which is 54 minutes past the deadline.


Given that procedural deadlines are in place to ensure fairness and efficiency, I respectfully request that their witness request be ruled invalid due to late submission.
 
Your Honor,

The timeline of this request is clearly related to concern by the Defendant on the questions provided, not the submission time of the witness list. I had unfortunate real-world concerns that prevented the posting of the witness list, which is why I apologized for what was a brief delay of less than one hour.

Under Eastern Standard Time, the defense had all of Saturday, Sunday, Monday, and Tuesday to raise this complaint, a greater than 96 hour timeframe to raise an objection. The defense was clearly present, because they signaled that they were for the witness summons. This objection is not in line with the spirit of the law, but is instead a clear attempt to avoid having to answer questions that clearly support the Plaintiff's case.

I respectfully request you rule against this objection.
 
The witness is asked to answer the questions posed by the Plaintiff.
 
Motion For Reconsideration

Your Honor,

The witness has had 72 hours from your order to respond to actually respond to the questions, and has failed to do so. The common timeframe for requiring a response in the court is 48 hours, at most. There is no precedent for an individual to be granted 96 hours of time to respond to the court without having requested an extension. I am requesting the witness be held in contempt of court.



Request to Advance Trial

Your Honor, every day that goes by is another day my client is without access to his wrongfully frozen funds. If the Defendant refuses to answer questions as a witness, then to avoid dragging this trial out any further, I would request we move past this witness. I would request, however, that the court notes the failure of the Defendant to answer the questions.



Request to Call Witnesses

Given the failure of the witness to respond, the Plaintiff needs to call additional witnesses to better establish the case, that we would have otherwise been able to use the missing witness for.

As such, I am requesting the court add Oliver Spy, Nanicholls Nanicholls, and Nopuu Catenjoyer to the witness list, and issue a summons. These individuals can testify to the facts and necessity of the damages the Plaintiff is requesting.



Amendment to the Prayer Of Relief

Your Honor, this case was filed nearly a full month ago, and the Defendant’s own delays, including waiting to challenge the witness list and then failing to respond when ordered by the court, have increased the cost of representation for my client.

As such, it is my unfortunate responsibility to amend the prayer for relief one final time, to finalize the costs my client has accumulated and will continue to accumulate the longer this trial takes.

I have provided a fully updated prayer for relief for you here:

1) A ruling that Vanguard National Bank has committed a material breach of their contractual obligations, that orders the immediate unfreezing of the Plaintiff's assets and transfer to his person.
2) Compensatory damages in the amount of $10,000, to cover the harm incurred to the Plaintiff for being unable to access his funds for a week.
3) Special damages in the amount of $25,000, to cover the attorney's fees the Plaintiff would not have incurred without the Defendant's actions.
4) Payment by the Defendant of all court fees, including witness fees, incurred by the Plaintiff.
 
The Court will reject the motion for reconsideration at this time. The witness, Nexalin, must respond to the 48-hour deadline that was specified yesterday. If he fails to do so, he will be held in contempt of court.

In addition, your request to advance the trial has been rejected. Given the large amount of money that the Plaintiff is seeking in this lawsuit, it is important that the full facts of the case are heard. If the Defendant is unable to adequately respond and engage with the Court, they are advised to hire legal counsel as soon as possible.

As for the additional witnesses, please be advised that per the Miscellaneous Changes & Foreign Affairs Omnibus Act, you (or your client) will unfortunately be required to pay any witness summoned a total sum of $250 for their initial summons. If you still wish to summon these three witnesses after the current witnesses answers the questions accordingly, the Court will allow it.
 
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