One night, a promiscuous woman goes to the bar, gets drunk, and sleeps with three men. In the following months, this promiscuous woman finds out she’s pregnant. Unable to remember all of the men she slept with that night, there is one man who is most attractive and the wealthiest of the three she slept with. This wealthy and attractive man claims to be the father although he is not absolutely certain.

Meanwhile another man, poor and unattractive, who also slept with this promiscuous woman that night – has learned that she’s pregnant. He too comes foreword to claim fatherhood, although he’s not absolutely certain either.

Before the invention of forensic analysis, it was simply someone’s word against another. Now, through the use of forensics (i.e. “Discovery”) – feuding parties can accurately determine who can properly claim interest.

Honorable Judge, unfortunately this has been a very promiscuous note. It’s allegedly been conveyed, auctioned, and assigned quite a bit – without using protection set forth by state and federal rules. After being with multiple partners, this promiscuous note is pregnant with value and ready for delivery to the proper party in interest.

Honorable Judge, in this case before the court, both the wealthy man and the poor man has come forward to declare they both had a relationship with this promiscuous note. Embarrassingly, both men are now claiming “paternity”. On information and belief, the only way to determine the legitimate party in interest, is to take a detailed accounting to determine whose ‘forensics’ match – in order to properly establish which man is responsible for the “support” of the note in dispute.

Honorable Judge, unless forensic analysis is performed, it matters not who merely claims to be the party in interest. Without determining (a) when and where the note was consummated; (b) who properly endorsed the note (d) and who put up the money on its behalf, it remains virtually impossible for anyone to determine beyond any shadow of doubt, which man is the legal party in interest.

Honorable Judge, the possibility remains that the real party in interest is neither the wealthy man nor the poor man; but an unidentified third party. For this reason Your Honor, The Plaintiffs humbly request Discovery under Federal Rule 26.

Smallz

PS
Thank you Nye Lavelle.

OUTSTANDING!

smallz