March 2023 - Mr. Hwang's Story

IN THE CIRCUIT COURT OF TENNESSEE
FOR THE THIRTIETH JUDICIAL DISTRICT AT MEMPHIS

No. CT-2449-22
Div. V

Hwang vs. Holt

Notice of Plaintiff‘s Statement(s)

Part A.

1. Plaintiff submits these statements for the record or/and for the subsequent proceedings.

2. Comes now Plaintiff, Hwang(Pro Se), and respectfully submits this
notice of Plaintiff’s statements.

3. Plaintiff alleges or/and states the following in terms of the hearing which
occurred on March 24, 2023 in the courtroom of Division V of the Honorable
Court.

4. Plaintiff prays that this Honorable Court award such other relief, at law or in equity, as to which Plaintiff may be justly entitled or the Court may find
appropriate/just/proper.

5. Plaintiff was not surprised at the process, sequences, or/and outcomes during the legal proceeding which was presided over by the Honorable Judge Rhynette N. Hurd.

6. Plaintiff already predicted such kinds of a series of the process, sequences, or/and outcomes during the session of hearing.

7. However, there was a incident which really surprised the above named
Plaintiff.

8. Three(3) Motions were at the issues during the time of session. They were
the motion to recuse the judge, the oral motion to retain an attorney(counsel), and/or the motion for involuntary dismissal.

9. After the involved parties talked about the two motions(the motion to recuse the judge, the oral motion to retain an attorney(counsel), Plaintiff was beginning or/and was trying to mention/make his legal argument(s) about/on the third motion(the motion for involuntary dismissal).

10. As soon as Plaintiff began to mention ‘Local Rule(s)‘, especially Rule
Five(5) and Rule Six(6), he was being and/or was disrupted by the Honorable Judge Rhynette N. Hurd.

11. Rule Five(5) is about NON-DISPOSITIVE MOTIONS, and Rule Six(6) is
about DISPOSITIVE MOTIONS. Especially Rule Six(6) is conjunctly, jointly,
or/and directly, interconnected or related with the motion for involuntary
dismissal.

12. The motion for involuntary dismissal is a DISPOSITIVE MOTION.

13. Regrettably, Plaintiff got the impression, or/and could not and cannot exclude his reasonable suspicion(s) that the Honorable Judge Rhynette N. Hurd disrupted Plaintiff’s legal argument(s) ON PURPOSE and/or INTENTIONALLY.

14. Because of the judge‘s sudden, abrupt, and/or unexpected
disruption/interruption, Plaintiff could not continue to make his legal arguments which he initiated. Plaintiff had to stop both legal and logical development of his arguments.

15. And then, the Honorable Judge Rhynette N. Hurd declared, suddenly,
abruptly, and/or unexpectedly, that she made a decision about the motion and/or the case.

16. Therefore, Plaintiff could not make or/and finish the remaining argument(s) about the motion for involuntary dismissal.

17. Plaintiff respectfully alleges that his legal claim(s) should not be dismissed
this way.

18. Plaintiff continues to mention/make his legal arguments as below for the record, or/and for the subsequent proceedings.

Part B.

In terms of the motion for involuntary dismissal.

(a). Plaintiff‘s Legal Argument: Point One(1).

19. Plaintiff has a website about his story since he became a serious victim by the car accidents.

HwangStory
www.hwangstory.com

20. Plaintiff wrote the information, his experience, and his opinion about a
hearing on the website on January 6, 2023, and on January 7, 2023 right after the hearing which occurred on January 6, 2023 in the courtroom of Division V of the Honorable Court. The legal proceeding was presided over by the Honorable Judge Rhynette N. Hurd.

21. Therefore, Plaintiff had a crystal clear or very vivid memory about the
hearing.

22. And when necessary, Plaintiff’s former spouse, Ms. Northcutt, can testify that how much good memory Plaintiff had and has. For example, Plaintiff had an ability which enabled him to notice the ’different and twisted angle’(made by someone who was hired temporarily because of a trip) of an external hard drive of Plaintiff’s computer after the couple(Ms. Northcutt and Plaintiff) had a trip and came back from Saint Louis, Missouri to their apartment in Memphis, Tennessee in the past.

23. You, or the readers of this writing in the Plaintiff’s statements can read
what he wrote through below links.

The reasons why Mr. Hwang suspects Judge Hurd in accomplice relations with the white-collar criminals
https://hwangstory.com/hurd-1

About the Suspicion of Accomplice Relations by Judge Hurd
https://hwangstory.com/hurd-2

24. This is what the court said on January 6, 2023.

“6. Judge Hurd said, Mr. Hwang’s cause(claim/lawsuit) will be dismissed if he cannot respond to motion to compel within 30 days.”

25. This means that Plaintiff’s cause was not dismissed. His claim was not
dismissed on January 6, 2023.

26. Plaintiff filed his second motion to recuse the judge on or about January 9, 2023.

Supreme Court of Tennessee Rule 10B:
https://www.tncourts.gov/rules/supreme-court/10b

“1.02. While the motion is pending, the judge whose disqualification is sought shall make no further orders and take no further action on the case, except for good cause stated in the order in which such action is taken.“

27. Therefore, Judge Rhynette N. Hurd must not/should not/could not make any further orders, or/and take any further action on the case. (Case No. CT-2449-22 Div. V)

28. ORDER GRANTING DEFENDANT’S THIRD MOTION TO COMPEL
WRITTEN DISCOVERY RESPONSES AND PRODUCTION was filed on
January 23, 2023.

29. Plaintiff’s Legal Argument:

ORDER GRANTING DEFENDANT’S THIRD MOTION TO COMPEL
WRITTEN DISCOVERY RESPONSES AND PRODUCTION should not have
been filed on January 23, 2023.

The oral decision by Judge Hurd at the hearing on March 24, 2023 in terms of the motion for involuntary dismissal was wrong and legally flawed.

(b). Plaintiff‘s Legal Argument: Point Two(2)

30. There is another issue which is related to (a). Plaintiff‘s Legal Argument:
Point One(1). Let’s suppose the court order was legal and legitimate. It was not legal and legitimate, but, theoretically speaking, let’s suppose it was legal and legitimate.

31. The court order has been filed on January 23, 2023 because there was an
orally granted order at the hearing on January 6, 2023. However, Plaintiff filed, on March 23, 2023, the PLAINTIFF‘S RESPONSE(S) TO DEFENDANT SANIA S. HOLT’S INTERROGATORIES AND REQUESTS FOR PRODUCTION TO PLAINTIFF.

32. PLAINTIFF‘S RESPONSE(S) was filed BEFORE the hearing on March 24,
2023.

33. PLAINTIFF‘S RESPONSE(S) complied with the court order.

34. It complied with the court order completely. Plaintiff answered to every
questions without omiting or missing out any item of questions.

35. At least it complied fundamentally or/and substantially. Plaintiff can submit additional documents when necessary as he mentioned or explained in the document.

36. What PLAINTIFF‘S RESPONSE(S) did not comply with the court order was the timing(date).

37. PLAINTIFF‘S RESPONSE(S) should have been filed by no later than
February 6, 2023. Plaintiff did not do that.

38. However, Plaintiff filed his response(s) on March 23, 2023 BEFORE the
hearing on March 24, 2023 when/where the motion for involutary dismissal was orally granted.

39. Plaintiff’s Legal Argument:

The motion for involutary dismissal should not have been orally granted at the hearing on March 24, 2023 because Plaintiff filed his response(s) before the hearing and complied with the court order.

The oral decision by Judge Hurd at the hearing on March 24, 2023 in terms of the motion for involuntary dismissal was wrong and legally flawed.

(c). Plaintiff‘s Legal Argument: Point Three(3).

40. You, or the readers of this writing in the Plaintiff’s statements can read
what he wrote through below links.

The reasons why Mr. Hwang suspects Judge Hurd in accomplice relations with the white-collar criminals
https://hwangstory.com/hurd-1

About the Suspicion of Accomplice Relations by Judge Hurd
https://hwangstory.com/hurd-2

This is what what the court said on January 6, 2023.

“7. Judge Hurd said, Mr. Hwang have to pay 500 dollars if he cannot respond
within 30 days.“

41. Plaintiff would like to point out the fundamental INCONSISTENCY(discrepancy, discordance, difference) of the content between the orally granted court order on January 6, 2023, and the court order which was filed/made on January 23, 2023.

42. What the judge orally ordered on January 6, 2023 was that Plaintiff had to pay 500 dollars if Paintiff could not respond within 30 days.

43. However, on the court order which was filed on January 23, 2023, it says
like this as below.

“ORDERED, ADJUDGED, AND DECREED that pursuant to Rules 37.01(4) and
37.03(2) of the Tennessee Rules of Civil Procedure, Defendant is awarded
$500.00 (five hundred and zero/100 dollars) in attorney’s fees to be paid by
Plaintiff for having to bring Defendant’s Third Motion to Compel Written
Discovery Responses and Production. Plaintiff shall make payment to Defendant of the same, through Defendant’s counsel of record, by no later than February 6, 2023.“

44. The court order said that Plaintiff should make payment by no later than
February 6, 2023.

45. What doest this INCONSISTENCY mean?

46. Plaintiff respectfully alleges that the parties involved about the court order did make such inconsistency ON PURPOSE and/or INTENTIONALLY.

47. That’s the result of manipulation and/or deception. That is not just pure form of mistakes. That is not just a bad example of bad faith players.

48. That’s why Plaintiff strongly continued and/or continues to allege that he experienced so-called white-collar crime since he experienced his car accidents in the United States.

49. Regrettably, that’s why Plaintiff strongly continued and/or continues to allege that he got the impression, or/and could not and cannot exclude his reasonable suspicion(s) that such so-called “white-collar criminals“ must/may/could have been involved in his legal cases and claims since he experienced such car accidents.

50. That’s why Plaintiff suspects Judge Hurd in accomplice relations with the white-collar criminals.

51. That’s why Plaintiff filed his motions to recuse the judge.

52. That’s why Plaintiff filed his motions to recuse the judge because Plaintiff thought and ended up concluding that he could not have a fair process of litigation or legal procceeding to resolve the issues and claims in his legal case.

53. Judge Hurd already became the suspect of the accomplice of the white-collar crime.

54. FBI(Federal Bureau of Investigation), TBI(Tennessee Bureau of Investigation), or/and district attorney general’s office in Shelby County should investigate the background of Judge Hurd in terms of her judicial behaviours and decisions.

55. Such manipulation, deception, and even crime on the court order which was filed on January 23, 2023 strongly shows that the legal proccedding of this case is not lawful, legitimate, or fair. It is seriously, fundamentally, or fatally flawed.

56. Plaintiff respectfully alleges that the outcomes of the hearing on March 24, 2024 is basically the extension of such unfair, manipulative, deceptive, or/and even criminal process.

57. Plaintiff’s Legal Argument:

The oral decision by Judge Hurd at the hearing on March 24, 2023 in terms of the motion for involuntary dismissal lacked the judicial justification or/and legitimacy.

The oral decision (on March 24, 2023) was based on and/or originated from the court order(on January 23, 2023) which contained INCONSISTENCY.

The court order(on January 23, 2023) was the result of manipulation. The oral decision by Judge Hurd at the hearing on March 24, 2023 was wrong because it was based on/originated from the manipulated court order.

(d). Plaintiff‘s Legal Argument: Point Four(4)

58. The hearing on March 24, 2023 should not have dealt with the issues of the motion for involuntary dismissal.

59. Legal Ground: RULE SIX. DISPOSITIVE MOTIONS (A).

“(A) All motions for summary judgment and to dismiss shall be filed with the Clerk AT LEAST THIRTY (30) DAYS before the motion is heard…“

60. Legal Ground: RULE SIX. DISPOSITIVE MOTIONS (B).

“(B) No motions will be heard unless all parties have complied with this rule.“

61. DEFENDANT SANIA S. HOLT’S MOTION FOR INVOLUNTARY DISMISSAL was filed on or about March 1, 2023.

62. The hearing at these issues ocurred on March 24, 2023.

63. Therefore, DEFENDANT SANIA S. HOLT’S MOTION FOR INVOLUNTARY DISMISSAL was not filed with the Clerk AT LEAST THIRTY (30) DAYS before the motion was heard.

64. DEFENDANT SANIA S. HOLT’S MOTION FOR INVOLUNTARY DISMISSAL should have been filed AT LEAST THIRTY (30) DAYS before the motion was heard on March 24, 2023.

65. Plaintiff’s Legal Argument:

LOCAL RULE SIX. DISPOSITIVE MOTIONS (A), (B). were violated by the opposing parties/counsel(s).

The motion for involuntary dismissal was not filed with the Clerk at least thirty (30) days before the motion was heard. The hearing on March 24, 2023 for DEFENDANT SANIA S. HOLT’S MOTION FOR INVOLUNTARY DISMISSAL should not have occurred.

The oral decision by Judge Hurd at the hearing on March 24, 2023 in terms of the motion for involuntary dismissal was wrong and legally flawed.

(e). Plaintiff‘s Legal Argument: Point Five(5).

66. Plaintiff sent an email to Mr. Scofield on or about March 2, 2023.

“To Mr. Scofield, This is my reply to your previous email whose title was “Hwang v. Holt – Motion to Dismiss” which you sent me on or about February 22, 2023……………… 2. About my opinion of/about the motion to dismiss. I am opposed to such a motion which you mentioned in your previous email. I am, emphatically and implacably, opposed to such a motion to dismiss which you mentioned. I don’t agree. I disagree…………….. 4. About the hearing date. The hearing date is not convenient for me. Your hearing date on Friday, March 10, 2023, at 9:00 a.m. is not convenient for me. I don’t agree to that date. I
disagree. I am, emphatically and implacably, opposed to such a hearing date
which you mentioned………………”

67. Since then, Plaintiff did not agree to any hearing date with the opposing
parties/counsel(s) for DEFENDANT SANIA S. HOLT’S MOTION FOR INVOLUNTARY DISMISSAL.

68. In terms of the hearing date on March 24, 2023, Plaintiff agreed to that
date with the opposing parties/counsel(s) for the MOTION TO RECUSE THE
JUDGE.

69. Mr. Scofield sent an email to Plaintiff on or about March 2, 2023.

“Mr. Hwang, Thank you for the emails. As you advised you are available on
March 24, 2023, we will set the Motion to Dismiss for hearing on March 24, 2023. You will receive a copy when we file the Motion……………….“

70. Regrettably, Mr. Scofield or/and the opposing parties/counsel(s) was/were misleading or manipulating ON PURPOSE/INTENTIONALLY what Plaintiff said in the emails.

71. Mr. Nicoson sent Plaintiff an email on or about March 4, 2023.

“Mr. Hwang: Thank you consulting with us………………You said you were
available on March 24 for our motion for dismissal;…………..“

72. Regrettably, Mr. Nicoson or/and the opposing parties/counsel(s) was/were misleading or manipulating ON PURPOSE/INTENTIONALLY what Plaintiff said in the emails.

73. Plaintiff did not / has not said he was available on March 24 for the
DEFENDANT SANIA S. HOLT’S MOTION FOR INVOLUNTARY DISMISSAL.

74. Plaintiff sent an email to Mr. Nicoson on or about March 4, 2023.

“To Mr. Nicoson, 1. I received your email which you sent today on March 3, 2023……………..2. Regrettably, I got the impression or/and cannot exclude my reasonable suspicion that you were misleading or manipulating ON PURPOSE/INTENTIONALLY what I said in the emails which I sent to Mr. Scofield on or about March 1, 2013. 3. I sincerely request you to read again
what I said in the previous emails in terms of the hearing and the hearing date. Please, read them again. Hwang“

75. Plaintiff could not and cannot understand the pattern of their behaviors.

76. In term of the CERTIFICATE OF CONFERENCE on DEFENDANT SANIA
S. HOLT’S MOTION FOR INVOLUNTARY DISMISSAL.

In term of the issues of Rules 5(H) and 12(E), and “in a good faith effort“, the CERTIFICATE OF CONFERENCE mentioned above did not note Plaintiff‘s opposition in the defendant‘s Certificate of Consultation. And it was not a good faith effort. It was a bad faith effort. Because the opposing parties/counsel(s) were misleading or manipulating what Plaintiff said in the emails.

77. Plaintiff’s Legal Argument:

The hearing on March 24, 2023 for DEFENDANT SANIA S. HOLT’S MOTION
FOR INVOLUNTARY DISMISSAL should not have occurred. The oral decision
by Judge Hurd at the hearing on March 24, 2023 in terms of the motion for
involuntary dismissal was wrong and legally flawed.

(f). Plaintiff‘s Legal Argument: Point Five(6).

78. There are issues about disruption of litigation in this case.

79. There was the failure of the delivery of the Court’s Order in this case.

80. It is suspected that such failure of the delivery happened either from the
court/court clerk or from the post office.

81. Generally speaking, such failures can be either intentional or negligent.

82. However, Plaintiff thinks and already concluded that such failures were/are very INTENTIONAL because such failures continued/continues to happen in his legal cases and claims. Plaintiff sees such failures as intentional.

83. Plaintiff sent an email to Mr. Scofield on or about March 2, 2023.

“To Mr. Scofield, This is my reply to your previous email whose title was
“Hwang v. Holt – Motion to Dismiss” which you sent me on or about February 22, 2023. 1. About the failure of the delivery of the Honorable Court’s order. I could not see/read the Honorable Court’s order yet because the order was not delivered to my P.O.Box. I did not and/or could not see such a document in my P.O.Box. So I could not see/read the instruction in it, either. Therefore, I didn’t know that, on or about January 23, 2023, the Honorable Court ordered me to produce responses to Defendant’s written discovery requests by February 6, 2023. I can/will try to visit the clerk’s office in the court soon when I can, and see/read the document which contains the Honorable Court’s order and
instruction in it.”

84. Plaintiff received, saw, and/or ended up reading the written court order in the attached file(“EXHIBIT A”) in the email(“Hwang v. Holt – Motion to
Dismiss Filed”) which Mr. Scofield sent Plaintiff on or about March 2, 2023.

85. Mr. Scofield sent Plaintiff an email, on or about January 7, 2023, whose
title was “Proposed Order Granting Third MTC“. Plaintiff received the proposed order from Mr. Scofield, but alleges that he did not receive the ‘official written court order‘.

86. Plaintiff’s Legal Argument:

It is suspected that the disruption of litigation existed in this case.

Plaintiff was not served on timely manner.

Especially the official written court order was not delivered to Plaintiff‘s
P.O.Box, or it was not found in his P.O.Box until this day.

The copy of official written court order was sent or/and delivered by Mr. Scofield to Plaintiff‘s email box on or about March 2, 2023.

Plaintiff’s argument is about the fair process of litigation.

The motion for involutary dismissal should not have been orally granted at the hearing on March 24, 2023 because Plaintiff did not and/or could not have a fair opportunity to respond on timely manner against the opposing parties/counsels.

The oral decision by Judge Hurd at the hearing on March 24, 2023 in terms of the motion for involuntary dismissal was made under the UNFAIR process of litigation. Or it was influenced by such environment of unfair process of litigation.

Respectfully submitted,

Hwang (Pro Se)

Dated: March 25, 2023

[The End]
This is the end of the documents. The total pages are 15 pages.

Written by Mr. Hwang

Published: March 25, 2023

Mr. Hwang participated in a hearing on March 24, 2023.

The hearing was presided over by the judge Rhynette Hurd.

Mr. Hwang thinks the hearing was “a comedy”.

Mr. Hwang concluded that the judge Hurd had very serious problems as a judge.

Someday in the future, Mr. Hwang would like to perform “an investigative journalism” about her, her judgeship, and her life.

Mr. Hwang has been thinking and is thinking the allegations and possibilities of not only judicial corruption but also judicial crime(judges’ crime).

The courtroom of Division 5 in Shelby County Circuit Court is a place where comedies occur.

Investigative journalism may dicover whether crimes existed behind such comedies.

Written by Mr. Hwang

Published: March 25, 2023

Ps:

There were three issues(motions at the hearing).

Motion to recuse the judge
Oral motion to retain an attorney(counsel)
Motion for involuntary dismissal

Month: March 2023

Mr. Hwang filed Plaintiff’s Response(s) on March 30, 2023

Tennessee Rules of Civil Procedure 68

Mr. Hwang submitted a tip to FBI about Judge Rhynette Hurd on March 28, 2023

[Docket] [Email] Notice of Plaintiff’s Statement(s)

[Docket] [Email] Notice of Inquiry to Clarify or/and Explain

Mr. Hwang and his experience about court hearings

[Docket] Notice of Plaintiff’s Statement(s)

Mr. Hwang filed Notice of Plaintiff’s Statement(s) on March 25, 2023

Mr. Hwang participated in a hearing on March 24, 2023

Mr. Hwang sent an email to the opposing counsels(attorney Scofield, attorney Nichoson) on March 23, 2023