Month: December 2024

[Hwang] I intend to file a motion to extend time (December 30, 2024).

To Mr./attorney Scott Vincent, and/or the opposing counsels/parties/witnesses,

1. I intend to file a motion to extend time with/to the Court of Appeals of Tennessee at Jackson.

2. What I try to mean is that I would like to, am considering to, or/and am going to try to file a motion to extend time (or a motion for extension of time) with/to the Court of Appeals of Tennessee at Jackson. 

3. This is my attempt to consult with you, (if any,) pursuant to the Tennessee Rules of Appellate Procedure, Tennessee Rules of Civil Procedure, Tennessee Rules of Criminal Procedure, any Local Rules, or/and any controlling rules/regulations/laws/(judicial) precedents. 

4. Please, let me know your response/position/opinion/advice as soon as possible if you can. 

5. Or/and Plaintiff-Appellant Hwang expects Appellees (including the opposing counsels/the parties/the witnesses) to respond to this email correspondence until 5 P.M.(pm) on January 1, 2025, Wednesday (1/1/2025) if you/they can. 

6. Thank you for your time and attention to this matter. 

Sincerely, 

Hwang. 

(Sent on December 30, 2024, Monday (12/30/2024), on or about at 11:11A.M.(am).

[Hwang] NOTICE OF CORRESPONDENCE with/to the COURT OF APPEALS (December 27, 2024).

1. Plaintiff-Appellant Hwang filed the NOTICE OF CORRESPONDENCE with/to THE COURT OF APPEALS OF TENNESSEE, WESTERN SECTION, AT JACKSON. 

2. Plaintiff-Appellant Hwang just filed the NOTICE OF CORRESPONDENCE today on December 27, 2024, Friday (12/27/2024). 

Written by Mr. Hwang.

Published: December 27, 2024, Friday (12/27/2024), at 1:46PM(pm).

[Hwang] This is my reply to your email correspondence (December 27, 2024).

To Mr./attorney Scott Vincent, and/or the opposing counsels/parties/witnesses,

1. This is my reply to your email correspondence which you sent me on December 26, Thursday (12/26/2024), on or about at 11:14A.M.(am).

2. I agree to you with a motion to request additional time.

3. I agree with a motion to request additional time for a new trial judge.

4. However, both for our mutual communication and for the record, I would like to comment/indicate or/and am mentioning some comments/indication about/with regard to/in terms of some factors/elements/facts/thoughts including, but not limited to such factors/elements/facts/thoughts hereinafter or as below.

5. I don’t agree that the Honorable Judge, Gina C. Higgins should take or/and preside over this case/action/matter/cause.

6. I would like to argue or/and am arguing that this case/action/matter/cause should be assigned to a new judge randomly or at random, or/and according to the laws or other legal procedure.

7. References:

Supreme Court Rules of Tennessee.
https://www.tncourts.gov/courts/supreme-court/rules/supreme-court-rules

Rule 10B: Disqualification or Recusal of a Judge; Filing and Disposition of Motions and Appeal.
https://www.tncourts.gov/rules/supreme-court/10b

Rule 1.04.

1.04. Designation Prodedure. A judge who recuses himself or herself, whether on the judge’s own initiative or on motion of a party, shall not participate in selecting his or her successor, absent the agreement of all parties. With the agreement of all parties to the case, the judge may seek an interchange in accordance with Tenn. Sup. Ct. R. 11, § VII(c)(1). Otherwise, the presiding judge of the court shall effect an interchange in accordance with Tenn. Sup. Ct. R. 11, § VII(c)(2) and/or (3) in sequential order. If the presiding judge is the recused judge, the presiding judge shall take no action in selecting a successor. In such cases, the presiding judge pro tempore of the court shall effect an interchange in accordance with Tenn. Sup. Ct. R. 11, § VII(c)(2) or (3). If an interchange cannot be effected by following the above procedure in sequential order, the presiding judge or the presiding judge pro tempore shall request by – using the designation request form appended to this rule – the designation of a judge by the Chief Justice, pursuant to Tenn. Sup. Ct. R. 11, § VII(c)(4). In a judicial district where the presiding judge is the only judge and he or she recuses himself or herself, the judge shall skip the sequential steps set forth in Tenn. sup. Ct. R.11, § VII(c)(2) and (3) and instead request the designation of a judge by the Chief Justice, pursuant to Tenn. Sup. Ct. R. 11, § VII(c)(4), using the designation request form. Similarily, if the recusing judge is a general sessions judge or juvenile court judge, and he or she is the only general sessions or juvenile court judge in that county, the judge shall skip the sequential steps set forth in Tenn. Sup. Ct. R. 11, § VII(c)(2) and (3) and instead request the designation of a judge by the Chief Justice, pursuant to Tenn. Sup. Ct. R. 11, § VII(c)(4), using the designation request form. Special permission to skip the sequential steps may be granted by the Chief Justice for good cause shown.

8. I would like to make or/and am making these arguments for the fairness, objectivity, neutrality, procedural fairness, procedural legitimacy, reliability or credibility in terms of the rule of law.

9. Thank you for your time and attention to this matter.

Sincerely,

Hwang.

(Sent on December 27, 2024, Friday (12/27/2024), on or about at 10:50A.M.(am).

————————————————————————-

This is your email correspondence which you sent me on December 26, Thursday (12/26/2024), on or about at 11:14A.M.(am).

31193; Motion to Extend with Court of Appeals

I am filing a motion with the court of appeals tomorrow related to the nondispositional remand order that will request additional time for a new trial judge to rule on your post-judgment motions in light of Judge Felicia Corbin Johnson recusing herself at the last hearing. I am filing the motion tomorrow at 2 pm CST. Please let me know whether you agree or disagree with the request for additional time for the new judge to rule on your motions. My motion will outline the history of the case since the remand order, attach all filings with the trial court since the remand order, include a statement that Judge Felicia Corbin Johnson recused herself at the last “status conference” after reading filings post remand that will be attached, and request additional time for a new judge to review the case and rule on your pending motions so that the appeal may proceed.

R. Scott Vincent
Allen, Summers & Gresham, PLLC
XXXXX Plaza
XX XXXXX Avenue, Suite XXX
Memphis, Tennessee XXXXX-XXXX
(XXX XXX-XXXX
Fax: (XXX) XXX-XXXX
XXX@XXXXX

[To/dear Mrs. F_____s Golden] [Hwang] About an available date for such a/the hearing (date) (December 23, 2024).

To/dear Mrs. F_____s Golden, 

. Case Number: CT-4094-20. 

1. Plaintiff-Appellant Hwang is asking/thinking about setting or/and intends to set a/the hearing and/or a/the hearing date & time. 

2. Plaintiff-Appellant Hwang is asking/thinking about setting or/and intends to set a/the hearing and/or a/the hearing date & time for/with regard to/in terms of the/a next status conference, or/and such conferences/meetings/court days/court hearings. 

3. Plaintiff-Appellant Hwang would like to ask or/and is asking you when or which date is, can be, or/and may be AVAILABLE (available) (emphasis added) for such a/the hearing (date) for a/the status conference. 

4. Plaintiff-Appellant Hwang is asking this question because it is holiday/holidays/holiday period/holiday season at the end of this year. 

5. Plaintiff-Appellant Hwang is asking this question because of what the honorable court/judge(Division One(1)) said/mentioned, in terms of a/the calendar or a/the court calendar, at a hearing recently/this year. 

6. Plaintiff-Appellant Hwang is asking this question for the record, too. 

Respectfully, 

Hwang. 

(Sent on December 23, 2024, Monday (12/23/2024), on or about at 4:33P.M.(pm).

[To/dear Division Four(4)] [Hwang] About an available date for such a/the hearing (date) (December 23, 2024).

To/dear Division Four(4),
To the court clerk’s office, 
To the honorable court, 
To whom it may concern, 
Dear Sir or Madam, 
Or/and to the opposing counsels or/and parties, 

. Case Number: CT-4094-20. 

1. Plaintiff-Appellant Hwang is asking/thinking about setting or/and intends to set a/the hearing and/or a/the hearing date & time. 

2. Plaintiff-Appellant Hwang is asking/thinking about setting or/and intends to set a/the hearing and/or a/the hearing date & time for/with regard to/in terms of the/a next status conference, or/and such conferences/meetings/court days/court hearings. 

3. Plaintiff-Appellant Hwang would like to ask or/and is asking you when or which date is, can be, or/and may be AVAILABLE (available) (emphasis added) for such a/the hearing (date) for a/the status conference. 

4. Plaintiff-Appellant Hwang is asking this question because it is holiday/holidays/holiday period/holiday season at the end of this year. 

5. Plaintiff-Appellant Hwang is asking this question because of what the honorable court/judge(Division One(1)) said/mentioned, in terms of a/the calendar or a/the court calendar, at a hearing recently/this year. 

6. Plaintiff-Appellant Hwang is asking this question for the record, too. 

Respectfully, 

Hwang. 

(Sent on December 23, 2024, Monday (12/23/2024), on or about at 4:24P.M.(pm).

[Hwang] About an available date for such a/the hearing (date) (December 18, 2024).

To the court clerk’s office, 
To the honorable court, 
To whom it may concern, 
Dear Sir or Madam, 
Or/and to the opposing counsels or/and parties, 

. Case Number: CT-4094-20. 

1. Plaintiff-Appellant Hwang intends to set a/the hearing and/or a/the hearing date & time. 

2. Plaintiff-Appellant Hwang intends to set a/the hearing and/or a/the hearing date & time for/with regard to/in terms of the/a next status conference, or/and such conferences/meetings/court days/court hearings. 

3. Plaintiff-Appellant Hwang would like to ask or/and is asking you when or which date is, can be, or/and may be AVAILABLE (available) (emphasis added) for such a/the hearing (date) for a/the status conference. 

4. Plaintiff-Appellant Hwang is asking this question because it is holiday/holidays/holiday period/holiday season at the end of this year. 

5. Plaintiff-Appellant Hwang is asking this question because of what the honorable court/judge said/mentioned, in terms of a/the calendar or a/the court calendar, at a hearing recently/this year. 

6. Plaintiff-Appellant Hwang is asking this question for the record, too. 

Respectfully, 

Hwang. 

(Sent on December 18, 2024, Wednesday (12/18/2024), on or about at 4:30P.M.(pm).

[Hwang] I intend to set the/a next status conference (December 18, 2024).

To Mr./attorney Scott Vincent, and/or the opposing counsels/parties/witnesses, 

1. I intend to set the/a next status conference, or/and such conferences/meetings/court days/court hearings. 

2. What I try to mean is that I would like to, am considering to, or/and am going to try to set the/a next status conference in order to address all of the pending/remaining/other issues including, but not limited to such pending motions, court orders, court documents, legal documents, and/or other documents which were already filed, or/and which will be filed, sooner or later, in the future. 

3. This is my attempt to consult with you, (if any,) pursuant to the Tennessee Rules of Appellate Procedure, Tennessee Rules of Civil Procedure, Tennessee Rules of Criminal Procedure, any Local Rules, or/and any controlling rules/regulations/laws/(judicial) precedents. 

4. Please, let me know your response/position/opinion/advice as soon as possible if you can. 

5. Or/and Plaintiff-Appellant Hwang expects Appellees (including the opposing counsels/the parties/the witnesses) to respond to this email correspondence until 7 P.M.(pm) on December 20, 2024, Friday (12/20/2024) if you/they can. 
 
6. Thank you for your time and attention to this matter. 

Sincerely, 

Hwang. 

(Sent on December 18, 2024, Wednesday (12/18/2024), on or about at 3:54P.M.(pm).

Mr. Hwang participated in a hearing on Dec. 13, 2024

Mr. Hwang participated in a hearing in the Circuit Court (Div. 1) on December 13, 2024, Friday (12/13/2024).

The scheduled time was on 9 AM in the morning.

The session for Mr. Hwang’s case occured on, about, or after 1 PM in the afternoon.

Mr. Hwang just checked the court docket, on December 16, 2024, Monday (12/16/2024), about the result of that hearing.

It says as below.

File Date: “12-13-2024 Court”

Case History: “ORDER ENTERED – STANDING ORDER OF RECUSAL AND REQUEST FOR TRANSFER”

“Filed by: Court”

File Date: “12-13-2024 Court”

Case History: “ORDER PENDING – MOTION FOR STATUS CONF DENIED ORDER PENDING PER THE JUDGE”

“Filed by: Court”

Written by Mr. Hwang

Published: December 16, 2024, Monday (12/16/2024), at 9:08P.M.(pm).