On August 25, 2011, we have a Motion for Summary Judgment hearing scheduled. We filed the Motion a few weeks ago. We are asking the Judge to rule that the Mediation Settlement of October of 2009 barred Adler from filing the same case against me a few weeks later.
Winning would mean that everything that happened after October 19, 2009 never should have happened, therefore, their $400,000 in fees never should have happened.
Get rid of Herman in an "ex parte" hearing and no motion for summary judgment. A distinct possibility!