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[QUOTE]Originally posted by fhalyesss: [QB] FILED IN CLERKS OFFICE U.&D.C . Atlanta W0 0 7 2047 JAMES N . 7 EN• L K IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION 1 ;06-CV-2565-CC Defendants . SECURITIES AND EXCHANGE COMMISSION, Plaintiff, V. CONVERSION SOLUTIONS HOLDING CORPORATION and RUFUS PAUL HARRIS a/k/a PAUL RUFUS HARRIS, Civil Action No . MOTION FOR RECONSIDERATION/REHEARING OF THE OCTOBER 3D''H ORDER ENTERED BY THIS COURT COMES NOW the Defendant, RUFUS PAUL HARRIS, a/k/a PAUL RUFUS• HARRIS and Moves this Court to reconsider the findings of fact and vacate the Order entered based on those erroneous findings an/or conclusions in this cause based upon this Defendant being denied due process of law and hindered in answering Plaintiff's Complaint by other unethical practices and in support thereof states : This Motion is based on the Court's denial of this Defendant's Motion to set aside the default entered by the Clerk in this action . This Order was entered by this Court without the benefit of a h earin g on this Case 1:06-cv-02568-CC Document 20 Filed 11/07/2007 Page 1 of 9 matter to hear the Defendant's argument on this matter . 1 . That after service of process upon this Defendant, the said Defendant did not have funds available for the substantial retainer to employ an attorney versed in Securities Law. 2. This Defendant was s ubjected to a n unauthorized and illegal change of officers and directors of Conversion Solutions Holding Corporation and was unable to have access to all records necessary to formulate a proper defense and Counterclaim to the Plaintiff's Complaint. 3. During the time that this Defendant was deprived access to records to defend this action, the Securities and Exchange Commission seized the records from those individuals who had control of said records and once again, this Defendant had no access to said records to prepare his answer to Plaintiff's Complaint. 4. This Defendant entered into talks with the Plaintiff, cooperated in every way and was given a false sense that the Plaintiff would subpoena the documents necessary for the Defendant to defend this action but the Plaintiff did not acquire these documents or if they did, they did not Case 1:06-cv-02568-CC Document 20 Filed 11/07/2007 Page 2 of 9 share them with the Defendant as promised, causing a default to be entered against the Defendant while the above referenced talks were ongoing, depriving this Defendant of due process of law . 5. :eek: The conduct of the Plaintiff and its attorneys has violated the standards of professional conduct for members of the Georgia Bar as well as Federal ethics standards by withholding information from this Defendant while defaulting him and continuing talks after the default was entered . :eek: 6. This Defendant finally realized that the Plaintiff was never going to supply him with the promised information he needed to file an appropriate answer and th erefore the Defendant filed his answer, late as it was, without the needed information to file a proper answer and the Plaintiff moved to strike said answer . 7. :eek: The Plaintiff does not have clean hands in dealing with this Defendant, has committed a breach of ethics and has had a severe conflict of interest by withholding exculpatory evidence and records from the Defendant, thus denying the Defendant Due Process in this :eek: action. Case 1:06-cv-02568-CC Document 20 Filed 11/07/2007 Page 3 of 9 C} The phone recordings and messages of the Home Office were unavailable to defendant after the illegal hostile takeover to provide as evidence . 8. The failure to file a timely answer by this Defendant is due to excusable neglect which was caused by the unethical actions of the Plaintiff and its Attorneys . 9. Defendant is in the process of drafting a complaint to be fi led with the Georgia Bar Association to investigate the ethics of the Plaintiff's attorney's in dealing with this Defendant. lO.Other events that occurred to prevent this Defendant from filing a timely answer, defenses and counterclaim to Plaintiffs Complaint are as follows : A) The Email account holding the majority of the evidence was illegally seized by James Gee and never remitted to Defendant. B) After strenuous evidence gather process by Conversion Executives of the 1000 Plus illegal shareholders names and the firms that sold them their shares, The Names of the illegal shareholders were illegally seized by :eek: James Gee, Justin Frazier and John Arlitt to prevent the production of said evidence to the court. :eek: Case 1:06-cv-02568-CC Document 20 Filed 11/07/2007 Page 4 of 9 WHEREFORE, THE Defendant, RUFUS PAUL HARRIS, a/k/a PAUL RUFUS HARRIS, MOVES THIS Court to reconsider and vacate the Order that was entered by this Court on October 301b 2007 for the foregoing reasons and allow this Defendant to properly-answer Plaintiff's Complaint. e ~...a Rufus 1 Harris alk/a Paul Ru u s Harris P.O. Box 18 Adairsville, Georgia 30103 Case 1:06-cv-02568-CC Document 20 Filed 11/07/2007 Page 5 of 9 BEFORE ME, the undersigned authority, personally appeared RUFUS PAUL HARRIS a/k/a PAUL RUFUS HARRIS, who, after first being duly sworn by me according to law, states that the foregoing facts set forth in the above Motion For Reconsideration/Rehearing are true and correct to the best of his knowledge and belief. NOTARY PUBLIC 0114 F . At L, STATE N ~ OF TENNESSEE NOTARY ~ PUBLIC ~ 10 .01 ~lllV v" ~ My Commission Expires : I ~ (-Z,t ,c0 I, RUFUS PAUL HARRIS a/k/a PAUL RUFUS HARRIS, after being duly sworn according to law , do state and affirm, under penalty of perjury, that the facts set forth in the foregoing Motion for Reconsideration/Rehearing are true and correct to my best knowledge and belief . d Rufus null Harris aIk/a Paul Rufus Harris STATEOF County of ~ r~ s Case 1:06-cv-02568-CC Document 20 Filed 11/07/2007 Page 6 of 9 Office of the Attorney General State of Georgia 40 Capitol Square, SW Atlanta, Ga 30334 I HEREBY CERTIFY that a true and correct copy of the foregoing Motion for Reconsideration/Rehearing has been furnished t o William P Hicks, Debbie T. Hampton and Alana R Black, Attorney's for Plaintiff, 34 75 Lenox Road, NE, Suite 1000, Atlanta, GA 30326-1232 by U .S. Mail this 5th day of November, 2008. ~. ~ ~., Rufus aul Harris a/k/a Paul Rufus Harris :eek: Copied to the following ; United States Attorney General U.S. Department of Justice 950 Pennsylvania Avenue, NW Washington, DC 20530-0001 :eek: Case 1:06-cv-02568-CC Document 20 Filed 11/07/2007 Page 7 of 9 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION Civil Action No. 1 :06-CV-2568-CC Defendants. Plaintiff or its Attorneys or unknown third parties and cannot be retrieved in SECURITIES AND EXCHANGE COMMISSION, Plaintiff, V. CONVERSION SOLUTIONS HOLDING CORPORATION and RUFUS PAUL HARRIS a/k/a PAUL RUFUS HARRIS, MOTION FOR ENLARGEMENT OF TIME TO FILE SUPPLEMENTAL AFFIDAVITS COMES NOW the Defendant, RUFUS PAUL HARRIS, a/k/a PAUL RUFUS HARRIS, and moves this Court to extend the time period for filing affidavits and submitting documentation supporting this Motionfor an additional 60 days, until January 2nd , 2008. The grounds for this Motion are that the time period set forth in the Federal Rules of Civil Procedure is insufficient to find witnesses to execute affidavits or to find and submit other documents and/or evidence supporting this Defendants Motion . The needed documents to support this Motion are in the possession of the Case 1:06-cv-02568-CC Document 20 Filed 11/07/2007 Page 8 of 9 Paul Rufus Harris a 10 day period from the entry of this Courts Order entered on October 30, 2007. WHEREFORE, THE Defendant, RUFUS PAUL HARRIS, a/k/a PAUL RUFUS HARRIS, moves this Court for an enlargement of time, until January 2, 2008, to file supplemental affidavits, documents and/or other evidence to support the Defendant's Motion for Reconsideration/Rehearing heretofore filed in this cause I HEREBY CERTIFY that a true and correct copy of the foregoing Motion for Enlargement of Time has been furnished to William P Hicks, Debbie T. Hampton and Alana R Black, Attorney's for Plaintiff, 3475 Lenox Road, NE, Suite 1000, Atlanta, GA 30326-1232 by U.S. Mail this 5th day of November, 2008. f~ Rufus ul Harris a/k/a Case 1:06-cv-02568-CC Document 20 Filed 11/07/2007 Page 9 of 9 Link to Post - Back to Top Logged [/QB][/QUOTE]
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