Notice Filed: Notice, filed 007 Notice of Improper Service/Motion to Extend Time to File Answer/Notice of Foriegn Service Defendant F.D./EJ E;05/21/2018
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Page 1 E\7"32067
m
IN
THE CIRCUIT COURT FOR PRINCE GEORGES COUNTY, MARYLAND
Keith Coleman. et al.
)
)
)
Case No: CAE17-32067
Plaintiffs,
Bola A. Tinubu, et al.
)
)
)
)
)
33
)
Defendant.
)
5'1
O
NOTICE OF IMPROPER SERVICE! MOTION TO EXTEND TIME To FILE ANSWEg
NOTICE OF FOREIGN SERVICE DEFENDANT
1a:
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.
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CONSULTING. and hereby sufifits
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1'53
1.
--..I
Defendant is a foreign citizen whom owns properly in the jurisdiction, at all times relevant to
this litigation Plaintiff has been on notice of the foreign nature, location, and electronic only
communication with the foreign Defendant during the proposed sale of the aggrieved real
property.
2.
.
0n September
11, 2017. over eight (8) months ago, after being contacted by Plaintiff's
counsel, Brandon Wyatt (myself/ Defendants counsel) agreed to accept electronic delivery
of a proposed complaint on behalf of the Defendant/s. (Ex 1)
Since September 2017, no action, communication. or information has been directed or
delivered by Plaintiff's counsel.
Since September 2017, Defendants' counsel (myself), has not had any direct contact with
4
.
the Defendant/s regarding this matter or otherwise.
.
On or about May 1, 2018, over eight months since the original authorization by Defendants'
Counsel to accept "electronic" service of, opposing counsel delivered a paper Complaint
summons without any notice, contact. or entry of an appearance in the pending matter by
Defendants' counsel.
Considering the time lapse (September 2017 May 2018), opposing counsel reasonably
should have contacted Defendant counsel to obtain verification of present authorization to
accept service of the Complaint on behalf of Defendant/s.
-
7
Considering the time lapse (September 2017 May 2018). Defendant's counsel must reestablish contact with Defendant/s to inquire if present legal services are authorized and will
be obtained & tendered in defense of this present compliant.
-
c
3 '1'.
E}?
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03'
H.
o
.
COMES NOW: Brandon Wyatt and WYATT LEGAL
MD Rule RULE 2-321 motion and notice.
9.0
g:
3'
~19
'Page 2 ("I
.
l'll
8.
Considering the time lapse (September 2017 May 2018). Defendant's counsel has not yet
been able to re-establish contact with Defendant/s, who are located in Africa. but is making
diligent efforts.
9.
Defendant's counsel presents this motion and notice in an attempt to align fairness and
avoid prejudice to either party.
-
Wherefore, based on the aforementioned. the Plaintiff's present attempted at service of this
complaint should be deemed improper. In the alternative, Plaintiff's present delivery of the
summons should be considered as serviced outside of the US pursuant to RULE 2-321. In the
alternative, if service is deemed effective. Counsel humbly requests an extension of 30 days to
file an answer, due to the length to time since contact with Defendants. the need to re-establish
contact the Defendant, and the foreign nature of dealings.
Brandon L. Wyatt
Wyatt Legal & Consulting
10903 Indian Head Hwy #204
Fort Washington, MD 20744
Tel. 202.390.4929
BW att@4B Le al.comPage 3 11
CERTIFICATE 0F SERVICE
l HEARBY
all
CERTIFY, that on May l7, 2018, as copy of the aforegoing was delivered to the Defendant
April Richardson Esq.
4806 Rhode Island Ave
#2
Hyattsville, MD 20781
Brandon L. Wyatt
Wyatt Legal & Consulting
10903 Indian Head Hwy #204
Fort Washington, MD 20744
Tel. 202.390.4929
BWyatt@4BLegal.comPage 4 m
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EXHIBIT
1Page 5 ,.~
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April Richardson
ggfimail
Re: Demand Notice
1
message
Brandon Wyatt Esq.
To: April Richardson
Cc: 'lGmberiy N. Henderson. Esq."
Mon. Sep 11. 2017 at 11:29 AM
Good day.
Please feel free to direct service in this matter to my stead. I will accept electronic method for efficiency.
Thank you.
Wyatt
Brandon L. Wyatt Esq., MBA'
Wyatt Legal & Consulting
Maryland
10903 Indian Head Hwy #204
Fort Washington. MD 20744
Tel. 202.390.4929
Email; Bwyatt@43Legai.com
Notice: This e-mail message. including any attachments. ls confidential and is intended only for the named reclplent(s)
above. lf'you have received this message in error. or are not the named recipient(s). please immediately notify the sender
at 202-390-4929 and delete this email message from your computer Mthout making any copies or distributing it to any
other person. Thank you.
.
On Sep 8. 2017. at 12:25 AM. April Richardson wrote:
Mr.. vvyatt.
Please find the attached Demand. In short. I have been authorized to file suit against your client. Please
advise the intention of your clients so we may determine our next steps.
Take Care.
April N. Richardson Esq.
240-41 7-5259
"*3
coleman demand letter 090517.doc
46K
littpszllrnall.googie.cornlmalValanui=2aik=459865ab4&isvefiCPlyEZWTIdcen.&vlenl=pl&q=wyau&qs=true&search=query&lh=15e71
1M
PDF Page 1
PlainSite Cover Page
PDF Page 2
E\7"32067
m
IN
THE CIRCUIT COURT FOR PRINCE GEORGES COUNTY, MARYLAND
Keith Coleman. et al.
)
)
)
Case No: CAE17-32067
Plaintiffs,
Bola A. Tinubu, et al.
)
)
)
)
)
33
)
Defendant.
)
5'1
O
NOTICE OF IMPROPER SERVICE! MOTION TO EXTEND TIME To FILE ANSWEg
NOTICE OF FOREIGN SERVICE DEFENDANT
1a:
"
.
'4
&
{R's
CONSULTING. and hereby sufifits
'
W
1'53
1.
--..I
Defendant is a foreign citizen whom owns properly in the jurisdiction, at all times relevant to
this litigation Plaintiff has been on notice of the foreign nature, location, and electronic only
communication with the foreign Defendant during the proposed sale of the aggrieved real
property.
2.
.
0n September
11, 2017. over eight (8) months ago, after being contacted by Plaintiff's
counsel, Brandon Wyatt (myself/ Defendants counsel) agreed to accept electronic delivery
of a proposed complaint on behalf of the Defendant/s. (Ex 1)
Since September 2017, no action, communication. or information has been directed or
delivered by Plaintiff's counsel.
Since September 2017, Defendants' counsel (myself), has not had any direct contact with
4
.
the Defendant/s regarding this matter or otherwise.
.
On or about May 1, 2018, over eight months since the original authorization by Defendants'
Counsel to accept "electronic" service of, opposing counsel delivered a paper Complaint
summons without any notice, contact. or entry of an appearance in the pending matter by
Defendants' counsel.
Considering the time lapse (September 2017 May 2018), opposing counsel reasonably
should have contacted Defendant counsel to obtain verification of present authorization to
accept service of the Complaint on behalf of Defendant/s.
-
7
Considering the time lapse (September 2017 May 2018). Defendant's counsel must reestablish contact with Defendant/s to inquire if present legal services are authorized and will
be obtained & tendered in defense of this present compliant.
-
c
3 '1'.
E}?
'w
03'
H.
o
.
COMES NOW: Brandon Wyatt and WYATT LEGAL
MD Rule RULE 2-321 motion and notice.
9.0
g:
3'
~19
'
PDF Page 3
("I
.
l'll
8.
Considering the time lapse (September 2017 May 2018). Defendant's counsel has not yet
been able to re-establish contact with Defendant/s, who are located in Africa. but is making
diligent efforts.
9.
Defendant's counsel presents this motion and notice in an attempt to align fairness and
avoid prejudice to either party.
-
Wherefore, based on the aforementioned. the Plaintiff's present attempted at service of this
complaint should be deemed improper. In the alternative, Plaintiff's present delivery of the
summons should be considered as serviced outside of the US pursuant to RULE 2-321. In the
alternative, if service is deemed effective. Counsel humbly requests an extension of 30 days to
file an answer, due to the length to time since contact with Defendants. the need to re-establish
contact the Defendant, and the foreign nature of dealings.
PDF Page 4
11
CERTIFICATE 0F SERVICE
l HEARBY
all
CERTIFY, that on May l7, 2018, as copy of the aforegoing was delivered to the Defendant
April Richardson Esq.
4806 Rhode Island Ave
#2
Hyattsville, MD 20781
Brandon L. Wyatt
Wyatt Legal & Consulting
10903 Indian Head Hwy #204
Fort Washington, MD 20744
Tel. 202.390.4929
BWyatt@4BLegal.com
PDF Page 5
m
i
("t
.
r"
EXHIBIT
1
PDF Page 6
,.~
.
-----
.
("l
.
---'§§m13-
-
-
"*~'
.
-
-~---Glnall-Re;nemanu.mgce
é: k
,
\ou-l 5:...- »-~-
- -
~-*'
'
April Richardson
ggfimail
Re: Demand Notice
1
message
Brandon Wyatt Esq.
To: April Richardson
Cc: 'lGmberiy N. Henderson. Esq."
Mon. Sep 11. 2017 at 11:29 AM
Good day.
Please feel free to direct service in this matter to my stead. I will accept electronic method for efficiency.
Thank you.
Wyatt
Brandon L. Wyatt Esq., MBA'
Wyatt Legal & Consulting
Maryland
10903 Indian Head Hwy #204
Fort Washington. MD 20744
Tel. 202.390.4929
Email; Bwyatt@43Legai.com
Notice: This e-mail message. including any attachments. ls confidential and is intended only for the named reclplent(s)
above. lf'you have received this message in error. or are not the named recipient(s). please immediately notify the sender
at 202-390-4929 and delete this email message from your computer Mthout making any copies or distributing it to any
other person. Thank you.
.
On Sep 8. 2017. at 12:25 AM. April Richardson wrote:
Mr.. vvyatt.
Please find the attached Demand. In short. I have been authorized to file suit against your client. Please
advise the intention of your clients so we may determine our next steps.
Take Care.
April N. Richardson Esq.
240-41 7-5259
"*3
coleman demand letter 090517.doc
46K
littpszllrnall.googie.cornlmalValanui=2aik=459865ab4&isvefiCPlyEZWTIdcen.&vlenl=pl&q=wyau&qs=true&search=query&lh=15e718145hZS§dc8slm...
1M
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