wordsworth

Admissions

Admissions should be drafted as soon as possible. The first drafts should be directed to the individual defendants and based upon the allegations of the complaint.

Subpoenas

The federal rules say that I can subpoena anyone. Jerry Jennings? Pet stores (i.e., Bird Crazy)? Florida Association of Counties? FWC licensees. I need to start on that as soon as possible. Next week. Review the rule. Check the case law.

It did occur to me (after sending out an email request) that the information I’ve asked FWC licensees to volunteer (and might demand by subpoena) is precisely the information the FWC requires them to keep on record. So, I could ask the returning chair of the FWC Rodney Barreto to help me: we want the same information; and, that information (by increasing the damages award) will give the ultimate judicial decision more weight.