Reply to Answer Brief of Richman Greer Filed
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Jason Halle files Reply Brief

Reply to Richman Greer Answer Brief Filed

Reply to Richman Greer Answer Brief Filed

On March 6, 2014, Jason Halle pro se filed a Reply Brief to answer the Answer Brief filed by Michael Napoleone and John G. White of the law firm of Richman Greer on February 21, 2014. The Answer Brief was prepared on behalf of Richman Greer client, Peter Halle of Morgan Lewis in Washington.

Jason Halle wrote the Reply Brief himself.

Fourth District Court of Appeal

Now that the Reply Brief is filed with the Court, there is nothing to do but wait for the ruling of the Honorable Fourth District Court of Appeal of Florida.

 I’ve answered Richman Greer

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Richman Greer Reply Brief
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Richman Greer Attorneys

Michael Napoleone and John G. White

File Answer Brief for Peter Halle of Morgan Lewis

Reply brief by Richman Greer

Richman Greer Answer Brief by Michael Napoleone and John G. White for Peter Halle of Morgan Lewis

Michael Napoleone of Richman Greer and John G. White of Richman Greer filed an Answer Brief with the Fourth District Court of Appeal of Florida on behalf of their client Peter Halle of Morgan Lewis.

It consists of 35 pages and was filed on February 21, 2014. The case number with the Fourth District Court of Appeal of Florida is: 4D13-3796.

Jason Halle, the brother of the Defendant is still waiting for Peter Halle, the Trustee of the Edward Halle Trust to disburse the money that was left to Jason Halle more than 6 years ago.

Peter Halle has already spent more than $100,000.00 in legal fees with Richman Greer in an attempt to avoid disbursing the money.

Peter Halle requests extension for Answer Brief
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Micheal J. Napoleone

of Richman Greer needs more time

Peter Halle & Jason Halle

Peter Halle & Jason Halle
at summer camp in the 1950’s

Peter Halle’s attorney, Michael J. Napoleone, has requested an extension of several weeks to file his Answer Brief in the Fourth District Court of Appeal. This is Peter Halle’s response to Jason Halle’s Pro Se Initial Brief filed on January 8, 2014.

The Answer Brief was originally due to be filed Michael J. Napoleone on January 28, 2014. With the extension that was agreed to by Jason Halle the Answer Brief is now due on Friday, February 21, 2014.

The progress of this appeal can be followed at the Fourth District Court of Appeal of Florida, Jason Halle vs. Peter Halle, Case Number 4D13-3796.

As of Sunday, February 16, 2014, Michael J. Napoleone still has not filed a motion with the Fourth District Court of Appeal of Florida for the extension.

Initial Brief filed in the Fourth District Court of Appeal.
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Peter Halle

I filed a pro se brief in the Fourth District Court of Appeal in Florida today, Case Number: 4D13-3796. I have been in court for more than two years trying to get my brother Peter Halle  who works at the law firm of Morgan Lewis, to give me the funds he has been withholding from me for more than 6 years from my father’s estate.

Michael J. Napoleone of Richman Greer

Peter Halle has hired the law firm of Richman Greer and Michael J. Napoleone. They have been making me work very hard to get my money.

The Initial Brief filed with the Fourth District Court of Appeal is 23 pages long and it might take a little while to download.

Jason Halle files Appeal against Peter Halle
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Jason Halle v. Peter Halle Intial Brief

Jason Halle v. Peter Halle

On October 15, 2013, Jason Halle filed a Notice of Appeal against his brother Peter Halle in the Fourth District Court of Appeal of Florida.

I am a pro se litigant, which means I am acting as my own lawyer. It is not the position I wish to be in, but my brother, Peter Halle, has spent such a huge sum of money on lawyers that I cannot afford to compete with him. I am forced to act pro se and hope that my rudimentary skills and justice will prevail.

I am always looking for a Florida attorney that can give me some help and guidance on a pro bono basis.

On August 28, 2013, I was basically shut down when the Honorable Judge David E. French granted my brother’s motion to dismiss with prejudice.

I went to the Sheppard Broad Law Library at Nova University. It is a very benevolent institution and allows pro se litigants to use their facilities.

After many hours of research it became apparent that the Florida Courts of Appeal have ruled that a Plaintiff (attorney or pro se litigant) must have the opportunity to amend a minimum of three times each time a complaint is dismissed for failure to state a cause of action. I was not given one opportunity.

I filed a Notice of Appeal with the Fourth District Court of Appeal of Florida. This truly does seem to be the never-ending law suit.

John G. White III, represents Peter Halle.
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Motion to Dismiss is Granted with Prejudice.

Motion to Dismiss is Granted with Prejudice

On August 28, 2013, the Honorable Court held a hearing on Defendant Peter Halle’s Motion to Dismiss Jason Halle’s Fourth Amended Complaint for Failure to State a Cause of Action. John G. White III, of the law firm of Richman Greer was representing my brother, Peter Halle. I was representing myself. Judge David E. French Granted the motion to dismiss with Prejudice. This basically means the law suit is over!

I was expecting that the Judge would give me the opportunity to amend my complaint and correct the problems with it. But I was not given one opportunity to amend my Complaint as a result of any complaint of mine being dismissed for failure to state a cause of action.

I was totally  depressed and in a state of disbelief that this case was shut down by the Judge. I could not imagine why he made such a ruling. It certainly did not seem fair to me or in the interests of justice.

I answered Michael Napoleone’s Intial Brief.
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Michael Napoleone

My First Appellate Brief

On May 24, 2013, Michael Napoleone of the law firm Richman Greer in West Palm Beach, Florida, Charles H. Johnson of Richman Greer in Miami and Ethan J. Wall of Richman Greer in Miami who are all representing my brother, Peter Halle of Morgan Lewis in Washington, DC, filed the Initial Brief in the Fourth District Court of Appeal of Florida. They are disputing The Honorable David E. French’s Order that took jurisdiction for the State of Florida and more specifically Palm Beach County.

Now it was my turn. I studied their brief. I spent many hours in the Law Library and Nova University. I started writing. My friend Bob helped me with the editing and I came up with an Answer Brief. With the appendix it came to 150 pages. It truly exhausted me during a time when I was not feeling very well to begin with.

On June 28, 2013, I served the Answer Brief to Michael Napoleone at Richman Greer. I am a pro se litigant, meaning I am representing myself. Richman Greer is considered one of the top law firms in South Florida.

There was nothing to do but wait. Michael Napoleone had one more brief to write. It is called a Reply Brief and then it is up to the Court to render its decision.

Nothing left to do but wait.

Peter Halle Appeals Judge David French’s Decision
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Peter Halle Appeals Jurisdiction

Peter Halle Appeals Jurisdiction

On April 22, 2013, Michael J. Napoleone, Peter’s attorney served a Notice of Appeal on me. I was really shocked and amazed.

Peter was appealing the Honorable Judge David French’s Order to take jurisdiction of the case.

I had no idea what this test would be like. I certainly never wrote an appellate brief before. I guess Peter and his attorney were testing how much a pro se litigant could deal with. It must have been very upsetting to have a pro se litigant win jurisdiction after they spent almost a year and a half fighting it.

I had one thing going in my favor. Since they were filing for the appeal, it was their obligation to write the first brief. I could wait and see how they did it.

On April 25, 2013, the Appeal was assigned the number 4DCA#: 13-1381 by the Fourth District Court of Appeal of Florida.

David E. French – Takes Jurisdiction
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The Honorable David E. French

Florida Take Jurisdiction

Florida Takes Jurisdiction

On March 20, 2013, at a hearing presided over by the Honorable David E. French, the Defendant’s Motion to Dismiss Plaintiff’s Third Amended Complaint for Lack of Personal Jurisdiction, Improper Venue, and Failure to State a Cause of Action was denied.

Florida officially took jurisdiction of the law suit I filed on November 2, 2011, against my brother Peter Halle. It was a tremendous relief. Peter Halle’s attorney Michael J. Napoleone of the law firm of Richman Greer had been using all of his skills as a seasoned attorney with a prestigious law firm against me, a pro se litigant, in the hopes of making this law suit disappear. This had been going on for almost a year and a half.

Now to get on with the business of the law suit and to get my brother, Peter Halle, to disburse the funds my father left to me.

On March 26, 2013, the Honorable Judge David French signed an order to deny the motion to dismiss and take jurisdiction of the law suit.

Hearing before Judge David French
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Hearing before the Honorable

Judge David E. French

On Wednesday, January 23, 2013, I am going to court for a hearing on the lawsuit I filed against my brother, Peter Halle, of the Washington law firm of Morgan Lewis.

The Honorable Judge Martz is no longer going to be presiding over the case. He is being rotated to a different bench. The purpose of the hearing on Wednesday is to meet the new judge and to set a date for a hearing for him to rule on motions that have been made by me and Michael Napoleone of Richman Greer, Peter Halle’s attorney.

The two main documents involved in the next hearing will be my Third Amended Complaint and Peter Halle’s Motion to Dismiss my Third Amended Complaint.