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from a non-legal point-of-view, such a motion should be thrown out by the judge: it should not even be considered (nor ultimately approved. ) THIS IS A CASE OF POSSIBLE FRAUD, SCAMMING. LIES, ET AL AS RECORDED BY THE NEW YORK ATTORNEY GENERAL'S UNDERCOVER AGENTS WHILE ACTING AS POTENTIAL PURCHASERS AT A MANHATTAN CLUB SALES PRESENTATION. the judge should see right through the weaseling reason for this motion AND DENY IT IMMEDIATELY IN THE NAME OF JUSTICE. chris