Wednesday, November 4, 2009

Don't Mess With a Single Lawyer

I recently came across an interesting document which speaks to my dating desperation three years ago and also to my dedication to the pursuit of justice.

After a disappointing string of dates with another lawyer, I sought counsel from a friend/lawyer who helped me draft this motion, which I considered filing in the Court of Common Pleas, or at least serving on the Defendant.

(To protect the not-so-innocent, I have changed the Defendant's name, but all other facts remain accurate).

____________________________________
STACY B. HEENAN, IN THE COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY :
Plaintiff, Civil Action No.: 06-12345

v.

JASON R. LAPINSKY

Defendant.
____________________________________



PLAINTIFF STACY B. HEENAN’S MOTION TO COMPEL DEFENDANT JASON LAPINSKY TO PRODUCE THE BRUCE HORNSBY BOX SET


Plaintiff Stacy B. Heenan (“Plaintiff”) hereby moves this Court to enter an Order pursuant to Rule 4019 of the Pennsylvania Rules of Civil Procedure, compelling Defendant Jason R. Lapinsky (“Lapinsker”) to produce the Bruce Hornsby Box Set given to him by Plaintiff on or about November 14, 2006. In support of this Motion, Plaintiff avers as follows:

1. At the end of September, 2006, Plaintiff met Lapinsker while watching the Michigan vs. Notre Dame football game at the sports bar, Fox and the Hound, in Philadelphia, Pennsylvania. Defendant had receding blond hair and blue eyes and in no way matched Plaintiff's "type," but Plaintiff was trying to be open-minded.

2. Soon thereafter, in early October, 2006, Plaintiff and Lapinsker met for a drink at The Continental in Philadelphia. Lapinsker convinced Plaintiff to try hummus for the first time and Plaintiff agreed reluctantly.

3. At the end of October, 2006, Plaintiff and Lapinsker dined at Twenty Manning in Philadelphia. Plaintiff tried the pumpkin ravioli, the first and last “dinner special” Plaintiff ever ordered. Lapinsker sampled the sea bass.

4. On or about November 2006, Plaintiff and Lapinsker dined at Pesto in South Philadelphia. Plaintiff ate gnocchi, Defendant gorged himself on pasta bolognese.

5. In Lapinsker’s car on the way home from Pesto, Plaintiff and Lapinsker discussed Lapinsker’s love of Bruce Hornsby in light of the fact that Plaintiff was to attend an upcoming Bruce Hornsby concert at the Keswick Theater in Glenside, Pennsylvania.

6. On or about November 14, 2006, Plaintiff and Lapinsker hung out at Lapinsker’s apartment to watch the finale of “Dancing with the Starts,” featuring Emmitt Smith.

7. At this time, knowing that Lapinsker was a big Bruce Hornsby fan, Plaintiff gave Lapinsker her only copy of the Bruce Hornsby Box Set (the “Box Set”) she had received from Bruce Hornsby himself at the Bruce Hornsby concert.

8. This Box Set cannot be purchased anywhere. It is a special, limited edition Box Set, which included special live recordings and a dvd, and was given to all ticket-holders at the concert.

9. Plaintiff waited patiently that night for Lapinsker to make a move, yet he only patted her head and then drove her home. Plaintiff vomited approximately 45 seconds after returning home, probably due to the double dose of birth control she had ingested that morning. The extra dosage was in no way related to any events that Plaintiff anticipated occurring at Lapinsker’s residence but was merely to make up for a forgotten dose the day before.

10. In a later phone conversation, Lapinsker told Plaintiff that he had uploaded the Bruce Hornsby cds from the Box Set onto his i-pod and promised to return the Box Set to Plaintiff as soon as possible.

11. On November 18, 2006, Lapinsker met Plaintiff and her friends at the Fox and the Hound to watch the Michigan vs. Ohio State football game. Lapinsker hugged and flirted with Plaintiff.

12. Lapinsker told Plaintiff he had a holiday party to attend in New Jersey that night. Plaintiff told Lapinsker that he should come back after the holiday party at a normal hour to “hang out.”FN1

13. Lapinsker said he would call Plaintiff later and left for the party.

14. That night, Lapinsker called Plaintiff around midnight, but Plaintiff was sleeping.

15. On Sunday, November 19, Lapinsker and Plaintiff talked briefly. Plaintiff was tired and got off the phone around 10pm.

16. Plaintiff emailed Lapinsker Wednesday, November 22, 2006, to wish him a Happy Thanksgiving. Plaintiff loves Thanksgiving and still gets excited to watch the Macy's Day Parade each year.

17. Lapinsker responded to the email, indicating he would call Plaintiff at some point during the long weekend. FN2

18. To date, Plaintiff has not heard from Lapinsker and he has not returned the Bruce Hornsby Box Set as promised.


FN1 Unbeknownst to Lapinsker, Plaintiff had purchased a toothbrush for Lapinsker and several pairs of new, sexy underwear to add to her lingerie collection.

FN2 Again, unbeknownst to Lapinsker, Plaintiff was planning to ask Lapinsker to accompany her on vacation, either to London or Jamaica.



WHEREFORE, Plaintiff Stacy Heenan. respectfully requests this Honorable Court to enter an order directing Lapinsker to produce the Bruce Hornsby Box Set as soon as possible.

Respectfully submitted,



________________________
Stacy B. Heenan

Dated: January 4, 2007


On January 20, 2007, just a couple of weeks after this motion was drafted, my friend bought me a brand new Bruce Hornsby Box Set and I met the love of my life, hereby making this motion moot. However, I think it remains a good warning to all of those single guys out there: don't mess with a single lawyer!

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