State's Objection to Motion For Sanctions Against Tara Heater, Martha Ann Hornick, Keith Cormier and Andrew Livernois.
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Answering a pile of documented accusations with a couple pages of complete BS, Attorney Tara Heater still hasn't provided any affidavits to back up her lies. This is her objection to my latest motion, which basically says she'd like to rely on her objection to the last motion for sanctions. Total laziness and obviously now a matter of being afraid to dig herself deeper.
State's Objection to Motion For Sanctions Against Tara Heater, Martha Ann Hornick, Keith Cormier and Andrew Livernois.
•0 gefällt mir•1,393 views
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Answering a pile of documented accusations with a couple pages of complete BS, Attorney Tara Heater still hasn't provided any affidavits to back up her lies. This is her objection to my latest motion, which basically says she'd like to rely on her objection to the last motion for sanctions. Total laziness and obviously now a matter of being afraid to dig herself deeper.
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State's Objection to Motion For Sanctions Against Tara Heater, Martha Ann Hornick, Keith Cormier and Andrew Livernois.
- 1. STATE OF NEW HAMPSHIRE Grafton, SS. Superior Court State of New Hampshire v. Richard Bergeron Superior Court Case: 211-2019-CR-0163 Charge ID: 1602978C, 1602979C, 1602980C, 1602981C, 1602995C, 1602996C STATE'S OBJECTION TO AMENDED MOTION FOR SANCTIONS NOW COMES the State of New Hampshire, by and through the Office of the Grafton County Attorney, Tara J. Heater, Deputy County Attorney and states as follows: 1. The State is in receipt of Defendant’s Amended Motion for Court Ordered Sanctions. It was received on or about February 1, 2021. 2. The State objects as the issue is Moot. 3. The defendant filed a Motion for Sanctions on or about July 20, 2020. There was a hearing on the Motion held on September 9, 2020. An Order on the Motion was issued October 23, 2020 denying the defendant’s Motion. 4. As the Motion was decided and an Order was entered, the defendant’s Motion to Amend is untimely and should be dismissed as Moot. 5. If the defendant was attempting to file a Motion to Reconsider, it is untimely and should be denied. See N.H.R.Cr.P. 43(a). 6. If the Court finds that the Motion is neither Moot nor Untimely, the State would request an extension of the filing deadline to 10 days after the Order to file a substantive response on the matter. If the Court denies the extension request, the State would incorporate the Objection as previously filed on July 27, 2020 as if more fully set forth herein and ask that those arguments be extended to cover the undersigned and County Attorney Hornick. WHEREFORE, the State requests that this Honorable Court: A. DENY the Defendant's Motion without a hearing; or B. HOLD a hearing on the matter; or Filed File Date: 2/9/2021 10:46 AM Belknap Superior Court E-Filed Document
- 2. C. Grant any other relief deemed proper and just. Respectfully Submitted, STATE OF NEW HAMPSHIRE February 9, 2021 /s/Tara J. Heater _______________________ Tara J. Heater, Esq. Deputy County Attorney NH Bar # 265655 Grafton County Attorney's Office Office of the Grafton County Attorney, 3785 Dartmouth College Highway North Haverhill, NH 03774 (603) 787-6968 CERTIFICATE OF SERVICE I hereby certify that I, or my representative, have served a copy of the foregoing through the New Hampshire Judicial Branch eCourt System on Richard Bergeron, counsel for the defendant. Respectfully Submitted, STATE OF NEW HAMPSHIRE February 9, 2021 /s/Tara J. Heater _______________________ Tara J. Heater, Esq. Grafton County Attorney's Office