CR_Opposition to Bausch and Lomb_Motion2STRIKE_1stBrief_Filled9_2015
Carlos Ramirez Pro Se Opposition to crocked BauschandLomb VRX Motion to Strike the 'Truth'. Motion to Supplement the Record on Appeal with the 11th Cir. Carlos Ramirez Pro Se Opposition to crocked BauschandLomb VRX Motion to Strike the 'Truth'. Motion to Supplement the Record on Appeal with the 11th Cir.
Case: 15-11914 Page: 4 CARLOS RAMIREZ, Pro Se Plaintiff/Appellant, UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT vs. Appeal No. 15-11914-BB BAUSCH & LOMB, INC. Defendant/ Appellee. APPELLANT CARLOS RAMIREZ MEMORANDUM IN OPPOSITION TO DEFENDANT’S MOTION TO STRIKE PORTIONS OF APPELLANT’S APPENDIX AND BRIEF Appellant asks that these facts at issue do not be stricken because; they are part of the truth which, Appellee has avoided by misleading the Judge with a bunch of affidavits presented on its MSJ. Since Appellant has moved as a Pro se Party, he stipulate not being schooled on Law, he hasn’t, intentionally or disrespectfully intend to bypass the local written rules and law related mandates and etiquette; he is just humbling ‘appealing’ a Motion for Summary Judgment granted to the Defendant party. I am answering it with my clean conscious, truth, and evidence. The seeking to trial Appellee Bausch & Lomb inc, at a Federal level has been an uphill process in the quest for truth and justice, and since, I am handling it Pro Se,
Case: 15-11914 Page: 5 during appeal I am using this opportunity to set the record straight and in order to attain that, Appellee’s motion to strike ought to be deny. This Pro Se appeal endeavor was taken with the purpose of finding justice in your Federal Judicial system, as it was, previously, the case at two (2) other instances as it was the case at, the Florida Unemployment Compensation proceeding at which Appelle, legal team of attorneys, produced evidence in the form of document exhibits and, controversial and contradictory oral testimony offered by two of Appellee’s employees; Gordon from Quality and, Callejas from Human Resources which, (compared to their testimony at this litigation) . The second instance it was, an Equal Employment Opportunity Commission complaint that also produced evidence in the form of two written contradictory, letters responses given by Appellee Bausch & Lomb corporate legal department, in reply to the federal agency inquiries. Appellee now seeks the windfall of excluding these well-known documents. Appellee has known for years of these documents, has possession of them. Besides the claims at: the State of Florida Unemployment Compensation and to the Equal Employment Opportunities are public records or somehow accessible to this Court of Appeals and its Judges.
- Page 1 and 2: UNITED STATES COURT OF APPEALS FOR
- Page 3: Case: 15-11914 Page: 3 T.M. Guyer a
- Page 7 and 8: Case: 15-11914 Page: 7 unnecessary
- Page 9 and 10: Case: 15-11914 Page: 9 reason for t
- Page 11 and 12: Case: 15-11914 Page: 11 “…. the
- Page 13 and 14: Case: 15-11914 Page: 13 65, P. 209
- Page 15 and 16: Case: 15-11914 Page: 15 Same entry,
Case: 15-11914 Page: 5<br />
during appeal I am using this opportunity <strong>to</strong> set the record straight <strong>and</strong> in order <strong>to</strong><br />
attain that, Appellee’s motion <strong>to</strong> strike ought <strong>to</strong> be deny.<br />
This Pro Se appeal endeavor was taken with the purpose of finding justice in your<br />
Federal Judicial system, as it was, previously, the case at two (2) other instances as<br />
it was the case at, the Florida Unemployment Compensation proceeding at which<br />
Appelle, legal team of at<strong>to</strong>rneys, produced evidence in the form of document<br />
exhibits <strong>and</strong>, controversial <strong>and</strong> contradic<strong>to</strong>ry oral testimony offered by two of<br />
Appellee’s employees; Gordon from Quality <strong>and</strong>, Callejas from Human Resources<br />
which, (compared <strong>to</strong> their testimony at this litigation) .<br />
The second instance it was, an Equal Employment Opportunity Commission<br />
complaint that also produced evidence in the form of two written contradic<strong>to</strong>ry,<br />
letters responses given by Appellee <strong>Bausch</strong> & <strong>Lomb</strong> corporate legal department, in<br />
reply <strong>to</strong> the federal agency inquiries.<br />
Appellee now seeks the windfall of excluding these well-known documents.<br />
Appellee has known for years of these documents, has possession of them. Besides<br />
the claims at: the State of Florida Unemployment Compensation <strong>and</strong> <strong>to</strong> the Equal<br />
Employment Opportunities are public records or somehow accessible <strong>to</strong> this Court<br />
of Appeals <strong>and</strong> its Judges.
Change language