Opinion
1:20-mc-00381-KPF
08-27-2021
Nationwide Judgment Recovery Inc., Plaintiff, v. Luigj Berishaj, Defendant.
DEFENDANT'S MOTION FOR REHEARING
HON. KATHERINE POLK FAILLA, UNITED STATES DISTRICT JUDGE
Defendant, LUIGJ BERISHAJ, hereby files pro se and states as follows:
1. Defendant was not adequately represented during show cause hearing on August 20, 2021, at 11:00am.
2. Defendant has not waived his right to representation by counsel.
3. The exemption notice provided by Chase Bank as required by the state law of New York includes earned income in the last 60 days (90% of which may be exempt). Such exemption of bank account assets was not asserted in Defendant's position at said hearing.
4. In Defendant's Response to Plaintiff's Objection to Defendant's Claim of an Exemption, Defendant provided proof of income derived from wages within the last 60 days dating from March 22, 2021 through May 22, 2021, in the total amount of $39, 118.02.
5. Defendant requests a motion for rehearing in this matter to have these issues relitigated by counsel.
Luigj Berishaj, Defendant
Application GRANTED. The parties are hereby ORDERED to appear for a telephonic conference on October 22, 2021, at 2:30 p.m. At the specified time, the parties shall call (888) 363-4749 and enter access code 5123533. Please note, the conference line will not be available prior to 2:30 p.m.
The Clerk of Court is directed to mail a copy of this endorsement to Defendant's address of record.
SO ORDERED.