Abraham v. Leigh et al

Filing 795

MEMO ENDORSEMENT denying 794 Motion re: 794 MOTION To File Additional Exhibits with Sur Reply by July 28 2023 . ENDORSEMENT: Application DENIED. The bench trial that is the issue of thisorder to show cause and Counter-Claim Def endant's responses wasthree months ago, and Counter-Claim Defendant has had ampleopportunity to submit evidence to this Court. Counter-ClaimDefendant is clearly aware of the Court's June 29, 2023 Order(Dkt. #793) directing the filing of a s hort reply by July 21,2023, as it is cited in her above motion. Counter-ClaimDefendant has had three weeks to prepare a reply with fullunderstanding of the Court's indication that it will not extendthis deadline. This last-minute request, filed on the eve ofthat July 21, 2023 deadline, offers no real justification for anextension, and is therefore denied.Consistent with the Court's prior Order at docket number 793,Counter-Claim Defendant may submit a reply by the end of the daytoday, J uly 21, 2023. As ordered, the Court will not considerany additional exhibits, nor any submission longer than tenpages. Should Counter-Claim Defendant fail to submit a timelyresponse, the Court will consider the issue fully briefed.The Clerk of Court is directed to terminate the pending motionat docket number 794.. (Signed by Judge Katherine Polk Failla on 7/21/2023) (rro)

 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

ROBYN ABRAHAM
Plaintiff / Counter Defendant

MEMO ENDORSED
Case No. 17-cv-5429 (KPF)

v.
ABBY LEIGH., et al.,
Defendants/ Counter Plaintiff
___________________________________________/
PLAINTIFF'S MOTION TO FILE EXHIBITS WITH SUR REPLY BY JULY 28, 2023 TO
DEFENDANT'S REPLY TO PLAINTIFF'S MAY 2, 2023 CEDARS SINAI BEVERLY
HILLS HOSPITALIZATION
Plaintiff/Counter Defendant Robyn Abraham1 files this Motion Requesting Authorization to File
Confirming Responsive Exhibits With Plaintiff's Sur Reply In Accordance with the Federal Rules
of Evidence and all Due Process Requirements and in support states as follows:
1. On May 2, 2023, this Court issued its Fourth (4th) Order to Show Cause Against Plaintiff, this
time for being hospitalized at Cedars Sinai Hospital in Beverly Hills California following the
recent premeditated felony murder of Plaintiff's mother Joyce Olshen Abraham, which confirmed
premeditated felony murder of Plaintiff's beloved Mother specifically was threatened against
Plaintiff in this $250 Million breach of contract case filed on Plaintiff's behalf by Plaintiff's
former Arnold and Porter New York counsel.
2. Notwithstanding receipt of former Defendant Alan Honig's filed Declaration that remaining
Defendant Leigh intentionally committed fraud against Plaintiff in this case, this Court
previously issued Three Prior Orders to Show Cause only against Plaintiff, including an Order to
Show Cause Ordering Plaintiff pay Court Reporter Fees Never Previously Served or Mailed to
Plaintiff and Two Separate Orders to Show Cause, Ordering Plaintiff to Withdraw Valid Bar
Complaints for Blackmail and Extortion of Plaintiff's Partial Six Figure Settlement Funds by a
Washington DC Political lobbyist who Never was Plaintiff's attorney and which Bar Complaints
1

As confirmed by NYSD court record, both Plaintiff's prestigious British Schillings law counsel and the New York
office of Arnold and Porter confirmed Plaintiff successfully closed this $250 Million business contract. In 2019, Two
(2) of the Three (3) Defendants settled in Plaintiff's favor. Former Defendant Alan Honig provided a filed
Declaration that remaining multimillionaire Defendant Leigh Committed Fraud against Plaintiff in This Case.

specifically were recommended by both New York Bar Ethics Counsel and the Washington DC
Bar Ethics Counsel.
3. The Court repeatedly has been noticed with confirming medical evidence that Plaintiff suffers
from a serious congenital heart defect, which serious heart defect is exacerbated by stress and
illness.
4. The Court also has been noticed that Plaintiff was diagnosed as COVID positive shortly prior
to May 2, 2023.
5. On May 2, 2023, from her hospital bed at Cedars Sinai Hospital in Beverly Hills and as stated
on court record and confirmed via contemporaneous May 2, 2023 emails and court video to and
from the Court filed while Plaintiff was hospitalized on May 2, 2023, Plaintiff immediately and
repeatedly advised the Court and opposing counsel that the court provided 'video link' to
watch or see the May 2, 2023 Bench Trial was inoperable.
6. On May 2, 2023, the Court spoke directly to Cedars Sinai Hospital staff who confirmed that
Plaintiff was hospitalized in the Emergency Room at Cedars Sinai Hospital.
7. Whilst Plaintiff has attempted in good faith to obtain additional confirming medical
documentation from Cedars Sinai Hospital, Plaintiff has not been able to obtain further
information as of this date.
8. On June 29, 2023 (Docket 793), this Court issued an Order prohibiting Plaintiff from filing
any Exhibits to defend the false claims against her.
9. Pursuant to the Federal Rules of Evidence and Due Process requirements, including but not
limited to Federal Rule of Evidence 103, Plaintiff should be allowed to present all relevant
evidence applicable to her defense.
10. Defendant Leigh will not be prejudiced by the presentation of relevant evidence confirming
Plaintiff's necessary May 2, 2023 Emergency Hospitalization at Cedars Sinai Hospital in Beverly
Hills.
Wherefore Plaintiff/Counter Defendant Robyn/Abraham respectfully requests the Court to
Grant Plaintiff/Counter Defendant's Motion to file additional Exhibits with her Sur-Reply
to be provided by July 28, 2023.

Dated: July 20, 2023
Los Angeles, CA

Respectfully Submitted,
/s/ Robyn Abraham, Esq

CERTIFICATE OF SERVICE
I Hereby Certify that a True and Correct Copy was served on Counsel of Record via ECF as of
July 20, 2023
Robyn Abraham, Esq.

Application DENIED. The bench trial that is the issue of this
order to show cause and Counter-Claim Defendant's responses was
three months ago, and Counter-Claim Defendant has had ample
opportunity to submit evidence to this Court. Counter-Claim
Defendant is clearly aware of the Court's June 29, 2023 Order
(Dkt. #793) directing the filing of a short reply by July 21,
2023, as it is cited in her above motion. Counter-Claim
Defendant has had three weeks to prepare a reply with full
understanding of the Court's indication that it will not extend
this deadline. This last-minute request, filed on the eve of
that July 21, 2023 deadline, offers no real justification for an
extension, and is therefore denied.
Consistent with the Court's prior Order at docket number 793,
Counter-Claim Defendant may submit a reply by the end of the day
today, July 21, 2023. As ordered, the Court will not consider
any additional exhibits, nor any submission longer than ten
pages. Should Counter-Claim Defendant fail to submit a timely
response, the Court will consider the issue fully briefed.
The Clerk of Court is directed to terminate the pending motion
at docket number 794.

SO ORDERED.
Dated:

July 21, 2023
New York, New York
HON. KATHERINE POLK FAILLA
UNITED STATES DISTRICT JUDGE