Thread: Don Allen Holbrook IEDC Rogue Former Member / Jeff Finkle Orchestrates Cover-up

Destroy and ruin my professional reputation? What's he a professional of? Blowing smoke up the kisters of taxpayers? Methinks Donny-boy needs to start preparing for his second career, either used-car salesman or WWE "Entertainer". I could hear Vince McMahon right now, "And in this corner, weighing over....well, over-weight, spewing forth blabberistic blubberings, Mr. Perf...I mean MR. MELTDOWN".....LMAO

Originally Posted by pantherdadX2

Destroy and ruin my professional reputation?

It'll be a neck and neck race to see who destroys what first.

At this stage, Mr Holbrook is doing an exceptional job of destroying whatever professional reputation he had left after his string of successive failures without the need for any outside help.

I don't know what came over me.

There I was happily typing away, when suddenly this old quotation sprung to mind:

It' coming down to the wire....and we have a winner, (by a NOSE), the self-trained, stabled in Gepetto's workshop, ridden by Seeberger,and owned by the IRS......SIR GASBAG

How dare you, littleroundman! Obviously it was us vicious internet bloggers and cyber-stalkers from the future (2012) who borrowed Soapboxmom's (that wicked witch of the South) time-travel broomstick and traveled back in time and contributed to those failures! Hast thou forgotten Commandment (#2)< that's a good one....Speaketh not the Supreme Ruler of the Internet's name in vain, lest thou be struck by lightning bolts from his arse! (William Wallace)................dude seriously needs to lay off the Red Zeppelin for a while.

HeHe,

one thing's for sure.

The next time you hear the expression "self destructive" used, I can almost guarantee I know what mental picture immediately springs to mind.

No doubt, littleroundman. The next time I read an article or watch a documentary on the self-destuctive behavior of herion addicts, someone else's image will be clouding my memory bank. signed........no fool

1
IN THE COMMON PLEAS COURT OF MONTGOMERY COUNTY, OHIO
CIVIL DIVISION
CITY OF HUBER HEIGHTS, OHIO
Plaintiff
-vs-
DON ALLEN HOLBROOK, LLC
Defendant
*
*
*
*
*
CASE NO. 12 CV 2947
JUDGE MICHAEL TUCKER
CITY OF HUBER HEIGHTS’ REPLY TO HOLBROOK’S MEMORANDUM
IN OPPOSITION TO THE CITY’S MOTION TO STRIKE
HOLBROOK’S THIRD-PARTY COMPLAINT
A plain reading of Civ.R. 14(A) indicates that a third-party complaint is proper only if
the third-party defendant is “liable…for all or part of the plaintiff’s claim . . . .” It is not an
avenue for asserting independent claims against non-parties to the suit. Nor is it an avenue to
“provide the Court with a more complete picture of the relevant underlying scenario” as
asserted by Holbrook (See Holbrook’s Memo in Opp., 3)—there are many other, less
disruptive, avenues to provide this information. Holbrook’s cited case, Franklin Cty. Dist. Bd.
of Health v. Paxson, 152 Ohio App.3d 193, 2003-Ohio 1331, aptly stated the proper
application of Civ.R.14:
In order to bring a third-party claim under Civ.R. 14(A), the claim must be
derivative of the outcome of the main claim, and the third-party defendant
must be “secondarily liable” or “liable over.” A third-party claim is
ELECTRONICALLY FILED
COURT OF COMMON PLEAS
Tuesday, July 24, 2012 10:43:02 AM
CASE NUMBER: 2012 CV 02947 Docket ID: 17369436
GREGORY A BRUSH
CLERK OF COURTS MONTGOMERY COUNTY OHIO2
inappropriate where the right or duty set forth in the third-party complaint
alleged to have been violated does not emanate from the plaintiff’s claim
but exists wholly independent of it. Thus, “in order to be the proper
subject of a third-party action, the alleged right of the defendant to
recover, or the duty allegedly breached by the third-party defendant, must
arise from the plaintiff’s successful prosecution of the main action against
defendant.” Civ.R. 14(A) does not allow a third-party complaint to be
founded on a defendant’s independent cause against a third-party
defendant, even though arising out of the same occurrence underlying
plaintiff’s claim. Impleader under Civ.R. 14(A) cannot be used to combine
all claims tangentially related to one another. (internal citations omitted).

Simply put, none of the third-party defendants would be liable to Holbrook if the City were successful on any of its claims: This is required under Civ.R.14(A) before conducting the three-part test outlined by Holbrook. (See Holbrook’s Memo in Opp., 4–5). Defendant’s claims do not arise from nor are they derivative to the successful prosecution of the City’s claims. That is, Holbrook’s claims do not depend on the successful prosecution of the City’s claims.

The success or failure of Holbrook’s claims—though tangentially related to the same
occurrence as the City’s complaint—are not dependent on the City’s claims. If the City is
unsuccessful, the third-party defendants may still be liable to Holbrook. And the City’s
successful prosecution of its claims is not required for Holbrook to establish its third-party
claims.

The City’s Motion to Strike is also appropriate because Defendant’s third-party complaint does not promote judicial efficiency. Instead, it causes an increase in multiple
unnecessary parties, causes increased legal issues to resolve (including each of the third-party defendants’ anticipated motions to dismiss), and results in a confusion of the issues. The City’s causes of action focus first on Holbrook’s work product: either it conformed to the contract and industry standards, or it did not. If Holbrook’s work product failed to conform, 3

Holbrook’s pre-contract behavior comes under scrutiny to determine if his conduct supports the City’s tort claims. The testimony of the many third-party defendants does not aid in determining whether Holbrook’s product was conforming nor does it aid in determining whether Holbrook’s conduct was tortious. If Holbrook’s product conformed—Holbrook has no damages and the City would continue to owe under the contract. If Holbrook’s product does not conform—Holbrook’s damages result from the non-conformity not the actions of the third-party defendants.
Even if the third-party defendants are necessary for Holbrook’s defense, their
testimony is not necessary until these preliminary issues are resolved, which makes severance or separate trials appropriate. The point remains, however, that Holbrook’s claims are not dependent on the City’s successful prosecution of its claims—they are independent causes of action.

Thus, the Court should strike Holbrook’s third-party complaint. Though Holbrook’s actions are under scrutiny across the nation, this Court need not resolve Holbrook’s affairs in Texas, Nevada, Arizona, or any other state in which its actions have faced scrutiny. Nor should the City face the increased costs associated with matters of foreign affairs. Even if a reporter contacted the City as alleged by Holbrook, this does not make every news organization scrutinizing Holbrook’s actions a necessary or valid third-party defendant.
4
Respectfully submitted,
/s/ L. Michael Bly___________________
L. Michael Bly (0042074)
Joshua M. Kin (0086965)
PICKREL, SCHAEFFER & EBELING CO.
2700 Kettering Tower
Dayton, Ohio 45423
Telephone: (937) 223-1130
Facsimile: (937) 223-0339
mbly@pselaw.com
jkin@pselaw.com
Attorneys for Plaintiff

Uh, Oh! Could be trouble in Gasbagville...!

A brilliant response
Roman Forest Online Message Board - An Error Has Occurred

Stephen Rorai
Guest

	Re: Latest on Earthquest theme park « Reply #281 Today at 11:04am »
The great wonders of our age; skyscrapers, sports domes, dams, and massive theme parks were conceived, developed, and constructed by visionaries. These intellectual and financial giants had the ability to work beyond the common, the simply ordinary, and create an atmosphere where exceptionality thrived and where their ideas and dreams became reality through the sheer weight of their personalities. It was not enough to receive compensation for the idea, for if that was their goal they would simple go from place to place drumming up support for the ideas, never really caring if it ever went beyond concept. No, these men and woman could not simply develop political stratagems where the landscape would be conductive to it occuring, they completely dominated the social, political, and financial environments ensuring the success of the idea. Sadly, these traits were not part of the psychological make up of the principles who conceived the Earthquest idea so it was doomed from the start. The firms and individuals involved focused on the economic development of this idea at the expense of the final product. Packaging the idea became an end unto itself. Unfortunately, the sucessful completion of the idea has nothing to do with economic development. The measure of their success is only creating the conditions where the idea may be possible, and nothing else. Like locusts they go from place to place consuming the available resources until they are forced to move on, satisfied of a job well done. Our leadership failed to observe the fundamental principles of project management. They had no real experience on how to proceed past the concept stage with a project of this magnitude and failed to secure an individual with extensive, and relevant, expertise in the field of theme park construction. I guess they thought their little band of fools was up to the task. Their arrogance, and greed, blinded them to their ignorance, condemning the project to an epic failure and putting the taxpayers of the district on the hook to pay back millions of dollars worth of bonds with absolutely nothing to show for it.

Hi Stephen Rorai,

Could not have said it better myself.

Originally Posted by Soapboxmom

A brilliant response
Roman Forest Online Message Board - An Error Has Occurred

This must be Holbrook's Biographer, talk about a spot-on analysis...!

My only question is will Don now ammend his lawsuit to add Stephen Rorai to his list of defendants?

Don's lawsuit keeps reminding me of Dwight Schweitzer and Todd Disners lawsuit in the ASD Case. Totally without merit and taking up valuable court time for the absurd ego of the Plaintiff's.

Hmm, now I wonder if I will be added for making fun of Don's lawsuit?

Originally Posted by EagleOne

My only question is will Don now ammend his lawsuit to add Stephen Rorai to his list of defendants?

Don's lawsuit keeps reminding me of Dwight Schweitzer and Todd Disners lawsuit in the ASD Case. Totally without merit and taking up valuable court time for the absurd ego of the Plaintiff's.

Hmm, now I wonder if I will be added for making fun of Don's lawsuit?

He can't push his way past 'fred mann' who is allegedly in the front of the line. LOL!

Though Holbrook's actions are under scrutiny across the nation.......EPIC!!! By the time he's done shooting himself in the foot repeatedly, his actions will be under world-wide scrutiny. Nice of ya'll to hook your boxcars up to the Holbrook Lawsuit (Runaway) Freight Train, Stephen and EagleOne. We don't know if Don and Sue can handle the extra baggage, though, they're huffing and puffing already!

The nutbag patrol is weighing in again:

SueHeatherPaulDobrott --- 4 hours ago - quote - hide comments Heather there are no state lines when committing
Multiple crimes on the Internet. The many actions from you and your members against Don and many others are criminal in more than one state and in other countries. When Don is done with you and your members the intel is the Feds are next. Also in consulting be aware that all members of your website are going to have their real names exposed including little round man, professor Henry Higgins and the others who hide and commit cyber crimes. It must be horrible to be you. All will be out in the open. Isn't that the way you like it.

The Feds are going to come after the very people that work with them to stop crime????

intel is the Feds are next.

O.K. NOW, I'm amused:

vig·il: /ˈvijəl/

Noun:

A period of keeping awake during the time usually spent asleep, esp. to keep watch or pray. A stationary, peaceful demonstration in support of a particular cause, typically without speeches.

antis: plural of an·ti

Noun:

A person opposed to a particular policy, activity, or idea.

I'm ashamed to say someone from this neck of the woods even posted that comment. Apparently this bored little troll's latest issue of Weekly Reader or Highlights For Children hasn't arrived in the mail yet. (note to mother of bored little troll) Will you PLEEASE take your daughter to the mall to see a movie, buy a new training bra, bag of lollipops,......Good Lord, SOMETHING!

SueHeatherPaulDobrott --- 2 hours ago - quote - hide comments Omg. Lmao. You work with the Feds. You will eat those words. The Feds can't stand vigil antis.

You break laws to harrass people. Remember this, all members hiding will be exposed. Then they can defend their actions. You can insult all day but your little site has been copied. Every little word and has been sent to many. They will be exposed just like you were Doc.

Don Holbrook's fan club has the most charming of members. Mad taxpayers and every nut out from under their rock. Holbrook is going to have a marvelous time!

Soapboxmom

Especially those morons who wear rediculous robes. Who are they? The Templar Knights? Just think, had Sir Gas Bag wore that rediculous robe and a hood with it to the Jasper Co. city council meeting in East Texas, they would have mistaken him for a Grand Wizard of a different organization, and EarthQuest would have been up and running in no time.(Just my opinion, I USED to own property near there)

Originally Posted by SueHeatherPaulDobrott

all members of your website are going to have their real names exposed including little round man,

YAY !!!!!

My efforts on the forum aren't in vain.

I got a mention.

Now all I need is a list of all this criminal activity in which I'm supposedly involved and my day will be complete.

It's funny, but, in my world, "criminal" proceedings and "civil" proceedings are quite different beasts.

I'm not really into watching TV, so I I've quite probably missed the episode of "Law and Order" from which Mr/Ms "SueHeatherPaulDobrott" gained his/her legal training and expertise.

P.S. "SueHeatherPaulDobrott" for when you get around to having your favourite friendly neighbourhood "Fed" knock on my door, that would be "Australia" as in Crocodile Dundee and kangaroos, not "Austria" as in William Tell and apfelstrudel.

P.S.S. "SueHeatherPaulDobrott" when it gets closer to the day, have your people ring my people and we'll arrange to do lunch and swap specific addresses.

There was an old Buddy Holly song that covered this situation...That'll be the day - buddy holly - YouTube

I was beginning to feel left out, but then saw where they said "all" members of this forum would be exposed with their real names. Now I feel all warm and fuzzy inside as I am included as a vigil antis, as I would hate to miss out on all the fun.

Considering that only a tiny fraction of the total registered members have ever posted in one of the Holbrook threads, I wonder how they would rationalize that should one of the majority members take offense at such a revelation? Of course, the likelihood of this Sue person managing to figure out who even 10% of the members actually are without hacking is astronomical odds.

And as I've commented in the past, I'm not involved with the Heather vs. Holbrook matter, so if someone drags me into it, I won't be polite.