Dear Sir/Madam:

            Please accept this concise reply relative to said case.

     Despite the fact, that the opposition filed by the defense is [not] complying with the Rules of this Court, [i]t remains without merit [i]f not frivolous at best.

     Since the Defendants have failed to demonstrate or even mention to this Court how the core and substantial findings of the Order under appeal can survive legitimacy in the absence of the transportation company imposed within [,] the Court can explain to the entire world how the Order under review can stand in light of that undeniable fact. What, if any, other question or general public importance that should be settled by the Supreme Court or calls for an exercise of the Supreme Court's supervision, or where the interest of justice requires more than the one at hand here –––– For this reason, this reply will [b]e published to the outside world to give them a glance of how the American Rule of Law really function in real operation where [t]he publishers out there love Abulkhair's "strong" language.

     By desperately maneuvering with their imagination regarding "amounts potentially owed by plaintiff to PLIGA", which does [not] exist, not only disparaged the court and its legal proceeding, but also implied, not very subtly, that Defendants had manufactured their allegation and then repeated it in their useless effort to deceive or trick the Court together with the Plaintiff and to eventually defeat the petition as they did with the motion. The simple question must be asked, where [is] their proof of double payments? Defendants' evidence is [absent] from the record below and above in order to support such [a] useless claim. Likewise, there is [no] application filed in any court concerning their assertion from the entire records. This Court must send its own investigator to the lower court to find where their application since the Petitioner has never been served with such [a] mysterious application. The graduate law school, the "Officer of the Court", should have learned there, that this kind of claim must be addressed in [a] special forum where the third party who went [out] of business [must] come [t]o court to provide [t]he evidence concerning the payments of both parties. This forum must [not] be taken advantage of totally different motion concerning varies reliefs that [h]ad nothing to [do] with Defendants' claim in [t]he absence of their application. [T]here is [NONE]. Abulkhair's motion reach[ed] its conclusion in lower court [.] The burden of proof here lie[s] (solely) on the Defendants [t]o submit their evidence, [not] the Petitioner to be caught between two "professional liars", [a] corrupt strayed judge and [a] deceptive manipulated counsel, who dragged [a] simple reimbursement of ($167.92) with her clients to what [w]e face now in order [t]o benefit herself and her firm at the expense of Abulkhair and the judiciary.  

     On the other hand, this petitioner/patient has not visited his orthopedist since (December 2014), and stopped his physical exercise at the gym since July 15, 2015 directly caused by this awkward saga created (only) by Defendants' failure and the (wrong) determination under review. According to the cafeteria manager located on the same floor adjacent to the transportation company in question, "[T]hey are [out] of business since March or April", where the Order under appeal was entered (June 22, 2015) [Db1] to impose the service of the same company. [H]ere [are] the disconnected listed phones and fax for service:

     T. (201) 935-7900, (201)646-1010 & F. (201)646-1255.    

     [W]e have warned the Court carefully prior to its entry of [t]he "void" Order concerning the possibility of this particular company going out of business because [w]e can read and see what of the arrogant, ignorant philosophers of law cannot [.] But as usual, the arrogant judges would not listen nor care [.]

     In his letter dated (May 7, 2015) addressed and faxed to the Court before entering the Order under appeal exhibited as (A-4) within the record below, Petitioner Abulkhair argued [:]

"[R]egardless, what [i]f the chosen company goes [out] of business?  Abulkhair then would have to waste another $500 from his pocket and to deprive himself from his valuable time to repeat the same scenario.  [T]his will [be] the wrong ruling that [no] reasonable person could or accept [.]"

     Therefore, this Court has the absolute duty and obligation to educate this litigant and the whole world [h]ow could [h]e ride with [a] transportation company that went [out] of business   several months before issuing the unlawful Order [.] Otherwise, [i]t would make [a] mockery of the entire "American Judicial System", state and federal alike that rest[s] for the rest of their remaining existence [.]

With that in mind, the fraudulent "void" Order must not stand in the eye of the Law and the Rule of Law.

Respectfully submitted,

By:  /s/ Assem A. Abulkhair, Pro Se