[brief] He next misrepresents at his brief page 8 that Defendant received a fee arbitration letter at the Gorge Road address, when he knows that is false as he conceals from this court that Defendant had counsel [...] of [...].  Mr. Fiorenzo appeared for the entire fee arbitration process, and he received all mail and notices for Defendant and responded to the fee committee.  Next, Defendant misrepresents an appeal of the fee arbitration was “fully briefed and argued. ”  There was no “argument” and the appeal is irrelevant to this matter.  Defendant also misrepresents that an August 27, 2019 substitution was filed to claim Defendant appeared in the case (see Pa16).  Disturbingly, Plaintiff purposely omits numerous pages that were attached to that filing which states it “incorporates by reference in their entirety the attached Certifications of [...] and Honorable [...], both made a part of the record supporting this substitution. ”  Those attachments showed that Defendant objected to personal jurisdiction and that the trial court inappropriately demanded that Defendant file a “substitution” when no prior appearance by Defendant or any counsel was filed for the exact reason that Defendant objected to jurisdiction.  The attorney [...] listed on that “substitution” never filed an appearance as well.  In fact, Plaintiff admits that by his June 3, 2019 letter stating she “has yet to enter a formal appearance in this case (court docket [...]).  Thus, the substitution filed at the demand of the court the day the case was dismissed was not only a special appearance that Plaintiff deliberately omits its attachments proving that, but it also was void as there was nothing to substitute from.  Finally, Plaintiff misrepresents at his brief page 25 that Defendant never sought to withdraw from the fee arbitration within the initial 30-day withdrawal period upon learning of Plaintiff’s legal malpractice.  This misrepresentation is made in direct contravention to the fact that Defendant’s opening brief, page 7, that makes clear Plaintiff’s malpractice and frauds were discovered long after the 3-day initial period as they were discovered the day of the fee arbitration appearance when Defendant for the first time produced documents he fabricated for that hearing.  Thus, the proper procedure was for her to wait for the fee arbitration decision, and if negative then file her counterclaims and affirmative defenses once Plaintiff filed the requisite R 4:67 plenary action.  However, Plaintiff insured that Defendant could not raise her answer, counterclaims and defenses by manipulating the process in refusing to file a R 4:67 action.  Instead, he filed for reinstatement of a dismissed and void complaint where Defendant was prevented from filing an answer, counterclaims and affirmative defenses in the first place as that complaint was dismissed three years before.  Thus, Plaintiff did everything to interfere with Defendant’s due process rights as he manipulated the system, starting with refusing to follow R 1:26-A Pre-Action Notice and ending with refusing to follow it again by filing a R 4:67 action to enforce arbitration where Defendant could have answered.  All of this caused the case to be dismissed before an answer, counterclaims and defenses could be filed, then to Defendant’s detriment the court reinstated the void complaint to prevent Defendant from answering in any way and held her to a fee arbitration decision that only a R 4:67 filing could enforce.