Posts
From: "Free Assembler"
Subject: about a phone conference and motions to file and timelines
Organization: Lycos Mail (http://www.mail.lycos.com:80)
To: jverlinden@tmklawpc.com
Reply To: freesmokeybear@lycos.com
Dear Joy,
Good morning from Cheryl Gardner, a/k/a Summer Breeze.{this is how most folks know me} I wanted to touch base with you as soon as possible. As yet we have not discussed my case or any strategies. With a court date two and one half weeks away, I feel we are running out of time to prepare motions, to discuss important issues, and to file for pre-trial discovery. It is urgent that we speak Monday or Tuesday so we can begin to line up our mode of operations. Otherwise, the Michigan date for court of March 17 will be upon us and nothing will have been accomplished.
As it is, I have to beg and borrow money just to make the trip.
It will be three to four days for us by bus or train, as our van
is broken down. So that is four to five days not available for document preparation.
Also, as of yet I have received no records from previous Michigan
hearings or filings. As of yet, I have received no records from
the arraignments in Sacramento. I want the court transcript, most
urgently, to cover some events that took place there. Please get this as soon as possible.
I want to preserve my right for a trial by a jury of my peers, absolutely. ...no bench trial. I need to have a motion put in for that.
I have an affidavit in progress and will write a summary of events over the next few days, but first and foremost records are needed, formal notification by the court allowing me the time needed; a conference with you on strategy; and a MOTION TO DISMISS.
I believe a Motion to Dismiss is our first important move. Please
explain the rules of procedure on this for me and give me a timeline to submit this motion as well as all other motions possible in my case. I need to understand the process for obtaining discovery.
Please communicate with Scottie Addison regarding my case. Scottie has important documents and related information directly related to my case. Scottie is a witness for me as well. Please email him at sca@design.org to establish some form of direct communication and please tell me the rules of client attorney privilege (what can we share, what can we not share,etc.).
I will look forward to a reply about some of these concerns on Monday, March 1, 2004. I will review any emails sent to me on Monday and contact you by phone on Tuesday, March 2.
Until then I await instruction from you and will forward whatever
documents will be necessary for a motion to dismiss or to isolate
a list of items to acquire in discovery.
Thank you and have a great weekend.
Sincerely,
Cheryl
(530) 926-3923
freesmokeybear@lycos.com
cc: sca@design.org
GardnersIndustries@now.nu
http://GardnersIndustries.now.nu
http://cosmicmonkey.50megs.com
http://www.angelfire.com/mt/spirit/AngelsofTheLight.html
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http://www.angelfire.com/ut2/peacetest/index.html
P.S. Sending some attached files of documents that might be of interest to prepping the motion to dismiss or other aspects of the case. The attachments will come in subsequent emails.
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