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7
_______________________________________________________________
Reply to Defendants' Opposition to Plaintiff's Motion to Reconsider Court's 7/24/2003 Ruling
III CONCLUSION
Plaintiff respectfully requests the Court to:
Vacate its July 24, 2003 Ruling in its entirety.
Award plaintiff the sum of $3,699.00 in legal fees for an excess of 100 hours actually
spent by her on her Motion for Protective Order.
Award plaintiff all costs incurred to file her Motions for Protective Order, Motion to
Reconsider, and Applications for Ex Parte Hearings.
Impose sanctions against defendants for noncompliance with the discovery process,
for submission of false statements to the Court and for refusal to reasonably
accommodate plaintiff's disability.
Grant a protective order requiring defendants to comply with the letter and spirit of
California law regarding reasonable accommodation of plaintiff's disability,
discovery, and In Pro Per status.
Grant a stay in responding to defendants' 1st Set of Interrogatories and Inspection
Demand until completion of Secretary Contreras-Sweet's deposition and other
related discovery.
Grant an order that Secretary Maria Contreras-Sweet be compelled to attend and
cooperate at her deposition pursuant to the time, date and location of formal notice in
San Diego County.
Grant an order that defendants pay all costs associated with the taking of Secretary
Contreras-Sweet's deposition.
In the alternative, plaintiff respectfully requests the Court to stay its July 24, 2003 Ruling to
permit her to file an immediate appeal.
Executed on this 19th day of September, 2003 at Encinitas, California.
______________________________
Jacquelyn Finney, Plaintiff
In Pro Per
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