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motion for leave to file surreply

April 9, 2023 banish 30 vs omega

This site uses cookies, I think, but only to check whether you have voted in a Lowering the Bar poll or something like that. WHEREFORE, Defendants respectfully request that the Court grant it leave to file a Surreply, which proposed filing, with accompanying affidavit, is attached hereto as Serves you right. These links are provided for the user's convenience. %%EOF _______________"/s/"________________ Robert L. McGeorge Tracey D. Chambers Janet R. Urban Andrew K. Rosa John R. Read Trial Attorneys U.S. Department of Justice Antitrust Division, PROPOSED ORDER FOR LEAVE FOR PLAINTIFF UNITED STATES TO FILE A SURREPLY. Webinfringement, defendants motion to strike the expert report of Dr. Traylor, plaintiffs motion for leave to file a surreply and defendants motion for leave to file a surreply. Plaintiff later filed a motion for leave to file a surreply in response to Defendants reply brief [77]. >> Local Rule 7.1.A.3, counsel for the parties conferred prior to the filing of this motion. The site is secure. /Resources 33 0 R WebRule 27. Documents Filed Under Seal Rule CV-7. Now, themotion for leave usually isthe surreply, basically, because youre saying, hereswhat Id file if you let me, your Honor, see how persuasive it is. She agrees or she doesnt agree. West Palm Beach, FL33411 /Length 35 0 R Bankruptcy Local Rule 9006-1 also provides that a motion for leave to file a late reply may be filed, and, if so filed, the Court will consider the motion for leave at the hearing on the underlying motion papers. Bankr. An application for an order or other relief is made by motion unless these rules prescribe another form. endstream endobj startxref The cookie is used to store the user consent for the cookies in the category "Other. Would they? /Type /Pages Each side gets to make its arguments, and the moving party gets the last word. Court cases can be very complicated, and even if you are representing yourself, you should see a lawyer for legal advice as to how the law applies to you, and what is best for your particular situation. endobj Filing 3 . The Motion for Leave to File a Surreply Should Not Be Granted Contrary to the DEAs assertions, EPIC did not raise new facts or arguments, and this Court should not grant WebOn January 12, 2016, Plaintiff filed a motion seeking leave to file a Surreply to respond to two new cases relied upon by Southfield Defendants in support of their motion to strike Plaintiffs Second Amended Complaint. (D.E. Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features. Choose Responses and Replies from the main Civil menu and then select one of the following events, as appropriate: After attaching your document, the system will show a list of all pending motions. 20 ORDER GRANTING IN PART AND DENYING IN PART MOTIONS TO COMPEL AND FOR %PDF-1.5 % 5.1.1. /Contents [18 0 R 19 0 R 20 0 R] Commencement of Action Rule CV-5. Nosso objetivo garantir a satisfao e sade de nossos parceiros. These cookies ensure basic functionalities and security features of the website, anonymously. Click on the following link to access the forms in Word and to download them in other languages: For a complete set of the CPO Forms in both Word and pdf formats, please click on the following link to the Ohio Supreme Court Website: Motion for Contempt and Statement - Uniform DR Form 21.pdf, Statement of Health Insurance - Uniform DR Form 4.pdf, Parenting Proceeding Statement - Uniform DR Form - Affidavit 3.pdf, Statement of Property - Uniform DR Form 2.pdf, Statement of Income and Expenses - Uniform DR Form 1.pdf, Information for Parenting Proceeding Affidavit - DV Form 10.01-F.pdf, Petition for Domestic Violence Civil Protection Order - DV Form 10.01-D.pdf, Affidavit 2: Affidavit of Property and Debt, Health Insurance Affidavit(Uniform DR Form 4), Affidavit 5: Motion and Affidavit for Temporary Orders Without Oral Hearing, IV-D Application for Child Support Services, Order Converting Dissolution to Action for Divorce - Word, Order Converting Divorce Action to Dissolution - Word, Required Language for Child Support, Spousal Support and Health Insurance Orders, Financial Disclosure/Affidavit of Indigence, Motion, Entry & Certification for Appointed Counsel Fees, Notice of Registration of Foreign Support Order - Word, Notice of Registration of Multiple Foreign Support Orders, Judgment Entry Confirming Registration of Foreign Support Order - Word, Notice of Registration of Foreign Custody Order - Word, Judgment Entry Confirming Registration of Foreign Custody Order - Word, Application for the Appointment as Standing Process Server - Word, Motion & Order appointing Process Server (one-time appointment) - Word, Request Affidavit & Order for Service by Posting*- Word, Request Affidavit & Order for Service by Posting of Civil Protection Orders*- Word, Legal Notice for Posting of Civil Protection Orders*- Word, Application/Resume to Serve as Guardian ad Litem, Request for Appointment of Foreign Language Interpreter, Order Appointing Foreign Language Interpreter - Word, Request for Appointment of Sign Language Interpreter, Order Appointing Sign Language Interpreter - Word, http://www.supremecourt.ohio.gov/JCS/CFC/DRForms/default.asp, Complaint for Divorce Without Children (Uniform DR Form 6, Counterclaim for Divorce Without Children, Counterclaim for Divorce With Children (Uniform DR Form 9), Reply to Counterclaim for Divorce Without Children, Reply to Counterclaim for Divorce With Children, Judgment Entry - Decree of Divorce Without Children, Judgment Entry - Decree of Divorce With Children, Judgment Entry Converting Interest in Real Estate(Uniform DR Form 16) - Word, Petition for Dissolution of Marriage and Waiver of Service Summons (Uniform DR Form 17), Judgment Entry - Decree of Dissolution of Marriage (Uniform DR Form 18) - Word, Complaint for Parentage, Allocation of Parental Rights and Responsibilities and Parenting Time, Motion for Contempt and Affidavit and Instruction for Service, Motion for Change of Parental Rights and Responsibilities, Motion for Change of Child Support, Medical Support, Tax Exemption, or Other Child-Related Expenses, 10.01-A GENERAL INFORMATION ABOUT DOMESTIC VIOLENCE PROTECTION ORDERS, 10.01-C INFORMATION ABOUT FILING A DOMESTIC VIOLENCE OR DATING VIOLENCE CIVIL PROTECTION ORDER PETITION, 10.01-D PETITION FOR DOMESTIC VIOLENCE CIVIL PROTECTION ORDER (R.C. 2013) (granting leave to file surreply over defendants objection where surreply will allow the Court to more fully and fairly evaluate Defendants pending motion, is relatively short, [and] challenges Defendants interpretation and application of newly-cited caselaw). Pursuant to Local Rule 1.10, the United States -- the Plaintiff in this action -- hereby moves for leave to file the attached Surreply and Memorandum of Points and Authorities. Choose Responses and Replies from the main Civil menu and then select Reply to Response to Motion. Webthe Debtors could not file the Reply prior to the Reply Deadline. WebTable of Contents U.S. District Court of Maryland Local Rules (July 1, 2021) i TABLE OF CONTENTS I. They stated that they do not take a position on the motion for leave to file a Surreply. Further, the inclusion of links is not intended to reflect their importance or to endorse any views expressed, or products or services offered, on these outside sites, or the organizations sponsoring the sites. Sarasota, FL34231 24 at Pg ID). 75, 80 (D. Del. /CreationDate (D:20150203220056Z00'00') WebORDER ON MOTION FOR LEAVE TO FILE SUR-REPLY THIS CAUSE is before the Court upon Plaintiffs Motion for Leave to File Surreply to Defendants Reply to Motion to Dismiss Count I of Plaintiffs First Amended Complaint, ECF No. The judge said fine, just attach the questions and answers instead. WebPETITIONERS MOTION FOR LEAVE TO FILE SURREPLY IN OPPOSITION TO MOTION TO COMPEL Petitioner Federal Trade Commission (Commission or FTC) Filing Documents Under Seal 4 . WebTO MOTION FOR LEAVE TO FILE SUR-REPLY Counterclaim-Plaintiff GS Labs LLC (GS Labs) opposes the motion for leave to file sur-reply by Blue Cross and Blue Shield of Kansas City (BKC), ECF No. But sort of. To be fair, this was a motion to compel, and a local rule requires all relevant questions and answers to be included in the brief. All fairly standard, except maybe for the exhibits. /Annots [] << Plaintiff responded, and Defendants replied. Certificate of Service for Paper Filings. This The Court has indulged the parties abusive litigation tactics for long enough, she wrote in a July 19 order. contact this location, Window Classics-Tampa Plaintiffs motion (ECF No. WebPLAINTIFFS MOTION FOR LEAVE TO FILE SURREPLY Plaintiffs respectfully request permission to file a short (eight-page) surreply brief in opposition to Defendants motions to dismiss. >> WebShould Be Allowed To File A Similar Surreply . /Type /Catalog In support of this motion, the Objectors state as follows: 1. 455) and upon plaintiffs Motion for Leave to File Surreply to Defendants Reply Memorandum in Support of Motion to Compel (Doc. [35] (Motion), filed on May 12, 2022. But opting out of some of these cookies may affect your browsing experience. Plaintiff proposed Surreply merely clarifies the evidence already in the record. 933 0 obj <>stream I. /Resources 25 0 R Therefore, if you feel that a surreply is warranted, you must file a motion requesting leave to file a surreply as soon as possible and attach the proposed surreply to the motion for the court's consideration. Usuallymorethan enough. This might save you time, money, trips to the courthouse, and help you avoid serious mistakes. << Motions for leave to file a reply and surreply are not necessary for a Rule 56 motion because replies and surreplies are automatically allowed. /MediaBox [0 0 612 792] contact this location, Window Classics-West Palm Beach 9Ub; W Plaintiff said it couldnt do that and also fit everything into 24 pages. The proposed brief is attached as Exhibit A. Pursuant to Rule 7(m), the undersigned counsel conferred with counsel for Defendants, who /Kids [4 0 R 5 0 R 6 0 R 7 0 R 8 0 R 9 0 R] I hereby certify that I have caused a copy of the foregoing document to be served on the following counsel for Defendants by first class mail, postage prepaid and facsimile transmission: U.S. v. LSL Biotechnologies, Inc., et al. A .gov website belongs to an official government organization in the United States. There is such a thing as asurreply, or a reply to the reply. Check the motion(s) to which your reply relates do not link to the Response. WebDefendants leave to file a Surreply, as Plaintiffs Reply sets forth new evidence and proposes a new remedy, to which Defendants should have the opportunity to respond. >> Which is why Plaintiff filed a motion for leave to file a surreply to it. On April 13a Fridaythe plaintiff in V5 Technologies v. Switchasked for permission to file 108 pages. endstream WebHowever, leave of Court is required to file surreply briefs regarding motions for summary judgment. Two of those cases, including one which the United States believes supports our position, were issued after the United States submitted its Opposition. Samsung Elecs. WebTO MOTION FOR LEAVE TO FILE SUR-REPLY Counterclaim-Plaintiff GS Labs LLC (GS Labs) opposes the motion for leave to file sur-reply by Blue Cross and Blue Shield of WebDefendants Motion for Leave to File Surreply (ECF No. << 2781 Vista Pkwy N Ste K-8 /Annots [] 4141 S Tamiami Trl Ste 23 490). An official government website. The Surreply Is Procedurally Improper. The Defendants filed a Motion to Dismiss this action on December 5, 2000; the United States submitted its Opposition on February 2, 2001; and the Defendants filed their Reply on March 20, 2001. Other uncategorized cookies are those that are being analyzed and have not been classified into a category as yet. The motion provides as follows: On 11/14/12, counsel for Schramm appealed the denial of the claim to this Court by filing a Notice of Appeal and Petition and Complaint. As part of the public service I provide, I have counted up the number of pages that were written, rewritten, printed, scanned, and/or filed by the lawyers during this titanic struggle, and, including exhibits, that number is 1,749. The U.S. District Court for the District of Maryland does not control or guarantee the accuracy, relevance, timeliness, or completeness of this outside information; nor does it control or guarantee the on-going availability, maintenance, or security of these Internet sites. Bill Would Establish Official State Aroma, Judge: F-Word No Longer Has Sufficient Shock Value to Be a Problem at Work, Canadian Democracy Survives Cinnamon-Bun Scandal, UPDATE: Auto Insurer May Not Have to Pay for Back-Seat Transmission, Congratulations on Not Catching Jack the Ripper, Surveillance-Camera Thief Captures Complete Record of His Crime, French Court Recognizes Basic Human Right Not to Be Fun, DSUWI (Driving Something Unusual While Intoxicated), Sheriff: We Need Armored Vehicles to Intimidate People, California Supreme Court Rules In Tasters Case, 153rd Time is the Charm for Frequent Arrestee, Bulgaria Suffering From Too Much Democracy; Must Import Envelopes to Hold It All, Man Beaten With Own Leg by Leg-Wielding Girlfriend. Almost always, the standard briefs are enough. /MediaBox [0 0 612 792] 924 0 obj <>/Filter/FlateDecode/ID[]/Index[910 24]/Info 909 0 R/Length 74/Prev 784305/Root 911 0 R/Size 934/Type/XRef/W[1 2 1]>>stream Secure .gov websites use HTTPS 94). 4. L.R. NAR shall provide the discovery allowed by this order w/in twenty-one (21) days. /MediaBox [0 0 612 792] I. /Length 34 0 R /Resources 21 0 R x\r8}W#]pHo*8G[S$lDon*MAI. This cookie is set by GDPR Cookie Consent plugin. Tel: (11) 3538-1744 / 3538-1723 - Fax: (11) 3538-1727 General Format of Papers Presented for Filing 3 . The Liquidator does not object to the Objectors' request for leave to file a surreply. The disaster itself began to unfold the following week, when Plaintiff filed the motion itself. 148, relative to a pleading that (1) was timely filed under the Courts amended scheduling order, ECF No. The .gov means it's official Then Defendants replied again, filing a corrected copy of the previous reply, or possibly filing a different document they meant to file the day before, which would suggest they too had completely lost track of what was going on. To file a response to a motion, follow the standard filing procedure. Check the motion(s) to which your response relates, and continue as you would for filing any other document. endobj WebCivil Rules, Local Court Rules for the Western District of Texas Rule CV-1. You also have the option to opt-out of these cookies. Amendment of Pleadings Rule CV-16. 9. WebPLAINTIFFS MOTION FOR LEAVE TO FILE SURREPLY The Plaintiffs in the above-captioned case, through counsel, respectfully move for leave to submit the attached Surreply in response to new arguments and factual claims made by Defendants Disclaimer: Some links on this page may contain information created and maintained by other public and private organizations. endobj The motion to dismiss is fully briefed and pending. (b) Motions. endobj /Title (Microsoft Word - EPIC-Opp-Surreply) Motion for Contempt and Statement - Uniform DR Form 21.pdfStatement of Health Insurance - Uniform DR Form 4.pdfParenting Proceeding Statement - Uniform DR Form - Affidavit 3.pdfStatement of Property - Uniform DR Form 2.pdfStatement of Income and Expenses - Uniform DR Form 1.pdfInformation for Parenting Proceeding Affidavit - DV Form 10.01-F.pdfPetition for Domestic Violence Civil Protection Order - DV Form 10.01-D.pdf, Click on the following link to access the forms in Word and to download them in other languages: http://www.supremecourt.ohio.gov/JCS/CFC/DRForms/default.asp, For a complete set of the CPO Forms in both Word and pdf formats, please click on the following link to the Ohio Supreme Court Website:CPO Forms, Affidavit 1: Affidavit of Basic Information, Income, and Expenses, Poverty Affidavit & Order Seeking Court Appointed Counsel, Request, Affidavit & Order for Service by Publication, *Posting can only be used in association with a Poverty Affidavit, Poverty Affidavit & Order Seeking Waiver of Deposit. /ModDate (D:20151008160901-04'00') /Contents [26 0 R 27 0 R 28 0 R] The standard page limit for motions filed in the District of Nevada is 24 pages, which is oddly specific but perfectly reasonable. Undo Vote Helpful Undo Unhelpful Undo. The cookie is used to store the user consent for the cookies in the category "Analytics". You dont fully brief it. There are lawyers who will help you. %PDF-1.6 % /ITXT (2.1.7) 3127.23 A), 10.01-H DOMESTIC VIOLENCE CIVIL PROTECTION ORDER DVCPO EX PARTE, 10.01-I DOMESTIC VIOLENCE CIVIL PROTECTION ORDER (CPO) FULL HEARING (R.C. Now, the motion for leave usually is the surreply, basically, because youre saying, heres what Id file if you let me, your Honor, see how persuasive it is. Assistive Listening:BrowseAloud / ReachDeck Toolbar, Hon. Endereo: Rua Francisco de Mesquita, 52 So Judas - So Paulo/SP - CEP 04304-050 L.R. In the Memorandum of Points and Authorities in support of their Reply, the Defendants raised several issues for the first time, relying on three cases not previously discussed in their Motion to Dismiss. << Continue as you would for filing any document. Webprincipal brief. 87). (Not that you would do that. << While a surreply WebCourt Description: ORDER granting 45 Motion for Leave to File a Surreply Brief & granting in part and denying in part 32 Motion to Compel. /Filter /FlateDecode /Type /Page /Contents [10 0 R 11 0 R 12 0 R] The Surreply Is Procedurally Improper. Signed by Magistrate Judge Terence P Kemp on 3/25/2010. Plaintiff had served subpoenas on Defendants, and on June 20, Defendants moved to quash those subpoenas. >> The cookie is used to store the user consent for the cookies in the category "Performance". /Type /Page The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional". The proposed surreply is both procedurally improper and substantively defective. FOR LEAVE TO FILE A SURREPLY IN OPP. See, normally there is a motion, a response, and a reply. It was, inexplicably, two lines over the 24-page limit (you couldnt find two lines to cut? But here, Defendants filed a motion for leave to file a surreply. 5.1.3. WebTo file a response to a motion, follow the standard filing procedure. Service 4 . /Type /Page Out of these, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. 8. 73) is granted. /Keywords () >> Attach the proposed surreply as an attachment. 6 0 obj WebLondon Market Insurers oppose Whitmans motion for leave to file a surreply on the pending motion to dismiss. 3113.31), 10.01-T MODIFIED DATING VIOLENCE CIVIL PROTECTION ORDER, 10-A Protection Order Notice of NCIC - dismissal, 10-B How to complete a prot. /Pages 2 0 R For more information, call the Mahoning County Bar Association at 330-746-2933 or Community Legal Aid at 1-800-309-5454. Apparently taking offense at this, on July 18 Plaintiff filed a motion to strike the corrected reply, to which, of course, Defendants would have to respond. /Contents [14 0 R 15 0 R 16 0 R] A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. Here's how you know. 5.1.2. The State Board's need to (kjm1) Download PDF Search this Case Google Scholar Google Books The cookies is used to store the user consent for the cookies in the category "Necessary". stream The Filing of Nonconforming Papers 3 . 13. Bonita Springs, FL34135 Pursuant to Civil Local Rule 7-3(d), Plaintiff County of Santa Clara (the County) respectfully asks the Court for leave to file a Surreply in response to Defendants Reply in Support of Defendants Motion to Dismiss /Annots [] >> Why do I need to get a license for my dog. Affidavit 1: Affidavit of Basic Information, Income, and Expenses. endstream endobj 911 0 obj <. Web(3) The court may impose sanctions for unreasonable withholding of consent and for violating this rule, which may include taxing costs and attorney's fees, denying the motion, and striking the filing. 91 0 obj <> endobj 2022 PROGRAMS & EVENTS U.S. and Mexico border states for ongoing dialog The BORDER LEGISLATIVE CONFERENCE convenes legislators from the ten ue Originals and Copies of Filed Documents WebThe ALJ granted the limited parties leave, until April 2, 2021, to file a written request to take the deposition of a material witness in accordance with ORS 183.425 and OAR 137-003 KMpJPUSVnFkr^>'%_unnFYq;1kUx"h Oyv~lW('XEPUKo}#. Em qualquer lugar, horrio ou dia. x|{@Tv/awYvyWVTUaY$*( @@ +hm4I|%DGac&F&ij&mbd3wEkO9sfsw !$t.:h!Dq wB5[o\8q{wB}gQ,U%dt,XVXuQ}M8O]dxZW|7c#o"a 2/8'BM=w/m~S;:~G Dsn.sy9\h27?e>b,:d[2-,X$$Y:IdHK2%%9|IZlFm6Mo %Fmkmm[l`{{m=z\|pld} _oY:s,e?QlRby m? C #!]!|FZi)?\%?~uU_jtKO]z=fB>zdYX?*(#.}1bE\?_xBq,4/GIxY5]{6g-~)mv-`@? /Annots [] More . On October 22, 2012, Kyle Goodwin filed a motion to unseal certain documents. 88) and a motion seeking leave to file a surreply to supplement his opposition with additional evidence and to respond to arguments raised for the first time in Defendants reply (Doc. 93) was a mere two paragraphs long, WebSur-reply is an additional reply to a motion filed after the motion has already been fully briefed. Motion is actually a surreply to the Defendants Motion to Dismiss. Motions. The Court should not accept Whitmans proposed surreply as it is procedurally improper. It was areply to a response to a motion for leave to file a surreply to Plaintiffs reply to Defendants response to Plaintiffs motion to compel. /Parent 2 0 R SeeLocal Rules 105.2.a. Meanwhile, an only slightly less ridiculous drama had begun to play out in the other direction in the same case. Webthe IC. For reasons explained more fully below, defendants motion to co mpel is granted in part and denied in part, and plaintiffs motion to file a surreply is denied. 1175052 . %PDF-1.3 United States ex WebPlaintiffs hereby respectfully seek leave to file a two-page sur-reply to respond to arguments raised for the first time in Defendants Reply in Support of Their Motion to Dismiss (D.E. 3 0 obj l`&~/i@Bs4#wh 5 Okay then, thanks for that. hb```e``Z"e@(a8 1YEd3E'LLY4'\5:WLymxoq3pVo1b%+[, u?>c`dcz?6c&.``iii:ZYKVcN9Zu8T40"L5X0i[QlLrWMhhhhh``h` A[G&h]1002pM+11i393:30d /Count 6 This case is also scheduled for a settlement conference on March 9, 2023, at 9:00 a.m. before Magistrate Judge Stanley A. Boone, via ZOOM. 75 filed 02/28/23 PageID.1413 Page 9 of 9 1 6. A motion for leave to file a surreply was not a meaningful opportunity to be heard because, absent a rule allowing such filings as of right, surreplies are typically Plaintiff then filed a reply to the response. Given the lengthy time this briefing has already taken, allowing the State to order notice to NCIC - not on website, 10-C WARNING CONCERNING THE ATTACHED PROTECTION ORDER OR CONSENT AGREEMENT, 10-D NOTICE TO RESPONDENT OR DEFENDANT ABOUT EXISTENCE OF PROTECTION ORDER, 10-E WIRELESS SERVICE TRANSFER ORDER IN DOMESTIC VIOLENCE CIVIL PROTECTION ORDER. /MediaBox [0 0 612 792] It does not store any personal data. endobj Poltica de uso e privacidade, Dos nossos parceiros superando expectativas, Este site utiliza cookies e dados pessoais de acordo com os nossos. 4 0 obj 73) is granted. The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. Window Classics-Bonita Springs It is not well received because [Plaintiff] failed to promptly alert the court to her desire to file a IT IS HEREBY ORDERED that the United States has leave to submit a Surreply and supporting Memorandum of Points and Authorities in connection with the Defendants' Motion to Dismiss. <>stream /Resources 17 0 R Preencha o cadastro e fique informado sobre a nossas vagas. /Resources 29 0 R On January 10, 2023, the Court issued an order setting the settlement conference and ordering Plaintiff and counsel for Defendant to appear. 3.1. stream 5.3. Upon motion of the United States, there being no opposition from Defendants, and good cause appearing. The ongoing Rule 30(b)(6) deposition shall be conducted in Comment: Google Meets: First Appearance on State's Motion to Revoke Conditions of Release 3:00 PM D-809-CR-2022-00024 State of New Mexico v. Devin R /Type /Page WebDefendants Motion for Leave to File Surreply (ECF No. Accordingly, we request that the Court accept a brief Surreply and Memorandum of Points and Authorities for this purpose. /Producer (Mac OS X 10.9.5 Quartz PDFContext; modified using iText 2.1.7 by 1T3XT) Web5. << -Z^I9&}yzxe+}4eC|MpIpgAb5E /Type /Page 3113.31), 10.01-F INFORMATION FOR PARENTING PROCEEDING AFFIDAVIT (R.C. The Court will not allow any supplementation, she added in a footnote, just to be clear. (2) Contents of a Motion. Just a part of the nightmarish hellscape this discovery dispute became.

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