Free Reply to Response to Motion - District Court of Arizona - Arizona

FILED __ LODGED I
..._._ RECEIVED ___ GOFV
WYVONNAMBARNETI
ami EAST MCKAMEY (][]'|' 2 ]_ 2005
PAYSON ARIZONA , 85541
CLEIRII LJ I3 DI., ; . 4.DuI~IT
I928 474 5609 OR 1 928 978 3203 DISTFIICT OF ARIZONA
B`·’...._....____ DEPUTY
REPRESENTIGN SELF
UNITED STATES DISTRICT
COURT DISTRICT OF ARIZONA
WYVONNA M BARNETT CASE NO. 03 2566 PHX ROS
PLAINTIFF PLAINTIFFS RESPONSE
VS DEFENDANT S RESPONSE RE:
MESA GENERAL HOSPITAL PLAINTIFFS MOTION TO
DEFENDANTS SCHZEDUAL TRIAL BY JURY
TI-IIS CASE HAS GONE ON FOR ALMOST TWO YEARS .. WITH DEFENDANTS FII..ING
THE SAME OLD MOTIONS OVER AND OVER ..
PLAINTIFF HAS BEEN READY TO GOTO TRIAL FOR A VERY LONG TIME AS HER
CASE IS A RES IPSA LOQUITUR CASE IT SPEAKS FOR ITSELF .
PLAINTIFF IS CONFIDENT ANY IURY WOULD HAVE NO TROBLE MAKING A FAIR
AND HONEST EVALUTION AND WILL GIVE A FAIR AND HONEST
BASED ON PHYSICAL AND EVIDANCE PRESENTED BY PLAINTIFF
( MAKING EXPERT WITNESS TESTIIVIONY UNNECESSARY ....
IN THEIR MOTION DATED OCT II ENTITLED RESPONSE TO PLAHNITII-'FS MOTION FOR
COURT TO SCHEDUAL TRIAL BY IURY......DEFEI~IDANTS ASK COURT TO FIRST RULE
ON THEIR MOTION FOR SUMMARY IUDGEMENT BEFORE SETTINGA TRIAL DATE
AND YET BY THEIR OWN ACKNOWLEDGEMENT THEY ARE NOT READY TO GO TO
TRIAL DUE TO FACT (THEY) HAVE NOT COMPLETED THEIR DISCOVERY EVEN THO
THEY HAVE HAD ALMOST TWO YEARS TO DO SO...
TO RULE IN DEFENDANTS FAVOR AND GRANT A SUMMARY JUD WOUII) BE
A GROSS ACT OF NEGLIGENCE ON THE PART OF THE COURT".
ADDITIONALLY DEFENDANTS ONCE AGAIN ASK THE COURT TO ALLOW THEM
ADDITIONAL TIME TO COMPLETE DISCOVERY IT IS VERY OBVIOUS THAT THE
DEFENDANTS ARE AFRAID FOR THIS CASE TO GO TO TRIAL ,.
AND ALSO ARE POSSIBLE HOPING THAT DEFENDANT MAY DIE , DUE TO HER
SERIOUS HEART CONDITION IF THEY ARE ABLE TO GET THIS EXTENSIONH.
HOWEVER
PLAINTIFF I-IAS NO MORE OBIECTIONS TO A SHORT EXTENSION FOR DEFENDANTS
TO COMPLETE DISCOVERY ( AS LONG AS ) PLAINTIFF HAS TI-IE SAME COURTESYU.
THAT IS TO FOLLOW THRU WITH HER AMENDED COMPLAINTS AND ADDITIONAL
PARTIES AND THEIR SUPEONAS AND ECT
DATE `_’{, n
Case 2:O3—cv—O2566—FIOS Document 102 Filed IO/21/2005 Page1 0fI

Case 2:03-cv-02566-ROS

Document 102

Filed 10/21/2005

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