Subject: Diary entry 1/8/99
On Wednesday I dropped the following letter off at the AG's office while
I was in Springfield filing other Oppositions of Motions to Dismiss.
H. Gregory Williams
Assistant Attorney General
Western Massachusetts Division
436 Dwight St.
Springfield, MA 01103
Dear Attorney Williams,
This is my attempt, in Good Faith, to comply with the Local Rules of the
Court by attempting to confer with you prior to filing a Motion to reply
you your Motion to Dismiss in order to elaborate on the particularities
as required. I am also filing a Motion for some latitude to extend the
deadline for filing my response to your Motion to Dismiss.
Since you made absolutely no effort to confer or comply with Local Rule
7.1(a)(2) prior to the filing of your motion, I am unsure whether I will
also be allowed to ignore the rules of the Court and dispense with any
attempts to confer with you.
However, since I believe, as obviously the authors of these rules
believed, that the rules are to be followed and have some purpose, I
will err on the side of obeying the rules and attempting to confer with
you in Good Faith prior to the filing of my Motions. Furthermore since
I do not know if the court will strike your Motion for failure to
comply, I am forced to file my answer or miss the deadline.
Your office has had 2 months to attempt to confer with me in Good Faith
and not made a single attempt. My late attempt is due to the fact that
I recieved your Motions on December 29, 1998 and so my response will be
due January 11, 1999, which is only 5 days from now. As you are aware I
have been responding to 4 other Motions this month, 3 of them within the
last 2 weeks.
Therefore, I am hand-delivering this letter to your office today. If
you have any intention of dealing with me in Good Faith, please call me
prior to Monday. Without permission from the Court, I will most likely
be forced to file my Oppositions to your Motions and my Motions anyway.
My telephone number is still (413) 267-3606.
If I do not hear from you by Monday morning, I will assume you did not
have any intention of conferring with me in Good Faith as the Court
Judy Morris, MD
Mr. Williams did call me on Thursday. As far as conferring in "good
faith" there wasn't any of that. He offered to agree to any extension
if I needed it but just flatly didn't respond to any of my other
requests to discuss the case further or meet. So I told him I could use
two extra days, but how would I know by Monday whether the court was
going to grant it or not. He told me he would fax in his consent to the
court within 24 hours.
So today, I called the Court clerk. He did get the fax, but says I
really should file a motion for an extension. Since it's Friday and
snowing and the response is due on Monday, there's no way I could get a
motion written and filed anyway. When you file a motion for an
extension, you have to explain why you need it and blah, blah, blah. I
figure if I spend that time working on my opposition, I can probably get
it in by the deadline anyway.
Mr. Williams seems to want my case against the government defendants
dismissed because I didn't give ENOUGH information, like he couldn't get
it from them.
So I'm making copies of EVERY LETTER I WROTE THEM, EVERY bullshit
response I got back, and a few other details that add up to a nice
little web of lies, deceit and delays. His other defense is that the
law supposedly says that I can't sue state employees in federal court
UNLESS I ASK THEIR PERMISSION.
Yeah, I know how far that would have gotten me. And he has a few
citations and a state law that supposedly give state officials total
immunity even if they commit INTENTIONAL INFLICTION OF EMOTIONAL
Check back here next week for my response to his motion. It's going to
be a beauty.
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Created: January 9, 1999
Last Updated: May 28, 2000