Hi, according to the rules we have to have more time before the status conference hearing to file for a motion for summary judgement so I will let you know when the judge says it is okay. I do need to file a motion to compel discovery this week, I have what we filed before and the reason the court denied it so we just have to take that and ensure we put it right this time. I can send you the word document I filed before, we did one then ammended it because her then attorney said it was not procedurally correct, then the second attorney opposed it but now that attorney is gone too. Thought we could strike while she is still pro se. and get it in before the status conference hearing though we may not be in time to have it heard then as she has 30 days to oppose it, we can at least get it filed so the judge can review it. Can you do this one please so we don’t get denied again?
