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RE: Letter to Juddge Maras, Plaintiff's motion to file out-of-time, and Plaintiff's replay to Defendant's opposition to Plaintiff's motion for leave to amend
Lisa,
1000% agree. Thanks!
Best regards,
Bill
William F. Slater, III, PMP, CISSP, SSCP, CISA
Chicago, IL
United States of America
slater@billslater.com
http://billslater.com
http://billslater.com/career
> I have always had to juggle multiple responsibilities including family
> responsibiities and have never been allowed the opportunity to not meet a
> deadline as a result. This is a normal part of life. A responsible
> caretaker has multiple back up options at all times to ensure she or he is
> able to meet their responsibilities and I as th defendant should not be
> penalized for her inability to manage her workload and personal life and
> responsibilities. I would submit that my responsibilities as a single mom
> with no family support and no support from my ex-husband with two
> children, one of which is a child with multiple disabilites have always
> been far greater than any Ms. Johnson has to deal with. It is normal for
> a single mom to have backup care options, the same is true for any
> professional who is also the sole caretaker for an elderly relative. The
> fact that she is a sole practitioner should not be relevant, she has a
> co-counsel so that excuse really doesn't hold water. there are a ton of
> resources for care providers for the elderly, a responsible caretaker
> would have already had those lined up. The fact the she is unable to
> handle the juggling of her caseload is an exhibit of a lack of responsible
> professionalism on her part. Clearly she doesn't take her
> responsibilities seriously. The fact that she had to take her mother to
> the hospital on her birthday, I say boohoo! I would like my objections
> noted with the court. As backup information my son has cerebral palsy, is
> a quadriplegic, legally blind and is moderately mentally retarded. I
> spent many nights in the ER (for stitches because he acted like a boy and
> would take his walker down steps-- walkers and steps don't work well) and
> in the hospital for surgeries and still I met all of the responsbilities
> that were in front of me. sometimes that meant I didn't get much sleep.
> Everyone's life is filled with special circumstances but still life must
> go on. I never felt that the rest of the world had to bend over backwards
> and cry for me and my son. Sometimes life is hard and you just have to do
> what you have to do. Besides she was only replying to the motion and the
> court has already bent over backwards for her multiple times and she is
> just taking advantage. Please use this information in your objection and
> response. Her request for more time is punishing to me. She has gone way
> beyond the leeway that the court granted her and she should be
> reprimanded for that (or whatever the legal term is).
> She must be held responsible or she will continue to ask for "special
> circumstances".
> Thanks -
>
> Lisa N. Wolford
> CSSS.NET
> 402-393-8059w
> 402-393-1825f
> www.csss.net <http://www.csss.net/>
> SDVOB, 8(a)/SDB & WOB - TS clearances
>
> ________________________________
>
> From: Kevin Duff [mailto:kduff@rddlaw.net]
> Sent: Wed 06/08/2011 11:17 AM
> To: Wolford Lisa; slater@billslater.com; 'Haytham Faraj'
> Cc: jmurray@rddlaw.net; mhughes@rddlaw.net
> Subject: FW: Letter to Juddge Maras, Plaintiff's motion to file
> out-of-time, and Plaintiff's replay to Defendant's opposition to
> Plaintiff's motion for leave to amend
>
>
>
> Attached is plaintiff's motion for leave to file a late reply brief in
> support of his motion for leave to amend his complaint along with the
> reply brief. Exhibits will follow in a separate email.
>
>
>
> The hearing is tomorrow at 1:00 p.m. We will contact you after the
> hearing.
>
>
>
> Kevin
>
>
>
> ________________________________
>
> From: THERESA JOHNSON [mailto:theresavjohnson@prodigy.net]
> Sent: Wednesday, June 08, 2011 10:55 AM
> To: Kevin Duff
> Cc: Theresa Murata; Peter V. Bustamante
> Subject: Letter to Juddge Maras, Plaintiff's motion to file out-of-time,
> and Plaintiff's replay to Defendant's opposition to Plaintiff's motion for
> leave to amend
>
>
>
>
>
>
>
> Mr. Duff,
>
> Attached please find June 8, 2011 letter to Judge Maras which attaches the
> following documents:
>
> * PLAINTIFF'S MOTION FOR LEAVE TO FILE OUT-OF-TIME PLAINTIFF'S MEMORANDUM
> IN REPLY TO DEFENDANT'S RESPONSE MEMORANDUM IN OPPOSITION TO PLAINTIFF'S
> MOTION FOR LEAVE TO AMEND.
> * PLAINTIFF'S MEMORANDUM IN REPLY TO DEFENDANT'S RESPONSE MEMORANDUM IN
> OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO AMEND.
>
> Exhibits will follow
>
> Sincerely,
>
> Karin
> Legal Assistant
>
>
>
> Sincerely,
>
> Theresa V. Johnson
> Attorney at Law
> Law Office of Theresa V. Johnson
> 200 East Chicago Ave. Suite 200
> Westmont, IL 60559
> Tel.: (630) 321-1330
> Fax: (630) 321-1185
>
>
>
>
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