    
Christine
Board Administrator
Username: Christine
Post Number: 2697
Registered: 09-2002
| | Posted on Sunday, March 08, 2009 - 11:59 pm: | 
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3/8/09: Response in opposition of the Defendants’ Motion to Dismiss or, in the alternative, for Security of Costs, and Baker’s Motion for the Attorneys to Have to Withdraw from this Case or in the alternative, Require Their Motion and Reply to be Verified and to Require All Future Filings to be Verified.
Table of Exhibits
1. October 2008 emails including Baker’s 10/21/08 offer to attend the 10/24/08 deposition in Kingman, the attorneys’ failure to cancel the deposition until Baker requested the address on 10/23, Baker’s offer to schedule the deposition on 11/7 (one of the defendants’ suggested dates) in Kingman or in Las Vegas if the defendants paid for her travel expenses and time, notice of Baker’s unavailability in December and January and the attorneys failure to respond.
2. Baker’s 12/14/08 and 12/29/08 emails to Equifax attorney Cara Hergenroether to notify her that she would NOT attend the 1/16/09 deposition in PHOENIX. [Previously submitted as Exh. 1 to Baker’s 1/12/09 Motion for Protective Order].
3. Equifax attorney Hergenroether’s 1/16/09 attempt to schedule a conference call to the court and Baker’s reply, advising that she was available every afternoon the following week.
4. The attorneys’ 1/22/09 request to call the court that afternoon and Baker’s reply stating that she was available. Baker received no reply.
5. 2/26 to 3/5/09 communications with Trans Union attorney Tiffany Hawkins to schedule the Baker deposition in late March. Attorney Hawkins’ attempts to schedule a conference call with the court on 3/6/09 because she could not find a room in Kingman. She had failed to contact a single hotel.
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3/8/09 Response