I appreciate those of you who have reached out to discuss the your pro se experiences, trials, tribulations, and now and again victories. After my recent “mistake” of hiring an attorney to prepare my Opposition to Defendants Motion for Summary Judgment and realizing he kind of slept walked through it and left me short on time to re-do it myself, I remembered the biggest advantage we have as pro se litigants. Intimate knowledge and understanding of our case and the fact that we care more than any lawyer ever could, would (or should, actually). That said, preparing the MSJ opposition was by far the most difficult filing I’ve done to date (it’s really more like four pleadings in one).
The hearing on CitiMortgage Motion for Summary Judgment was indescribable, so I won’t try, but I will post the transcript when I receive it. In the meantime, as promised, here are the MSJ documents. I won’t comment, because I don’t want to discuss strategy going forward, but I can tell you I have filed a motion for Statement of Disqualification regarding the judge assigned to my case, as well as a Notice of Motion for New Trial.
There are a massive amount of documents involved in a Motion for Summary Judgment, but the easiest and most important one if you want a quick overview is the Separate Statement of Undisputed Facts found here.
Marina Boyd Pro Se Plaintiffs Complaint for Equitable Relief Against Judge Lisa Hart Cole (Judge was not happy I sued her)
Minute Order GRANTING CMI’S Motion for Summary Judgment or Summary Adjudication I kid you not when I say she literally made some of this up. Either it was something that CitiMortgage didn’t plead in their Motion, or there was no evidence submitted where she said “the evidence demonstrates”. It was a very twilight zone experience when I had to read it carefully to prepare my Motion for New Trial. But here it is:
Just so no one forgets, here is the audio of Judge Hart Cole abusing her discretion:
Documents Coming Soon
Declaration of Mark Alston in support of Citimortgage Motion for Summary Judgment
Declaration of Cindy Swan in Support of Citimortgage Motion for Summary Judgment