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Old December 8th 09, 12:21 PM posted to rec.games.chess.politics,rec.games.chess.misc,alt.chess
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Default Polgar Response

PLAINTIFF’S RESPONSE TO DEFENDANTS’ MOTION FOR LEAVE TO FILE
REPLY BRIEF IN SUPPORT OF DEFENDANTS’ RESPECTIVE MOTIONS FOR
SUMMARY JUDGMENT

TO THE HONORABLE UNITED STATES DISTRICT JUDGE SAM R. CUMMINGS:

1. COMES NOW SUSAN POLGAR, Plaintiff herein, files this her Response to
Defendants’ Motion for Leave to File Reply Brief in Support of
Defendants’ Respective Motions for Summary Judgment, and in support
thereof would respectfully show the Court as follows:

2. Defendants are aware of this Court’s prohibition of reply briefs, and
presumably are also aware that reply briefs generally contain
counter-arguments attempting to refute those presented in a response to
a motion. Nevertheless, Defendants request leave to file a reply based
on the fact that they wish to refute Plaintiff’s arguments, something
not new, novel, or noteworthy. Without some reason other than a desire
to refute Plaintiff’s arguments, Defendants have no valid reason to
request leave to file a reply brief with this Court, and thus, Plaintiff
respectfully requests this Court deny Defendants’ Motion for Leave.

3. Defendants also base their request on the fact that they have taken
another deposition since the filing of their original motions.
Defendants are well aware of the Court’s prohibition of reply briefs,
and, had they wished to include testimony from a deposition in their
motion for summary judgment or had the testimony been essential to said
motions, they could have taken the deposition before filing the motions.
Defendants state no reason why they could not have taken the deposition
before filing their motions for summary judgment. Thus, Defendants have
presented no valid reasons why they should be permitted to file a reply
brief. Accordingly, Plaintiff respectfully requests this Court deny
Defendants’ Motion for Leave.

4. WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully requests this
Court deny Defendants’ Motion for Leave to File Reply Brief in Support
of Defendants’ Respective Motions for Summary Judgment, that Defendants’
reply not be filed of record with this Court, and that Plaintiff be
granted such other and further relief to which she may be justly
entitled, at law or in equity.

Respectfully submitted,
KILLION LAW FIRM 2521 74th Street
Post Office Box 64670 Lubbock, Texas 79424-4670 (806) 748-5500 Telephone
(806) 748-5505 Facsimile
/s/ Samantha Peabody Estrello
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