7-6 exhibit a to writ : march 11 2015 motion for exparte hearing for medical continuance and motion...
DESCRIPTION
D. Andrew Beal's Nevada LNV Corporation filed a fraudulent foreclosure action against property belonging to Denise Subramaniam. These pleadings claim that Andy Beal manufactured a digitally altered mortgage note and deed of trust then submitted them to the court as "genuine" and "original" instruments. As a result of this deception Andy Beal obtained a summary judgment issued by Judge Micheal W. Mosman who has a history of making decisions that violate civil rights. Ms. Subramaniam claims Judge Mosman discriminated against her as a disabled person and denied her due process and equal protection of law as a result. This exhibit shows how difficult Judge Mosman made it for Ms. Subramaniam to obtain a medical stay when she needed spinal surgery and set up a court environment where Ms. Subramaniam became afraid to request needed ADA accommodation in fear of retaliation from Judge Mosman.Numerous victims of D. Andrew Beal's debt collection and fraudulent foreclosure scheme who like Ms. Subramaniam were forced to represent themselves in court to protect their properties from fraudulent foreclosures by D. Andrew Beal filed Notices of Constitutional Questions in their respective U.S. District Courts challenging the constitutionality of summary judgments in cases like theirs but these notices were ignored by U.S. District Court Judges in violation of the Federal Rules of Civil Procedure. Andy Beal targets the elderly, the disabled, minorities and single mothers because he knows they lack the resources to defend themselves against his fraudulent debt collection and foreclosure scheme.Case No. 15-35963EMERGENCY PETITION FOR WRIT OF MANDAMUSUNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUITDENISE SUBRAMANIAMDefendant – Petitionerv.LNV CORPORATIONPlaintiff – RespondentFrom the United States District CourtDistrict of Oregon Portland DivisionJudge Michael W. Mosman PresidingCase No. 3:14-cv-01836TRANSCRIPT
Case: 15-35963, 03/31/2016, ID: 9922316, DktEntry: 7-6, Page 1 of 3
Denise Subramaniam Self-represented 13865 SW Walker Rd Beaverton OR 97005 503-764-5300
UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION
LNV CORPORATION Civil Case No. 3:14-cv-01836
Plaintiff, v. DEFENDANT’S MOTION FOR
DENISE SUBRAMANIAM EX PARTE HEARING pro per
Defendant
MOTION FOR EX PARTE HEARING ON FRIDAY MARCH 13, 2015 FOR DEFENDANT’S MOTION TO DISMISS AND MOTION FOR MEDICAL
CONTINUANCE
1. Here comes Defendant Denise Subramaniam, representing herself, and hereby motions
this court to set an ex parte hearing on Friday March 13, 2015 to hear her motion to dismiss and
if the court fails to grant her motion to dismiss; then to hear her motion for 120 day medical
continuance. In support of her motion she states the following:
2. Defendant is scheduled for an MRI on Thursday March 12, 2015. Surgery is scheduled
for Tuesday March 17, 2015; and Monday March 16, 2015 Defendant needs to prepare for the
trip to the hospital which is an ordeal due to her other disabilities which require special
accommodations. Friday March 13, 2015 is the only day that a hearing can be scheduled in time
to grant the continuance before the surgery date.
Case: 15-35963, 03/31/2016, ID: 9922316, DktEntry: 7-6, Page 2 of 3
Page 2 of 2
3. It is unfortunately the nature of serious medical conditions to be unpredictable; and had
counsel for Plaintiff informed this Honorable Court from the beginning about the cause for
Defendant’s ongoing medical needs for time extensions the court would not be so
inconvenienced at this moment; i.e. the need for such an ex parte action would have been
prevented. (Since December 18, 2015, Plaintiff’s counsel knew about the seriousness of
Defendant’s medical condition and the possible need for surgery yet they consistently refused to
inform this court.)
CONCLUSION
4. Defendant has no choice but to now make an ex parte motion to schedule a hearing due to
Plaintiff’s counsel’s refusal to inform this court about the seriousness of her medical condition
and that the possibility of spinal surgery existed as early as December 18, 2014, which would
require ongoing need for time extensions.
5. WHEREFORE Defendant prays this court grant her motion and schedule a hearing on
Friday March 13, 2015 on the matters brought before this court by Defendant’s aforementioned
motions.
Respectfully,
_________________________________________ Denise Subramaniam
Case: 15-35963, 03/31/2016, ID: 9922316, DktEntry: 7-6, Page 3 of 3