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COURT TIMELINE 2007

1) Plaintiff filed lawsuit against KittyKind for Failure to Return Money and
Failure to pay for Services Rendered.

2) April 16: Hearing #1


Postponement for Plaintiff to gather copious Discovery for Defendant

3) On or About April 23
Plaintiff delivered all Discovery requested to Defendant’s office

4) June 8 Incoming Phone call to Plaintiff


Defendant’s attorney makes settlement offer of $5,000

5) June 19 Hearing #2
Judge Wright informed Defendedant that Mediation is not binding
Both parties sent into Mediation by court
Defendant’s attorney brought up June 8 Settlement offer
Offer is now off the table
Defendant alleged that all or most of the cat were not KittyKind cats
Stipulation signed by both parties agreeing to finish Discovery requests by 7/7/07
Defendant agreed to give Plaintiff all Discovery by 6/28/07
Defendant claimed to have a signed contract by Plaintiff and was ordered to bring it
to next Hearing

6) August 8 Hearing #3
Judge asked to see alleged signed contract
Defendant gave email taken out of context from Mediation with Jane Hoffman
2nd Judge to inform Defendant that Mediation is not binding
Judge asked if there was a limit to costs of medical care provided per cat
Defendant’s attorney said no
Judge asked Plaintiff if Plaintiff made agreement and now wanted more money
Plaintiff replied “No”
Defendant admitted that there is no signed contract
Plaintiff showed Judge Defendant’s Response to Discovery
Judge advised Plaintiff to file Motion to Compel
Defendant’s attorney said that Jane Hoffman would make an appearance in court
within 20 minutes and asked if he could wait for her.
Judge asked if I wanted to go to trial at that time. I said yes, however did not have
my receipts with me. A new hearing date was set.

7) August 29 Motion to Compel Hearing


Judge Hagler changed trial date from Sept 18 to Oct 15 to give Defendant time to
send Plaintiff Discovery materials and affidavits ordered by Judge within 30 days.
Defendant’s attorney stated that their defense has always been that Plaintiff was never
authorized to take KK cats to her vet and again claimed that not all cats were KK cats
8) Oct 5 Deposition of Hilary Harris
(Deposition also sent to Marlene Kess)
Defendant’s attorney responded for both parties with Rejection of Deposition and no
one showed up for Deposition.

9) Oct 15 Trial Date


Judge Wright attempted Mediation and set new trial date at Dec 7 leaving time to
Subpoena Ms. Kess and attempt another deposition.

10) Oct 17 Judge Signed Order To Compel Deposition on Nov. 7

11) Nov 2: Plaintiff Receives Plaintiff Receives Affirmation from KK Attorneys


Claiming that Ms Kess is not a party to this suit and that Plaintiff is trying to stall

o Any stalling has been due to Defendant’s claims of having a signed contract
when in fact it did not exist

 Defendant’s response to timely Discovery was compelled by the Court despite


Plaintiff’s cooperation in gathering copious Discovery requests by Defendant

• On or about April 23 Plaintiff delivered all Discovery requested to Defendant’s


attorney office

o Per Stipulation by Court Defendant agreed to finish Discovery requests by


7/7/07 and to give Plaintiff all Discovery by 6/28/07
as of August 8 Defendant did not cooperate and Judge advised Plaintiff to file a
Motion to Compel

 At Motion to Compel on August 29, Judge Hagler changed trial date from Sept
18 to Oct 15 in order to give Defendant 30 days to send Discovery materials and
affidavits ordered by the Court

12) Nov 7 Hearing to Compel Deposition


Case dismissed due to lack of documents by both parties.

13) Judge advised Defendant’s attorney that Rejection of Deposition is not part of
our Justice System and that they could not make up the rules as they went along.
He also advised them that in this particular case he believed that this
organization had taken advantage of a softhearted person in the amount of
$25,000. Attorney tried in vain to convince him that KittyKind is a “wonderful,
caring organization”.