07 September 2005

NAACP Nashua President Timmons was served with Discovery requests, including Interrogatories, Requests for Document Production and Admissions with her complaint, on 15 July, 2005. Her Attornies' claims that somehow they don't know when the Discovery Requests were issues rings hollow. Not only were they served on 15 July, 2005 they had been online on my website, www.christopherkingesq.com for at least a week or two earlier. These requests were due thirty (30) days later per Rule. Futher, I duly noticed Timmons for a Depostion on 19 September, 2005. Timmons' attorneys called me and asked for an expedited structuring conference, and I agreed only to the extent of further discovery, not that which I had already initiated. They claim that I initiated discovery without the benefit of a structuring order, but nowhere in the rules does it say that such an order is necessary.

But the court, perhaps misled by counsel for Defendant's Motion, granted a stay. Let the record be clear: Never at any time has any of my conduct in this matter indicated that I was willing to let Defendant Timmons off the hook for Discovery requests that are overdue, or her depositon. I therefore place this Honorable Court on Notice that I request an exigent, Show Cause ruling on this matter because many of the documents I have requested include emails that are subject to purge, and because Defendant Timmons' lies and misrepresentations have led me to face criminal charges of Attempted Felony Extortion. As such, my 5th and 14th Amendment Due Process Rights may have been inadvertently trammeled by the Court as the Court mistakenly believed that I assented to continuing pending discovery. I therefore respectfully request a Show Cause Hearing immediately.

Defendants claim that I have not been prejudiced by this continuance, but none of them are subject to a bogus criminal indictment. See Becker v. Zellner 684 N.E.2d 1378 (1997), rehearing denied, 690 N.E.2d 1379:
Finally, setting forth a "hard bargaining position," threatening to institute civil%2

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