Professional Documents
Culture Documents
While we have yet to see confirmation from the court granting the Plaintiff’s extension to
respond by 17 September (and we have no material objection), we desire to inform the court that
it is our intention:
1) to make application to the court for a sur-reply to the Plaintiff’s reply motion.
2) that we have sufficient time to draft a well crafted response,
3) that we have adequate pages in which to respond, which we expect will be somewhat
more than the 10 pages specified by the courts Individual Practices (except with prior
permission).
5) We are also in the process of obtaining CPA commentary and review, as this is pro-bono
support, this support is on a catch as catch can. So far CPA’s who have reviewed Dunlevy’s
submission have stated that there is no need for CPA certification, and there is no evidentiary
requirement under the FRCP for CPA certification. As such that expense is not required.
6) We will stand ready to brief the court as to the admissibility of Dunlevy’s Declaration and the
electronic supplements in all respects after we submit it. As explained in Dunlevy’s Declaration,
sufficient information is provided for independent validation. We are also prepared to provide
more than sufficient, possibly abundantly excessive backup for validation. We are also prepared
to publish this information in the Internet and subject it to public scrutiny and review. As such
this data set may become a study model for forensic accounting projects, much as the Visible
Human Data was to be the basis for exercising Digital Morse Theory.
7) As such in 6) above, our proposed sur reply will focus only on Constitutional Issues and
Issues of Collateral Estoppal in opposition to the Plaintiff’s Motion for Summary Judgment
We have been preparing other letters and documentary reports, and collating material alluded
to above, but due to computer and holiday issues, we expect that they will be forthcoming next
week
This letter discloses our intentions. More specific request letters will be forthcoming next week.
Thank you for your fairness and patience as we marshal yet more abundant evidence to support
our contention that we have, even yet, a possibility of prevailing at trial..
Sincerely,
D. B. Karron
pro se