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2
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Reply to Defendants' Opposition to Plaintiff's Motion to Reconsider Court's 7/24/2003 Ruling
2.
SLAPP-type actions against patients who exercise their Constitutional Right to
Petition.
3.
Willful non-performance of clear, present ministerial statutory duties mandated by
the Knox-Keene Act.
4.
Continuing fraudulent misrepresentations causing misplaced reliance by and
detriment to all managed care patients.
5.
Conspiracy with health care service plans and large employers to violate patients'
Constitutional, common law and statutory rights and protections in violation of
Public Policy.
6.
Breach of multiple express, implied and 3®
d
party beneficiary contracts with plaintiff.
7.
Approval of unconscionable contracts of adhesion between health plans and
subscribers in licensing and regulating health plans, pursuant to secret ex parte "meet
and confer" agreements.
8.
Violation of the California Discovery Act to wrongfully deny deposition of witnesses,
absent sworn declarations that they have no knowledge of facts leading to admissible
evidence, which are properly tested for their truth.
9.
Refusal to recognize and accommodate a plaintiff In Pro Per's polio disability.
10. Refusal to meet and confer on issues to advance this litigation to promote judicial
economy.
11. Perjury and other false statements.
II. ARGUMENT
A. Plaintiff's Motion for Reconsideration Is Not Procedurally Defective.
1.
Plaintiff submitted sworn declarations in support of her Motion to Reconsider.
Defendants' request that this Court deny plaintiff's Motion on the basis that
declarations do not serve the same purpose as affidavits insults this Court's
intelligence and is akin to arguing that this Court is incapable of reasoning that a
baked "potato" or a "baked potatoe" is still an appropriate accompaniment to the
"meat" of this Motion.
Indeed, Motions for Reconsideration are commonly supported by declarations which
are acceptable to the Court, e.g.: "… On February 20, 1981, Blue Mountain filed a
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