Pretrial is over!

Court is over.

I successfully argued against the defendant’s motion for summary judgement which I thought my lawyer had already done successfully. ☺️ but I held my ground steadily.

My evidence focused on negligence / strict liability with foreseeability and owner notice. my case is about the plaintiff’s dogs running at large and attacking me.

statutes/municipal code = negligence per Se = the dogs at large didn’t knock me down in the street but there is law meant to protect me from this happening. Don’t let dogs run at large - it is simple. and that an officer had told Ronald that a dog does not have to bite to be considered dangerous. Strict liability = they’re his dogs, he knew they had at the very least a hereditary lineage with a dangerous dog as the matriarch. Diamond’s daughter Matilda bit multiple people and me, and her offspring was fathered by the second dog that attacked me. The juvenile attacked me first!

Aggression is an inherited trait. He should take better care to “keep” his dogs in check.

He admits on camera that they’re aggressive and “they only like that because they don’t know you- he wouldn’t have done that if I was here” - which is the definition of owner knowledge /forseeability.

I explained that on a previous incident - I quoted what the police report said. - Ronald asked the victim (Kent Emperly) “what the eF do you want me to do about it”. And he says on camera that he “had just gone to trial for the same s h i t last year.” which is the wanton pattern of disregard for public safety.

I said the body camera shows the gate was open, shows Ronald admitting he had someone over raking his yard and that guy probably left the back gate open,

That’s his negligence.

Then I explained my requests for court-ordered production of body worn camera footage and florez tried to act like it was my fault that he had 9 videos and I had 13 videos and I said -this is partly why I’m requesting that the court compel production of the full length videos and I described the specific chunks of video that I was seeking that had been edited out and why they were important.

Then I explained that I requested the transcript production at court expense along with my indigent / poverty affidavit and why it was rejected and that I didn’t understand why I should direct the request to a judge who would probably reject it outright because it wasn’t her case. So I pivoted to florez when he admitted he had it and intended to use it.

I informed the judge that the vet records were apparently sent to my email address this morning at 8 am and that I had not checked my mail so, no…discovery had not been completed.

A two day trial is set for September 29th and 30th.

And lastly, the judge warned against the use of AI without disclosure and then looked me straight in the eye. I immediately stood up and said “your honor, I have been using ChatGPT to draft my documents and for some knowledge acquisition but I am forming the arguments and theories in the motions and strategies.”

I guess he accepted that as disclosure.

I don’t know what the judge intends to do about the requests for production, but he seemed interested in why I would ask the court to intervene and compel production of it and was writing notes on his notepad when I spoke.

So hopefully he will put out an order and get both the cop camera video and the transcript with affadavit attached to both and put it on the docket- since Florez weakly admitted that he couldn’t share it because of court reporter “copywrite”. (Judge was looking at Florez absolutely sideways while he explained his position.)

Trial is set for September 29th and 30th.