08-3187 Volume Appendix15.pdf - Medical Supply Chain

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Repudiation and the defendants’ failure to verify whether they were observing the contract excuse Medical Supply of any duty. See plaintiff’s reply to motion to dismiss. 5. Medical Supply under antitrust and contract law is clearly entitled to its expectations under Missouri and Kansas law in its deal with the GE defendants, where they had knowledge of those expectations before committing an antitrust violation against Medical Supply or breaching the contract to purchase the lease from Medical Supply. The GE conspirators have committed a separate and distinct predicate act from the previous acts committed by US Bancorp/Neoforma. Depending on the length of this action and whether Medical Supply’s market opportunity still exists at the conclusion, that injury is 4 to 6 million dollars a day. Both the defendants (notwithstanding the advice of their otherwise capable counsel) and Medical Supply are injured by any delay in the prosecution of this matter. Whereas, the injury suffered by Medical Supply and the American market for healthcare supplies and the related market for healthcare services in which costs are dependent on supplies is immense, and increases exponentially as Medical Supply is denied relief, the plaintiff respectfully requests the court deny the defendants motion for stay of discovery. Respectfully Submitted S/----------- Bret D. Landrith, Esq Supreme Court No. 20380 12820 SW Hwy 4 Topeka, KS 66614 Cell 816-365-1306 CERTIFICATE OF SERVICE I certify that on October 10th, 2003, emailed this document to the defense counsel named below: Jonathan L. Glecken Ryan Z. Watts Arnold & Porter 555 Twelfth Street, N.W. 08-3187 Medical Supply Chain vs. Neoforma Volume XV 5915
Washington, DC 20004-1206 John K. Power Husch & Eppenberger, LLC. 1200 Main Street Suite 1700 Kansas City, MO 64105 Counsel for: JEFFREY R. IMMELT GENERAL ELECTRIC COMPANY GENERAL ELECTRIC CAPITAL BUSINESS ASSET FUNDING CORPORATION GE TRANSPORTATION SYSTEMS GLOBAL SIGNALING, L.L.C. S/----------- Bret D. Landrith, Esq Supreme Court No. 20380 12820 SW Hwy 4 Topeka, KS 66614 Cell 816-365-1306 08-3187 Medical Supply Chain vs. Neoforma Volume XV 5916
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IN THE UNITED STATES DISTRICT COURT
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Respectfully submitted, /s/ Jay E.
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After the instant Motion to Compel
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Thus, under Rule 26(a)(1)(A)(i), Pl
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help focus the discovery efforts of
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With respect to the first requireme
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Defendants, are documents that he (
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IT IS SO ORDERED. Dated in Kansas C
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2008 pretrial conference, and an Au
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motive on the part of the movant, r
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Plaintiff’s contention that he ne
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08-3187 Medical Supply Chain vs. Ne
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IN THE UNITED STATES COURT DISTRICT
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FILED United States Court of Appeal
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plaintiff sanctioned for not produc
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Monday, August 18, 2008 9:06 AM Sub
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method of communication, that it ma
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********************PRIVATE AND CON
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Monday, August 18, 2008 9:55 AM Sub
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DJW/bh IN THE UNITED STATES DISTRIC
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MARK A. OLTHOFF KS # 70339 SHUGHART
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Not Reported in F.Supp.2d Page 2 No
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21, 2008. 4 On August 21, 2008, Def
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Here, the parties have submitted se
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Whereas the trial judge has not rev
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(mh) (Entered: 08/20/2008) 7. The d
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that rejected in Glass v. Pfeffer,
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Prior Extrajudicial Source Bias The
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molthoff@stklaw.com ademarea@stklaw
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supplies. Similarly, the defendant
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JUDICIAL COUNCIL THE TENTH CIRCUIT
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the respondent ordered dismissal of
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Appearance Docket of the subject li
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were parties to the action at the t
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21. The petitioner had opposed tran
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State Court and the Western Distric
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dismissed, contradicting controllin
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(1) Respondent’s Effect On Litiga
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enter the market where Missouri doc
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58. Through the petitioner’s lobb
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made by the respondent that would h
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due date for a response to the defe
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Head v. Platte County, Mo., 749 P.2
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this court, we must call attention
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petitioner’s appeal or to other t
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adopted their poorly concealed fals
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without independent review resultin
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The action has the petitioner’s m
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Date: February, 1 st 2008 Office of
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permitted the repeated outcomes her
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JUDICIAL COUNCIL OF THE TENTH CIRCU
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Council. As set out in the miscondu
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SUMMARY OF DEADLINES AND SETTINGS E
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UNITED STATES DISTRICT COURT FOR TH
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MEMORANDUM IN SUPPORT The plaintiff
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law); Cincinnati Insurance Co. v. B
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generating source of the power (to
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Judge Carlos Murguia’s prior deci
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Case 2:05-cv-02299-CM-GLR Document
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enter the market. The Defendants ta
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(1) the attendance of a witness or
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598. The USA PATRIOT Act reaffirmed
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611. Defendants’ actions were wil
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UNITED STATES DISTRICT COURT FOR TH
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admitted was incorrect about the US
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government need only prove that the
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Accordingly, one who opts into or p
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other elements of the Section 1962(
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y circumstantial evidence and the l
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dealers or potential dealers. The p
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Kilroy reveal the law firm was the
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US Department Of Justice Post Trial
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of Liggett; Ernest Pepples of B&W;
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Certificate of Service I certify th
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2. I know first hand the consequenc
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Army officer and an African America
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Social and Rehabilitation Services
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answered the complaint and sent add
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shared. The stress aggravated their
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objective of eliminating liability
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14 08-3187 Medical Supply Chain vs.
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The Hon. Magistrate Judge James P.
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Bancorp and its investment bank sub
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the earlier ethics complaint as an
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misconduct that can remedy its effe
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Kansas District court would not cor
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he served as a lawyer in the matter
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Attorney James P. O'Hara Named U.S.
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Kansas City, MO. -- January 26, 200
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Exb 13 Atch 3 08-3187 Medical Suppl
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19 In contrast, as a practical matt
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02-3443 Medical Supply Chain v. US
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Page 289 and 290: 08-3187 Medical Supply Chain vs. Ne
Page 335 and 336: IN THE UNITED STATES DISTRICT COURT
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Page 339: lack of health insurance and the co
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Page 353 and 354: Id pg. 328. d. Identity of claims U
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Page 373 and 374: saml@medicalsupplychain.com Pro se
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Page 379 and 380: in ensuring that the claims he brin
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