Tamara Filas v. Kevin Thomas Culpert and Efficient Design, Inc.

A third-party auto case (against the negligent driver and his employer)
Michigan Court of Appeals Case No. 317972
Michigan Supreme Court Case Nos. 151198 and 151463

If you are seeking the truth about the case, Tamara Filas v. Kevin Thomas Culpert and Efficient Design, Inc., you've reached the right place. If you landed on this page via a search engine, I ask that you please click here first to be taken to the sections on the home page that explain what prompted me to create web pages about my past litigation.

Because of the strong similarities in the content being litigated (a Plaintiff's right under the Michigan Court Rules to use SCAO-mandated Form 315 to provide medical records to a Defendant requesting them), I highly suggest you first read my commentary on Tamara Filas v. MEEMIC Insurance Company.  Rather than re-write explanations about the arguments and evidence that were the same as the MEEMIC case on this page, I wanted to instead focus on the differences between this case and the MEEMIC case.  This way, the reader can better understand how the Court of Appeals erred in its final decisions regarding this case.

This page is currently in progress and will be updated with more information as time permits.

REBUTTAL OF THOMPSON O'NEIL, P.C. BLOG POST

I am listing this section first, because this law firm's two-paragraph blog post dominates the search engine results for a search of my name. It is the most egregious posting on the internet about me and the circuit court proceedings for this case, originating from a law firm called Thompson and O’Neil, operating out of Traverse City, MI, which is 255 miles (a 4-hour drive away) from the Wayne County Circuit Court, where my proceedings took place. To my knowledge, this law firm was never directly involved with my case, and if they were, it was all behind the scenes. I have no idea why this firm decided to write libelous statements about me that are not even derived from the Court of Appeals Opinion, the pleadings filed with the circuit court, or the hearing transcripts.

The firm's post, titled “Court upholds dismissal of injury claim after woman refuses to sign medical authorizations,” has been destroying my credibility and negatively affecting my reputation for almost a decade, which is why I am providing a direct rebuttal on my website. This firm also authored a blog post about Tamara Filas v. MEEMIC Insurance Company, to which I will also eventually provide a rebuttal, as it is equally harmful and untruthful. Because my rebuttal of the aforementioned blog post involves explaining many facts already on this page in the EXPLANATION OF CIRCUIT COURT PROCEEDINGS section below, I am including it on its own page to avoid redundancy. It would be best to first read the commentary on this page so that my rebuttal to the blog post will be easier to comprehend. Click here to read my rebuttal to the Blog Post by the Thompson and O’Neil Law Firm.

EXPLANATION OF CIRCUIT COURT PROCEEDINGS

Tamara Filas v. Kevin Culpert and Efficient Design, Inc. was a third-party tort case resulting from the January 15, 2010 auto accident in which I was rear-ended by Kevin Culpert through no fault of my own (I was stopped waiting for the car in front of me to turn). Because it was possible Mr. Culpert was in the scope of his employment at the time of the accident (around 7:20 a.m.), this lawsuit also included Mr. Culpert’s employer at the time of the accident, Efficient Design, Inc. (“EDI”), as a Defendant. There were three different Defense attorneys in this case: Culpert’s attorney representing Progressive Insurance (Mr. Hassouna); and EDI’s attorneys (Mr. Wright and Mr. O’Malley) representing two different insurance companies which were not named or evident in any filings.

I was a pro se litigant for the final proceedings at the circuit court because I was denied time to find a new attorney after I dismissed my attorney for breach of contract. In 2011, my first attorney had filed a combined first- and third-party case that was dismissed without prejudice via a stipulated dismissal. It was allowed to be refiled in 2013 by my second attorney as two separate cases, and was still timely in accordance with the statute of limitations for personal injury cases.

When I hired my second attorney, he agreed to allow me to produce my medical records to the Defendants without the use of a record-copying service, which was an unresolved issue with my first attorney when my 2011 combined case was dismissed with the stipulated order. Ultimately, my second attorney breached his contract and failed to uphold his agreement with me to stand up for my right to either provide my medical records myself; or use the form approved by the Supreme Court Administrative Office (“SCAO”), Form MC 315; which were both legitimate options under the Michigan Court Rules. I was left all alone in this battle to protect my right to medical privacy---my legal right not to allow my medical records to be copied, digitized, stored in a database, and sold for profit.

It was never determined if Mr. Culpert was in the scope of his employment because he was never deposed, and EDI’s attorneys argued in their pleadings that he was not an agent of EDI, nor in the course and scope of his employment at the time of the accident (Exhibit B of my 12-20-13 COA Brief contains the relevant page of Mr. Wright’s 2-5-13 Answer to the circuit court Complaint against Efficient Design). Before providing my medical records to EDI, I exercised prudence and motioned for a stay of the proceedings so it could first be determined if EDI was even liable for damages, but the judge denied my motion and I was ordered by the Court to provide EDI with my medical records or risk case dismissal.

One would think that if Mr. Culpert truly was not in the scope of his employment, instead of simply making this claim in their pleadings, EDI’s attorneys would have provided the court with proof and motioned to be removed from the case, but they did not. All that would have been required to dismiss EDI from the case was a signed/notarized statement from Culpert. EDI’s attorneys participated in the litigation all the way through the Supreme Court. It seems absurd that a company would put such effort into fighting a case in the COA and MSC if they didn’t believe they were a legitimate party to the case.

The merits of my case against Kevin Culpert and EDI were never litigated (i.e. my life-altering and lifelong injuries sustained in the accident, the pain and suffering I endured and will continue to endure the rest of my life, the loss of ability to do many of the things I enjoyed in life, and the loss of my career and gainful employment). I never received any compensation for said damages. This case was dismissed because the judge allowed one of EDI’s attorneys (Mr. Wright) to refuse to accept my execution of SCAO-mandated MC 315, which as explained in the MEEMIC case, is the only form mandated by court rule to be used to produce a Plaintiff’s medical records to a Defendant.

Similarly to the MEEMIC case, I was given the choice of having my case dismissed or completing the forms Mr. Wright demanded of me, forms which would have allowed Mr. Wright permission to act similarly to a record copying service, which no Plaintiff has a legal obligation to accept and agree to, since MC 315 does not allow for this practice. When I wasn’t timely provided with Mr. Wright’s authorization forms so I could meet the deadline I was given by the court, I executed copies of Form MC 315 instead of using Mr. Wright’s forms. Clearly the records sent to him by my health care providers following my execution of MC 315 should have been accepted by Mr. Wright and the Court, and I should not have been required to re-do the process with his forms that contained clauses that went over and above what was permitted on form MC 315.

Tamara Filas v. Kevin Culpert and Efficient Design, Inc. is extremely similar to Tamara Filas v. MEEMIC Insurance Company in that the sole focus of the litigation is in regard to a Plaintiff’s clear and unambiguous right to use the Supreme Court Administrative Office’s form MC 315, which is a medical authorization form mandated by Michigan Court Rule 2.314(C)(1)(d), to provide one’s medical information to the Defendant(s) when a request for production of documents under MCR 2.310 is sent to the Plaintiff. I received a request for production of medical records under MCR 2.310 from EDI (Ex A of my 12-20-13 COA Brief), and therefore, had the right under the Michigan Court rules to use MC 315 to provide my records to Mr. Wright, the attorney for EDI. There were no medical authorization forms enclosed with Mr. Wright’s 2-7-13 request, as he stated, and his request wasn’t mailed to me until 4-30-13. More details about Mr. Wright’s authorization forms, which were not received by me until 6-24-13, are provided later in this commentary.

Click here for an example of one of Mr. Wright’s forms (Exhibit O of my 12-20-13 COA Brief). You can compare it with MC 315 (provided as Exhibit K of my 12-20-13 COA Brief). Item 6 of my 12-20-13 COA Brief on pgs. 32-38 contains a discussion and detailed comparison between his form and MC 315.

SCAO-mandated Form MC 315 does not allow for medical records to be copied, digitized, stored in a third-party database, and sold for profit, as forms for record-copying services and the forms provided to me by Mr. Wright allowed. Refer to the arguments on the MEEMIC page regarding the mandatory use of MC 315 under MCR 2.314(C)(1)(d). Exhibit J of my 12-20-13 COA Brief provides proof that MC 315 is mandatory under MCR 2.314(C)(1)(d), a document which was also filed in the MEEMIC case. Exhibit DD of my 1-21-14 Answer to Culpert’s 12-30-13 Motion consists of State Court Administrator, Chad Schmucker’s 6-23-11 Memo, and pages from the Supreme Court Administrative Office’s webpages, representing solid proof that courts must accept the use of SCAO forms. These documents were also filed as exhibits in the MEEMIC case.

While the arguments I presented in this case regarding a Plaintiff’s right to use Form MC 315 to provide their medical records to the Defendants were the same as the arguments for the MEEMIC case, two important differences between these two cases existed:

1) In the MEEMIC case, I had only requested to use MC 315 and was denied my right to use the authorization form to provide my medical records to MEEMIC.

In Tamara Filas v. Kevin Culpert and Efficient Design, Inc., I had already executed copies of MC 315 for my health care providers, mailed them to the providers, and informed the Defendants that the records were on their way! I provided both Defendants (Culpert and EDI) with proof that I had completed copies of MC 315 for each health care provider and mailed them to the providers: I gave the Defendants’ attorneys (Hassouna and Wright) copies of each cover letter and each completed Form MC 315, as well as copies of each Certificate of Mailing for over twenty different providers. I legally fulfilled my obligation to provide my medical records to both Defendants, Culpert and EDI, by my execution of Form MC 315. My health care providers did their part by sending the medical records to both Defendants’ attorneys. Later, I provided proof to the Court of Appeals that after the providers received my executed copies of MC 315, the Defendants were indeed mailed copies of my medical records from birth to present. Exhibits A – E of my 11-7-14 Answer to Culpert’s 10-17-14 Motion to Affirm represent proof that the Defendants received medical records from my executed copies of Form MC 315.

2) Unlike the MEEMIC case, there was no protective order in this case, which can be verified by the 6-21-13 Order to Vacate the previous protective order that was entered when my first- and third-party cases were first filed together as one case (Ex F from my 11-7-14 Answer to Culpert’s 10-17-14 Motion to Affirm). If you will remember, in the MEEMIC case, the Court of Appeals justified the circuit court’s denial of my right to use MC 315 by its novel claim that it was the protective order entered in the MEEMIC case that required me to sign record copy service forms and disallowed the use of MC 315. Again, not only was it unlawful for the Court of Appeals to fabricate its own argument that was not derived from arguments presented in any of the party’s pleadings, but the COA’s argument regarding the protective order was also without merit, since the protective order didn’t even contain any such language regarding the medical authorization forms I had to sign.

It is a true statement that I refused to execute medical authorizations that allowed the Defendants to copy and re-distribute my records, which would have been a permitted action had I signed the forms provided by Mr. Wright. However, it is not true that I refused to execute medical authorizations, because I did execute copies of Form MC 315 and my health care providers sent both Defendants copies of my medical records.

I had provided Mr. Hassouna with copies of the cover letters and completed MC 315 forms, and Certificates of Mailing for each provider, by hand just before a June 21, 2013 hearing at the circuit court; and had therefore met my obligation to provide records to Culpert’s attorney. Mr. Hassouna did not complain about my use of Form MC 315 to provide the records to him.

At the time of the June 21, 2013 hearing, I still had not received any authorization forms from Mr. Wright, and he did not have any forms prepared to provide to me at the hearing. The 6-21-13 hearing transcript verifies that the judge ordered him to e-mail the forms to me by the end of the business day and that I was provided with short and strict deadline to execute these medical authorizations for Mr. Wright by 2:00 PM June 24, 2013. I was facing case dismissal if I did not provide him with signed medical authorizations by this deadline. When the forms had not arrived in my e-mail inbox by 5:00 p.m. on 6-21-13, I worried that he may not send them at all, causing me to miss the deadline. Since copies of MC 315 forms were accepted by Mr. Hassouna, I reasoned they would also be accepted by Mr. Wright, so I set to work preparing them in the same manner I had done for Mr. Hassouna, which took hours of work, even with additional help.

On Monday, June 24, 2013, at 11:24 AM, I personally delivered copies of the aforementioned cover letters, signed MC 315 authorizations, and copies of the certificates of mailing to Mr. Wright's office, meeting my legal obligation imposed by the Court of providing signed authorizations disclosing my medical records to Mr. Wright by 2:00 PM June 24, 2013. Exhibit C of my 12-20-13 Court of Appeals Brief is a copy of a signed cover letter verifying copies of the executed medical authorizations were received by Mr. Wright’s law firm at 11:24 AM on 6-24-13.

That very afternoon of June 24, 2013, shortly after I delivered the copies to Mr. Wright’s office, in a highly irregular and unlawful turn of events, the court subsequently held a secret “special conference” with Mr. Wright without notifying me and without scheduling it on the Register of Actions. Exhibit D of my 1-21-14 Answer to Culpert’s 12-30-13 Motion contains a copy of the Register of Actions printed 6-24-13, which does not show the “special conference”, and a copy of the 1-21-14 Register of Actions, which does show the “special conference,” proving the 6-24-13 “special conference” was not scheduled and I was not provided with notice.

At the 6-24-13 “special conference,” Mr. Wright told the judge that the authorizations I provided him that morning were “altered” and that I did not provide everything he requested. He never even mentioned that I executed copies of Form MC 315, and he falsely led the judge to believe that Culpert’s attorney was also relying on the medical authorizations he had requested, even though I had already executed a separate set of MC 315 Forms for Culpert’s attorney, Mr. Hassouna, of which copies were provided to him in person at the 6-21-13 hearing.

The transcript of the 6-24-13 “special conference” indicates that the judge’s clerk tried to contact me by phone and there was no answering machine. However, the clerk didn’t even call the correct phone number, the only phone number I had ever provided on my court filings, which was my cell phone number of 734-751-0103, which had voice mail so that a message could have been left for me. This same court clerk had called me before on my correct number and left messages for me, so it was highly unusual that she would call a number I never even provided to the Court (which was my parents’ home land line). Then the transcript states that someone called back and said they were my mother, but that the clerk thought it sounded like me, and that “this person claiming to be her mother” provided a telephone number that the clerk called and left a message. It was my cell number the clerk called (the only number provided on my pleadings) after receiving the number from my mother. I called the court back and was told my case was dismissed because I had “altered the forms.” The clerk would not clarify any further. I was told I would have to appeal and order the transcripts to find out what was placed on the record for June 24, 2013.

Culpert’s attorney, Mr. Hassouna, included claims in his 12-30-13 Motion to Affirm and his 1-9-14 COA Brief, continuing to accuse me of impersonating my mother, even though I had already rebutted this claim during the circuit court proceedings, prior to the final hearing held on 8-9-13, and had even provided a sworn, notarized Affidavit from my mother, including photos of her caller ID displays and phone record to substantiate that the court clerk did indeed speak to my mother, not me; and that the clerk called the home landline in my mother’s name in service at her home address, instead of the number underneath my name on my pleadings filed with the circuit court. Exhibit BB of my 1-21-14 Reply to Culpert’s 12-30-13 Motion to Affirm contains my mother’s affidavit, her caller ID and phone records, and my cell phone record showing my call to listen to my voice message from the clerk and subsequent return call to the court. Strangely, shortly after this accusation of impersonating my mother and that I was the owner of the number the court clerk called, records began to appear on the internet associating my mother’s number with me (I know for certain they were not there before because I regularly entered my name in search engines and monitored results). These records still exist on the internet to this day, stating that I am the owner of that phone number, even though I have never had ownership of the number and have not disclosed it to be my phone number since I last lived at my parents’ residence in 1994.

The 6-24-13 transcript gives the impression I should have known about the “special conference,” but I believed I had fulfilled my legal obligation to provide Mr. Wright with signed medical authorizations, and he had not called me to inform me that there was any problem with the forms I provided that morning. Let it be clear that the reason I executed copies of Form MC 315 was because I had not timely received Mr. Wright’s forms. Mr. Wright’s hard copies of the forms were not delivered to my home until 3:00 p.m., after the 2:00 p.m. deadline expired for me to provide him with signed forms. Had I waited for his forms to arrive, I would have missed the deadline.

It should also be clear that I actually didn’t even have to provide Mr. Wright with any authorization forms at all under MCR 2.314(C)(1)(d), because in addition to the option of providing signed authorization forms under MCR 2.314(C)(1)(d), I also had the option under MCR 2.314(C)(1)(a) to simply provide the medical records, of which I already had copies since I had previously requested them from all of my providers for my own files. Click here for the full text of MCR 2.314(C)(1), which appears on the MEEMIC page.

At the 6-24-13 “special conference”, my entire case against both EDI and Culpert was dismissed, even though Kevin Culpert’s attorney, Mr. Hassouna, hadn’t objected to my use of form MC 315 to provide him with my medical records. Even more disturbing was the fact that back when my case was filed as a combined first- and third-party case by my first attorney, before it was re-filed separately by my second attorney, Mr. Hassouna was ready to settle for Mr. Culpert’s entire $20,000 insurance policy. Ex M of my 12-20-13 COA Brief contains a copy of the settlement agreement Mr. Hassouna sent to my first attorney for me to sign. My case against Culpert should not have been dismissed at the 6-24-13 “special conference” since Mr. Hassouna did not complain about the MC 315 forms I used to provide him with my records. Mr. Hassouna didn’t even attend the 6-24-13 “special conference.” As stated, at the 6-24-13 “special conference,” Mr. Wright made false statements that Mr. Hassouna was also depending on the authorizations that Mr. Wright was demanding I sign.

The 6-24-13 transcript gives the impression that Mr. Wright and the Court were somehow giving me special treatment by waiting 7 days before entering the Order of Dismissal. I was led to believe I had 7 days to object to it, which to me, meant that I was going to have a chance to present my arguments to the judge as to why my copies of MC 315 should have been accepted by Mr. Wright, and how his forms contained clauses above and beyond the requirements of MC 315. It wasn’t until I was preparing this commentary, nearly 12 years later, that I realized that I was completely misled about the purpose of objecting to a 7-day order.

Even Culpert’s COA pleadings continued to mislead me to think that by filing an Objection to the 7-day Order, I was objecting to the dismissal itself. Mr. Hassouna stating on pg. 3 of his 1-9-14 COA Brief that “the court delayed entry of this order until July 1, 2013, so that Plaintiff would have an opportunity to object.” I understand now, after all of my court experience that followed this case, that 7-day orders are standard practice following a hearing. Generally, an order is not signed at the hearing itself---one of the attorneys submits it to the court as a 7-day Order and the other party has 7 days to make corrections to the wording in the order, not to present arguments objecting to what actually happened at the hearing itself. There was no special treatment given to me by the court by “delaying entry of this order” for 7 days---this is standard practice, and objecting to the order would not even allow the judge the ability to change the decision made at the hearing.

I didn’t understand how a 7-day Order functioned at that time, so I filed an objection to the 7-day Order of Dismissal, believing I was actually objecting to the dismissal itself. A hearing was held on August 9, 2013. The 8-9-13 hearing transcript gives the appearance that this hearing was in regard to a Motion to Compel because Wright falsely claimed the motion was his motion for me to sign the authorizations, even though the case was already dismissed at this point, and it would have been impossible under the court rules for him to motion to compel me to sign authorizations. Most importantly, it was supposed to be a hearing on my Objection to the 7-day Order. I didn’t catch on to what was happening at the time of the hearing, and actually didn’t realize the extent of these misrepresentations until working on this commentary. I now understand why the judge was so impatient, why I wasn’t allowed to present any of my arguments about Mr. Wright’s forms, and why the hearing only lasted a mere 2 minutes. The judge couldn’t legally reverse her decision at a hearing for an Objection to a 7-day order since the only objections a party could raise would be that the wording in the order did not accurately represent what took place at the hearing, which in this case was not even a hearing, but a “special conference” that was held without me on 6-24-13.

It is important to understand that the judge who dismissed my third-party case is the same judge who had just recently dismissed my first-party case against MEEMIC, when she refused to allow me my right to use Form MC 315 to provide my records to MEEMIC, and forced me to choose between having my case dismissed or signing Records Deposition Service’s forms (a record copying service that would have stored my records digitally in a database; re-distributed them to whoever paid for them; and refused to allow me to even see what records they had collected).

It is highly likely the judge’s decision to dismiss my third-party case was related to her decision to dismiss my first-party case because I refused to release my records to a record copying service. To require the Defendants in this third-party case to accept the records they received from my use of executed copies of Form MC 315, but to have denied me the use Form MC 315 in my first-party case, would have made the judge’s decision in the MEEMIC case appear arbitrary and capricious.

Back then, I had faith in our justice system. I believed the Court of Appeals would overturn the MEEMIC dismissal, which was clearly an abuse of the judge’s discretion because it was contrary to MCR 2.314(C)(1)(d), a rule which mandated the use of Form MC 315 to provide one’s medical records to the opposing party. I believed I would receive justice in the Court of Appeals for this case as well, considering I had fulfilled my obligation to provide my medical records to both Defendants by exercising my right to execute copies of Form MC 315. My completed and signed forms were sent to my health care providers, who then sent copies of said medical records to both Defendants. I believed there was no way such a clear violation of the court rules could stand, so I appealed to the Court of Appeals, expecting the dismissal to be overturned, so my case could be remanded back to the circuit court, my medical records examined and analyzed, and the case heard on its merits. However, like the MEEMIC case, the Defense attorneys and Court of Appeals again went to extraordinary lengths to prevent me from prevailing.
 

EXPLANATION OF COURT OF APPEALS PROCEEDINGS

Coming soon!

CONCLUDING REMARKS

Coming soon!

DOCUMENTS FILED WITH THE COURTS

Below is a list of links to three separate sets of documents filed with the Michigan Court of Appeals and Michigan Supreme Court, and Orders issued by these Courts. As you can observe, I was absolutely inundated with paperwork related to this case.  One complication was that there were two separate Defendants (Culpert and his employer, Efficient Design, Inc.) bombarding me with pleadings containing numerous misstatements of fact and arguments without merit that required responses from me.  The second complication was that due to the Court of Appeals misrepresentation of its 11-25-14 Order, I had to file two separate Supreme Court appeals, which is highly irregular and never should have happened: The Court of Appeals' entered an Order on 11-25-14 which it falsely represented to be a "partial dismissal," but because of the particular issues it chose to dismiss, the 11-25-14 Order actually constituted a final order and a full dismissal of my case. I first filed a Motion for Reconsideration of the 11-25-14 Order with the Court of Appeals on 12-16-14, explaining this grievous error, but it was denied on 1-27-15. The first set of documents are the Court of Appeals filings through the 1-27-15 Denial of my 12-16-14 Motion for Reconsideration of the Court of Appeals 11-25-14 Order.

I then appealed the Court of Appeals 11-25-14 Order to the Supreme Court, since it represented a final order. The filings from MSC No. 151198 are linked in the second set of documents. 

The Court of Appeals also issued a 3-10-15 Opinion, which was separately appealed to the Supreme Court as MSC Case No. 151463. These filings are linked in the third set of documents.

For purposes of transparency, both my own (the Plaintiff-Appellant's, "PL-AT's") filings, Culpert's and Efficient Design, Inc.'s (the Defendant-Appellees', "DF-AEs'") filings are included.  You will notice that the Defendants' filings contain few, if any exhibits.  This is not because I failed to include them---every one of the Defendants' pleadings appear in their entirety.  The Defendants' pleadings consisted primarily of unsubstantiated false claims for which I had the daunting task of disproving, hence the numerous exhibits attached to my filings.

My filings appear in purple font. Culpert's filings are in blue, Efficient Design, Inc.'s filings are in orange, and Court Orders are in green.

FIRST SET OF DOCUMENTS:  Court of Appeals Filings through the 1-27-15 Denial of Tamara Filas's 12-16-14 Motion for Reconsideration of the Court of Appeals 11-25-14 Order

SECOND SET OF DOCUMENTS:  Supreme Court Filings - Appeal of Court of Appeals 11-25-14 Order (Issues 1-3 & 6)

THIRD SET OF DOCUMENTS:  Supreme Court Filings - Appeal of Court of Appeals 3-10-15 Opinion (Issues 4 & 5)

3-10-15 Opinion of the Court of Appeals (regarding issues 4 & 5 only, since 1-3 & 6 were dismissed with the 11-25-14 Order, which was separately appealed to the MSC on 3-10-15)

4-21-15 Tamara Filas's Application for Leave to Appeal the 3-10-15 Order to the Supreme Court

4-21-15 Tamara Filas’s Motion to Exceed Page Limit for 4-21-15 Application

4-28-15 Order of the Supreme Court Granting Tamara Filas’s 4-21-15 Motion to Exceed Page Limit

4-28-15 Culpert’s Answer to Tamara Filas’s 4-21-15 Application to the Supreme Court

5-12-15 Efficient Design, Inc.’s Answer to Tamara Filas’s 4-21-15 Application to the Supreme Court

5-14-15 Tamara Filas’s Motion for Extension to Reply to Culpert’s 4-28-15 Answer

5-28-15 Order of the Supreme Court Granting Tamara Filas’s 5-14-15 Motion for Extension

6-1-15 Tamara Filas’s Motion for Extension to Reply to Efficient Design, Inc.’s 5-12-15 Answer

6-9-15 Tamara Filas’s Reply to Culpert’s 4-28-15 Answer, Exhibits A & B, Exhibits C - N, Exhibits O - S, Exhibits T & U

6-9-15 Tamara Filas’s Motion to Exceed Page Limit for 6-9-15 Reply

6-23-15 Order of the Supreme Court Granting Tamara Filas’s 6-1-15 and 6-9-15 Motions

6-23-15 Tamara Filas’s Reply to Efficient Design, Inc.’s 5-12-15 Answer, Exhibits A - G, Exhibits H - N, Exhibits O - Y, Exhibits Z & AA

6-23-15 Tamara Filas’s Motion to Exceed Page Limit for 6-23-15 Reply

6-29-15 Efficient Design, Inc.’s Joint Answer to Tamara Filas’s Motions to Exceed Page Limit in cases 151198 & 151463

6-30-15 Tamara Filas’s Reply to Efficient Design, Inc.’s 6-29-15 Answer

6-30-15 Order of the Supreme Court Denying Tamara Filas’s 6-23-15 Motion to Exceed Page Limit and Striking her 6-23-15 Reply to Efficient Design’s 5-12-15 Answer

7-21-15 Tamara Filas’s [revised per 6-30-15 Order] Reply to Efficient Design, Inc.’s 5-12-15 Answer, Exhibits A - P, Exhibits Q - HH

9-9-15 Order of the Supreme Court Denying Tamara Filas’s 4-21-15 Tamara Filas's Application for Leave to Appeal the 3-10-15 Order to the Supreme Court

9-30-15 Tamara Filas’s Motion for Reconsideration of 9-9-15 MSC Order

10-5-15 Tamara Filas’s Corrected Motion for Reconsideration of 9-9-15 MSC Order and Exhibits A - K, Exhibits L - W (revision of the 9-30-15 Motion to be 10 pages)

10-7-15 Culpert’s Answer to Tamara Filas’s 10-5-15 Motion for Reconsideration

10-15-15 Efficient Design, Inc.’s Answer to Tamara Filas’s 10-5-15 Motion for Reconsideration (same filing as for case 151198)

10-19-15 Tamara Filas’s Motion for Leave to Reply to Culpert's 10-7-15 Answer and Efficient Design, Inc.'s 10-15-15 Answer

10-28-15 Order of the Supreme Court Granting Tamara Filas’s 10-19-15 Motion

11-12-15 Tamara Filas’s Reply to Culpert's 10-7-15 Answer and Efficient Design, Inc.'s 10-15-15 Answer

12-30-15 Appearance of new attorneys representing Efficient Design, Inc. in cases 151198 & 151463:  Appearance #1, Appearance #2 (Note: This filing was unusual since all possible filings had already been submitted, so there was no need to substitute different attorneys at this point.)

2-2-16 Order of the Supreme Court Denying Tamara Filas’s 10-5-15 Motion for Reconsideration