Thank you for receiving the Particulars which I gave Lindsay when I saw her last week. I had previously indicated that I would not be holding you to the original 20-day deadline with regard to your Statement of Devence in Green v Anchan, but now that we have appeared before Master Lee I feel that all other matters are back on track. I will therefore expect your response to my Statement of Claim by the end of next week, failing which I will, as you understand, proceed accordingly.Further to these and other proceedings, I am attaching herewith a list of the priorities which I presented to Lindsay at our last meeting. I have added a couple of items for you information; I think it is best that we have these all on record.Thanks,Marty Green-------------------------PRIORITIES1. I wish to serve the Statement of Claim CI13-01-83238 (Green v Anchan, or “Breach of Duty of Care”) on the defendant Jane Doe whose identity is known to the Univeristy. I will be asking the Court to instruct the University to either accept service on her behalf, or to provide me with contact information so I can have her served before October 29th which will be 6 months from the filing of the claim.2. With regard to CI12-01-79879 (Green v Tram, or “Conspiracy to Injure”) I wish to proceed with discovery and accordingly would like to argue the three associated motions together. In addition to the relief I have already asked for, I will now be asking further that in view of the defendants’ unresponsiveness in terms of the interrogatories, that further discovery shall be held in front of a master rather than a court reporter.3. With regard to CI13-01-82216 (Green v Bush, or “Defamation”) I intend to cross-argue their Motion for Summary Judgment with a Motion for Leave to Amend Pleadings Pending Discovery.4. I believe I am going to need to add the WSD as a co-defendant in Green v Tram. I had earlier broached this subject with Mr. Mackwood and in view of the circumstances I think I need to go ahead with this.5. In the matter of Green v Bush, I will be moving for leave to add additional defendants, based on new information which has recently come to light.6. I have prepared a list of witnesses in Green v Tram who were minors at the time of the events, and I wish to negotiate an understanding whereby I will be permitted to examine them. If opposing counsel is not willing to discuss this, I will need to put it forward in the form of a motion.
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As usual in such circumstances, opposing counsel did not respond.