1 Hiawatha Hoeft-Ross

Monica Hoeft-Ross
2 PO Box 6946
(775)544-2721
3 IN PRO SE
UNITED STATES DISTRICT COURT
4 DISTRICT OF NEVADA
*****
5
6
Hiawatha Hoeft-Ross Et. Al.
7 CASE NO. CV-N-05–0121 LRH(VPC)
8 Plaintiffs,
9
vs.
10
Werner and Christel Hoeft, Et Al.
11
12 Defendants.
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14 PLAINTIFFS REPLY TO DEFENDANTS OPPOSITION TO PLAINTIFFS’
MOTION FOR REVIEW BY THE DISTRICT COURT OF OBJECTION
15 TO MAGISTRATES DECISION REGARDING 60(b) MOTION
16 COMES NOW PLAINTIFF HIAWATHA HOEFT-ROSS , MONICA HOEFT-ROSS,
17 MARTIN HOEFT-ROSS AND KIRSTEN HOEFT-ROSS and reply to DEFENDANTS
18 OPPOSITION TO PLAINTIFFS’ MOTION FOR REVIEW BY THE DISTRICT
19 COURT OF OBJECTION TO MAGISTRATES DECISION REGARDING 60(b)
20 MOTION. Fed.R.Civ.P. 72(b) does not apply to the action at bar, and as far as 28 USC Sec 636
21 (b)(1), Plaintiffs are already aware of this section as it was hashed through in previous papers.
22 Counsel brings nothing new and in truth and in opposition to the action at this table.
23 Defendants counsel, Michael Kealy, did not file a mandatory disclosure of witnesses and
24 exchange of documents until September 8th, 2006 well after the mandatory 30 day requirement.
25 Defendants purposely waited to file until well after the 30 day mandatory disclosure filing
26 requirements but continued to inform the Court that the Defendants were diligent, while the
27 Plaintiffs were not. There is no other reason, either rational or apparent, why Counsel would conceal
28 the July 27th 2006 mandatory disclosure list of the Plaintiffs.
 1 LR 16-1. SCHEDULING AND CASE MANAGEMENT; TIME AND ISSUANCE OF
2 SCHEDULING ORDER.
3 (a) In cases where a discovery plan is required, the court shall approve, disapprove or modify the
4 discovery plan and enter the scheduling order within thirty (30) days from the date the discovery plan
5 is submitted. (Emphasis added)
6 Plaintiffs’ experience in the act of discovery is that the represented party initiates the
7 discovery.
8 Plaintiffs waited patiently until the 27th of July 2006 and submitted their own discovery plan
9 and witness list to the defendants. During this time the Plaintiff Hiawatha Hoeft-Ross started feeling
10 effects of his on-going medical condition.
11 Michael Kealy, without regard to the time being of the essence in initial disclosures,
12 remained unavailable for two weeks during the Meet and Confer time frame After that period of
13 time, between existing engagements and Plaintiff Hiawatha Hoeft-Ross’ onset of deterioration of his
14 medical condition, which affected his ability to negotiate and understand the matters before him,
15 the Meet and Confer was set off indefinitely. Plaintiff blames this partially on opposing counsel,
16 for if opposing counsel conformed to the Local Rules 16-1. Hiawatha Hoeft-Ross would have been
17 medically fit to do the Meet and Confer.
18 During the times of negotiation, to get a time that agrees with both parties and the wellness
19 of the Plaintiff Hiawatha Hoeft-Ross, the weeks became months, and on October 12th, 2006, Plaintiff
20 Hiawatha Hoeft-Ross was in a hit and run car accident. He was seen in the emergency room for his
21 immediate injuries and was referred to a specialist for review of his on-going medical condition.
22 This accident exacerbated Plaintiff Hiawatha Hoeft-Ross' existing injuries and/or created new ones.
23 On November 1st 2006 Plaintiff Hiawatha Hoeft-Ross saw his specialist and said specialist prepared
24 a letter for the court. Unfortunately when Plaintiff thought he had sent this document to the Court
25 and opposing counsel, but it subsequently was discovered in his "files"while preparing this motion.
26 In a write-up on November 13th 2006, by Dr. Berman, the surgical procedures that Plaintiff
27 Hiawatha Hoeft-Ross underwent were not effective at alleviating his pain or stabilizing his
28 condition. Plaintiff advised counsel on November 21st 2006 of this and asked to stipulate to an

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 1 indefinite continuance, but did not receive an answer by November 27th 2006. Plaintiff then
2 received a letter from counsel stating that they would not stipulate to an indefinite continuance, but
3 would seek a summary judgement. Plaintiff wrote back to Mr. Kealy, Defendants' counsel and stated
4 that he regretted that a stipulation cannot be reached without court intervention. Plaintiff Monica
5 Hoeft-Ross wrote Mr. Kealy on January 3rd 2007, stating that Hiawatha Hoeft-Ross' condition had
6 not stabilized and was awaiting their summary judgement. Plaintiffs received a response from Mr.
7 Kealy on January 10th 2007, wherein he stated he was confused about Plaintiffs awaiting a summary
8 judgement from counsel and discussing a resolution. As stated before, Plaintiff Hiawatha
9 Hoeft-Ross was in no condition to discuss any such resolution as he was not mentally capable of
10 resolving legal matters.
11 Dr. John N. Chappel wrote a declaration in that Plaintiff Hiawatha Hoeft-Ross has not been
12 able to function well enough to attend court. Plaintiff Hiawatha Hoeft-Ross has had another
13 appointment with Reno Diagnostics for additional diagnostic medical examinations to be performed
14 due to his non-responsiveness to previous medical procedures
15 Plaintiff simply did not “show up” for the case management conference on January 18th,
16 2007, But rather Plaintiff was too ill to attend and Plaintiff out of excusable neglect thought he
17 mailed that letter from John N. Chappel M.D. to the Honorable Valerie P. Cooke to explain his
18 medical situation. Plaintiffs had agreed that Plaintiff Hiawatha Hoeft-Ross would be the only party
19 speaking on their behalf in order to minimize confusion that might arise from multiple pleadings.
20 Plaintiffs did not voluntarily waive their right to conduct discovery and did not voluntarily refuse
21 to attend the meeting. But Plaintiffs were confused for two reasons: 1) Hiawatha Hoeft-Ross’ long-
22 standing illness and 2) the misrepresentation that opposing counsel will immediately seek a summary
23 judgement which would render moot the January 18th 2007 meeting. Judge Cooke exceeded her
24 discretion by sanctioning Plaintiffs so harshly for a first-time offense which they had made through
25 excusable neglect. Counsel Michael Kealy also contributed to this by not being candid towards this
26 tribunal.
27 Rule 172 Candor Toward the Tribunal
28 [4] In an ex parte proceeding, a lawyer shall inform the tribunal of all material facts known to the

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 1 lawyer which will enable the tribunal to make an informed decision, whether or not the facts are
2 adverse.
3 Mr. Kealy appeared at the Case Management Conference on January 18th, 2007. He provided
4 documentation and correspondence he had received from Plaintiffs. However he intentionally failed
5 to provide a complete history of the documentation and correspondence as shown in Plaintiffs’
6 exhibits. Mr. Kealy also failed to note for the court the fact that Plaintiffs had responded to the
7 mandatary disclosure requirements and the proposed Discovery Plan prior to any action being taken
8 on behalf of his client. This omission falsely led the Court to believe that Plaintiffs were non-
9 compliant with all discovery matters. Additionally the omission of the documentation and
10 correspondence carried on between Plaintiffs and defendants counsel could only lead the Court to
11 believe that Plaintiffs were refusing to comply with court orders and thus appeared to be
12 contemptuous of the Court. This may be the basis for the extreme sanctions imposed by the Court
13 on Plaintiffs. Clearly the AbA Model Code of Professional Responsibility cited above requires all
14 members of the ABA to be completely candid with the Court and to provide information to the Court
15 which may not always be in the best interest of their client(s).
16 Rule 173 Fairness to Opposing Party and Counsel
17 A lawyer shall not:
18 [1] Unlawfully obstruct another party’s access to evidence or unlawfully alter, destroy or conceal
19 a document or other material having potential evidentiary value. A lawyer shall not counsel or
20 assist another person to do any such act; (emphasis added)
21 Mr. Kealy concealed from the Court all documentation and correspondence between the parties
22 which showed an ongoing effort by the Plaintiffs to keep Mr. Kealy apprized of the unfortunate
23 results from the accident suffered by the Plaintiff Hiawatha Hoeft-Ross. If Mr Kealy had notified the
24 Court of the information in his possession the Court would have been in a better position to act in
25 a manner consistent with the long established case law involving medical disabilities which
26 constitute excusable neglect. Mr. Kealy was fully aware that Plaintiff Hiawatha Hoeft-Ross was
27 under medical orders to not engage in any “legal conflict.”
28 [4] In pretrial procedure, make a frivolous discovery request or fail to make reasonably diligent effort

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 1 to comply with a legally proper discovery request by an opposing party;
2 Mr. Kealy was dilatory in corresponding with plaintiffs and in several instances ignored discovery
3 requests outside of the purview of this Court as required by the FRCP: the movant (Plaintiffs) have
4 in good faith conferred or attempted to confer with other affected parties in an effort to resolve the
5 dispute without court action, or failing to file a motion to compel, whereas Mr. Kealy has been
6 totally unamenable to negotiation which would avoid consuming the time of the Court. As Plaintiff
7 states on December 4th, 2006, in response to Mr. Kealy’s letter of November 28th, 2006, “Since you
8 appear unwilling to stipulate to indefinite continuance or stabilization of Mr. Hoeft-Ross’ medical
9 conditions, we will prepare a motion before the court. We regret that we cannot stipulate to an
10 agreement without intervention of the court.”
11 Mr. Kealy placed additional stress on Plaintiff Hiawatha Hoeft-Ross by offering a settlement
12 contingent upon Plaintiff Hiawatha Hoeft-Ross obtaining a medical release or he faced with
13 defending a motion for summary judgement..
14 Mr. Kealy also failed to do the Certification of Counsel pursuant FRCP 37(a)(2) and/or a
15 motion to compel and should be sanctioned for not following the rules of court, as there is a higher
16 standard placed on practicing attorneys than on pro-se’s. Plaintiffs wrote to Mr. Kealy that they had
17 tried to work with Mr. Kealy outside of this court but unfortunately weren’t able to do so due to the
18 (in)action of Mr. Kealy. Mr. Kealy was under the Model Code of Professional Responsibility to do
19 his best to work with Plaintiffs in keeping discovery outside of this Court. He did not. Instead, he
20 immediately, on September 8th, 2007, without negotiations with plaintiffs, submitted his proposed
21 discovery plan, and did not file a certificate of making good faith attempts for Meet and Confers
22 without judicial help pursuant to FRCP 37(a)(2) . Mr. Kealy even failed to take a more drastic step
23 of filing a motion to compel. It is for these actions or lack thereof that Mr. Kealy should be
24 sanctioned for being not candid with this tribunal and unfair to opposing counsel (Plaintiffs).
25 Mr. Kealy should be sanctioned for making malicious attacks on the Plaintiffs trying to
26 prosecute their case. Although Mr. Kealy may have a higher standing in the community than the
27 likes of the Plaintiffs, that does not allow him to denigrate plaintiffs attempts at securing every bit
28 of information they may attain to prosecute their case. Mr. Kealy States that Mr. Hoeft-Ross

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 1 “sought broad judicial notice of some ill-defined matters, claims or information submitted in other
2 litigation filed in federal court in 2002.” Firstly, counsel over states the matter to make the issue
3 seem more dramatic than it really was. Plaintiff Hoeft-Ross did not seek “broad judicial discretion”
4 but merely sought judicial notice on a publicly filed document that provides medical diagnoses his
5 condition very well and was submitted to the Honorable Valerie P. Cooke who has personal
6 knowledge of this document so that she may refresh her memory regarding the major disorders Mr.
7 Hoeft-Ross suffers from. Here again, Mr. Kealy resorts to besmirching Plaintiff Hoeft-Ross’
8 evidence, stating that it was ill-defined. This document was generated by two prominent physicians
9 over years of testing and evaluation to come to a very well received and thorough document. It is
10 Mr. Kealy who is displaying his ignorance. The Magistrate Judge was beyond her discretion in
11 denying sanctions towards Mr. Kealy who obviously broke the Model Code of Professional
12 Responsibility in seeking out a “victory” for his clients. Mr. Kealy’s instant Motion is just as
13 amorphous as he purports the request for judicial notice to be. The fact of the matter is that Counsel’s
14 motion is devoid of any case law demonstrating the judicial definition or the acceptable parameters
15 of the points and authorities he cites.
16 II
17 LAW AND ARGUMENT
18 A. THE MAGISTRATES ORDER IS NO CLEARLY ERRONEOUS OR CONTRARY TO
19 LAW
20 Counsel only here reiterates that the magistrate has broad discretion to conduct pre-trial
21 matters and non dispositive matters inter alia. Then goes into discovery matters, but at no time does
22 Counsel directly address the basic tenets set forth in Plaintiffs’ reconsideration of the 60(b) motion,
23 Counsel merely reiterates the same old reasons as in his initial motion to deny Plaintiffs a 60(b)
24 motion - that the Magistrate did not act in excess of her authority. Counsel addresses none of the
25 theories advanced by the plaintiffs, instead counsel leaves us with a few remaining housecleaning
26 items, that counsel should not be able to raise since he loses his rights to bring these actions forward
27 since he did not raise them ab initio.
28 Plaintiffs will address these issues to preserve their rights for this litigation. Counsel’s main

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 1 concern seems to be why the remaining three Plaintiffs did not show for the case management
2 conference. First of all, besides the established medical issues, Plaintiff Hiawatha Hoeft-Ross did
3 not attend the meeting due to medical advice and under the mistaken understanding that it was only
4 he who was supposed to be attending the meeting, since the federal issues came first. The remaining
5 Plaintiffs have only State issues of which the Court took jurisdiction. Plaintiff Monica Hoeft-Ross
6 is under a Doctor’s supervision and is to avoid major stressors and receives medication to ameliorate
7 the effects of unavoidable stressors, as quoted in a previous motion, and is noticed under John N.
8 Chappel’s M.D. declaration of November 1st, 2006, which states that plaintiff Monica Hoeft-Ross
9 is under the care of the Nevada Mental Health Dept.. The children, whether the age of majority or
10 minority, are still under the auspices of their parents, and are not allowed to enter into any legal
11 agreements or stipulations without their parents presence as long as they live in the household. Mr.
12 Kealy who is very artful, will be certain to ensure that the Plaintiffs lose all rights as he has done in
13 the past if. As set forth supra Plaintiff Hiawatha Hoeft-Ross has been designated as counsel and the
14 children will only attend Court when ordered to do so or their testimony is necessary in order to
15 avoid exacerbation of the familial situation.
16 Then Counsel goes on a rant that “Plaintiff Hiawatha Hoeft-Ross only offers incomplete,
17 cryptic, unauthenticated, and vague material which purport to be physicians papers, and contain
18 conclusory statements about Hiawatha Ross.” Let it be known to counsel, that notes by physicians
19 are made under penalty of perjury or else they can lose their license:
20 NRS 630.3062 Failure to maintain proper medical records; altering medical records; making false
21 report; failure to file or obstructing required report; failure to allow inspection and copying of
22 medical records; failure to report other person in violation of chapter or regulations. The following
23 acts, among others, constitute grounds for initiating disciplinary action or denying licensure:
24 (emphasis added)
25
26 1. Failure to maintain timely, legible, accurate and complete medical records relating to the
27 diagnosis, treatment and care of a patient.
28 2. Altering medical records of a patient.

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 1 3. Making or filing a report which the licensee knows to be false, failing to file a record or
2 report as required by law or willfully obstructing or inducing another to obstruct such filing.
3 4. Failure to make the medical records of a patient available for inspection and copying as
4 provided in NRS 629.061.
5 5. Failure to comply with the requirements of NRS 630.3068.
6 6. Failure to report any person the licensee knows, or has reason to know, is in violation of the
7 provisions of this chapter or the regulations of the Board.
8 (Added to NRS by 1985, 2223; A 1987, 199; 2001, 767; 2002 Special Session, 19; 2003, 3433)
9 Let it be also known to counsel that a declaration carries the same weight as an affidavit :
10 28 U.S.C. § 1746. Unsworn declarations under penalty of perjury:
11 Wherever, under any law of the United States or under any rule, regulation, order, or requirement
12 made pursuant to law, any matter is required or permitted to be supported, evidenced, established,
13 or proved by the sworn declaration, verification, certificate, statement, oath, or affidavit, in writing
14 of the person making the same (other than a deposition, or an oath of office, or an oath required to
15 be taken before a specified official other than a notary public), such matter may, with like force and
16 effect, be supported, evidenced, established, or proved by the unsworn declaration, certificate,
17 verification, or statement, in writing of such person which is subscribed by him, as true under penalty
18 of perjury, and dated, in substantially the following form:
19 (1) If executed without the United States: “I declare (or certify, verify, or state) under penalty of
20 perjury under the laws of the United States of America that the foregoing is true and correct.
21 Executed on (date). (Signature)”.
22 (2) If executed within the United States, its territories, possessions, or commonwealths: “I declare
23 (or certify, verify, or state) under penalty of perjury that the foregoing is true and correct. Executed
24 on (date). (Signature)”.
25 All materials are not subjective because they are either 1) Doctor’s notes which must conform
26 to the Medical Examiners Board of Authentication; 2) mail, which was sent via certification or ; 3)
27 by third party proof, or 4) Mr. Kealy’s and/or his clients’ own writings.
28 Counsel should look at his blatant non-compliance with the rules and have the Judge

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 1 determine that Defendants are not entitled to any relief and that the Magistrates’s rulings are clearly
2 erroneous and contrary to law pursuant to Pioneer Investment Svcs Co.
3
4 B.
5 THE MOTION FOR REVIEW IS AN UNTIMELY ATTEMPT TO OBTAIN REVIEW
6 OF THE JANUARY 18, 2007 ORDER
7 This is a timely objection to the Magistrate’s ruling and therefore review is required U.S.W.
8 v. New Jersey Zinc Co., 828 F.2d 1001 (3rd Cir 1987); Moores Federal Practice 72.11[1][a]. The
9 final order and/or judgement came from the Magistrate on April 10th, 2007 and the plaintiffs received
10 the judgement and/or order on April 11th, 2007.
11 Counsel states that the Plaintiffs were not entitled to engage in any more discovery due to
12 their non-compliance. This non-compliance, in addition to the Plaintiffs’ ailments were part and
13 parcel the responsibility of Michael Kealy who wrote in or about January that counsel apparently did
14 not believe Mr. Hoeft-Ross’ letters and stated he would be filing a summary judgement request with
15 the District Court immediately. Based on Mr. Kealy’s written statements, Mr. Hoeft-Ross believed
16 the hearing scheduled for the 18th of January 2007 had been vacated since the Summary Judgement
17 would preempt that hearing. That is misleading and a falsehood and an attempt to get Plaintiffs
18 sanctioned by and through deceit, by remaining silent on the issue of January 18th, 2007. “In an
19 action of deceit, it is true that silence as to a material fact is not necessarily , as a matter of law,
20 equivalent to a false representation. But Mere silence is quite different from concealment; aliud est
21 tacere, aliud tcelare: A suppression of truth of the truth may amount to a suggestion of false hood;
22 and if with intent with intent to deceive, either party to a contract of sale or conceals or suppresses
23 a material fact which he is good faith bound to disclose, this evidence of and equivalent to a false
24 representation, because the concealment or suppression is in effect a representation, is in effect a
25 representation that what is disclosed is the whole truth. The gist of the action is fraudulently
26 producing a false impression upon their mind of the other party; and if this result is accomplished,
27 it is unimportant whether the means of accompanying it are words or acts of the defendants , or his
28 concealment or suppression of material facts not equally within the knowledge or reach of the

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 1 plaintiff.” Stewart v. Cattleman’s Ranche Company ,128 US 383; 9 S.Ct. 101; 32L.Ed. 439; 1888
2 US LEXIS 22224.
3
4
5 C. PLAINTIFFS CONFUSE THE MAGISTRATES ORDER WITH A DEFAULT
6 Counsel states that Plaintiffs devote several of their passages of their argument to suggest that
7 the magistrate entered some type of judgement by default. Then counsel goes on to say that these
8 arguments are misplaced because the magistrate did not enter any judgement by default or otherwise.
9 Plaintiffs would like to point to Blacks Law. That the magistrate issued an order on January 18th,
10 2007, and an order according to Blacks Law may also be a judgement Traders & General Ins. Co.,
11 v. Baker Tex.Civ.App., 111 S.W. 2d 839, 840.
12
13 D. THE MAGISTRATES DECISIONS NOT TO TAKE JUDICIAL NOTICE IS NOT
14 CLEARLY ERRONEOUS
15 Judicial notice as per Black’s law: The act by which a court, in conducting a trial or framing
16 its decision, will, of its own motion or on request of a party, and without the production of evidence,
17 recognize the and truth of certain facts, having bearing on the controversy at bar, which, form their
18 nature are not properly the subject of testimony , or which are universally regarded as established
19 by common notoriety, e.g., the laws of the state, international law, historical events, the constitution
20 and the course of nature, main geographical features , etc.. Such notices excuses party having burden
21 of establishing fact from necessity of producing formal proof. (Emphasis added) Hutchinson v. State
22 447 N.E.2d 850, 854. Fed.Evid.Rule 201
23 Will - Black’s Law : An auxiliary verb having the mandatory sense of “shall” or “must”. It is a word
24 of certainty while the word “may” is one of speculation and uncertainty.
25 Together with these two terms the Magistrate Judge has no choice BUT to take judicial notice
26 when requested by one of the parties.
27 According to Blacks Law, common law and statute, Plaintiff has the burden of proof showing
28 excusable neglect due to medical excuse and the Judge Magistrate must issue a judicial notice in

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 1 order to prove the on-going medical conditions. This type of material is exactly what Fed.Evid.Rule
2 201 is made to do. Plaintiffs again state that the Magistrate Judge has exceeded her jurisdiction.
3 And as stated before, Doctor’s reports, whether they state on their face or not are under penalty of
4 perjury or else the Doctors so subscribing shall be subjected to punishment.
5 The material was not given over during discovery because it is a public document and
6 available for counsel to discover and copy on its own accord.
7
8 III.
9 CONCLUSION
10 Michael Kealy should be sanctioned according to LR 7-2 (d): The failure of a moving party
11 to file points and authorities in support of the motion shall constitute a consent to the denial of the
12 motion. The failure of an opposing party to file points and authorities in response to any motion
13 shall constitute a consent to the granting of the motion; by having the court grant the Plaintiffs’
14 motion for a 60(b). Since Counsel addresses none of the points or authorities in the Plaintiff’s motion
15 for review and again, submits this puerile piece of paper that doesn’t warrant being before this
16 Honorable Court. As such, Plaintiffs have made out a prima facie showing by and through their
17 pleadings and papers that they have made a demonstration of excusable neglect due to good cause
18 of a medical nature pursuant to the premier case of Pioneer Investment Svcs., and are as such,
19 entitled to a 60(b) motion under the Motion for Review by the District Court of Objection to
20 Magistrates Decision Regarding 60(b) Motion. The motion by Mr. Kealy is bare bones, and Mr.
21 Kealy has attempted to take two bites of the apple. Any new issues raised should be stricken.
22 Plaintiffs are before this court, sick and barely able to make this response in the time allotted.
23 Defendants once again are forcing Plaintiffs to litigate against Doctor’s orders and counsel should
24 also be sanctioned for the unnecessary litigation. For the above reasons and points and authorities
25 stated herein and all the pleading, papers on file, with the exception of those filed before the First
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 1 amended complaint1 Plaintiffs’ motion shall be granted.
2
3 DATED:
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5 ____________________
Hiawatha Hoeft-Ross
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____________________
8 Monica Hoeft-Ross
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1
Since an amended pleading supersedes the original, facts not incorporated into the amended pleading are considered
24
functus officio. See 6 CHARLES ALAN WRIGHT & ARTHUR R. MILLER, FEDERAL PRACTICE & PROCEDURE§ 1476 (2d
25
ed. 1990); Parry v. Mohawk Motors of Mich., Inc.,236 F.3d 299, 306-07 (6thCir.2000) (when a plaintiff files amended complaint,
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new complaint supersedes all previous complaints and controls the case from that point forward)(citing In re Atlas Van Lines, Inc.,
27 209 F.3d 1064, 1067 (8thCir.2000); Duda v. Board of Educ. of Franklin Park Pub.Sch. Dist. No. 84, 133 F.3d 1054, 1057

28 (7thCir.1998).

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 1
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PROOF OF SERVICE BY MAIL
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Pursuant to FRCP 5(b), I certify that, I on May 18th 2007, I, Monica Hoeft-Ross deposited in the U.S.
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Mail at Reno, Nevada, in a sealed envelope, a PLAINTIFFS REPLY TO DEFENDANTS
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OPPOSITION TO PLAINTIFFS’ MOTION FOR REVIEW BY THE DISTRICT COURT OF
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OBJECTION TO MAGISTRATES DECISION REGARDING 60(b) MOTION and
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declarations of Hiawatha hoeft-Ross, Monica Hoeft-Ross Kirsten hoeft-Ross and Martin Hoeft-Ross
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in support of REPLY attached hereto, a true and correct copy postage prepaid thereon, addressed
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to:
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18 Michael Kealy
50 West Liberty Street Suite 750
19 Reno, NV 89501
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21 _____________________________
Monica Hoeft-Ross
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