Section 12 – Exhibit 19 – filed January 16, 2004

          This Exhibit is Edwards’ Reply to Metris’ Objection to the telephonic hearing.  Edwards again stated that Metris had failed to rebut her previous charges made in her Objection and she invoked NMSA 1-008(D), Effect of Failure To Deny, so Metris, by law, agrees with and admits to her charges.  Edwards further stated that ex-parte communications took place between Harris, the court and Metris’ attorneys, which is prohibited by law.  Edwards rebutted Metris’ referral to Edwards’ letters as “ alleged evidence” and states that counsel and DMB received these letters and failed to rebut Edwards’ charges, thus, they stand as admitted.  Edwards further presents excerpts from her letters, marked exhibits A-F, which DMB, Metris and their attorneys failed to rebut.  Thus, pursuant to the Effect of Failure To Deny, Metris, their attorneys and DMB admit to Edwards’ charges.             

          The Reply follows on the next page.