Section 4 – Exhibit 11 – filed July 18, 2003

Once a Motion has been filed, the opponent must file a response to that Motion within the days specified by local court rules.  It is 15 days after service in New Mexico.  Metris failed to file its Response within that time period, thus, by rule, admitted to the Edwards’ Motion To Dismiss and her  charges made therein.  However, since Harris favored Metris, he failed to hold Metris accountable to this or any other rule, thus, he failed to uphold the rule, the law and his duty as a judge, which he continued to do throughout this case.

On the following page is Edwards’ Reply To Plaintiff’s Response To Motion To Dismiss.  Edwards points out that Metris failed to rebut her charges made in her Motion To Dismiss, therefore, by court rule, Metris agrees to her charges and, by rule, the case must be dismissed.  Harris, as usual, failed to abide by this or any other rule in this case.  In order to fully comprehend the objectives and intent of a case, it is important to understand the mechanics and ingredients of the Motions and pleadings.  The laws, rules, procedures and case law Edwards cited in her pleadings support her lawful positions.  Most states have similar or related laws, and all state Constitutions mimic the Federal Constitution.  Those of you who are interested in such actions should research the laws and case laws cited to understand why Edwards cited them, and act appropriately in your own cases.