Section 5 – Exhibit 12 – filed - September 30, 2003

A plaintiff has the responsibility to prosecute its case, and many courts require that cases be prosecuted within six months.  Anything longer can be considered failure to prosecute, and the case can be dismissed for failure to prosecute.  Metris failed to file any further Motions until more than three months after its complaint was filed, then filed for Judgment On The Pleadings.  Edwards filed her Response to Plaintiff’s Motion For Judgment on the Pleadings, rebuts Metris’ charges and states that Metris is not registered with the Public Regulations Commission and its appearance in court is deceptive by counsel.

The Response follows on the next page.