APPLICANT’S MEMORANDUM OF ARGUMENT
PART I – OVERVIEW
STATEMENT OF FACTS AND MATTERS OF PUBLIC IMPORTANCE
1. The applicant, Ms. Kueber, is self-represented, the plaintiff and appellant in the
courts below where she faced 4 law firms in a complex medical negligence, with
evidence of lack of consent and fraud.
2. Ms. Kueber did put forth a coherent case in the courts below. There was a large
amount of evidence, and multiple facta, and briefs, were filed. There were also oral
submissions, yet, the Self-represented Applicant submits, she was not heard, her evidence, and arguments were given no consideration, in either courts.
3. In the Superior Court of Justice, H.K. O’Connell declared Ms. Kueber’s evidence,
the evidence of the responding and moving Plaintiff, was moot, almost year after the 5th
day of summary judgment finding the Defendants, all met their burdens as moving parties on their respective summary motions, and, the partial cross-motion…
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