100120 city response to motion for judgment on pleadings
TRANSCRIPT
-
8/3/2019 100120 City Response to Motion for Judgment on Pleadings
1/2
1L Vr !~C.',',' He .. t ,.. . f\."> ISEYENTH J U D IC IA L
D IS T R IC T C O U R TFILEDCOUNTY OF SIERRASEVENTH JUDICIAL DISTRICT COURT
No.: D-0721-CV-2009-00098Judge: WILLIAM SANCHEZ
2 0 1 0 L l R N 20 P P 1 1 3 6C O U R T C L E R K
D E P U T YSTATE OF NEW MEXICO, ex. rei.DEBORAH TOOMEY, Individually,
Petitioner,vs.CITY OF TRUTH or CONSEQUENCES, a Municipality;LORI MONTGOMERY, Individually,and in her Official Capacity as Mayor;JERRY D. STAGNER, Individually,and in his Official Capacity as Mayor Pro-Tern;FRED TORRES, Individually,and in his Official Capacity of City Commissioner;EVELYN RENFRO, Individually,and in her Official Capacity of City Commissioner;STEVE GREEN, Individually,and in his Official Capacity of City Commissioner;JAIME AGUILERA, Individually,and in his Official Capacity of City Manager;MARY PENNER, Individually,and in her Official Capacity of City Clerk and Custodian of Records;BERNADINE GARCIA, Individually,and in her Official Capacity as Utility Billing Supervisor;DISTRICT ATTORNEY FOR SIERRA COUNTY,
Respondents.CITY'S RESPONSE TO PETITIONER'S
MOTION FOR JUDGMENT ON THE PLEADINGS
Page 1 of2
]]]]]]]]]]]]]]]]]]]])]]]]]]
-
8/3/2019 100120 City Response to Motion for Judgment on Pleadings
2/2
COMES NOW the City and hereby states that it opposes the Petition r'sMotion. As grounds, therefor, the City relies on the arguments made in its astpleadings including its October 21, 2009 Response to the Petition, its Decem er28, 2009 Motion to Dismiss, and its January 7, 2010 Reply. As the reques eddocuments do not exist, this matter should be dismissed.
JAIME UBIN, Esq.City AttorneyJaime F. Rubin, LLCP.O. Drawer 151Truth or Consequences, NM 87901575.894.3031 Fax: 575.894.328
CERTIFICATE OF MAILINGThe undersigned hereby certifies that a copy of the foregoing CIT 'S
RESPONSE TO PETITIONER'S MOTION FOR JUDGMENT ON T EPLEADINGS was mailed to Deborah Toomey, Petitioner, at 415 W. Riversi eDr., Truth or Consequences, New Mexico, 87901, on the zof~ day of Janua y,2010.
Page 2 of2