Denise Subramaniam 

Self-represented 

13865 SW Walker Rd 

Beaverton OR 97005 

503-764-5300 

FIL£D17 JIJi '1516:341JSOC~ 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

LNV CORPORATION 

Plaintiff, 

v. 

DENISE SUBRAMANIAM 

pro per 

Defendant 

Civil Case No. 3:14-cv-01836 

DEFENDANT'S MOTION TO 

EXTEND DISCOVERY DEADLINE 

DEFENDANT'S MOTION TO EXTEND DISCOVERY DEADLINE 

Pursuant to Federal Rule 26 (General Provisions Governing Discovery) Defendant incorporates 

into this pleading her pleadings in her Motion to Dismiss and in her noticed related cases 

Subramaniam v. Beal et al, Case No. 3:12-cv-01681-MO and Subramaniam v. Beal, Case No: 

3:2014cv01482 as well as her pleadings and exhibits in her Notice of Related Cases and her 

Notice of Constitutional Questions; and she moves this court to extend discovery until 

September 1, 2015, and respectively shows the court as follows: 

As a pro-se litigant who's still recovering from spinal surgery, who is disabled and whose 

daughter just gave birth to twins on June 2, 2015 after a high risk pregnancy and emergency 

induced labor where we almost lost her and the youngest twin, Defendant is appalled by the 

ongoing bad faith exhibited by Plaintiff LNV Corporation ("LNV") and its counsel. 

Defendant's Notice of Related Case Page 1of5 

Case 3:14-cv-01836-MO Document 56 Filed 06/17/15 Page 1 of 5
The court Administrator had informed LNV's counsel and Defendant that we needed to agree to 

a discovery schedule before filing the Joint Status report due the day the medical stay lifted on 

June 8, 2015. Defendant reached out to LNV's counsel, Ms. Richards, two weeks ahead of time. 

Ms. Richards told her that her client would agree to extend discovery only until July 17, 2015. 

Defendant felt this was not long enough because she had been medically incapacitated since 

October 2014 (even before Plaintiff brought this action against her) so she asked for some time 

to think about this. Defendant wanted to research what the normal discovery period is supposed 

to be and then discuss it further with LNV's counsel. However her daughter's pregnancy and 

emergency delivery distracted her, as such an experience would distract anyone. Defendant is 

certain that if this were your Honor's daughter and twin grand-babies your attention would also 

be focused on them and their wellbeing at such a critical event; Defendant is certain that even 

Plaintiff LNV' s owner Daniel Andrew "Andy" Beal ("Beal") would focus his attention on his 

own daughter and twin grand-babies should he experience such a family event. 

As a pro-se litigant Defendant doesn't have the luxury afforded Beal in that she can't just pay 

someone else to do all the work required for legal research and writing like he can. 

Defendant evidently missed an email sent by Ms. Richards, who made no attempt to phone 

Defendant when she didn't receive a response. Had she done so, there would have been plenty 

of time to reach an agreement. Ms Richards did however phone Defendant on Friday before the 

deadline in the late afternoon while she was in the hospital with her daughter and family. At that 

time when Defendant told Ms. Richards about the birth of her twin grandchildren and asked if 

the call could wait until Monday she congratulated Defendant and said it would not be a 

problem. At no time did she inform Defendant it was urgent for them to speak at that moment or 

Defendant's Notice of Related Case Page2of5 

Case 3:14-cv-01836-MO Document 56 Filed 06/17/15 Page 2 of 5
she and/or her client would withdraw their "stipulated" agreement to extend the deadline until 

July 17, 2015. Had she done so, Defendant would have under the circumstances just agreed to 

the date hoping it could be extended again later if needed. 

On Monday June 8, 2015 Defendant was shocked at Ms. Richard's attitude and 

uncooperativeness. She said her client would not stipulate to any extension of the discovery 

deadline which ended on the date the medical stay ended June 8, 2015. There can be no due 

process without discovery and to deny Defendant of her right to discovery as a direct result of an 

emergency medical need for stay is the epitome of injustice; and it would deny Defendant of her 

constitutional rights to due process and equal protection of law. (Defendant has heard from other 

Beal victims that this type of behavior by counsel representing LNV is typical; and that Beal and 

his LNV, MGC, LPP and other Beal entities do everything possible to thwart discovery.) 

Defendant and other Beal victims named in the noticed related cases are victims of racketeering 

activity as defined by 18 U.S. Code§ 1961(l)(B). Although Defendant understands why the 

court was unable to grant her relief in Subramaniam v. Beal, this does not diminish the terror and 

fear she feels due to the facts she described in her complaint. The series of incidents Defendant 

experienced as stated in this complaint did not end after the complaint was filed and 

subsequently dismissed. In September 2014 the first time Defendant dared venture out of her 

home beyond short trips to get groceries the passenger side window of her jeep was smashed and 

her computer stolen. 

These terrorizing incidents that began on July 30, 2014 with Daniel Andrew "Andy" Beal's 

("Beal") discovery of a letter attached to legal pleadings in the LNV v. Breitlings; Case No. DC14-04053 related case which Defendant wrote to the Illinois Attorney Registration and 

Defendant's Notice of Related Case Page3of5 

Case 3:14-cv-01836-MO Document 56 Filed 06/17/15 Page 3 of 5
Disciplinary Commission about attorney Charles King and a phone call made to Tennessee State 

Bank where a Charles King used caller-ID spoofing and misrepresented himself as a government 

employee to inquire about a fed-wire transaction made by Beal victim Ms. Gebhardt into a Bank 

of America account later discovered to be a legacy global account with Beal' s LPS agent DMI as 

the domestic intermediary for an overseas recipient 

Other Beal victims and their families and friends have reported similar experiences; and worse. 

Regardless of our inability to prove at this point in time are that these things being done to us at 

the instruction of Beal; we are terrified and in fear for our lives. The mental anguish we each feel 

is very real and this mental anguish causes all of us to experience horrific health problems. In 

September Defendant had to go to the emergency room twice; and in fact was in the emergency 

room when Beal victim JoAnn Breitling phoned to tell her that Beal sold her house in spite of an 

automatic stay pursuant to Texas Rule of Civil Procedure 376.11. (See noticed related case: LNV 

v. Breitlings: Case No. DC-14-04053). 

Most of Beal's victims are elderly, disabled, female heads of household, and/or minorities; 

already the most vulnerable members of our society and most likely to lack meaning access to 

the courts. The noticed related cases are NOT typical foreclosures. Most of the Beal victims 

made payments which Beal's MGC and/or his LPS agents intentionally misappropriated as 

evidenced by the $6,000 check made payable to MGC issued by Beal victim Catherine 

Gebhardt and paid to Beal Bank SSB on October 29, 2008. (See Exhibit A attached to 

Defendant's Notice of Related Cases.) This payment which was to cover three months of 

payments was NEVER credited to Gebhardt's mortgage and this fact is conclusive as evidenced 

by the Erica Thomas letter dated June 23, 2011 where she states on page 2 paragraph 2: "MGC 

Defendant's Notice of Related Case Page4of5 

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Case 3:14-cv-01836-MO Document 56 Filed 06/17/15 Page 4 of 5
has received no payments since we acquired serving of the loan from GMAC Mortgage on or 

around July 1, 2009." This misappropriation of Beal victims' payments is NOT an isolated case 

but one instance of many in a pattern of such activity designed to result in a self-serving (for 

Beal) default so he can then use forged documents he knows courts rely on as genuine to 

intentionally deceive courts and thereby unconstitutionally confiscates the property of his 

victims. Likewise a misappropriation of Defendant's mortgage payments with a self-serving 

false claim of default is at the root of the present case. 

It is not in the public's interest to allow Beal to continue to get away with these crimes. Nor is it 

constitutional to deprive Defendant of discovery based on an emergency medical need that 

required a stay on these court proceedings. 

PRAYER 

WHEREFORE Defendant prays this court extend the discovery deadline until September 1, 2015 

to allow for appropriate discovery included but not limited to the expert examination by OMNI 

of the Notes the Plaintiff has claimed are "original" and of which the Plaintiff submitted what it 

claims are true copies to this court; knowing courts typically presume such documents are 

genuine. 

Respectfully Submitted, 

Denise Subramaniam 

Defendant's Notice of Related Case Pages of5 

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