\ 

Denise Subramaniam 

Self-represented 

13865 SW Walker Rd 

Beaverton OR 97005 

503-764-5300 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

LNV CORPORATION Civil Case No. 3:14-cv-01836 

Plaintiff, 

v. 

DENISE SUBRAMANIAM 

pro per 

Defendant 

NOTICE OF AFFIDAVIT 

TO SUPPORT MEDICAL 

CONTINUANCE 

DEFENDANT'S NOTICE OF AFFIDAVIT TO SUPPORT MOTION FOR MEDICAL 

CONTINUANCE 

1. Here comes Defendant Denise Subramaniam, representing herself, and hereby makes 

notice of the following: 

2. Whereas Defendant filed a motion for medical continuance on March 3, 2015 which was 

wrongfully opposed by LNV's counsel as being unsubstantiated when they knew, or should have 

known it was substantiated because Defendant emailed them copies of her medical records in 

confidence on December 18, 2014 to substantiate an extension of time to file her response to 

Plaintiffs complaint. These medical records evidenced serious degenerative spinal conditions 

and Defendant had in her email informed counsel for Plaintiff that surgery was a possibility; yet 

for motives unknown to Defendant, Plaintiffs counsel, although while agreeing to allow a short 

extension oftime and agreeing to prepare and file a joint motion, Plaintiffs counsel refused to 

Case 3:14-cv-01836-MO Document 37 Filed 03/13/15 Page 1 of 3
I 

inform the court as to the medical cause for such extension. Similar extensions of time were 

needed based on medical reasons and handled in the same manner. 

3. On March 2, 2015 counsel for Plaintiff, Gabrielle D. Richards, was out of the office when 

Defendant phoned to ask if she would oppose a motion for medical continuance. Although 

Defendant was told someone from Perkins Coie would call her back, no one did and due to the 

urgency of medical need for spinal surgery Defendant filed her own motion for medical 

continuance, which LNV' s counsel opposed. In LNV' s opposition its counsel claimed they did 

not know of any medical cause for a continuance and implied Defendant had fabricated the letter 

from her doctor. Relying on these intentional misleading allegations Judge Mosman denied 

Defendant's motion for medical continuance. In his denial Order he specified that Defendant 

needed to provide the court with an affidavit from her physician. 

4. However because of the late hour in which Defendant was unduly informed of the need 

for the affidavit and because there was no notary available at the hospital the affidavit is 

witnessed by the doctor's assistant. 

5. WHEREFORE Defendant has now obtained an affidavit from her physician and hereby 

submits such to the court in support of her motion for medical continuance. She prays that the 

court will acknowledge the urgent need for a medical continuance in light of Defendant's 

medical records already in court record. 

Respectfully, 

esh~~~ Denise Subramaniam 

Page 2 of 3 

Case 3:14-cv-01836-MO Document 37 Filed 03/13/15 Page 2 of 3
THE 

OREGON 

CLINIC 

Specialty Medicine 

with Commitment, 

Care & Compassion 

MICI'IIIII'I.I'IICII CIIUIIIIIS 

March 13, 2015 

STATE OF OREGON 

COUNTY OF WASHINGTON 

AFFIDAVIT OF DR. MICHAEL SANDQUIST 

RE: SUBRAMANIAM, DENISE 

008: 09-16-1954 

Dear Sir or Madam: 

Ms. Denise Subramaniam is a patient of mine scheduled to undergo a 

surgical procedure on March 17, 2015. The surgery is medically 

necessary and should not be unduly delayed. I would request that 

allowances be made for her recovery for up to two months following 

surgery, barring any other issues or complications; she may not be 

able to participate in the legal proceedings during the recovery 

process. 

If you have any questions or concerns, please do not hesitate to 

contact me. 

Cordially yours, 

~~ Michael A. Sandquist, M.D. 

The Oregon Clinic Neurological Surgery 

MAS/clr 

Witness: ~ be, RMA tf2M€ 

Case 3:14-cv-01836-MO Document 37 Filed 03/13/15 Page 3 of 3