Firdausi Motion To Reconsider
Firdausi Motion To Reconsider
Firdausi Motion To Reconsider
Plaintiff,
v. MOTION TO RECONSIDER
Fahad Firdausi,
Defendant.
Defendant hereby moves the Court to reconsider its ruling granting summary judgment to
Defendant had previously filed the paperwork to demonstrate that entitlement and did not
know that the documentation had an expiration date. Even though the original documents
may have expired, Defendant still meets the requirements of the moratorium, and all
parties or counsel to this matter knew or should have known that fact. Yet, even in the
face of undeniable knowledge that Defendant had a right to obtain the benefit of the
2. Defendant was representing himself in this action, proceeding pro se. He did not fully
know of the correct format to write reply paragraphs and reference correctly with
numbering, He also did not know of the of the potential consequences or sanctions that
the Court could impose. Defendant is in the process of securing counsel to represent him
Page 1 of 3
SAS Holdings, LLC v. Firdausi
Motion to Reconsider
in this proceeding. Defendant would respectfully request that, as a pro se party, he be
shown the leniency that is appropriate and typical under those circumstances when his
3. Defendant was representing himself in this action, proceeding pro se. He did not fully
understand the nature of discovery, his obligations in that process, or the potential
consequences or sanctions that the Court could impose. Defendant is in the process of
request that, as a pro se party, he be shown the leniency that is appropriate and typical
under those circumstances when his adversary is represented by a member of the Bar.
BY: __________________________________
Fahad Firdausi
Page 2 of 3
SAS Holdings, LLC v. Firdausi
Motion to Reconsider
CERTIFICATE OF SERVICE
The undersigned hereby certifies that he served upon the forgoing Motion by first class
mail as follows:
Andrew Gordon
The Law Offices of Andrew L. Gordon, PLLC
725 E. Trade Street, Ste 205
Charlotte, NC 28202
Attorney for Plaintiff
______________________________________
Fahad Firdausi
Page 3 of 3
SAS Holdings, LLC v. Firdausi
Motion to Reconsider