Links below pop open a new window; documents provided by Andrea Mogensen upon request after failing to be able to get electronic copies from the Clerk of Court

Memorandum in Opposition to Defendants' Motions for Summary Judgment (54 pages)
Mogensen points to an institutional pattern of of failure to maintain public records, argues that such failure is spoliation in her lawsuit against the city and city officials, specifically names City Clerk Lori Stelzer and I.T. Director Lance Heiss as primarily responsible for failure to maintain public records; former city manager Marty Black gets a bit creative in explaining why he "resigned" from the City of Venice; much more...

Plaintiff's Motion to Compel (26 pages)
Mogensen asserts that Councilwoman Sue Lang failed to turn over two emails as part of Discovery and prior public records requests, asks the court to direct Lang to produce all relevant materials that had been previously requested

Plaintiff's Notice of Refiling (3 pages)
Addendum of sorts to the above Motion to Compel -- a couple of documents that Mogensen forgot to include in the intial filing of the above motion

Affidavit of (attorney) Matthew Leish in Opposition to Defendants' Motions for Summary Judgment (507 pages)
An evidentiary treasure trove of material related to the lawsuit -- more documents than you can shake a city attorney at; includes excerpts from a number of depositions as well as numerous public documents that are now seeing the light of public view for the first time, all of which makes you wonder: Why did City Attorney Bob Anderson choose to fight this lawsuit so strongly when it was apparent from the beginning that such a stance would doom his client? If that was Anderson's original plan, it's working...