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`Ashley M. Gjovik, JD
`In Propria Persona
`2108 N St. Ste. 4553
`Sacramento, CA, 95816
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`(408) 883-4428
`legal@ashleygjovik.com
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`United States District Court
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`Northern District of California
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`Ashley M. Gjovik , an
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`individual,
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`Plaintiff,
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` vs.
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`Apple Inc., a corporation,
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`Defendant.
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` U.S. Dis tr ict Cour t Case No. 3 :23 -CV- 0459 7
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`U.S. Cour t of App eals Case No. 24 -6 058
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`Motion Requesting Leave
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`To File a
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`Motion for Reconsideration
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`Civil L.R. 7 -9.
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`Case 3:23-cv-04597-EMC Document 139 Filed 11/20/24 Page 2 of 3
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`1.
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`Motion Requesting Leave to
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`File a Motion for Reconsideration
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`Plaintiff, Ashley Gjovik, respectfully submits this Motion seeking
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`Leave to file a Motion for Reconsideration of the cour t's decision dated November
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`19, 2024, at Docket 137. Filed as Attachment 1 to Docket 139 is the proposed
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`Motion for Reconsideration, which has been filed concurrently. Should the court
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`find it appropriate to allow the filing of her reconsideration motion, Plaintiff
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`respectfully requests that the attached proposed motion be accepted.
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`2.
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`Plaintiff believes that her motion for reconsideration
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`is both
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`significant and substantiated. She additionally seeks this leave due to the
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`prejudice to her following her voluntar y response to the original matter, wherein
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`she crafted a 12 -page opposition within a span of just two days. Rather than
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`submitting a comprehensive response to the motion to shorten time, followed by
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`a separate 25 -page response to the motion to dis miss, Plaintiff opted for a concise
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`reply in the hope that the issue could be resolved swiftly without prejudice to
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`herself, thereby aiming to prevent unnecessar y delays.
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`3.
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`Had Plaintiff anticipated that the court would take adverse actions
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`against her and employ language that undermines her position, she would have
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`chosen to pursue a more thorough briefing and hearing process. Plaintiff
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`mistakenly assumed that if the court w ere to take any actions that could adversely
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`affect her, it would provide adequate time and allocate sufficient pages for her to
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`present her case. Unfor tunately, that was not the case in this instance.
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`Thank you for your consideration.
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`P l a in t i ff ’ s M ot ion R e qu e st in g R e c on si d e r at ion | C a s e 3 : 2 3 - C V- 0 4 5 9 7 - E M C
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`Case 3:23-cv-04597-EMC Document 139 Filed 11/20/24 Page 3 of 3
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`Dated: Nov. 20 2024.
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`Signature:
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`/s/ Ashley M. Gjovik
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`Pro Se Plaintiff
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`Email: legal@ashleygjovik.com
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`Physical Address : Boston, Massachusetts
`Mailing Address: 2108 N St. Ste. 4553 Sacramento, CA, 95816
`Phone: (408) 883-4428
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