mad-lawsuit/database/seeders/V1DataMigrationSeeder.php

<?php

namespace Database\Seeders;

use Illuminate\Database\Seeder;
use App\Models\DocketEntry;
use App\Models\Document;
use App\Models\Subscription;
use Illuminate\Support\Facades\DB;

class V1DataMigrationSeeder extends Seeder
{
    /**
     * Run the database seeds.
     * 
     * This seeder imports production data from v1.0 (Next.js/Prisma/PostgreSQL)
     * into v2.0 (Laravel/Eloquent/SQLite).
     * 
     * Data source: /tmp/v1-data.sql (PostgreSQL dump from production)
     * 
     * Schema mapping:
     * - docket_entries: id, date, summary, createdAt, updatedAt, notes, title
     * - documents: id, docketEntryId, originalFilename, storedFilename, filePath, title, summary, notes, fileSize, displayOrder, createdAt, updatedAt, mimeType
     * - subscriptions: id, email, isActive, unsubscribeToken, createdAt
     */
    public function run(): void
    {
        // Disable foreign key checks for clean import
        DB::statement('PRAGMA foreign_keys = OFF');
        
        // Clear existing data
        Document::truncate();
        DocketEntry::truncate();
        Subscription::truncate();
        
        // Import docket entries
        $this->importDocketEntries();
        
        // Import documents
        $this->importDocuments();
        
        // Import subscriptions
        $this->importSubscriptions();
        
        // Re-enable foreign key checks
        DB::statement('PRAGMA foreign_keys = ON');
        
        $this->command->info('✅ v1.0 data migration complete!');
        $this->command->info('   - Docket Entries: ' . DocketEntry::count());
        $this->command->info('   - Documents: ' . Document::count());
        $this->command->info('   - Subscriptions: ' . Subscription::count());
    }
    
    private function importDocketEntries(): void
    {
        $entries = [
    ['id' => 12, 'date' => '2025-06-06', 'summary' => 'Elizabeth Kragh swears under oath that the Montana Association of the Deaf cannot be on active military duty because it is a nonprofit corporation, not a person, and that MAD\'s registered agent Kirk Hash Jr. is Deaf and therefore ineligible for military service due to hearing requirements. This affidavit is required by federal law to ensure that people in the military are not unfairly treated in court cases, but since MAD is an organization and its agent is Deaf, military protections do not apply.', 'created_at' => '2025-06-25 22:25:16.605', 'updated_at' => '2025-06-25 22:49:54.761', 'notes' => '', 'title' => 'Affidavit of Military Service Check (ServiceMembers Civil Relief Act Compliance) (Filed By Kragh, Elizabeth on behalf of )'],
    ['id' => 5, 'date' => '2025-05-07', 'summary' => 'Elizabeth Kragh is suing the Montana Association of the Deaf (MAD) for three ultra vires actions. First, MAD won\'t let her see meeting records even though Montana law says she has the right to see them. Second, MAD\'s leaders were elected by acclamation instead of written ballots like their rules require. Third, $888 is missing from money reports and the people who should watch the money admit they haven\'t been doing their job.', 'created_at' => '2025-06-25 22:13:26.291', 'updated_at' => '2025-06-25 22:49:54.727', 'notes' => '', 'title' => 'Complaint (Filed By Kragh, Elizabeth on behalf of )'],
    ['id' => 8, 'date' => '2025-05-16', 'summary' => 'This document corrects and replaces the original certificate of service, confirming that Elizabeth Kragh properly delivered the lawsuit papers to the Montana Association of the Deaf through their registered agent Kirk Hash Jr. A professional process server from Equity Process Management served Kirk Hash Jr. on May 13, 2025, at the Partnership Health Center in Missoula, Montana.', 'created_at' => '2025-06-25 22:17:34.223', 'updated_at' => '2025-06-25 22:49:54.738', 'notes' => '', 'title' => 'Amended Certificate of Service (Filed By Kragh, Elizabeth on behalf of )'],
    ['id' => 9, 'date' => '2025-05-14', 'summary' => 'This document proves that Elizabeth Kragh properly delivered the lawsuit papers to the Montana Association of the Deaf through their designated agent Kirk Hash Jr. A professional process server handed the legal documents to Kirk Hash Jr. on May 13, 2025, at the Partnership Health Center in Missoula, Montana.', 'created_at' => '2025-06-25 22:19:21.997', 'updated_at' => '2025-06-25 22:49:54.744', 'notes' => '', 'title' => 'Certificate of Service (Filed By Kragh, Elizabeth on behalf of )'],
    ['id' => 10, 'date' => '2025-05-12', 'summary' => 'This is an official court document that notifies the Montana Association of the Deaf that Elizabeth Kragh has filed a lawsuit against them. The summons orders MAD to respond to the lawsuit within 21 days or the court will rule against them by default.', 'created_at' => '2025-06-25 22:21:22.374', 'updated_at' => '2025-06-25 22:49:54.75', 'notes' => '', 'title' => 'Summons Issued on Montana Association of the Deaf Inc. 05/12/2025'],
    ['id' => 11, 'date' => '2025-06-05', 'summary' => 'The Montana Association of the Deaf calls Elizabeth Kragh\'s lawsuit "frivolous" and accuses her of "harassment" without providing evidence to support their legal defenses. Instead of addressing the specific legal violations Kragh raised, MAD focuses on personal attacks against her character and claims about her past behavior with their local chapter. MAD admits they required Kragh to sign a "zero-tolerance policy" to access meeting minutes but doesn\'t explain why this requirement is legal under Montana law.', 'created_at' => '2025-06-25 22:23:22.573', 'updated_at' => '2025-06-25 22:49:54.755', 'notes' => '', 'title' => 'Answer to Complaint (Filed By Montana Association of the Deaf Inc. on behalf of )'],
    ['id' => 13, 'date' => '2025-06-06', 'summary' => ' Elizabeth Kragh swears under oath that MAD was properly served with the lawsuit papers on May 13, 2025, through their registered agent Kirk Hash Jr., giving them 21 days until June 3, 2025, to respond. She states that MAD failed to file any response, motion, or have any attorney appear on their behalf, making them in default and eligible for a default judgment.', 'created_at' => '2025-06-25 22:26:19.853', 'updated_at' => '2025-06-25 22:49:54.768', 'notes' => '', 'title' => 'Affidavit of Service and Non-Appearance (Filed By Kragh, Elizabeth on behalf of )'],
    ['id' => 14, 'date' => '2025-06-06', 'summary' => 'This is a draft default judgment order that would rule in favor of Elizabeth Kragh if the Montana Association of the Deaf fails to respond to the lawsuit. The proposed order would find that MAD violated Montana law by refusing to provide meeting minutes, improperly elected officers by acclamation instead of written ballot, and failed in financial oversight with an unexplained $888.54 missing from reports. If signed by the judge, it would order MAD to provide all requested records, follow proper election procedures, give complete financial accounting, and pay for an independent auditor to examine their books.', 'created_at' => '2025-06-25 22:27:19.37', 'updated_at' => '2025-06-25 22:49:54.775', 'notes' => '', 'title' => 'Motion for Default Judgment (Filed By Kragh, Elizabeth on behalf of ) 278719 '],
    ['id' => 16, 'date' => '2025-06-06', 'summary' => 'Elizabeth Kragh formally asks the court to rule in her favor because MAD failed to respond to her lawsuit within the required 21-day deadline that expired on June 3, 2025. She argues that MAD\'s silence legally admits to all her allegations about blocking records access, conducting improper elections, and financial oversight failures. Kragh requests the court enter default judgment and grant relief including immediate access to meeting minutes, proper financial reporting, and appointment of an independent auditor to examine MAD\'s financial records.', 'created_at' => '2025-06-25 22:29:11.492', 'updated_at' => '2025-06-25 22:49:54.791', 'notes' => '', 'title' => 'Proposed Order on Default Judgment 278719'],
    ['id' => 17, 'date' => '2025-06-06', 'summary' => 'Elizabeth Kragh asks the court to immediately stop MAD from holding their scheduled June 12-14, 2025 conference because the current officers were improperly elected and lack proper authority to make decisions for the organization. She argues that allowing these ultra vires officers to conduct business meetings, make financial decisions, and hold elections at the conference would cause irreparable harm that cannot be fixed later. Kragh requests the court allow educational and social activities at the conference to continue but block all official business and governance activities until the legal issues are resolved.', 'created_at' => '2025-06-25 22:30:23.578', 'updated_at' => '2025-06-25 22:49:54.798', 'notes' => '', 'title' => 'Motion for Temporary Restraining Order (Filed By Kragh, Elizabeth on behalf of )'],
    ['id' => 6, 'date' => '2025-05-07', 'summary' => 'The exhibits show the Montana Association of the Deaf\'s official bylaws for how the organization should operate. Email records show that when member Elizabeth Kragh asked for meeting minutes, MAD\'s secretary refused to give them to her and required her to sign a "zero-tolerance policy" first. Meeting minutes from 2023-2024 show the organization\'s activities, financial reports, and board decisions during the time period in question.', 'created_at' => '2025-06-25 22:15:24.183', 'updated_at' => '2025-09-05 19:52:01.437', 'notes' => '', 'title' => 'Complaint Exhibits'],
    ['id' => 1, 'date' => '2025-05-07', 'summary' => 'Elizabeth Kragh swears under oath that she made four written requests for MAD meeting minutes but was denied access and told she must sign a "zero-tolerance policy" to get them, even though Montana law doesn\'t allow such conditions. She also states that MAD\'s officers were improperly elected by acclamation instead of written ballot as required by their bylaws, and that she witnessed financial problems including missing money and trustees admitting they failed to do their oversight duties.', 'created_at' => '2025-06-25 20:20:09.097', 'updated_at' => '2025-06-25 22:49:54.719', 'notes' => '', 'title' => 'Affidavit in Support of Complaint (Filed By Kragh, Elizabeth on behalf of )'],
    ['id' => 19, 'date' => '2025-06-09', 'summary' => 'Elizabeth Kragh asks the court to throw out MAD\'s answer because Tyler Hansen, who is not a lawyer, illegally filed legal documents on behalf of the corporation, which violates Montana law requiring corporations to be represented by licensed attorneys. She argues that Hansen\'s unauthorized answer actually admits to all the violations she sued about, including blocking records access, conducting improper elections, and financial oversight failures. Kragh requests the court strike the invalid answer, find Hansen engaged in unauthorized practice of law, impose sanctions, and return MAD to default status for her pending motion for default judgment.
', 'created_at' => '2025-06-25 22:37:54.713', 'updated_at' => '2025-06-25 22:49:54.812', 'notes' => '', 'title' => 'Motion to Strike Answer for Unauthorized Practice of Law Alternative Reply Brief: Defendant\'s Admissions Confirm Every Allegation (Filed By Kragh, Elizabeth on behalf of Kragh, Elizabeth )'],
    ['id' => 20, 'date' => '2025-06-09', 'summary' => 'This is a draft court order that would strike Tyler Hansen\'s answer from the court record because he illegally practiced law by representing the Montana Association of the Deaf without a license, violating Montana law that requires corporations to have licensed attorneys. The proposed order would find Hansen engaged in unauthorized practice of law, prohibit him from filing any more legal documents, refer him to Montana authorities for investigation, and return MAD to default status. The order would also require Hansen to pay court costs and allow the case to proceed to consideration of Kragh\'s motion for default judgment.', 'created_at' => '2025-06-25 22:38:56.552', 'updated_at' => '2025-06-25 22:49:54.818', 'notes' => '', 'title' => 'Proposed Order Granting Motion to Strike Answer for Unauthorized Practice of Law'],
    ['id' => 21, 'date' => '2025-06-09', 'summary' => ' Elizabeth Kragh asks the court to impose sanctions against Tyler Hansen for violating court rules when he filed an unauthorized answer that focused on personal attacks against her rather than addressing the legal issues in the case. She argues that Hansen\'s answer violated all four parts of Rule 11 by being filed for improper purposes, containing legally frivolous arguments, making factual claims without evidence, and providing inadequate denials of her allegations. Kragh requests the court prohibit Hansen from filing more legal documents without a lawyer, require him to take legal education courses, refer him for unauthorized practice investigation, and impose monetary penalties to deter similar misconduct.', 'created_at' => '2025-06-25 22:39:58.278', 'updated_at' => '2025-06-25 22:49:54.824', 'notes' => '', 'title' => 'Motion for Rule 11 Sanctions Against Tyler Hansen (Filed By Kragh, Elizabeth on behalf of Kragh, Elizabeth )'],
    ['id' => 22, 'date' => '2025-06-09', 'summary' => 'This is a draft court order that would impose Rule 11 sanctions against Tyler Hansen for filing an unauthorized answer that violated court rules by containing personal attacks, legally frivolous arguments, and factual claims without evidence. The proposed sanctions include prohibiting Hansen from filing any more legal documents without a lawyer, requiring him to take a legal education course, referring him to authorities for unauthorized practice of law, and paying a monetary penalty to the court. The order would also require Hansen to notify all MAD board members of the court\'s restrictions and would make his admissions from the unauthorized answer binding for the rest of the lawsuit.', 'created_at' => '2025-06-25 22:40:54.24', 'updated_at' => '2025-06-25 22:49:54.83', 'notes' => '', 'title' => 'Proposed Order Granting Motion for Rule 11 Sanctions Against Tyler Hansen'],
    ['id' => 23, 'date' => '2025-06-10', 'summary' => 'Judge Tara Elliott granted Elizabeth Kragh\'s motion to strike Tyler Hansen\'s unauthorized answer, ruling that Hansen illegally practiced law by representing the Montana Association of the Deaf without a license, which violates Montana law requiring corporations to have licensed attorneys. The court struck Hansen\'s answer from the record and gave MAD 45 days to hire a real lawyer and file a proper response that follows Montana law. Kragh won on her motion to strike while the court denied her other motions for default judgment, temporary restraining order, and sanctions, but her main legal victory established that MAD\'s defense was invalid and must be refiled through proper legal representation.', 'created_at' => '2025-06-25 22:41:49.607', 'updated_at' => '2025-06-25 22:49:54.836', 'notes' => '', 'title' => 'Order Denying Petitioner\'s Motion for Default Judgement, Motion for Temporary Restraining Order and Motion for Sanctions and Granting the Motion to Strike'],
    ['id' => 24, 'date' => '2025-06-11', 'summary' => 'Elizabeth Kragh asks the court for a preliminary injunction to stop the Montana Association of the Deaf\'s ongoing violations while MAD searches for a lawyer, arguing that eight months of documented violations including records obstruction, ultra vires elections, and financial oversight failures demand immediate court action. She offers the court multiple options for relief, from full preliminary injunction to limited relief ensuring proper election procedures at MAD\'s upcoming June 12-14 conference, while acknowledging the procedural challenge that MAD currently lacks legal representation. Kragh emphasizes that MAD\'s current predicament flows directly from their own choices to violate laws and bylaws for eight months, then lose their unauthorized defense, making judicial intervention necessary to protect member rights and organizational integrity.', 'created_at' => '2025-06-25 22:42:41.797', 'updated_at' => '2025-06-25 22:49:54.844', 'notes' => '', 'title' => 'Motion for Preliminary Injunction (Filed By Kragh, Elizabeth on behalf of Kragh, Elizabeth )'],
    ['id' => 25, 'date' => '2025-06-11', 'summary' => 'This is a draft court order that would grant Elizabeth Kragh\'s request for a preliminary injunction, requiring the Montana Association of the Deaf to immediately stop conducting elections by acclamation and use written ballots as required by their bylaws, provide all meeting minutes from June 2023 to present without unauthorized conditions, and deliver written financial reports explaining the missing $888.54. The proposed order would also prohibit MAD from making major organizational decisions or financial commitments beyond routine operations until the legal issues are resolved, and would require compliance within specific timeframes (10 days for records, 15 days for financial reports). The order includes enforcement provisions allowing contempt proceedings for violations and requires MAD to notify members about the court\'s requirements while prohibiting them from mischaracterizing the order\'s terms.', 'created_at' => '2025-06-25 22:43:26.377', 'updated_at' => '2025-06-25 22:49:54.85', 'notes' => '', 'title' => 'Proposed Order Granting Preliminary Injunction'],
    ['id' => 15, 'date' => '2025-06-06', 'summary' => ' Elizabeth Kragh argues that MAD\'s failure to respond to her lawsuit within the required 21 days means the court should automatically rule in her favor on all three violations she alleged. She states that MAD\'s silence legally admits to blocking records access, conducting improper elections by acclamation, and failing to oversee nearly $900 in missing funds while trustees admitted they never checked the books. Kragh requests the court grant her motion for default judgment and order immediate relief including access to records, proper financial oversight, and an independent audit of MAD\'s finances.', 'created_at' => '2025-06-25 22:28:12.719', 'updated_at' => '2025-06-25 22:49:54.781', 'notes' => '', 'title' => 'Supporting Memorandum of Law in Support of Motion for Default Judgment (Filed By Kragh, Elizabeth on behalf of ) 278719 '],
    ['id' => 18, 'date' => '2025-06-06', 'summary' => 'This is a draft temporary restraining order template that would stop the Montana Association of the Deaf from conducting official business at their June 12-14, 2025 conference if signed by the judge. The proposed order would prohibit MAD from holding business meetings, elections, and making financial decisions while allowing educational and social activities to continue. The document contains blank spaces for the judge to fill in specific dates, times, and security amounts if the order is granted.', 'created_at' => '2025-06-25 22:31:30.046', 'updated_at' => '2025-06-25 22:49:54.806', 'notes' => '', 'title' => 'Proposed Temporary Restraining Order'],
    ['id' => 27, 'date' => '2025-07-24', 'summary' => 'On July 24, 2025, MAD responded to the lawsuit through their lawyer, Peter Lacny. Here\'s what their response says in simple terms:

MAD\'s response goes through each point in the original lawsuit and either agrees with it, disagrees with it, or says they don\'t have enough information to know. This is the standard way organizations respond to lawsuits.

MAD gives several reasons why they think the lawsuit should be dismissed. They say the lawsuit doesn\'t properly explain what they did wrong and that too much time has passed to bring some claims. They argue that some issues have already been fixed and that the person suing them has also done wrong things. MAD claims their board made reasonable decisions and that the person suing gave up certain rights. They insist they followed all the laws and that no real harm was caused. They also point out that the person resigned from positions and that courts shouldn\'t get involved in organization decisions.

In addition to defending themselves, MAD is also suing back. They claim that the person has said untrue things about MAD, interfered with how MAD runs, and used MAD\'s name when working with other organizations. These counter-claims ask the court to rule in MAD\'s favor and stop the person from continuing these actions.', 'created_at' => '2025-07-25 21:37:25.45', 'updated_at' => '2025-07-28 03:01:10.602', 'notes' => '', 'title' => 'Answer (Filed By Lacny, Peter on behalf of Montana Association of the Deaf Inc. )'],
    ['id' => 26, 'date' => '2025-07-24', 'summary' => 'On July 24, 2025, Peter F. Lacny, a lawyer from the firm McFarland Molloy Lacny & Duerk, filed a Notice of Appearance with the court. This is a simple document that officially tells the court that Peter Lacny will be representing MAD in this lawsuit. Before this notice was filed, MAD did not have a lawyer officially recognized by the court. This document is important because it means all future court papers and communications about the case should now go to Peter Lacny instead of directly to MAD. It also shows that MAD has hired professional legal representation to defend against the lawsuit.', 'created_at' => '2025-07-25 21:34:48.438', 'updated_at' => '2025-07-28 03:01:32.129', 'notes' => '', 'title' => 'Notice of Appearance (Filed By Lacny, Peter on behalf of Montana Association of the Deaf Inc. )'],
    ['id' => 36, 'date' => '2025-08-14', 'summary' => 'On August 12, 2025, Elizabeth Kragh filed a notice informing the court that she served discovery requests on MAD.

What happened:
The Plaintiff sent three types of legal requests to MAD\'s attorney:

- Document production requests (asking for specific records)
- Interrogatories (written questions requiring sworn answers)
- Requests for admission (asking MAD to confirm or deny certain facts)

What this means:
Discovery is the standard legal process where both parties exchange information and documents before trial. Both sides can request evidence from each other.

Timeline:
MAD has 30 days to respond to these requests under court rules.

Status:
The case has moved into the discovery phase, where both parties will gather and exchange information relevant to the lawsuit.', 'created_at' => '2025-08-22 13:48:17.057', 'updated_at' => '2025-08-24 15:17:56.236', 'notes' => '', 'title' => 'Notice of Service of Discovery Requests (Filed By Kragh, Elizabeth on behalf of Kragh, Elizabeth )'],
    ['id' => 31, 'date' => '2025-08-08', 'summary' => 'Elizabeth Kragh has asked the court to pause or limit MAD\'s discovery requests until the judge decides whether to dismiss MAD\'s counterclaims.

What Happened: On August 7, MAD sent Kragh 25 discovery requests asking for documents, answers to questions, and admissions. Many requests relate to MAD\'s counterclaims, which Kragh is trying to get dismissed.

Kragh\'s Request: She wants the court to either:

- Stop all discovery related to MAD\'s counterclaims until the dismissal motion is decided
- Limit discovery to only her original lawsuit claims
- Extend her response deadline from September 6 to 30 days after the court rules

Why She Filed This:

- Many discovery requests seem designed to harass rather than find relevant information
- Requests ask about personal communications, social media posts, and unrelated organizations
- As a pro se plaintiff, responding is invasive and time-consuming
- If MAD\'s counterclaims get dismissed, this discovery becomes pointless

Privacy Concerns: Some requests violate Montana\'s strong constitutional privacy protections by seeking personal information without good reason.

Legal Basis:
Montana courts can issue protective orders to prevent "undue burden" and have authority to pause discovery when claims might be dismissed.

Timing: 
Kragh requested expedited consideration since her discovery responses are due September 6.
', 'created_at' => '2025-08-11 20:04:58.042', 'updated_at' => '2025-08-11 20:04:58.042', 'notes' => '', 'title' => 'Plaintiff\'s Motion for Protective Order Regarding Defendant\'s First Combined Discovery Requests (Filed By Kragh, Elizabeth on behalf of Kragh, Elizabeth )'],
    ['id' => 33, 'date' => '2025-08-07', 'summary' => 'Defendant MAD\'s counsel served discovery requests upon Plaintiff Elizabeth Kragh in connection with their filed counterclaims and subsequently filed a notice of service with the court clerk. This represents a standard procedural step in the litigation process where parties seek relevant information from each other to support their respective claims and defenses.', 'created_at' => '2025-08-12 16:45:07.182', 'updated_at' => '2025-09-05 19:54:07.288', 'notes' => '', 'title' => 'Notice of Service'],
    ['id' => 29, 'date' => '2025-08-08', 'summary' => 'Why This Was Filed: 
After Elizabeth Kragh sued MAD over governance violations, MAD responded with three counterclaims against her. Kragh filed this motion asking the court to dismiss those counterclaims because they don\'t meet basic legal requirements.

MAD\'s Counterclaims: MAD wants the court to (1) declare they followed proper procedures, (2) stop Kragh from alleged interference, and (3) make Kragh pay their attorney fees.

Kragh\'s Arguments: 
 Montana law requires legal claims to include specific facts, not vague accusations. MAD\'s counterclaims fail this test by:

Claiming Kragh made "false statements" without saying what statements or when
- Seeking to stop "interference" without describing specific conduct
- Requesting attorney fees without factual basis for bad faith claims
- Filing ten defenses that are just legal labels with no supporting details

Legal Standard: Montana requires organizations seeking court orders to identify specific injured members by name and address, which MAD didn\'t do.

Kragh\'s Position: 
The counterclaims appear designed to justify broad discovery requests rather than address legitimate legal issues, potentially turning the focus away from MAD\'s documented governance problems.

Outcome: 
The court will decide whether to dismiss the counterclaims.', 'created_at' => '2025-08-11 19:46:51.167', 'updated_at' => '2025-08-11 19:46:51.167', 'notes' => '', 'title' => 'Motion to Dismiss Counterclaims (Filed By Kragh, Elizabeth on behalf of Kragh, Elizabeth )'],
    ['id' => 30, 'date' => '2025-08-08', 'summary' => 'Elizabeth Kragh has written a draft court order that Judge Elliott could sign if the judge agrees to dismiss MAD\'s counterclaims.

What MAD Filed: 
Three counterclaims asking the court to say they followed the rules, stop Kragh from interfering, and make her pay their lawyer bills.

The Problem: 
MAD\'s counterclaims don\'t include specific facts. They make vague accusations like "Kragh made false statements" but don\'t say what statements, when, or to whom. Montana law requires enough details so people know what they\'re accused of.

What the Order Would Do:

- Throw out all of MAD\'s counterclaims
- Remove their ten defenses
- Give MAD 20 days to try again with proper facts

Key Finding:  
The order notes that MAD\'s filings appear designed to force invasive legal discovery rather than address real issues.

"Without Prejudice" Dismissal: This means MAD gets another chance. They can refile within 20 days if they include specific dates, examples, and facts. For court orders, they must also name actual injured members as Montana law requires.

Bottom Line:
The proposed order would require MAD to either provide real evidence for their claims or drop them, while giving them one fair opportunity to file properly.
', 'created_at' => '2025-08-11 19:59:25.733', 'updated_at' => '2025-08-11 19:59:25.733', 'notes' => '', 'title' => 'Proposed Order Granting Plaintiff\'s Motion to Dismiss Counterclaims and Strike Affirmative Defenses'],
    ['id' => 32, 'date' => '2025-08-08', 'summary' => 'Elizabeth Kragh has written a draft court order that Judge Elliott could sign to protect her from MAD\'s discovery requests.

The Situation: 
MAD sent Kragh 25 discovery requests asking for documents and information. Many requests relate to MAD\'s counterclaims, which Kragh wants dismissed.

What the Proposed Order Does:

- Stops discovery about MAD\'s counterclaims until the court decides whether to dismiss them
- Allows MAD to only request information about Kragh\'s original claims
- Extends Kragh\'s response deadline to 30 days after the dismissal decision
- Orders both parties to meet within 14 days after the court rules

Why This Would Be Granted: 
 The order finds that many discovery requests would burden Kragh unfairly, especially since the counterclaims might be dismissed anyway. Some requests seek personal information that violates Montana\'s privacy protections without good reason.

Key Considerations:

- Kragh represents herself and has fewer resources than MAD\'s legal team
- Responding to discovery about invalid claims wastes time and court resources
- Montana law protects people from invasive discovery requests

Result: 
If the judge signs this order, Kragh would be protected from having to respond to most of MAD\'s discovery requests until the court decides whether MAD\'s counterclaims are legally valid.
', 'created_at' => '2025-08-11 20:10:03.902', 'updated_at' => '2025-08-11 20:10:03.902', 'notes' => '', 'title' => 'Proposed Order Plaintiff\'s Motion for Protective Order Regarding Defendant\'s First Combined Discovery Requests'],
    ['id' => 41, 'date' => '2025-08-18', 'summary' => 'On August 18, 2025, Elizabeth Kragh filed a motion asking the court to withdraw her request for emergency relief against the Montana Association of the Deaf (MAD).

Background:
In June, the Plaintiff sought urgent intervention before MAD\'s biennial conference to prevent election violations. She was concerned MAD would repeat 2023\'s improper elections, when officers were chosen "by acclamation" instead of using written ballots as required by MAD\'s bylaws.

Reason for withdrawal:
The conference concluded, making emergency relief unnecessary.

Impact:
This withdrawal doesn\'t affect Kragh\'s main lawsuit. The Plaintiff continues pursuing claims about MAD\'s refusal to provide meeting minutes and financial records, improperly elected officers, and financial oversight failures including an unexplained $888 discrepancy.

Next steps:
Elizabeth Kragh can address records access through normal discovery processes while pursuing MAD\'s governance violations and transparency failures.
', 'created_at' => '2025-08-24 15:20:26.268', 'updated_at' => '2025-08-24 15:21:17.99', 'notes' => '', 'title' => 'Motion to Withdraw Preliminary Injunction Motion (Filed By Kragh, Elizabeth on behalf of Kragh, Elizabeth )'],
    ['id' => 42, 'date' => '2025-08-18', 'summary' => 'On August 18, 2025, Elizabeth Kragh filed a supplemental notice regarding a procedural requirement in two previous court filings.

Background:
The Plaintiff had filed two motions in August:

- Motion to Dismiss MAD\'s Counterclaims
- Motion for Protective Order regarding discovery requests

The issue:
Local court rules require parties to contact opposing counsel before filing motions and inform the court whether the other side objects. This step was initially omitted from both filings.

Resolution:
After learning of the requirement, Kragh contacted MAD\'s attorney, Peter Lacny, on August 18th. Lacny confirmed that MAD opposes both motions. The Plaintiff then filed this supplemental notice to inform the court of these positions.

Outcome:
The court now has the required information about both parties\' positions on the pending motions. Both motions will proceed as contested matters, with MAD opposing the requests for dismissal and protective order.', 'created_at' => '2025-08-24 15:22:17.885', 'updated_at' => '2025-08-24 15:23:09.485', 'notes' => '', 'title' => 'Supplemental Notice Regarding Rule 3(G)(2) Compliance (Filed By Kragh, Elizabeth on behalf of Kragh, Elizabeth )'],
    ['id' => 43, 'date' => '2025-08-20', 'summary' => 'This is a court filing in a lawsuit between Elizabeth Kragh and the Montana Association of the Deaf. The defendant\'s lawyer is asking the judge to approve a proposed timeline for how the case will proceed. This timeline document (called a "scheduling order") sets deadlines for various steps in the lawsuit, such as when evidence must be shared, when depositions can occur, and when the trial might happen. Both sides have agreed to this proposed schedule - the plaintiff has no objections. The lawyer is formally requesting that the judge review and officially adopt this agreed-upon timeline for the case.', 'created_at' => '2025-08-26 21:16:38.871', 'updated_at' => '2025-08-26 21:17:45.65', 'notes' => '', 'title' => 'Notice of Filing Proposed Scheduling Order (Filed By Lacny, Peter on behalf of Montana Association of the Deaf Inc. )'],
    ['id' => 54, 'date' => '2025-10-06', 'summary' => 'Montana Association of the Deaf filed a legal motion asking the court to rule in their favor without a trial in a lawsuit brought by Elizabeth Kragh. They claim there are no factual disputes requiring a jury trial.', 'created_at' => '2025-10-08 18:22:12.518', 'updated_at' => '2025-10-08 18:22:12.518', 'notes' => '', 'title' => 'Defendant\'s Motion for Summary Judgment (Filed By Lacny, Peter on behalf of Montana Association of the Deaf Inc. )'],
    ['id' => 44, 'date' => '2025-08-20', 'summary' => 'The court may establish a timeline for Elizabeth Kragh\'s lawsuit against the Montana Association of the Deaf that runs from now through June 2026, providing Ms. Kragh with nearly a full year to gather evidence, identify expert witnesses, and build her case. During this period, both parties may engage in discovery—the process of sharing relevant documents and information—with all evidence collection completed by March 2026 and final preparations finished by April 2026. The court may prioritize resolution by requiring a settlement conference by June 30, 2026, where a neutral mediator will help both sides explore potential agreements that could address Ms. Kragh\'s concerns without the need for a lengthy trial. If no settlement is reached, the case will proceed to trial with dates set after the conference concludes. Both parties have agreed to this schedule, and the court has emphasized that all information requests must be answered fairly and completely, ensuring Ms. Kragh has access to the evidence needed to present her case effectively.', 'created_at' => '2025-08-26 21:18:24.803', 'updated_at' => '2025-08-26 21:19:21.805', 'notes' => '', 'title' => 'Proposed Scheduling Order'],
    ['id' => 46, 'date' => '2025-08-22', 'summary' => 'Elizabeth Kragh asked the court to pause discovery (the process where both sides share evidence) until her motion to dismiss MAD\'s counterclaims is decided. MAD opposes this request.

MAD argues that Kragh didn\'t follow proper procedure by failing to discuss the issue with them before asking the court for protection. They contend that most of their 25 discovery requests focus on Kragh\'s own allegations against MAD, not their counterclaims against her.

The discovery requests (attached as Exhibit A to MAD\'s response) ask Kragh to identify witnesses, provide documents supporting her claims about improper elections and financial oversight, detail her damages, and disclose communications with third parties about the lawsuit. MAD also seeks admissions about specific incidents, including whether Kragh filed a police report against a MAD treasurer and refused to sign a policy document.

MAD acknowledges Kragh is representing herself without a lawyer but argues their requests are standard for litigation. They offer accommodations like accepting responses in stages and granting time extensions.

MAD maintains that Montana\'s discovery rules are broad and allow information gathering on counterclaims, impeachment evidence, and credibility issues. They argue their counterclaims arise from the same facts as Kragh\'s claims, justifying simultaneous discovery.
', 'created_at' => '2025-08-26 21:36:19.767', 'updated_at' => '2025-08-26 21:37:24.678', 'notes' => '', 'title' => 'Defendant\'s Response to Plaintiff\'s Motion for a Protective Order (Filed By Lacny, Peter on behalf of Montana Association of the Deaf Inc. )'],
    ['id' => 47, 'date' => '2025-08-25', 'summary' => 'Judge Tara Elliott established a timeline for the lawsuit between Kragh and MAD. The order sets deadlines for when both sides must complete evidence gathering (discovery), identify expert witnesses, exchange exhibits, and file major legal motions. The court emphasizes that all parties must respond fairly and accurately to discovery requests or face potential sanctions. The schedule includes mandatory settlement conferences to encourage resolution without trial. If the case doesn\'t settle, it will proceed to trial scheduling. Both parties agreed to this timeline.', 'created_at' => '2025-08-31 19:04:08.01', 'updated_at' => '2025-08-31 19:04:59.313', 'notes' => '', 'title' => 'Scheduling Order'],
    ['id' => 72, 'date' => '2025-10-29', 'summary' => 'This is the court\'s electronic filing receipt confirming that Judge Tara Elliott granted Plaintiff Elizabeth Kragh\'s motion to extend time on October 29, 2025. The receipt shows the order was electronically signed at 8:56 AM by Judge Elliott. Like the earlier order granting the motion to strike, only the court\'s filing stamp and electronic signature are present in this PDF. The filing confirms that Plaintiff Elizabeth Kragh\'s request for additional time (extending her reply brief deadline from November 3 to November 17, 2025) was approved by the judge, as requested in her motion filed October 28, 2025.', 'created_at' => '2025-11-09 23:40:37.164', 'updated_at' => '2025-11-13 20:30:00.763', 'notes' => '', 'title' => 'Order Granting Motion to Extend Time For Filing Reply Briefs'],
    ['id' => 71, 'date' => '2025-10-28', 'summary' => 'This motion requests more time to file reply briefs in response to the Montana Association of the Deaf\'s responses filed October 24, 2025. Under court rules, Plaintiff Elizabeth Kragh\'s replies were originally due November 3, 2025 (ten days after receiving MAD\'s responses). However, Plaintiff Kragh is on a business trip from October 28 through November 2, 2025, and doesn\'t have access to her case files and legal research materials. She asks for a two-week extension, making the new deadline November 17, 2025. Plaintiff Kragh contacted MAD\'s attorney who confirmed they don\'t object to the extension. Since both sides agree and the delay won\'t harm either party, such motions are typically granted routinely by judges.', 'created_at' => '2025-11-09 23:39:13.429', 'updated_at' => '2025-11-13 20:30:30.535', 'notes' => '', 'title' => 'Motion to Extend Time for Filing Reply Briefs (Filed By Kragh, Elizabeth on behalf of Kragh, Elizabeth )'],
    ['id' => 48, 'date' => '2025-08-29', 'summary' => 'MAD\'s lawyers are defending against Kragh\'s attempt to throw out their legal claims and defenses. They argue that Montana courts use very lenient standards for legal pleadings - requiring only a "short and plain statement" rather than detailed facts.

MAD contends their counterclaims are "compulsory," meaning they must be filed because they arise from the same disputes Kragh raised. They claim they don\'t need to provide specific facts because their legal documents reference all the allegations from Kragh\'s original complaint.

Regarding the requirement to name specific injured members, MAD argues this law only applies to organizations that start lawsuits, not defendants responding to being sued. They also claim they\'re only seeking general protection for the organization, not damages for individual members.

MAD\'s position is essentially: "It\'s too early to dismiss our claims - let us gather evidence first through the discovery process, then decide if our case has merit." They request that if the judge finds problems with their pleadings, they should be allowed to rewrite them rather than having them dismissed entirely.
', 'created_at' => '2025-09-05 02:24:08.135', 'updated_at' => '2025-09-05 02:25:02.604', 'notes' => '', 'title' => 'Defendant\'s Response to Plaintiff\'s Motion to Dismiss and Strike (Filed By Lacny, Peter on behalf of Montana Association of the Deaf Inc. )'],
    ['id' => 28, 'date' => '2025-07-25', 'summary' => 'Lawsuit Schedule: What This Court Filing Means-

What Happened: 
The judge created a timeline for Elizabeth Kragh\'s case against the Montana Association of the Deaf. This protects the plaintiff\'s rights and keeps the case moving forward.

Step-by-Step Process:

Step 1 (Next 30 Days): 
Elizabeth Kragh must email MAD\'s lawyer (Peter Lacny) to agree on specific dates for all deadlines. Since she\'s representing herself (pro se), she\'ll communicate directly with opposing counsel via email and submit the agreed schedule to court.

Step 2 (7 Months):
Discovery phase - Kragh can demand documents, emails, and information from MAD. They must respond honestly. Kragh also has to answer MAD\'s requests fairly.

Step 3: 
Both sides identify expert witnesses who can testify about technical issues in the case.

Step 4: 
Mandatory settlement meetings - first Kragh meets directly with MAD\'s lawyer, then both parties try negotiating with a neutral court-appointed person.

Step 5: If no settlement, they prepare for trial with final witness lists and evidence.

Email Communication with MAD\'s Lawyer: 
Since Kragh is pro se, she emails Peter Lacny directly. All correspondence should be professional and documented via email. She must coordinate scheduling, exchange information, and handle all legal discussions herself through email communication.

Key Point: 
Every deadline matters. This schedule ensures MAD can\'t delay the case and guarantees Kragh gets access to information needed to prove her claims.
', 'created_at' => '2025-08-05 22:23:29.461', 'updated_at' => '2025-09-05 19:53:52.584', 'notes' => '', 'title' => 'Rule 16(B), M.R.CIV.P. Order'],
    ['id' => 49, 'date' => '2025-09-03', 'summary' => 'Elizabeth Kragh filed this reply brief defending her request to dismiss counterclaims made by the Montana Association of the Deaf (MAD) in their ongoing lawsuit. Kragh originally sued MAD for violating Montana laws by denying her access to organizational records, conducting improper elections, and mismanaging finances. Instead of simply defending themselves, MAD filed counterclaims against Kragh, essentially trying to sue her back. In this reply brief, Kragh argues that MAD\'s counterclaims are legally flawed "empty labels" without specific facts, pointing out that MAD contradicted themselves by admitting to the very conduct they claim was legal. She notes that MAD\'s own lawyer agreed to delay evidence gathering until the court rules on her dismissal motion, which she argues shows the counterclaims lack substance. Kragh contends that under Montana law, MAD\'s litigation-based counterclaims should be filed as a separate lawsuit rather than mixed with this case, and that MAD is using weak counterclaims as a fishing expedition to avoid accountability for governance violations.
', 'created_at' => '2025-09-05 22:34:36.922', 'updated_at' => '2025-09-05 22:34:36.922', 'notes' => '', 'title' => 'Reply Brief in Support of Plaintiff\'s Motion to Dismiss Counterclaims and Strike Affirmative Defenses (Filed By Kragh, Elizabeth on behalf of Kragh, Elizabeth )'],
    ['id' => 50, 'date' => '2025-09-03', 'summary' => 'Elizabeth Kragh filed this reply brief defending her request for a protective order to limit discovery demands made by the Montana Association of the Deaf (MAD) in their ongoing lawsuit. Discovery is the legal process where each side can demand documents, information, and answers from the other party before trial. Kragh argues that MAD\'s discovery requests are excessive and inappropriate because MAD has already admitted to the key violations in their legal filings, making extensive information-gathering unnecessary. She contends that six specific requests relate to MAD\'s weak counterclaims rather than her original lawsuit, and several other requests are overly broad, potentially requiring her to identify thousands of people who saw her social media posts about the case. Kragh points out that MAD\'s own lawyer acknowledged that dismissing the counterclaims would reduce the scope of discovery needed. She argues that forcing her, as a person representing herself in court, to respond to invasive requests about her private communications constitutes harassment rather than legitimate evidence-gathering, especially when MAD has already admitted to the conduct she\'s challenging.', 'created_at' => '2025-09-05 22:35:28.191', 'updated_at' => '2025-09-05 22:35:28.191', 'notes' => '', 'title' => 'Reply Brief in Support of Plaintiff\'s Motion for Protective Order (Filed By Kragh, Elizabeth on behalf of Kragh, Elizabeth )'],
    ['id' => 51, 'date' => '2025-09-08', 'summary' => 'This is a legal notice filed on September 8, 2025, informing the court that Elizabeth Kragh (the person suing) has responded to discovery requests from Montana Association of the Deaf (MAD). Discovery is when each side asks the other for information and documents related to the case. Kragh answered 9 questions, responded to 7 requests for documents, admitted or denied 9 statements, and provided 5 exhibits as evidence. She sent these responses to MAD\'s lawyers by email.', 'created_at' => '2025-09-11 03:13:29.717', 'updated_at' => '2025-09-11 03:13:29.717', 'notes' => '', 'title' => 'Notice of Service of Discovery Requests (Filed By Kragh, Elizabeth on behalf of Kragh, Elizabeth )'],
    ['id' => 52, 'date' => '2025-09-15', 'summary' => 'In lawsuits, both sides can request information from each other through a process called "discovery" - asking questions, requesting documents, and seeking admissions of facts. This notice simply informs the court and the plaintiff (Elizabeth Kragh) that the defendant (Montana Association of the Deaf) has completed and sent their responses to the plaintiff\'s discovery requests via email on September 15, 2025.
', 'created_at' => '2025-09-22 03:07:47.689', 'updated_at' => '2025-09-22 03:07:47.689', 'notes' => '', 'title' => 'Notice of Service of Discovery Responses (Filed By Lacny, Peter on behalf of Montana Association of the Deaf Inc. )'],
    ['id' => 53, 'date' => '2025-09-22', 'summary' => 'On September 22, 2025, Judge Tara Elliott ruled on Elizabeth Kragh\'s strategic motions in her lawsuit against the Montana Association of the Deaf (MAD).

Kragh had challenged MAD\'s counterclaims as legally insufficient, arguing they contained only vague accusations without specific supporting facts. She also sought to limit MAD\'s broad discovery requests for personal information.

While the court denied Kragh\'s motions, allowing MAD\'s counterclaims to proceed under Montana\'s liberal pleading standards, the ruling contained a significant strategic victory for Kragh. The court notably refused to grant MAD\'s request for permission to amend their counterclaims, forcing MAD to defend their original vague allegations without the opportunity to strengthen them with better factual support.

This outcome benefits Kragh\'s position: her substantive claims about MAD\'s governance violations remain fully intact and will proceed to trial, while MAD is now locked into defending poorly-drafted counterclaims they cannot improve. The case moves forward to discovery, where Kragh can build her evidence while MAD remains constrained by their inadequate pleadings.', 'created_at' => '2025-09-27 23:16:16.988', 'updated_at' => '2025-09-27 23:16:16.988', 'notes' => '', 'title' => 'Order'],
    ['id' => 55, 'date' => '2025-10-06', 'summary' => 'Montana Association of the Deaf filed a detailed legal brief explaining why they believe the court should rule in their favor without a trial. The brief addresses three claims made by Elizabeth Kragh.

First, regarding access to meeting minutes, MAD argues this claim is now unnecessary because they provided all requested minutes during the legal discovery process in September 2025.

Second, concerning the 2023 election conducted by acclamation rather than written ballot as required by bylaws, MAD acknowledges this occurred but argues it was intentional as a custom and not mandatory. They claim Kragh attended the meeting without objecting and waited nearly two years to raise concerns. MAD also notes they conducted proper elections in 2025.

Third, regarding financial oversight concerns, MAD provided comprehensive financial documentation accounting for all funds, including the disputed $888.54. They explain this amount represented documented income properly added to their general fund, and what appeared as a discrepancy was a corrected reporting error.', 'created_at' => '2025-10-08 18:23:51.638', 'updated_at' => '2025-10-08 18:23:51.638', 'notes' => '', 'title' => 'Brief In Support of Defendant\'s Motion for Summary Judgment (Filed By Lacny, Peter on behalf of Montana Association of the Deaf Inc. )'],
    ['id' => 56, 'date' => '2025-10-06', 'summary' => 'Attorney Peter Lacny filed a sworn legal statement on behalf of Montana Association of the Deaf on October 4, 2025. This declaration serves as proof to support MAD\'s request that the court rule in their favor without a trial.

The declaration contains nine numbered paragraphs, each referencing specific documents attached as exhibits. These exhibits include copies of meeting minutes that MAD provided to plaintiff Kragh during the legal discovery process, minutes from the June 2023 meeting where the disputed election occurred, Kragh\'s written responses to legal questions, and comprehensive financial records.

The declaration specifically references documents showing that MAD provided all requested meeting minutes, held proper elections in 2025, and provided detailed financial documentation including an explanation of the disputed $888.54 amount. As a sworn statement, the declaration carries legal weight and establishes the factual foundation that MAD believes supports their position in the case.', 'created_at' => '2025-10-08 18:24:58.126', 'updated_at' => '2025-10-08 18:24:58.126', 'notes' => '', 'title' => 'Declaration of Peter Lacny in Support of Defendant\'s Motion for Summary Judgment (Filed By Lacny, Peter on behalf of Montana Association of the Deaf Inc. )'],
    ['id' => 57, 'date' => '2025-10-07', 'summary' => 'Plaintiff Kragh filed a motion asking the court to compel Montana Association of the Deaf to produce evidence they admit exists but refuse to provide. The dispute centers on three categories of materials: video recordings of 15 board meetings MAD created when recording from January 2023 through February 2025, internal communications among officers regarding governance decisions and policy development, and a complete ten-year history of bylaw amendments.

Kragh attempted to resolve the matter through required pre-litigation discussions, but MAD maintained their objections as these evidences are irrelevant. She argues the materials are directly relevant to her claims about records access violations, improper elections, and financial oversight failures. Notably, MAD filed their motion for summary judgment on October 4, 2025, just three days before Kragh filed this compel motion.

The timing raises procedural concerns about seeking case dismissal while withholding potentially crucial evidence. Kragh emphasizes that for ASL communications, video recordings preserve important contextual information that written summaries cannot capture, making their production particularly important for determining what actually occurred during board discussions.
', 'created_at' => '2025-10-08 18:42:25.13', 'updated_at' => '2025-10-08 18:42:25.13', 'notes' => '', 'title' => 'Motion to Compel Discovery (Filed By Kragh, Elizabeth on behalf of Kragh, Elizabeth )'],
    ['id' => 58, 'date' => '2025-10-07', 'summary' => 'The exhibits filing contains the supporting documentation for plaintiff Kragh\'s motion to compel discovery. This collection of evidence demonstrates her good faith efforts to obtain information from Montana Association of the Deaf before asking the court to intervene.

The documents show a clear pattern: Kragh repeatedly requested specific materials through proper legal channels, MAD acknowledged possessing them, but then refused to provide them. Most notably, MAD admitted they recorded 15 board meetings and store them on the president\'s laptop, yet claimed these recordings aren\'t relevant or would be too burdensome to produce.

The exhibits include email exchanges where Kragh methodically identified missing items and legal deficiencies in MAD\'s responses. MAD\'s attorney maintained blanket objections despite Kragh\'s reasonable requests for clarification and compromise. The collection also includes the brief November 2024 meeting minutes showing the controversial zero-tolerance policy was adopted in just 17 minutes, highlighting why the video recordings could reveal important details not captured in written summaries.
', 'created_at' => '2025-10-08 18:43:36.204', 'updated_at' => '2025-10-08 18:43:36.204', 'notes' => '', 'title' => 'Exhibits A-H- Attachment to Doc #40 (Filed By Kragh, Elizabeth on behalf of Kragh, Elizabeth )'],
    ['id' => 59, 'date' => '2025-10-09', 'summary' => 'This is plaintiff Kragh\'s proposed court order - what she\'s asking the judge to sign after filing a motion to compel discovery against the Montana Association of the Deaf. The court hasn\'t ruled on it yet.

Kragh is requesting the judge to order the nonprofit organization to turn over:

- Video recordings of 15 board meetings from 2023-2025
- Internal emails and communications about her document requests, their zero-tolerance policy, election procedures, and a financial discrepancy of $888.54
- Complete history of changes to their bylaws since 2015

In her proposed order, Kragh argues that she properly followed legal procedures by trying to work things out beforehand, and that the organization\'s reasons for refusing were too vague. She claims the documents are relevant to her case about alleged violations of nonprofit law.

If the judge signs this order, the organization would have 14 days to comply or face potential sanctions. This represents Kragh\'s legal strategy to access information she believes she\'s entitled to as a member of the organization', 'created_at' => '2025-10-10 19:18:32.056', 'updated_at' => '2025-10-10 19:18:32.056', 'notes' => '', 'title' => 'Proposed Order Granting Motion to Compel Discovery'],
    ['id' => 61, 'date' => '2025-10-09', 'summary' => 'This is plaintiff Kragh\'s sworn statement asking the court to delay the Montana Association of the Deaf\'s request to end the case early. Kragh argues she cannot properly defend herself because the organization is hiding important evidence.

The organization filed a motion asking the judge to dismiss the case, claiming there was "no willful wrongdoing" and "no bad intent" in their actions. However, Kragh says the organization admits that crucial evidence exists - including video recordings of 15 board meetings and internal communications - but refuses to turn it over.

Kragh argues this is unfair: the organization cannot claim certain facts are undisputed while hiding the only evidence that could prove or disprove those claims. She points out that discovery (the evidence-gathering phase) is supposed to continue until March 2026, making the organization\'s request premature.

The organization has already provided documents in four separate batches, suggesting their initial searches were incomplete. Kragh states she needs access to the withheld evidence to properly respond to the organization\'s motion.', 'created_at' => '2025-10-10 19:21:28.245', 'updated_at' => '2025-10-10 19:21:28.245', 'notes' => '', 'title' => 'Affidavit in Support of Rule 56(f) Motion (Filed By Kragh, Elizabeth on behalf of Kragh, Elizabeth ) 283950 $1.00'],
    ['id' => 62, 'date' => '2025-10-10', 'summary' => 'Plaintiff Kragh filed this affidavit asking the court to extend the October 31, 2025 deadline for amending her complaint. She states that discovery has revealed additional violations she couldn\'t have known about when filing her original complaint. The defendant has provided documents in four separate rounds, with key materials like a policy manual only produced in October 2025. The defendant continues withholding video recordings of board meetings, internal communications, and bylaw histories. Kragh argues she has been diligent in pursuing discovery but needs more time to investigate newly discovered violations before the amendment deadline expires.
', 'created_at' => '2025-10-12 02:38:58.702', 'updated_at' => '2025-10-12 02:38:58.702', 'notes' => '', 'title' => 'Affidavit in Support of Motion to Modify Scheduling Order (Filed By Kragh, Elizabeth on behalf of ) 283988 $1.00'],
    ['id' => 63, 'date' => '2025-10-10', 'summary' => 'Plaintiff Kragh filed this motion asking the court to extend the October 31, 2025 deadline for amending her complaint in this lawsuit. She argues that discovery (the legal process where parties share documents) has revealed additional violations she couldn\'t have known about when originally filing. Her initial complaint focused on three issues, but newly discovered documents show a broader pattern of governance problems spanning policy creation, meeting procedures, and financial oversight.

The defendant organization continues withholding important evidence including video recordings of 15 board meetings, internal communications, and historical governance documents. Kragh argues she has been diligent in pursuing discovery but needs more time to investigate these newly discovered violations before the amendment deadline expires. The motion presents two options: either allow staged amendments or extend the deadline until after discovery is complete. She cites legal precedent requiring "good cause" and argues the current deadline cannot reasonably be met despite her diligence.
', 'created_at' => '2025-10-12 02:40:20.087', 'updated_at' => '2025-10-12 02:40:20.087', 'notes' => '', 'title' => 'Motion to Modify Scheduling Order Extension of complaint Amendment Deadline (Filed By Kragh, Elizabeth on behalf of ) 283988 $1.00'],
    ['id' => 64, 'date' => '2025-10-10', 'summary' => 'This is a template court order that Judge Tara Elliott would sign if she grants Plaintiff Kragh\'s request to extend the amendment deadline. The document first lists the court\'s findings, including that Kragh has been diligent in pursuing discovery, that newly discovered governance violations couldn\'t have been anticipated when the original deadline was set, and that the defendant organization continues withholding crucial evidence like video recordings and internal communications.

The proposed order then gives the judge three options to choose from: 1) Allow a staged approach with two separate amendment deadlines, 2) Extend the deadline to May 2026 after discovery is complete (plaintiff\'s preferred option), or 3) Extend the deadline to January 2026 with requirements for expedited discovery. Each option also addresses whether to pause the defendant\'s summary judgment motion until after the amendment process is complete.

This is essentially the "relief" or outcome that Plaintiff Kragh is asking the court to grant through her motion.
', 'created_at' => '2025-10-12 02:41:36.733', 'updated_at' => '2025-10-12 02:41:36.733', 'notes' => '', 'title' => 'Proposed Order Granting Motion to Modify Scheduling Order 283988 $1.00'],
    ['id' => 67, 'date' => '2025-10-23', 'summary' => 'This is the court\'s electronic filing receipt confirming that Judge Tara Elliott granted Plaintiff Elizabeth Kragh\'s motion to strike on October 23, 2025. The receipt shows the order was electronically filed at 9:25 AM by the court clerk\'s office in Missoula County. While the proposed order is this document, the filing stamp indicates the judge approved Plaintiff Kragh\'s request to remove the accidentally filed discovery responses from the court record, as requested in her motion filed just one day earlier on October 22, 2025.', 'created_at' => '2025-11-09 23:31:54.095', 'updated_at' => '2025-11-13 20:31:57.704', 'notes' => '', 'title' => 'Order Granting Motion to Strike Improperly Filed Discovery Responses'],
    ['id' => 65, 'date' => '2025-10-21', 'summary' => 'This document is a Certificate of Service filed by Elizabeth Kragh confirming she provided additional information in her lawsuit against the Montana Association of the Deaf. After the court denied two of Kragh\'s earlier requests in September 2025, the judge ordered her to answer six specific discovery questions within 30 days. Discovery is the legal process where both sides exchange information before trial. This certificate proves Kragh met the October 22 deadline by submitting her answers on October 21, 2025, and properly notifying the other side\'s attorney by email.', 'created_at' => '2025-11-09 20:19:55.036', 'updated_at' => '2025-11-13 20:34:01.57', 'notes' => '', 'title' => 'Certificate of Service (Filed By Kragh, Elizabeth on behalf of )'],
    ['id' => 66, 'date' => '2025-10-22', 'summary' => 'This motion asks the court to remove a document that Plaintiff Elizabeth Kragh accidentally filed. When responding to discovery requests (questions and document requests from the other side), lawyers typically send their answers directly to the opposing attorney and file only a certificate proving they did so. Plaintiff Kragh correctly sent her responses to the Montana Association of the Deaf\'s attorney and filed the certificate, but she also mistakenly filed the actual responses with the clerk of the court. Since discovery responses aren\'t supposed to be filed unless used in a motion, Plaintiff Kragh asks the judge to delete them from the court record while keeping the certificate of service.
', 'created_at' => '2025-11-09 20:21:46.039', 'updated_at' => '2025-11-13 20:34:29.807', 'notes' => '', 'title' => 'Motion to Strike Improperly File Discovery Responses (Doc #47) (Filed By Kragh, Elizabeth on behalf of )'],
    ['id' => 60, 'date' => '2025-10-09', 'summary' => 'This is Plaintiff Kragh\'s motion asking the court to delay the Montana Association of the Deaf\'s request to end the case early. Kragh argues it\'s premature to proceed when crucial evidence is still being withheld.

The organization filed a motion to dismiss the case on a Saturday, even though the evidence-gathering phase (discovery) is scheduled to continue until March 2026 - five months away. Kragh points out that the organization admits important evidence exists, including video recordings of 15 board meetings and internal communications, but refuses to turn it over.

Kragh notes a procedural inconsistency: the court previously criticized her for not trying to work things out with the other side before filing motions, yet the organization\'s lawyer did the same thing when filing their dismissal request.

The motion asks the court to either deny the organization\'s request entirely or delay it until all evidence has been properly shared and reviewed. Kragh argues the organization cannot claim certain facts are undisputed while hiding evidence that could prove or disprove those claims.
', 'created_at' => '2025-10-10 19:20:16.941', 'updated_at' => '2025-11-13 20:29:35.216', 'notes' => '', 'title' => 'Motion for Additional Discovery Time Pursuant to Rule 56(f) (Filed By Kragh, Elizabeth on behalf of Kragh, Elizabeth )'],
    ['id' => 68, 'date' => '2025-10-24', 'summary' => 'The Montana Association of the Deaf opposes Plaintiff Elizabeth Kragh\'s request for board meeting videos, internal communications, and bylaw history. MAD claims they\'ve already provided 700+ pages of documents and argues the additional materials aren\'t relevant to Plaintiff Kragh\'s three claims about meeting minutes, election procedures, and financial oversight.
MAD\'s main concern is that Plaintiff Kragh maintains a public website about the lawsuit and might share the videos online. They worry this could embarrass volunteer board members and misuse the discovery process for public relations rather than trial preparation.
MAD asks the judge to deny Plaintiff Kragh\'s motion, limit further document production, and order her to pay their attorney fees.
', 'created_at' => '2025-11-09 23:34:01.804', 'updated_at' => '2025-11-13 20:31:03.478', 'notes' => '', 'title' => 'Defendant\'s Response to Plaintiff\'s Motion to Compel and Cross-Motion for Protective Order (Filed By Lacny, Peter on behalf of Montana Association of the Deaf Inc. )'],
    ['id' => 70, 'date' => '2025-10-24', 'summary' => 'MAD opposes Plaintiff Elizabeth Kragh\'s requests for more discovery time and extension of deadlines before responding to their summary judgment motion. MAD argues Plaintiff Kragh is seeking "smoking gun evidence" without explaining how additional materials would help her case—something Montana courts have found insufficient for delays.

MAD claims they\'ve provided everything relevant: meeting minutes, financial records, and election documentation. They argue board meeting videos, internal communications, and historical bylaws won\'t change the fundamental facts.

MAD also disputes Plaintiff Kragh\'s accusations of "tactical manipulation" for filing their motion on a Saturday, noting there\'s nothing improper about weekend work. They ask the judge to deny both extension requests and grant summary judgment immediately, potentially ending the case without trial.
', 'created_at' => '2025-11-09 23:37:50.677', 'updated_at' => '2025-11-13 20:31:34.73', 'notes' => '', 'title' => 'MAD\'s Combined Response to Plaintiff\'s Rule 56(f) Motion and Motion to Extend Scheduling Order (Filed By Lacny, Peter on behalf of Montana Association of the Deaf Inc. )'],
    ['id' => 73, 'date' => '2025-11-12', 'summary' => 'Plaintiff Elizabeth Kragh asks the judge to extend the October 31 deadline for amending her lawsuit. She argues that recently produced documents revealed additional governance violations beyond her original three claims, but she needs more time to investigate before deciding whether to add them.

A policy manual produced in October showed seven potential new bylaw violations. However, MAD still withholds fifteen board meeting videos, internal communications, and bylaw records that could reveal even more violations. Plaintiff Kragh contends extending the deadline would allow her to file one comprehensive amended complaint rather than multiple separate lawsuits as new problems emerge.

She emphasizes being diligent—pursuing discovery immediately and negotiating in good faith. Since the discovery deadline isn\'t until March 2026, Kragh requests extending the amendment deadline to May 2026, allowing proper investigation of materials MAD continues withholding.', 'created_at' => '2025-11-13 20:35:59.621', 'updated_at' => '2025-11-13 20:35:59.621', 'notes' => '', 'title' => 'Reply Brief in Support of Motion to Modify Scheduling Order (Filed By Kragh, Elizabeth on behalf of )'],
    ['id' => 75, 'date' => '2025-11-12', 'summary' => 'Plaintiff Elizabeth Kragh responds to MAD\'s opposition, arguing the organization admits crucial evidence exists but refuses to provide it while simultaneously asking the judge to dismiss the case. Kragh seeks fifteen specific board meeting videos (which MAD confirms are stored on the president\'s laptop), internal officer communications, and bylaw amendment records spanning ten years.

She contends these materials could reveal whether MAD\'s violations of state law and bylaws were deliberate or accidental—the key question at the heart of her claims. Plaintiff Kragh argues it\'s fundamentally unfair for MAD to file for immediate dismissal while withholding the very evidence needed to prove or disprove their assertions about intent and knowledge.

She asks the judge to deny MAD\'s summary judgment motion or delay ruling until after discovery concludes in March 2026.', 'created_at' => '2025-11-13 20:39:05.282', 'updated_at' => '2025-11-13 20:39:05.282', 'notes' => '', 'title' => 'Reply Brief in Support of Motion for Additional Discovery Time Pursuant to Rule 56 (Filed By Kragh, Elizabeth on behalf of )
'],
    ['id' => 76, 'date' => '2025-11-12', 'summary' => 'Plaintiff Elizabeth Kragh responds to MAD\'s opposition, emphasizing that MAD admits crucial evidence exists but refuses to provide it. The disputed materials include fifteen board meeting videos (stored on the president\'s laptop), internal officer communications, and ten-year bylaw amendment records.

Plaintiff Kragh argues Montana law clearly allows discovery of video recordings as "electronically stored information," rejecting MAD\'s claim they\'re merely "working notes" exempt from disclosure. She contends these videos could reveal whether MAD\'s violations were deliberate or accidental—crucial to proving intent and knowledge.

Kragh addresses procedural errors MAD highlighted, calling them clerical mistakes that didn\'t prevent meaningful negotiation. She opposes MAD\'s request for a protective order and attorney fees, arguing MAD created the dispute by withholding relevant evidence while simultaneously requesting immediate case dismissal.', 'created_at' => '2025-11-13 20:40:54.639', 'updated_at' => '2025-11-13 20:40:54.639', 'notes' => '', 'title' => 'Reply Brief in Support of Motion to Compel Discovery (Filed By Kragh, Elizabeth on behalf of )
'],
];
        
        foreach ($entries as $entry) {
            DocketEntry::create($entry);
        }
        
        $this->command->info('Imported ' . count($entries) . ' docket entries');
    }
    
    private function importDocuments(): void
    {
        $documents = [
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    ['id' => 7, 'email' => 'wheeler6811@aol.com', 'is_active' => true, 'unsubscribe_token' => '7af79759-2c8f-464d-b3f0-e6807311f6dd', 'created_at' => '2025-06-28 03:31:46.426'],
    ['id' => 8, 'email' => 'Jared@Allebest.com', 'is_active' => true, 'unsubscribe_token' => '464a7cef-ff03-4c01-8443-354fb296464e', 'created_at' => '2025-06-28 23:00:04.484'],
    ['id' => 9, 'email' => 'kimanderson.ks@gmail.com', 'is_active' => true, 'unsubscribe_token' => '798ba07c-4d03-4afb-828c-df81c72650c2', 'created_at' => '2025-06-29 14:55:30.011'],
    ['id' => 25, 'email' => 'tane.schulte@gmail.com', 'is_active' => true, 'unsubscribe_token' => 'a85a06d4-124e-4164-8459-51a5c68adbf5', 'created_at' => '2025-09-29 01:03:14.805'],
    ['id' => 26, 'email' => 'trnelson89@gmail.com', 'is_active' => true, 'unsubscribe_token' => '5a3b50a5-d0c7-4441-a41e-c0b9a5075979', 'created_at' => '2025-10-24 16:27:59.56'],
    ['id' => 27, 'email' => 'letsgetonacid222@gmail.com', 'is_active' => true, 'unsubscribe_token' => 'fac65b07-79d3-4165-aaca-84ec3332ae85', 'created_at' => '2025-10-28 16:18:00.457'],
    ['id' => 28, 'email' => 'quarks.tattoo-09@icloud.com', 'is_active' => true, 'unsubscribe_token' => 'd8b53e7c-5a69-4670-85fe-604bc83813b2', 'created_at' => '2025-11-19 03:03:45.528'],
    ['id' => 10, 'email' => 'ksymansky@gmail.com', 'is_active' => true, 'unsubscribe_token' => 'b87f9a94-5cc1-4d9f-ad77-a1be4eb038ea', 'created_at' => '2025-07-01 01:21:19.951'],
    ['id' => 11, 'email' => 'martleonor@aol.com', 'is_active' => true, 'unsubscribe_token' => '816440d6-c7d5-4847-a50e-7ac621eb6f86', 'created_at' => '2025-07-01 07:11:02.288'],
    ['id' => 12, 'email' => 'this1is3john@gmail.com', 'is_active' => true, 'unsubscribe_token' => 'd3b5b72e-11aa-400c-9e2c-92f315819b27', 'created_at' => '2025-07-01 12:22:58.44'],
    ['id' => 13, 'email' => 'alexabauch@icloud.com', 'is_active' => true, 'unsubscribe_token' => 'f66410b0-3400-468e-87ee-34b84c40e35b', 'created_at' => '2025-07-03 04:16:47.928'],
    ['id' => 14, 'email' => 'wsad.president@gmail.com', 'is_active' => true, 'unsubscribe_token' => '982a0119-ea37-4151-acb2-04c27802a8a4', 'created_at' => '2025-07-04 20:06:14.97'],
    ['id' => 15, 'email' => 'deafwantstoknow@gmail.com', 'is_active' => true, 'unsubscribe_token' => '6c40ff30-1e7a-4c73-a188-d04055987b3f', 'created_at' => '2025-07-09 05:27:50.182'],
    ['id' => 17, 'email' => 'sjthomp0615@gmail.com', 'is_active' => true, 'unsubscribe_token' => '00fe7ff3-b42b-4c95-8882-efe68d0970f0', 'created_at' => '2025-07-18 19:05:23.217'],
    ['id' => 18, 'email' => 'eliza.kragh@gmail.com', 'is_active' => true, 'unsubscribe_token' => '9fe988b3-d317-4a01-bdf5-aed2895e17ba', 'created_at' => '2025-07-25 21:38:58.027'],
    ['id' => 19, 'email' => 'harding.cara89@gmail.com', 'is_active' => true, 'unsubscribe_token' => '74018cc6-4c7a-43af-891e-4949d5925fca', 'created_at' => '2025-07-26 00:01:22.296'],
    ['id' => 20, 'email' => 'rindelsd@gmail.com', 'is_active' => true, 'unsubscribe_token' => '01eb9061-8c20-4667-bd46-71e48e6dc384', 'created_at' => '2025-07-26 00:04:44.454'],
    ['id' => 21, 'email' => 'kat_kariann@hotmail.com', 'is_active' => true, 'unsubscribe_token' => '25ea5299-03f0-49e2-b556-447215e6d05c', 'created_at' => '2025-07-26 12:15:14.048'],
    ['id' => 22, 'email' => 'thejustinrold@gmail.com', 'is_active' => true, 'unsubscribe_token' => 'b13d4d6a-1b51-4ee1-9a77-d38115d51d0b', 'created_at' => '2025-07-26 23:37:15.978'],
    ['id' => 23, 'email' => 'ritabrandborg@gmail.com', 'is_active' => true, 'unsubscribe_token' => 'a8fbc7d9-81ed-4047-bab1-8d304597d4dd', 'created_at' => '2025-07-28 12:37:30.323'],
    ['id' => 24, 'email' => 'fullerkim777@icloud.com', 'is_active' => true, 'unsubscribe_token' => '4effbe07-04df-4371-87bf-15f14b90f90e', 'created_at' => '2025-07-28 22:46:53.302'],
    ['id' => 16, 'email' => 'mike.crago@gmail.com', 'is_active' => false, 'unsubscribe_token' => 'd2db168b-7869-4340-8d7c-fded7fc357b8', 'created_at' => '2025-07-14 23:58:34.353'],
];
        
        foreach ($subscriptions as $subscription) {
            Subscription::create($subscription);
        }
        
        $this->command->info('Imported ' . count($subscriptions) . ' subscriptions');
    }
}