April 29, 2000

The Honorable Kenneth O. Nix
Superior Court of Cobb County
30 Waddell Street
Marietta, GA 30090

RE: Civil Action File 99-1-7941-24 Portman vs. Kreeger, et. al

Dear Judge Nix:

The above cited case has been assigned to you since October 12, 1999 when the Honorable Michael Stoddard recused himself. The Recusal Order was postmarked October 14, 1999. As plaintiff, I filed a motion to disqualify you (with appropriate affidavit) on October 18, 1999. Said motion was filed within the 5 day requirement, but you made no response. I then filed a motion to amend my original motion to disqualify you (including the appropriate amended motion and affidavit) on March 9, 2000.

This Civil Action has been before you now for over six (6) months. During that time, numerous motions, answers, responses, discovery, etc. have been filed. Facts do not cease to exist because they are ignored.

Not only have you failed to respond in a timely manner to the original motion to disqualify, but your failure to do so has barred each subsequent motion from being heard. In this case, your failure to administer the actions of your office in timely manner has violated my right to due process.

Because many of the defendants in this case are your personal friends and immediate professional associates, I now question whether your failure to act is intentional. The ancient philosopher, Cicero, once said, "When you have no basis for argument, abuse the plaintiff." By your absence of action, are you purposely allowing these same defendants to attempt numerous acts of bullying and intimidation?

I appeal to you to act according to the law. I seek justice from your Court and from any other Court to which I may appeal this action or extend my pleas. Please respond.

Sincerely,

Marquitta Portman

sent with appropriate certificate of service, copies to all defendants