Whether the Court can stay this matter until final resolution of a related and dependent money damages case, or order the petitioner be allowed to obtain all withheld discovery from the respondents and make this lawsuit eligible for trial on the merits under Oregon's anti-SLAPP statute with specific provisions for available relief

QUESTIONS FOR REVIEW | 1. Can the Court stay of this matter until final resolution of a related and dependant money damages case, Cunningham v. Washington County et al., 9" Circuit Case No. 18-35413 (see Tab C); or, in the alternative, 2. Can the Court Order: (a.) the Petitioner be allowed to obtain all withheld discovery from the SONY et al.; and, (b.) Order this lawsuit eligible for trial on the merits under ORS 31.150 et seq. (1995) with specific provisions: all relief is available to the Petitioner including defenses to his [wrongful] conviction set forth in Cunningham v. Washington County et al., 9" Cir Case No. 18-35413 (Tab C), as well as available relief under the 1995 statute, including but not limited to, a full retraction and correction of Dead by Sunset by SONY et al., in the same prominance as all the promotions and November 1995 broadcast, in compliance with ORS 31.150 et seq. (1995), and specifically pursuant to Petitioner's October 27, 2016 Demand for Retraction and Correction. , i. ! 2605 STATE STREET | SALEM, OREGON 97310 i ; | j . OVERVIEW This lawsuit was filed against these defendants (SONY et al.) under 1995 state of Oregon Defamation and False-light statutes within one-year after I received Actual Knowledge of their 1995 broadcast of the movie, Dead by Sunset (DBS). , Due to my incarceration and no fault of mine, it took over 20 years to obtain a copy of DBS. Once I viewed DBS I prepared a comprehensive Demand for Retraction and Correction which was served within 20-days on SONY et al., and subsequently ignored. In addition to these state-law claims I am seeking relief for violation of my civil rights under 42 U.S.C.A. § 1983. The civil rights claims are based on the fact SONY et al. joined with the state of Oregon and became a state actor and agent in the production, filming, and promotion of DBS as follows: ~ 1. the state of Oregon provided SONY et al. state locations and equipment as movie sets at little or no cost to the production company; 2. the state of Oregon provided SONY et al. with state employees to appear as actors in roles in the DBS enterprise; 3. the state of Oregon provided state employees (including state police) to promote the DBS enterprise in the news and other public media prior to broadcast. These acts by SONY et al. and the state of Oregon violated my civil rights and are detailed in the Complaint. i. BRAD CUNNINGHAM 10456927 2605 STATE STREET SALEM, OREGON 97310 . The U.S. District Court never allowed me to receive any of my discovery requests and then granted the SONY et al. motion to dismiss my lawsuit. In his opinion (TAB B) the Hon. Judge Michael Simon stated non-existent federal statutes , and went on to grant relief to SONY et al. for my claims against them based on the statute of limitations, all which is 100% contrary to black-letter law on defamation which mandates my claims are tolled until I receive Actual Knowledge (even if it is 20 years later). The delay in receiving Actual Knowledge of the content of DBS was not my fault. In fact a few days prior to the November 1995 DBS broadcast on NBC Universal, I was abruptly and inexplicably transferred from the Oregon State Penitentiary in Salem, OR to the Snake River Correctional Institution in Ontario, OR and housed in the sex-offender treatment pod (I am not a sex-offender) where DBS was not allowed to be broadcast. The Oregon Department of Corrections allowed DBS to be broadcast to all other prisoners (approximately 14,500). As stated I have not been allowed to receive any discovery. The U.S. District Court, without providing me any basis, capriciously modified my original caption on this case. | SALEM, OREGON 97310