Melissa Wright Pro Se Debtor, Plaintiff, Respondent
1305 South Brown Road
Roswell, NM 88203
505-231-0968
575-637-1596

August 14, 2009

Puccini and Meagle, P.A.
P.O. Box 50700
Albuquerque, NM  87171-0700

Re: Melissa Wright Vs.
Vanderbilt Mortgage and Rio Grande Title Company 
Adversary No: 09-01048 M in the United States Bankruptcy Court in the District of NM

REQUEST FOR TELEPHONIC DEPOSITION

Dear Puccini and Meagle,

     With Regards to Notice of Deposition dated and filed on August 12, 2009, under Federal Rules of Civil Procedure30-(B) (4) Plaintiff Pro Se respectfully request that said Deposition take place telephonically.
     As a Pro Se Litigant, and a single mother of 5, 3 of which are school age children, traveling to Albuquerque would cause undo and additional extreme hardship.  One way it is over 198 miles from my place of residence.  I at this time do not have a reliable vehicle which is evident by my bankruptcy in which to travel such a distance safely, for a proceeding that can be conducted telephonically with ease.  I am also the sole provider for transportation of my children to and from school, and my children and I take pride on their attendance and academic achievements.  Plaintiff lives alone, and has no family or friends on which to rely on for the children’s care and or transportation during the school months.
     I am more than happy to oblige with the deposition as long as your office and clients are willing to conduct it via telephone.
     Thank you very much for your time, and consideration.  I apologize for any inconvenience and hope that we can reach an agreement for a telephonic deposition.

                                                                                     1.
      Sincerely,
      Melissa Wright pro se debtor, respondent, plaintiff
     1305 South Brown
      Roswell, NM 88203
      505-231-0968
                              Certificate of Service
Melissa Wright hereby certifies that I mailed by regular US Postal Mail a true and correct copy of this letter requesting Deposition of herself by Attorneys for Defendant Rio Grande Title Co. be held telephonically to:

SUSAN CRAWFORD                                                                     
ATTORNEY FOR VANDERBILT                                               
125 LINCOLN AVE, SUITE 400
SANTA FE, NM 87501

LINDA S. BLOOM
BANKRUPTCY TRUSTEE
PO BOX 218
ALBUQUERQUE, NM 87103-0218

UNITED STATES TRUSTEE
PO BOX 608
ALBUQUERQUE, NM 87103-0608

Mr. Chris Wilson
Deputy Clerk for the Honorable Judge McFeely
United state bankruptcy court
District of New Mexico
Box 546
Albuquerque, NM  87103-0546

Office of the Clerk
Attention Clerk of court
United States Bankruptcy Court, District of New Mexico
Po box 546
Albuquerque, NM  87103-0546

REMAX 
123 WEST BOOTH
SANTA FE, NM 87505

PUCCINI AND MEAGLE P.A.
ATTORNEYS FOR DEFENDANTS
RIO GRANDE TITLE AKA AMERICAN SURETY
PO BOX 50700
ALBUQUERQUE, NM 87181-0700
ON THIS 14 day of August, 2009

_______________________________
MELISSA WRIGHT PROSE DEBTOR/RESPONDENT/PLAINTIFF
1305 SOUTH BROWN
ROSWELL, NM 88203
575-637-1596  505-231-0968
                                  2.