STATE OF NORTH CAROLINA IN THE GENERAL COURTS OF JUSTICE

DISTRICT COURT DIVISION

MECKLENBURG COUNTY CASE NO. 20 CVD 11657

SAS Holdings, LLC,

Plaintiff,

v. MOTION TO RECONSIDER

Fahad Firdausi,

Defendant.

Defendant hereby moves the Court to reconsider its ruling granting summary judgment to

the Plaintiff. In support of this Motion, Defendant would show that:

1. He is entitled to the benefit of the recent orders placing a moratorium on evictions.

Defendant had previously filed the paperwork to demonstrate that entitlement and did not

know that the documentation had an expiration date. Even though the original documents

may have expired, Defendant still meets the requirements of the moratorium, and all

parties or counsel to this matter knew or should have known that fact. Yet, even in the

face of undeniable knowledge that Defendant had a right to obtain the benefit of the

eviction moratorium, Plaintiff proceeded with the eviction nonetheless.

2. Defendant was representing himself in this action, proceeding pro se. He did not fully

know of the correct format to write reply paragraphs and reference correctly with

numbering, He also did not know of the of the potential consequences or sanctions that

the Court could impose. Defendant is in the process of securing counsel to represent him

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Motion to Reconsider
 in this proceeding. Defendant would respectfully request that, as a pro se party, he be

shown the leniency that is appropriate and typical under those circumstances when his

adversary is represented by a member of the Bar.

3. Defendant was representing himself in this action, proceeding pro se. He did not fully

understand the nature of discovery, his obligations in that process, or the potential

consequences or sanctions that the Court could impose. Defendant is in the process of

securing counsel to represent him in this proceeding. Defendant would respectfully

request that, as a pro se party, he be shown the leniency that is appropriate and typical

under those circumstances when his adversary is represented by a member of the Bar.

This the 19th day of April 2021.

BY: __________________________________
Fahad Firdausi

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Motion to Reconsider
 CERTIFICATE OF SERVICE

The undersigned hereby certifies that he served upon the forgoing Motion by first class
mail as follows:

Andrew Gordon
The Law Offices of Andrew L. Gordon, PLLC
725 E. Trade Street, Ste 205
Charlotte, NC 28202
Attorney for Plaintiff

This the 19th day of April 2021.

______________________________________
Fahad Firdausi

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Motion to Reconsider