I am tired and having a very hard time finding the energy to work on the things I need to get done. They feel so overwhelming.
But by now, and because I am innately a seeker and a fixer, I know what is happening to me. It is exhaustion from seeking.
Not that long ago, I heard it explained that our bodies are always scanning for threats. It is always looking for any type of threat, and it reacts if it finds and senses one.
Because my brain injuries compromise my ability to regulate, I now have a body that is significantly more sensitive to threats. This makes logical sense with any brain injury if you think about it. The injured brain requires far more energy to do the same tasks. It is depleted much faster so naturally it is going to be more vigilant at scanning for those threats or more sensitive to them early to try and ensure it has the energy reserves to address any real threat it senses. The problem is that, much like allergies, this type of physiological hypervigilance is itself depleting. Especially when it is running all the time and especially when there are true ongoing threats to your health, safety, financial stability, or livelihood.
A person with any kind of underlying medical condition also has to always consider and learn to recognize when the threat is actually from internal sources of underlying conditions. This kind of threat recognition can be particularly difficult for a person with a brain injury or psychiatric conditions and not always because the person with the conditions struggle to recognize them, but because the healthcare providers themselves who are the only people qualified to diagnose and treat those conditions frequently ignore the patient and brush off their concerns -almost like if you are cognizant and intelligent enough question the internal workings of your body you can't possibly have a problem. It's a long standing problem within healthcare institutions and society. Many different names and situations come up, but comically due to TBI language recall difficulties I can picture these names and situations but I am struggling to actually put the right words to them ...my own personal hero Siemmelweiss is recallable... Here are some terms and descriptions that Google applies:
* "nerves," neurasthenia, or hypochondria, assuming the patient was merely over-intellectualizing harmless, transient feelings.
* "hysterical conversions."
* "epistemic injustice"
and then there it this:
The Asylum Era & "Moral Insanity"As the 19th century rolled into the 20th, large psychiatric asylums became overcrowded warehouses. A prominent theory utilized by asylum doctors (often called alienists) was moral insanity or behavioral deviance. [1, 2, 3, 4]
- The Bias: If a female chronic pain patient refused to accept her doctor's assertion that her pain was imaginary, her insistence was viewed as a psychiatric symptom: "morbid self-absorption," "obstinacy," or "hysterical simulation."
- The Paradox: The very lucidity and logic she used to argue her case was flipped against her. Doctors reasoned that a truly sane, compliant patient would defer to authority. Her intellectual resistance was documented as proof of an unstable mind, occasionally leading to voluntary or forced institutionalization to "cure" her defiance.
And I am reeling because my case and so many others show that society and medicine has not really come that far from these times in history.
But back to what is happening to me. Why I am feeling so exhausted and having such a hard time tackling the task before me.
It is the threat. My body is always scanning for threats and I need to be able to recognize them to know what to do AND how to protect my brain and stability. I have to be able to discern when the threat is internal or external and when external threats are causing or internal threats -and even when internal threats are causing external ones, like when my vision goes weird, working memory isn't functioning right, or impulse control and decision making are compromised. This later is probably the most tricky to recognize and manage because by the time this happens you are not very good at protecting yourself from what can so easily be used against you...
... which brings us back to the courts and Intermountain Health (who has dropped the "care" from their name). It is not hard to see how a compromised brain is more susceptible to danger in these environments and less able to protect themself from threats that may be coming from these places. It is also easy to see how abuses of power and process are more likely to occur to my particular demographics of medical conditions.
which now, and in a literary way I had not planned, brings me to my reason for coming here: the threats I am sensing I have been able to identify, and they are legitimate threats coming from the Utah Court of Appeals and Intermountain. But this is where I am struggling to articulate... and my brain even seems to be blocking me from it because it is paradoxically so simple and complex; its most recent and novel form being rooted in the evolution and up-and-coming uses of AI tools.
They are, I fear, wanting to make an example out of me instead of hearing me for my disclosed use of AI tools, much like they did in this case: Garner v. Kadince, 2025 UT App 80.
There are many problems with this conspiracy theory that logic says is an impossible outcome for my particular appellate case and brief, such as:
1. My use of AI tools was disclosed and requested use for use as an accommodation to assist with effective communication and managing various aspects of my disabilities that can affect and compromise access.
2. I did not and have not used AI the way they were used in this case or for the same reasons.
3. I verified all of my authorities through the correct verification tools and most were found in the first place through the Utah Law Library long before I started using AI chatbot tools.
4. The other party, Intermountain, literally succeeded in using disclosed disability accommodations sought from the courts through methods I objected to, and accommodations both granted (time) and denied (AI-tools) as reason for an excessive extension of time that is greater than the accommodation provided and that the granting of is highly prejudicial to me and supposed to be "disfavored" according to the rules. (See URAP Rule 22(c)(4))
But the problem is, even though logic, laws, the rules appear to be on my side, the courts have not been consistent, reliable, or equitable in their interpretations and applications of laws, rules, and logic. Their most recent ruling granted Intermountain an additional 60 days on top of the 30 they are allowed and even though I did not stipulate and the Utah Rules of Appellate Procedure (URAP) very clearly states:
(3) Good cause. For the purpose of this rule, good cause includes, but is not limited to, the complexity of the case on appeal, engagement in other litigation, and extreme hardship to counsel.
(A) If the good cause relied upon is engagement in other litigation, the motion must:
(i) identify that litigation by caption, number, and court;
(ii) explain how engagement in the other litigation has prevented or will prevent a timely filing; and
(iii) identify any other relevant circumstances.(B) If the good cause relied upon is the complexity of the appeal, the motion must state the reasons why the appeal is so complex that the current due date cannot reasonably be met.
(C) If the good cause relied upon is extreme hardship to counsel, the motion must state in detail the nature of the hardship.
(D) All facts supporting good cause must be stated with specificity. Generalities, such as “the motion is not for the purpose of delay” or “counsel is engaged in other litigation,” are insufficient.
(4) When motions disfavored. A motion for an extension of time for filing a brief beyond the time permitted by stipulation of the parties is not favored. (https://legacy.utcourts.gov/rules/view.php?type=urap&rule=22)
But here is Intermountain's motion verbatim:
Appellees Intermountain Neurosciences Institute; Jon Pertab, PhD; Cara Camiolo
Reddy, MD; Melissa Minton; and Jodi Allen (“Intermountain”), by and through their
counsel of record, Cortney Kochevar, Sean C. Miller, and Lance E. Bastian of NELSON
NAEGLE, PLLC, hereby move the Court for a sixty-day extension to file their principal
brief pursuant to Utah Rule of Appellate Procedure 22(c).
Argument
The Court should grant this Motion and give Intermountain sixty additional days
to file its principal brief. The Court issued its Briefing Notice on April 18, 2024. Under
the default briefing schedule, appellant Ms. Saxton would have needed to file her
principal brief on May 28, 2024. However, because of the repeated and generous
extensions and other accommodations afforded to Ms. Saxton by this Court, she was not
required to file her brief until April 23, 2026. This Court also gave Ms. Saxton until
May 8, 2026, to cure her failure to file on April 23. Ms. Saxton filed on May 8, 2026, 710
days after her brief was originally due. Intermountain has now asked Ms. Saxton to
stipulate to a sixty-day extension of time to file its principal brief, as allowed under Utah
Rule of Appellate Procedure 22(b). Ms. Saxton has refused. There is good cause for an
extension, so the Court should grant this Motion.
I. There is good cause for the Court to grant Intermountain an extension.
Good cause exists for a sixty-day extension because Ms. Saxton’s brief is an
overlength, eighty-four-page memorandum briefing seven issues with a 169-page
addendum. Good cause also exists because Ms. Saxton used artificial intelligence to draft
the brief. In her brief, Ms. Saxton cites forty-one cases, twenty-seven statutes, twenty3
eight court rules, and five federal regulations, as well as constitutional provisions and
model jury instructions. Ms. Saxton admits to using artificial intelligence extensively to
prepare her brief, and Intermountain must check every citation for accuracy with
particular attentiveness as a result. Addressing the arguments in Ms. Saxton’s brief is,
therefore, challenging and requires more time than normal, and Intermountain’s counsel
maintains a full caseload of matters besides this appeal.
Furthermore, good cause also exists because this Court has authorized
Intermountain to file a brief that is 4,000 words longer than allowed by the standard
briefing limit. Drafting a response to the seven issues Ms. Saxton has appealed is timeconsuming, and an extension of time is necessary to allow adequate time for
Intermountain and its counsel to collaborate on and revise its lengthy brief.
II. Intermountain has not previously received an extension.
This is the first time Intermountain has requested an extension to file its principal
brief.
III. A sixty-day extension will make Intermountain’s principal brief due
August 7, 2026.
Intermountain’s principal brief is currently due June 8, 2026. If the Court grants
Intermountain’s requested sixty-day extension, the new deadline will be August 7, 2026.
IV. Ms. Saxton does not agree with the requested extension.
Intermountain asked Ms. Saxton to agree to a sixty-day extension as permitted
under Utah Rule of Appellate Procedure 22(b). Ms. Saxton refused.
4
Conclusion
There is good cause for Intermountain to receive its requested sixty-day extension.
Intermountain wanted to stipulate to this extension with Ms. Saxton, and her refusal to
stipulate should not prevent Intermountain from receiving the extension. Intermountain
asks the Court to order that its time to file its principal brief is extended by sixty days to
August 7, 2026.
DATED this 1st day of June 2026.
NELSON NAEGLE, PLLC
/s/ Cortney Kochevar
CORTNEY KOCHEVAR
SEAN C. MILLER
LANCE E. BASTIAN
Attorneys for Appellees Intermountain
Neurosciences Institute; Jon Pertab, PhD;
Cara Camiolo Reddy, MD; Melissa
Minton; and Jodi Allen
And here is my objection with attachments:
I. Introduction
Appellant Erica V. Saxton, pro se, submits this Opposition to Appellees' Motion for Extension of Time to File Principal Brief, filed June 1, 2026. On May 21, 2026, Intermountain's counsel asked Appellant to stipulate to a sixty-day extension. On May 26, 2026, counsel articulated the grounds for that request: the complexity of the appeal, the length of the briefing, the iterative drafting and client-review process Intermountain anticipated undertaking, and a preference for one longer extension over sequential shorter ones. Appellant declined on May 28, 2026. Intermountain then filed the present motion on June 1, 2026.
The filed motion materially departs from the grounds articulated in counsel's May 26 email. Appellant references the email correspondence only to explain why she declined to stipulate and to compare the reasons Intermountain gave before filing with the grounds asserted in its motion. The motion does not lead with complexity or length. It instead advances a new ground — that Appellant's use of artificial intelligence to prepare her brief requires Intermountain to "check every citation for accuracy with particular attentiveness." Motion at 3. That characterization was not offered to Appellant when she was asked to stipulate, and it does not appear in counsel's prior correspondence. The discrepancy between the grounds Intermountain offered to Appellant and the grounds it has presented to this Court is itself relevant to whether good cause has been shown.
Stipulation is a form of affirmative agreement. Appellant cannot give that agreement in the posture of this case. The underlying claim concerns medical harm that adversarial-defense conduct caused or compounded, in a statutory and ethical context in which Utah law specifically protects healthcare providers and entities who choose candid disclosure and resolution-oriented engagement with their patients. See Utah Code §§ 78B-3-450 to -454 (Medical Candor Act); id. § 78B-3-406(8) (apology protection); Utah R. Evid. 408, 409. Throughout these proceedings, Intermountain has not initiated, proposed, or accepted any settlement, mediation, or resolution-oriented engagement, and its present motion identifies no such purpose for the additional sixty days sought. The extension is requested for continued adversarial briefing. In that posture, Appellant cannot affirmatively agree to extend the very form of conduct that the underlying claim arises from; she can only ask the Court to evaluate the request on the record and impose any safeguards necessary to prevent further one-sided prejudice.
For the reasons set out below, Appellant respectfully submits that Intermountain's motion fails on that record. The AI-citation ground is not a showing of good cause: citation verification is standard professional practice regardless of drafting method, and Intermountain has access to research and verification tools that substantially exceed those available to Appellant, who personally verified every citation in the Opening Brief using publicly available resources. The complexity ground cannot be reconciled with this Court's own repeated characterization of this appeal as "relatively narrow" across four orders dating from October 2025 through May 2026. The caseload and iterative-process grounds reflect scheduling preferences, not circumstances Intermountain could not have anticipated when the briefing schedule was set. And the request is irreconcilable with Intermountain's own July 2025 position, in which it urged this Court to require Appellant to proceed "without additional delay," invoked the "extraordinary circumstances" warning this Court had applied to Appellant, and offered her productivity as evidence that no further time was warranted. Intermountain now seeks sixty days — twice the standard period — on grounds that do not approach the threshold it urged this Court to apply to her.
In the event the Court grants any extension notwithstanding Appellant’s objection, Appellant respectfully requests that the extension be conditioned on the reciprocal safeguards set forth in Section II and that the Court consider the prejudice described in Section IV.D. Those safeguards are necessary to preserve the parties’ relative position consistent with 28 C.F.R. § 35.160(a)(1) and the reciprocity principle this Court invoked under Utah R. App. P. 24(h).
II. Relief Requested
Appellant respectfully requests that the Court:
1. Deny Intermountain’s motion. On the record before this Court, an extension longer than seven additional days would compound the harms preserved in Appellant’s Opening Brief, the May 22, 2026 Motion for Accommodation, and the procedural asymmetries identified below. A seven-day limit also preserves the briefing schedule around Appellant’s pre-existing September 2026 commitments described in Section IV.C.
2. In the event the Court grants any extension, Appellant requests the following conditions:
(a) Order that Appellant’s sixty-day reply-brief period—already established by this Court’s May 26, 2026 Order—run from service of Intermountain’s brief and be extended automatically, day-for-day, by the length of any extension Intermountain receives, without requiring further motion or good-cause showing from Appellant.
(b) Order that, to the extent Intermountain’s brief exceeds 14,000 words, Appellant’s reply-brief word limit be increased automatically, without further motion, by a number of words bearing a reasonable relationship to Intermountain’s enlargement. In the alternative, Appellant requests a one-for-one increase mirroring the reciprocity principle in Rule 24(h).
(c) Order that any further extension request by Intermountain shall require a renewed showing of good cause specific to circumstances arising after the date of this order.
The relief in paragraph 2(b) is consistent with this Court’s May 26, 2026 disposition deferring the proportionate-words question. Its quantum is contingent on what Intermountain actually uses and calibrated to what Appellant has already shown in prior motions.
III. PROCEDURAL AND FACTUAL BACKGROUND
A. This Court has consistently characterized this appeal as relatively narrow.
On October 8, 2025, this Court denied Appellant’s motion for an enlarged opening-brief word count, observing that “the relevant procedural and legal posture of the underlying case appears to be relatively narrow” and that the dispositive rulings below—motion to dismiss and summary judgment—are reviewed for legal correctness rather than on fact-intensive grounds. Order at 1–2 (Oct. 8, 2025). The Court allowed 3,000 additional words and directed Appellant to focus her issues. Subsequent orders on October 20, 2025, November 28, 2025, and May 26, 2026 maintained that framing, capping Appellant’s brief at 17,000 words and describing the reply scope as “narrow.”
B. Intermountain has had advance exposure to this appeal’s substance since October 2025.
Appellant served a proposed overlength brief on Intermountain in October 2025. Intermountain has therefore had approximately seven months of advance exposure to the appeal’s substantive issues, arguments, and cited authority prior to the Opening Brief’s filing on May 8, 2026. Additionally, much of the case law, statutory authority, and court rules cited in the Opening Brief was also cited in the underlying case proceedings, to which Intermountain’s counsel was a party.
C. This Court has expressly characterized time as Appellant’s accommodation.
In its February 7, 2025 Order, this Court stated: “This court has granted accommodations related to the time for filing of Saxton’s brief, which is intended to provide Saxton with the time needed to process information and draft written materials for the court. That accommodation is reasonable and appropriate.” Order at 2–3 (Feb. 7, 2025). The Order denied all further accommodation requests and stated: “Any further requests for additional accommodations will be returned to Saxton without further consideration by this court.” Id. at 3. Consistent with that framing, the Court’s May 26, 2026 Order denied Appellant’s requests for an auxiliary communication aid, an established expanded reply word count, a stay, and reimbursement of self-funded accommodation costs, while granting double the standard reply time.
Intermountain’s motion describes these time-based extensions as “repeated and generous extensions and other accommodations,” Motion at 2, without identifying what “other accommodations” the Court has provided. The record does not support that characterization. Time is, on this Court’s own repeated characterization, the sole accommodation it has afforded Appellant in this appeal.
Intermountain’s reference to the number of days between the original briefing notice and Appellant’s filing date omits the procedural reason that time accumulated. Much of that period was consumed by Appellant’s efforts to obtain disability-related access, including proceedings and motions addressing effective communication, accommodation, and the Rule 19 process. The accumulated time therefore does not show that Appellant received multiple effective accommodations. It reflects, in substantial part, this Court’s reliance on extensions of time as the primary accommodation mechanism in place of the auxiliary aids and accommodation structure Appellant repeatedly requested, while Appellant consistently objected that time alone was not an effective substitute and would itself create substantial prejudice, including as explained in the May 22, 2026 Motion for Accommodation docketed May 26, 2026.
D. Intermountain’s prior litigation position is in direct tension with the present request.
On July 28, 2025, Intermountain opposed any further pause in this appeal, “respectfully request[ing] that the Court set a briefing schedule that will move this appeal toward prompt resolution” and asking the Court to require Appellant to file “without additional delay.” Response at 2 (July 28, 2025). To support that request, Intermountain invoked this Court’s “extraordinary circumstances” warning against Appellant and offered, as evidence that she did not need additional time, the example of her sixty-four-page, approximately 16,000-word reply memorandum she had drafted in approximately thirty-seven days. Id. at 3 n.2.
Intermountain now seeks sixty days—nearly double the time it held up as evidence Appellant did not need—on grounds that include the complexity of the same appeal this Court has characterized as relatively narrow, and an iterative drafting-and-review process to which Intermountain’s own productivity-by-word-count yardstick allowed no equivalent. The contradiction between its July 2025 position and the present request is on the face of the record.
E. The grounds in the filed motion differ from the grounds offered to Appellant.
In counsel’s May 26, 2026 email, Intermountain articulated two grounds: (1) the complexity of the appeal, and (2) the length of the briefing, supported by reference to the iterative drafting and client-review process and a stated preference for one longer extension over successive shorter ones. Counsel noted that Intermountain “may file its brief sooner than the end of the sixty-day extension, but the longer extension allows for flexibility.”
The filed motion de-emphasizes complexity and substitutes a ground not raised in that email: that Appellant’s use of artificial intelligence requires citation verification “with particular attentiveness.” Motion at 3. The inconsistency between grounds offered to Appellant when stipulation was sought and grounds now presented to this Court is relevant to whether the motion reflects operational need or post-hoc justification.
IV. Argument
A. The sixty-day request is disproportionate and lacks individualized justification.
The standard response-brief period is thirty days. Utah R. App. P. 26(a). A sixty-day request is twice that standard, sought by an institutional party represented by no fewer than four attorneys with paralegal and legal-assistant support of no less than five (See Exhibit A). Extensions beyond stipulation are disfavored, and an extension of this magnitude requires individualized justification rather than general reference to caseload, length, or internal process. Intermountain has had the substance of the appeal available since October 2025, when they were served the first proposed over-length brief, and has not identified intervening circumstances that were not reasonably foreseeable when the briefing schedule was set. Intermountain’s reference to its counsel’s “full caseload of matters besides this appeal,” Motion at 3, does not supply that justification: caseload management is within counsel’s control, and the briefing deadline was set and known in advance.
B. Appellant’s use of AI-assisted drafting is not good cause for the requested extension.
Intermountain’s lead ground in its filed motion—that Appellant used artificial intelligence to prepare her brief and that this requires “particular attentiveness” in citation verification—does not constitute good cause. Three points bear directly on that claim.
1. Citation verification is standard professional practice regardless of drafting method. Intermountain would be obligated to verify every citation in Appellant’s brief whether it were drafted with AI assistance, a word processor, or longhand. The AI-use ground does not explain why this routine professional obligation requires sixty additional days beyond what any overlength brief would ordinarily require.
2. Intermountain’s verification resources substantially exceed Appellant’s. Counsel at Nelson Naegle, PLLC has Westlaw, law library access, attorney-specific AI research tools not available to the public, and professional research staff—resources designed specifically for legal citation work and more accurate and efficient than the general-purpose tools available to pro se litigants. Appellant verified every case, statute, court rule, federal regulation, and model jury instruction cited in the Opening Brief using publicly available resources—Google Scholar and the Utah Courts website Utah Appellate Court Opinions Search tool—without professional staff or any subscription service. Once Appellant identified workable public citation-checking resources, she completed that verification process in approximately one to two days. Appellant provides this information to answer Intermountain’s claimed AI/citation concern and to show that the concern can be addressed without a sixty-day extension. The suggestion that Intermountain requires sixty additional days for the same task, with institutional Westlaw access and a multi-attorney firm, is not a showing of need; it is a preference for additional time.
3. Intermountain had advance notice of both the citation volume and the cited authority. Appellant served a proposed overlength brief in October 2025. Much of the authority cited in the Opening Brief was also cited in the underlying case, in proceedings to which Intermountain’s counsel was a party with full opportunity to research and respond. There are no material surprises in the citation content or volume.
Appellant is prepared, if the Court requests it, to file a declaration/affidavit in the courts preferred format stating that she personally verified the cases, statutes, rules, federal regulations, and model jury instructions cited in the Opening Brief as accurate as of the date of filing. That statement is offered not because such a declaration is required, but because Intermountain’s generalized citation-accuracy concern can be addressed directly without imposing a sixty-day delay on Appellant.
C. The complexity ground cannot be reconciled with this Court’s own characterization of this appeal.
Intermountain’s complexity ground concerns the same appeal this Court has declined to treat as sufficiently complex to justify Appellant’s requested briefing enlargement or requested accommodation structure across multiple orders. The Court’s October 8, 2025 Order expressly described the posture as “relatively narrow,” characterized the dispositive rulings as legal issues reviewed for correctness, and denied the enlarged word allowance Appellant sought. Its May 26, 2026 Order described the reply scope as “narrow” and denied additional reply words as premature on the same view.
Intermountain’s description of how it would use the requested time—the iterative drafting, client-review, and revision process—describes the very iterative, resource-intensive process Appellant has identified as a function of the auxiliary aid she requested and that this Court denied her. Intermountain seeks, as routine scheduling, the iterative process Appellant must undertake without the auxiliary aid she was denied. Appellant asks only that the extension request be evaluated against the Court’s own prior characterizations of this appeal.
D. An extended timeline compounds documented harm to Appellant.
The cost of an extended timeline in this case is not abstract. A sixty-day extension would push Intermountain’s brief to approximately August 7, 2026, again moving Appellant’s briefing preparation directly into the season on which her income depends. Appellant has already incurred substantial expenses and lost work capacity while briefing under a structure in which extensions of time have been treated as the only accommodation provided. The May 22, 2026 Motion for Accommodation documents at least $536.72 in self-funded accommodation costs and over $3,000 in medical expenses attributable to participating in this appeal without effective accommodation.
Among Appellant’s documented disabilities are cognitive limitations affecting the processing of new information under time pressure and articulating concisely. An extension that gives Intermountain additional time to develop arguments Appellant will encounter for the first time on the response brief compresses the period in which Appellant must—without the auxiliary aid she requested and was denied—process those new arguments and compress them effectively. Increased preparation time for the represented institutional party operates in practical effect as compressed processing time for this disabled pro se appellant.
In addition, Appellant has, in reliance on the current briefing schedule, made commitments during September 2026 that cannot be rescheduled, including no fewer than three multi-day family obligations requiring travel planned precisely because the existing schedule made September available. A sixty-day extension would displace those commitments, requiring Appellant to choose between honoring pre-existing family obligations and meeting a reply-brief deadline she would be required to address without the auxiliary aid she requested for processing, organizing, and regulating disability-affected communication under stress.
E. The “extraordinary circumstances” standard the Court applied to Appellant has not been met by Intermountain
This Court stated in its November 18, 2024 Order: “Any further request for an extension of time will not be granted absent a showing of extraordinary circumstances.” Order at 1 (Nov. 18, 2024). The Court reiterated that standard in its September 2, 2025 Order. Intermountain itself invoked the “extraordinary circumstances” warning against Appellant in its July 28, 2025 Response, quoting that language verbatim to oppose Appellant’s request for additional time.
Intermountain’s request asks the Court to apply two different standards to the same procedural resource. When Appellant sought additional time, the Court applied a heightened threshold—which Intermountain invoked against her. When Intermountain now seeks the same resource, it has claimed no disability, identified no extraordinary circumstance, and—by its own counsel’s statement that it “may file its brief sooner than the end of the sixty-day extension” because “the longer extension allows for flexibility”—has framed its request as a preference for scheduling convenience rather than a demonstration of need. A request for additional time framed by the requesting party itself as supporting “flexibility” does not satisfy the standard the Court applied to Appellant and that Intermountain itself urged this Court to enforce.
F. Extending Intermountain’s time, without reciprocal safeguards, deepens a documented procedural asymmetry.
Intermountain’s motion illustrates prejudices Appellant has repeatedly identified from using time alone as the substitute for effective communication accommodations. The accumulated time was provided because the Court treated time as Appellant’s accommodation; Intermountain now characterizes that same time as delay and “repeated and generous extensions.” That framing shows why time alone is not an effective substitute for the auxiliary aids and accommodation structure Appellant requested: it fails to provide efficient communication support while creating a procedural record later used against the disabled litigant. And it defeats, rather than supports, Intermountain’s request for additional time: if the accumulated timeline is relevant, then Intermountain has had prolonged notice of the appeal’s issues and cannot treat those same issues as newly burdensome now.
This Court has characterized time as Appellant’s disability accommodation throughout this appeal. The same November 18, 2024 Order that established the “extraordinary circumstances” standard also characterized prior extensions as “scheduling accommodations . . . in deference to Appellant’s need for extra time in light of her disability.” Order at 1 (Nov. 18, 2024). Time and the heightened threshold for additional time were thus joined in a single order: the same procedural resource is simultaneously Appellant’s disability accommodation and subject to a heightened standard before further enlargement.
Utah R. App. P. 24(h) provides that when an overlength brief is authorized, the opposing party receives an equal number of additional words “without further order of the court.” On this record, that automatic reciprocity has operated in only one direction: Intermountain received its 4,000-word enlargement automatically, without motion practice. Appellant was required to make a good-cause showing across multiple orders, ultimately obtaining an enlargement substantially below what she requested. Intermountain now invokes its automatic enlargement as a basis for additional time, while Appellant—if any extension is granted—will again be required to motion for corresponding reply-brief adjustments.
Title II requires that communications with persons with disabilities be “as effective as” communications with others. 28 C.F.R. § 35.160(a)(1). Where the represented institutional party receives automatic scheduling relief and the disabled litigant must motion repeatedly for proportionate adjustments, an extension order that compounds that pattern is not consistent with Section 35.160(a)(1). The reciprocal conditions requested in Section II.2 are calibrated to that framework: they ask the Court to make operative, by order, the reciprocity its prior orders already contemplate, so that Appellant is not required to repeat burdensome motion practice merely to preserve proportionate time and space.
G. Utah’s voluntary medical-candor framework was available to Intermountain and was not invoked.
Utah Code §§ 78B-3-450 to -454 (Medical Candor Act) creates a provider-initiated process for candid disclosure of adverse events, with protections under Utah Rule of Evidence 409 ensuring such communications and offers of compensation are inadmissible to prove liability. Utah Code § 78B-3-406(8) separately protects expressions of apology or sympathy; Utah Rule of Evidence 408 protects compromise negotiations. These protections were and remain available to Intermountain. It has not invoked them. It now seeks substantial additional time for continued adversarial briefing, without any indication the time would be used for the resolution purposes Utah law specifically encourages and protects.
V. CONCLUSION
For the foregoing reasons, Appellant respectfully requests that the Court deny Intermountain’s motion or, in the alternative, grant an extension no longer than seven additional days. In either event, Appellant requests that the Court order the reciprocal time and word adjustments set forth in Section II.2(a) and (b), so that any extension preserves the parties’ relative position consistent with 28 C.F.R. § 35.160(a)(1). Appellant reiterates that she cannot affirmatively agree, by stipulation, to an extended adversarial-defense posture in a proceeding whose underlying claim concerns harm that adversarial-defense conduct caused or compounded. That objection is not abstract: continued delay prolongs the period in which the challenged institutional posture and its practical consequences remain unresolved. Appellant asks only that the Court evaluate the request on the record and, if any extension is granted, impose reciprocal safeguards adequate to prevent further one-sided prejudice.
DATED this 1st day of June, 2026.
Respectfully submitted,
/s/ Erica V. Saxton
Erica V. Saxton
EXHIBIT A: Stipulation Request Email
Erica Saxton <eristravels@gmail.com> Requestion for Extension of Time to File Principal Brief | Saxton v. Intermountain
Erica Saxton <eristravels@gmail.com> 27 May 2026 at 14:13 To: Landon Moore <lmoore@nelsonnaegle.com>
Cc: Cortney Kochevar <ckochevar@nelsonnaegle.com>, Sean Miller <smiller@nelsonnaegle.com>, Lance Bastian <lbastian@nelsonnaegle.com>, Ellen Harmon <eharmon@nelsonnaegle.com>, Baylei Crump
<BCrump@nelsonnaegle.com>, Tracy Lewis <tlewis@nelsonnaegle.com>, Sam Hunter <shunter@nelsonnaegle.com>, Devon Martin <dmartin@nelsonnaegle.com>
Mr. Moore,
I have considered your response. I am declining to stipulate. The complexity-based good-cause showing you have articulated intersects with prior characterizations in this appeal — including this Court's prior treatment of complexity in connection with my own briefing requests — in ways that warrant evaluation on the record rather than resolution through stipulation. The request also intersects with my pending motion for accommodation filed May 22, 2026, including specific relief requested therein concerning the timing of the reply brief.
If Intermountain elects to seek the extension by motion, I will respond on the merits. Absent such a motion, my position is that any extension is appropriately determined by the Court.
Regards,
Erica Saxton
801-726-3182
On Tue, 26 May 2026 at 13:42, Landon Moore <lmoore@nelsonnaegle.com> wrote:
Ms. Saxton,
Thank you for getting back to me. Intermountain is requesting extra time due to the complexity of the appeal and the length of the briefing. As you know, briefing seven issues for appeal is time consuming. The standard period of 30 days is based upon the assumption that the appellant's and appellee's briefs are the standard length (30 pages/14,000 words). The Court gave both of us permission to file an overlength brief, so extra time is needed to draft our overlength brief responding to your overlength brief. Intermountain did consider a shorter extension but decided to request the full sixty days so that we won't have to request another extension later. Intermountain reviews the documents we draft for them. When documents are this lengthy, it takes time for my office to draft the document, for Intermountain to review it and recommend changes, for my office to make those changes, and for Intermountain to review the document again, etc. Intermountain may file its brief sooner than the end of the sixty-day extension, but the longer extension allows for flexibility as my office communicates back and forth with Intermountain.
I hope this message provides the clarification you were seeking. Please let me know if I may send the stipulation for your review.
Landon Moore
Attorney
Nelson | Naegle
215 South State Street, Suite 1200
Salt Lake City, Utah 84111
(385) 292-4400
www.nelsonnaegle.com
6/1/26, 10:16 PM Gmail - Requestion for Extension of Time to File Principal Brief | Saxton v. Intermountain From: Erica Saxton <eristravels@gmail.com>
Sent: Tuesday, May 26, 2026 11:06 AM
To: Landon Moore <lmoore@nelsonnaegle.com>
Cc: Cortney Kochevar <ckochevar@nelsonnaegle.com>; Sean Miller <smiller@nelsonnaegle.com>; Lance Bastian <lbastian@nelsonnaegle.com>; Ellen Harmon <eharmon@nelsonnaegle.com>; Baylei Crump <BCrump@nelsonnaegle.com>; Tracy Lewis <tlewis@nelsonnaegle.com>
Subject: Re: Requestion for Extension of Time to File Principal Brief | Saxton v. Intermountain You don't often get email from eristravels@gmail.com. Learn why this is important
Mr. Moore
Regarding your May 21 message about a possible stipulated extension, I need clarification on the following before I can evaluate the request:
1. The specific reasons Intermountain considers to warrant a sixty-day extension beyond the standard response period, with the specificity URAP 22(b)(3) would require if the request were made by motion.
2. Whether Intermountain has considered any extension period shorter than sixty days.
I am evaluating any stipulation against the cumulative procedural posture of this appeal and the conditions necessary for my own reply-brief preparation. The information above will allow me to consider your request on its merits.
Regards,
Erica Saxton
On Thu, 21 May 2026 at 21:31, Erica Saxton <eristravels@gmail.com> wrote:
Mr. Moore,
Acknowledging receipt of your email. I am unavailable through the holiday weekend and will respond next week. Regards,
Erica Saxton
On Thu, 21 May 2026 at 16:43, Landon Moore <lmoore@nelsonnaegle.com> wrote:
Hi Erica,
I am an attorney at Nelson Naegle assisting with drafting Intermountain's principal brief in the appeal you have brought before the Utah Court of Appeals. I am emailing you to ask about an extension of time for Intermountain to file its brief. Under Utah Rule of Appellate Procedure 22, we can stipulate to an extension of up to 60 days for Intermountain to file its brief. Currently, Intermountain's brief is due June 8, 2026. A sixty-day extension will make the brief due August 7, 2026. Are you willing to agree to this extension? If so, I will send you the stipulation for your review and approval.
Thank you.
Landon Moore
Attorney
Nelson | Naegle
215 South State Street, Suite 1200
Salt Lake City, Utah 84111
(385) 292-4400
www.nelsonnaegle.com
CAUTION: External Sender.
And the court order:
While that might seem like no big deal- please notice, that:
1. Intermountain's proclaimed "good cause" claim was my disclosed use of AI requiring extra scrutiny due to the unreliability of the tools and having to check all my sources -which they have to do anyway. Their scrutiny contradicts the courts' (or rather, the Administrative Office of the Courts, AOC) prior reason for denying this as an accommodation tool because it could "provide a litigation advantage." Furthermore, Intermountain has access to these same tools and greater AI tools that are only available to licensed attorneys. As I explained in my opposition, verifying authority and laws cited is part of the process it always has been; the use of AI tools does not change that need nor does my use of those tools change the fact that they have greater access to the tools to check those AND even general public access to the laws and case laws is so accessible and easy to use that it does not take any special AI tools or paid services AND checking is fast and easy to do. The length doesn't change how simple that is either, especially when they have a whole team at their disposal.
2. They also add: "and Intermountain’s counsel maintains a full caseload of matters besides this appeal." to their "good cause" but remember URAP Rule 22(a)(3)(D) literally says: "Generalities, such as ... 'counsel is engaged in other litigation,' are insufficient."
3. Their other logic relies on the "generous" amounts of time the courts have granted me; aka the only accommodation and modification the courts would provide and that I had repeatedly objected to as prejudicial when granted in isolation- Intermountain's reliance on this thereby proving the prejudicial effects and uses of it.
The flaws and weaknesses of their arguments are pretty obvious- but still, without even engaging with my concerns and requests, the Utah Court of Appeals granted the full 60 days so Intermountain's attorneys could rack of maximum hours against the medical malpractice premiums that we all are paying for.
...But still there are flaws with my conspiracy theory/fear, right? There has to be... so I motioned for clarification and to ensure accommodations were truly accommodations and not added burdens (early, the way you are supposed to as a reasonable and responsible ADA-qualifying individual). Here is that exact Motion:
Appellant Erica V. Saxton, pro se, respectfully moves under Utah R. App. P. 23 for clarification of this Court’s June 3, 2026 Order granting Appellees’ extension of time to file their principal brief, and for clarification of the related reply-brief scheduling and effective-communication procedures identified below. Because this motion seeks clarification of effective-communication procedure, ADA-related safeguards, the treatment of disclosed accommodation tools, and the effect of those issues on merits briefing, Appellant respectfully requests that the motion be submitted to the Court rather than disposed of as a routine procedural scheduling matter.
This motion is not submitted to reargue whether Appellees should have received the extension. Clarification is needed because the June 3 Order materially changed the time baseline on which the May 26 accommodation ruling rested and did not address the reciprocal safeguards Appellant requested if Appellees received additional time. The June 3 Order did not address Appellant’s requested reciprocal time protection, proportionate reply-word protection, September scheduling concerns, effective-communication concerns, or the Order’s reference to a “first (1st), and second (2nd) extension of time.”
The May 26 Order established sixty days as the operative time-based accommodation for Appellant’s reply phase, after denying the requested auxiliary communication aid and denying additional reply words without prejudice. Once the June 3 Order granted Appellees a sixty-day extension, Appellees’ principal-brief preparation period became ninety days. Appellant’s sixty-day reply period therefore no longer functions as a double-time accommodation measured against the opposing party’s actual briefing period; it is now less time than Appellees received, even though Appellant is the party with documented disability-related processing and communication limitations, no legal team, no provided auxiliary communication aid or services, and only self-funded communication support obtained outside the Court’s accommodation framework. Appellant seeks clarification because the extension granted to Appellees destabilizes the only accommodation this Court has recognized for the reply phase unless reciprocal time protection is confirmed now.
Clarification is also needed because Appellant’s Opposition raised Rule 22 issues that the June 3 Order did not address. Rule 22 requires facts supporting good cause to be stated with specificity and provides that generalities, including counsel’s engagement in other litigation, are insufficient. Rule 22 also states that “[a] motion for an extension of time for filing a brief beyond the time permitted by stipulation of the parties is not favored.” Appellees’ motion relied on generalized assertions regarding counsel’s full caseload, internal review cycles, citation-checking, and the additional length authorized for the principal briefs. Appellant does not restate this point to reargue the extension. She raises it to identify the legal basis for the clarification requested: where the full extension was granted without stated good-cause analysis and without addressing Appellant’s requested reciprocal safeguards, Appellant cannot determine whether the Court intended to deny those safeguards, defer them, leave them unresolved, or whether the absence of engagement reflects an effective-communication problem requiring modification and accommodation adjustments before the reply period begins. See 28 C.F.R. §§ 35.160(a)(1), (b)(1)–(2); 35.130(b)(7)(i).
Appellant moves for clarification now so she can plan her work, family, disability-management, communication-support needs, and briefing schedule without having to seek emergency clarification or additional accommodation during the reply window itself, and without uncertainty about whether her disclosed use of AI tools to support communication will be treated as a basis for adverse procedural consequences.
I. Clarification Requested Regarding Reply Time
This Court’s May 26, 2026 Order established Appellant’s reply period as sixty days from service of Appellees’ principal brief. Appellant’s June 1, 2026 Opposition requested that, if Appellees received an extension, Appellant’s reply period be extended automatically, day-for-day, by the length of any extension granted to Appellees. The June 3 Order granted Appellees a sixty-day extension but did not address Appellant’s request. Appellant respectfully requests that the Court clarify whether her reply period is:
180 days from service of Appellees' principal brief — double newly established reply time and Appellees’ ninety-day total preparation period, consistent with this Court's established double-time disability accommodation standard; or
120 days from service of Appellees’ principal brief, reflecting the sixty-day reply period already ordered plus a sixty-day day-for-day reciprocal extension; or
some other period the Court intends to apply; or
subject to a separate motion Appellant must file after Appellees serve their brief.
Appellant moves for clarification now because requiring a separate motion during the reply period would impose an additional one-sided procedural and accommodation burden during the period in which Appellant’s cognitive resources must be reserved for processing and responding to Appellees’ principal brief, while compounding the scheduling and accommodation burdens already described in her June 1, 2026 Opposition.
Appellant preserves her standing objection that time alone is not an adequate substitute for effective communication accommodations. This motion does not concede that additional time, by itself, satisfies Title II. It asks only that, because this Court has treated time as the operative accommodation while denying the requested auxiliary communication aid, the time-based framework be clarified and applied consistently. Appellant further requests clarification because Appellees relied on Appellant’s disclosed use of self-funded communication support as part of their asserted good cause for additional time, while Appellant remains uncertain whether that same disclosed support may be treated as a basis for adverse procedural consequences. Appellant asks that she not be left with less preparation time than the represented institutional party opposing her, unresolved uncertainty about whether her disclosed use of AI-assisted communication support may be used to discount or adversely affect her filings, or the burden of spending the reply period filing additional motions to clarify the same accommodation-related issues after reply time has begun to run.
II. Clarification Requested Regarding September 2026 Scheduling
Appellant’s June 1, 2026 Opposition explained that she has pre-existing September 2026 work, family, and travel commitments made in reliance on the prior briefing schedule. Appellant respectfully requests clarification whether the Court will structure the reply period so that Appellant is not required to undertake active reply-brief preparation during September 2026. Those pre-existing commitments will already require Appellant to manage limited cognitive stamina, recovery time, and disability-related functional capacity; adding active reply-brief preparation during that same period would predictably compound the access and health burdens identified in Appellant’s Opposition.
If Appellees file on August 7, 2026 and Appellant receives 180 days from service, the reply deadline would fall well after September. If Appellees file earlier or if the Court applies a shorter reply period, the reply window may run through or end in September. That would require Appellant to divide limited cognitive, emotional, and recovery capacity between reply-brief preparation and pre-existing work, family, and travel obligations that others have relied on and that Appellant scheduled around the prior briefing structure. Appellant therefore requests clarification whether the reply period may be tolled during September 2026, or whether the reply period may begin October 1, 2026 if Appellees serve their brief on a date that would otherwise cause Appellant’s reply period to run through September.
III. Clarification Requested Regarding Reply-Word Count
This Court’s May 26, 2026 Order deferred Appellant’s request for a proportionate reply-word enlargement. Appellees received an automatic 4,000-word enlargement under Utah R. App. P. 24(h), and their extension motion relied in part on the burden of preparing an enlarged principal brief.
Appellant respectfully requests clarification whether she is automatically granted 2,000 additional reply-brief words, for a total of 9,000 words, as the proportionate reciprocal of Appellees’ 4,000-word enlargement. Appellees have represented that the enlarged brief, its length, and the complexity of responding to Appellant’s Opening Brief justified additional preparation time. That representation makes the need for proportional reply-word clarification foreseeable now, before Appellant’s reply period begins.
In the alternative, Appellant requests clarification whether she must file a separate motion for that proportional word adjustment after Appellees file their brief, and whether additional time or accommodation will be provided for preparing that motion if the Court requires it during the reply period.
Appellant does not request, through this clarification request, permission to exceed 9,000 words without a further showing. She requests only that the proportionate reciprocal word allowance be clarified now so she can plan her reply brief without expending reply-window time and cognitive resources on additional motion practice, uncertain word limits, and avoidable compression burdens that have already been shown to exacerbate disability-related limitations in prejudicial ways.
IV. Clarification Requested Regarding Effective Communication Procedure and AI-Assisted Communication Tools
Appellant requests clarification regarding the procedure now available for addressing effective-communication concerns. The June 3 Order granted Appellees the full extension without addressing Appellant’s objection to Appellees’ use of her disclosed accommodation tool as part of their asserted good cause, and without addressing the reciprocal safeguards Appellant requested. Appellant therefore requests clarification on the following questions:
Whether the Court understood Appellant’s June 1, 2026 Opposition as requesting reciprocal time protection, proportionate reply-word protection, September scheduling protection, and protection from adverse use of Appellant’s disclosed accommodation tool and prior grants of time as an accommodation;
If the Court understood those requests, whether the June 3 Order intended to deny them, defer them, or leave them unresolved;
If the Court did not understand those requests as Appellant intended them, what procedure Appellant should use to correct or supplement the ineffective communication in a timely manner, so that unresolved communication barriers do not affect the reply period or any other appellate deadline, filing, or procedural obligation;
Whether Appellant’s self-funded use of AI-assisted communication support may be treated as a basis for adverse procedural consequences, diminished engagement with her Opening Brief, reply brief, merits briefing, or other filings, relief to Appellees, or avoidance of merits engagement with Appellant’s arguments, citations, and requests;
Whether Appellant’s Opening Brief, reply brief, and other filings prepared with self-funded AI-assisted communication support will be evaluated on their merits and not discounted because Appellant used those tools as disability-related communication support; and
If the Court considers Appellant’s self-funded communication support ineffective, unreliable, procedurally problematic, or a basis for discounting any portion of Appellant’s Opening Brief or other filings, what process Appellant may use to correct, supplement, or remedy the affected communication without adverse procedural consequences and without unnecessary disclosure of disability-related accommodation information to Appellees.
Appellant has not found, and does not understand, any Utah law or Utah Rule of Appellate Procedure to make disclosed use of AI-assisted communication support, by itself, a basis to dismiss, discount, or decline to engage with a filing. Utah authority addressing AI misuse has focused on fabricated authority, inaccurate citations, and failure to verify legal sources, while recognizing that AI may be used as an assistance tool. See Garner v. Kadince, 2025 UT App 80, ¶¶ 6–12. The relevant concern appears to be accuracy, candor, and reasonable verification—not the mere use of a tool. Appellant has disclosed her use candidly, has represented that she used AI-assisted support as disability-related communication assistance, and reaffirms that she stands behind her Opening Brief, arguments, citations, and requests. Appellant independently collected and verified her citations to authority, including through publicly available court and Utah government resources. If Appellant’s understanding of Utah authority is incorrect, or if the Court has any concern that Appellant’s disclosed use of AI-assisted communication support affects the reviewability, credibility, or adequacy of her Opening Brief, Appellant requests notice of the concern and a process to correct, supplement, or clarify before any adverse procedural consequence, sanction, or merits-affecting consequence is imposed on that basis.
Appellant also requests clarification whether the Court expects effective-communication issues to be pursued through another motion in this appeal, through the AOC/Rule 3-417 process, or through some other procedure. If the Court’s position is that Appellant must return to the AOC/Rule 3-417 process, Appellant respectfully requests clarification regarding how that process can provide timely and effective relief before unresolved communication barriers affect the reply period or any other appellate deadline, filing, or procedural obligation, and how Appellant may pursue that process without further disclosure of disability-related accommodation information to Appellees absent necessity and appropriate safeguards.
Appellant does not waive her preserved position that the AOC/Rule 3-417 process has proved ineffective and futile on this record. She requests clarification only because the reply brief cannot be prepared effectively while the responsible procedure for obtaining effective communication remains unresolved, and while it remains unclear whether self-provided, self-funded communication support may be used as an accommodation without being discounted, characterized as improper, used as a basis for adverse procedural consequences, or treated as a reason to avoid engagement with the merits of Appellant’s filings.
Appellant does not ask these questions to reargue the June 3 extension order. She asks because she cannot prepare the reply brief effectively without knowing whether her current self-funded communication method will be accepted as communication support, treated as a reason to discount or diminish engagement with her filings, or treated as a reason to provide procedural relief to Appellees. If the Court considers the present communication method ineffective or procedurally problematic, Appellant requests clarification of the modification and accommodation process available before the reply period begins. See 28 C.F.R. §§ 35.160(a)(1), (b)(1)–(2); 35.130(b)(7)(i); 35.107.
Because this motion raises nuanced scheduling, effective-communication, and disclosed-accommodation-tool issues, Appellant respectfully requests that any perceived ambiguity be identified for clarification before it is treated as waiver, noncompliance, lack of merit, or a basis for adverse procedural consequence.
V. Clarification Requested Regarding “First and Second Extension” Language
The June 3, 2026 Order states that the matter was before the Court on “Appellees’ motion for a first (1st), and second (2nd) extension of time.” Appellant is aware of one motion filed by Appellees: the June 1, 2026 Motion for Extension of Time, which requested a single sixty-day extension. Appellant received no notice of a separate second motion or request.
Appellant respectfully requests clarification whether the Order’s reference to a “first” and “second” extension means that the Court treated Appellees’ single sixty-day request as consuming two extension periods under Utah R. App. P. 22, or whether there was a separate second request not served on Appellant. If there was a separate second request or communication, Appellant respectfully requests a copy and an opportunity to respond.
VI. Relief Requested
For the reasons stated above, Appellant respectfully moves for an order granting the following clarification and related procedural relief:
Clarifying Appellant’s reply deadline and ordering that Appellant’s reply brief is due 180 days, 120 days, or another specified number of days after service of Appellees’ principal brief;
Structuring Appellant’s reply period so that September 2026 is excluded from the calculation of Appellant’s reply period, or so that the reply period begins on October 1, 2026 if Appellees serve their brief on a date that would otherwise cause Appellant’s reply period to run through September;
Authorizing Appellant to file a reply brief of up to 9,000 words without a separate motion, or, if a separate motion is required, identifying when and how that motion should be filed without consuming Appellant’s reply-preparation time;
Clarifying whether Appellant’s requested reciprocal safeguards and effective-communication objections were denied, deferred, or left unresolved by the June 3 Order;
Identifying the procedure Appellant should use to correct, supplement, or clarify any communication barrier if any filing, including the Opening Brief, is not received as effectively communicating Appellant’s intended arguments or requests;
Clarifying that Appellant’s disclosed use of self-funded AI-assisted communication support will not, standing alone, be treated as a basis to discount, dismiss, discredit, diminish engagement with, or avoid merits review of Appellant’s filings, arguments, citations, or requests;
If the Court considers Appellant’s self-funded communication support ineffective, unreliable, procedurally problematic, or a basis for discounting any portion of Appellant’s filings, including her Opening Brief, identifying the process and tools available for Appellant to correct, supplement, or remedy the affected communication without adverse procedural consequences;
Identifying the process for raising any remaining effective-communication issue without unnecessary disclosure of disability-related accommodation information to Appellees;
Clarifying whether the June 3 Order’s reference to a “first” and “second” extension refers to Appellees’ single sixty-day request or to a separate request not served on Appellant; and
Directing that, because this motion concerns effective communication, disclosed accommodation tools, and merits-briefing consequences, it be submitted to the Court for disposition rather than treated as a routine clerk-disposable procedural order.
Appellant further requests any other clarification or procedural protection necessary to preserve effective communication, avoid adverse use of disclosed accommodation information, and allow Appellant to prepare her reply brief without avoidable accommodation-related prejudice.
DATED this 11th day of June, 2026.
Respectfully submitted,
Erica V. Saxton/s/ Erica V. Saxton
Appellant, pro se
And the Court responded with this order:
"The mission of the Utah judiciary is to provide the people an open, fair, efficient, and independent system for the advancement of justice under the law."
