Steven G. T
In the circuit court of the state of oregon for jackson county
IN THE MATTER OF:)
) Steven G. T Petitioner,
Case No: XXXXXXXXX
Vs. Division: Domestic) Amanda L. Ferguson) I-X John and Jane Does, I-X ROE Corporations) Respondent,
Opposition to motion to dismiss ammended petition to domesticate foreign (out of state) judgement
COMES NOW, Steven G. T, in PRO SE and files this OPPOSITION to MOTION TO DISMISS and respectfully moves this court to deny Respondents Motion. This Opposition is made upon the facts, filing and documents on file herein, the Affidavit of Petitioner and any oral argument that may be adduced at the time of hearing.
Dated this 20th day of March
STEVEN G. T
Petitioner in Pro Se
ABA No: 01853601
POINTS AND AUTHORITIES
Facts/History
This is an action pursuant to the Dissolution of Marriage in the State of Florida Nineteenth Judicial Circuit Court Indian River County. However after a Decree of Divorce was granted due to the Adulterous Lies of Respondent, there has been no Jurisdiction in Florida to decide on an Equitable Property &, debt settlement as well as permant spousal support through Conspiracy and
1. Tortious Interference committed by the following individuals: Dennis M. Williams (Convicted of Racketeering January), (Scott Ferguson Defendant in the Northern Trust vs. Daniel C. Ferguson Et.,
2. Al), (Lars Ferguson Defendant in the Northern Trust vs. Daniel C. Ferguson, et., al, (Steven C. White Convicted of Five Felonies including providing false information to a law enforcement agency during August 1996), Jay W. Nance Convicted of 12 Felonies including (Money Laundering) during March and James Simmons charged with possession of a Controlled Substance with intent to distribute Crack Cocaine at Vero Beach February in Las Vegas in order to receive monies from the
3. AMANDA SHARE TRUST aka The Amanda L. Ferguson-Trapp Limited power of Appointment Trust. (A Generation Skipping Trust set up through the work of Steven G. Trapp with an estimated $3,500, 000.00 in Trust assets with annual income of almost $100,000.00). See: Marshal vs. Marshal 547 U.S. 293 .
1. It should be noted that Dennis M. Williams & Jay Nance developed a Fetish for Respondent during December 1993 when they were neighbors and Respondent was my quest located at 2909 Keats street #8 & 2905 Keats Street, San Diego, Ca.
2. It should be further noted that this was formed during a related case: The Northern Trust Company Vs. Daniel C. Ferguson, Et al. Cook County Chancery Case Number: 1997-CH-03855 See Attachment A
3. It should be noted that the original Trust document was drafted by A Prominent Trust an Estate Lawyer from Chicago, IL. At McDermott, Will and Emory by the name of James Mack Trapp. [Emphasis Added] See Attachment B
Denial of this Domestication would be a Violation of Petitioners Fifth and Fourteenth Amendment Rights and a Grave Miscarriage of Justice. See Also LOGAN V. Zimmerman brush co., 455 U.S. 422,437, 71 l. Ed 2d 265,102 S. Ct. 1148 (1982) goss v. Lopez, 419 U.S. 565,579, 42 l. Ed 2d 725,95 S. Ct. 729 (1975).
Finally, the Petitioner asks for oral arguments and that the Respondent is ordered to produce the Trust Document, monthly and annual statements for the Amanda Share Trust aka The Amanda L. Ferguson-Trapp Limited power of Appointment trust as her financial statements filed during the spring of 2008 committed Fraud upon the Court and then she kept trying to avoid service in order to keep it covered up. (Obstruction of Justice).
Legal argument
The basis requirement of Due Process is the right to notice and an opportunity to be heard at a meaningful time and in a meaningful manner LOGAN V. Zimmerman brush co., 455 U.S. 422,437, 71 l. Ed 2d 265,102 S. Ct. 1148 (1982) goss v. Lopez, 419 U.S. 565,579, 42 l. Ed 2d 725,95 S. Ct. 729 (1975).
In this case, granting respondents Motion would a be a violation of Petitioners Fifth and Fourteenth Amendment Rights as he was not provided this meaningful contact or an opportunity to be heard, do To Conspiracy and Tortious Interference by the above aforementioned, as such her Motion to Dismiss must be denied. [Emphasis Added]
To resolve the question of Jurisdiction one must look to: Marshal vs. Marshal. 547 U.S. 293 . It quite simple states that a lower court of Competent jurisdiction held equal or concurrent Jurisdiction thus applying the Equal Protection Clause Found in the Fourteenth Amendment that the United State Constitution Guarantees.
4. It should be further noted, If the question of Jurisdiction still remains the Petitioner requests the Order he is submitting be used and the Court be named for further proceeding as instructed either Federal Court in Medford, Oregon or Indian River Circuit Court and that Mr. Steven G. T establish residency to resolve all of above aforementioned questions as to Property and debt settlement
As such 1st Circuit Court in Jackson County holds such power over the Parties and Respondents Motion to Dismiss must be denied. [Emphasis Added]
Conclusion
Based on the Foregoing, Petitioner, Steven G. T prays for the Respondent Amanda L. Ferguson Motion to dismiss is denied as it would violate the Petitioners Fifth and Fourteenth Amendment Rights as the equal protection clause Guarantees equal or concurrent Jurisdiction and any ruling contrary is a complete Miscarriage of Justice.
Whatever else this court determines is Just and Equitable. Wherefore Petitioner requests a hearing with Oral Arguments on the Amended Petition to Domesticate the final Judgment.
Signed and dated this 20th day of March
Steven G. T
STATE OF OREGON)
County of Jackson)
Affidavit
That I Steven G. T, being first duly sworn, depose and say: That I am the Petitioner in the above-entitled action; and have read the contents of the foregoing Opposition and know the contents thereof; that the same is true of my own knowledge and belief as well as others and as to those matters I believe them to be true.
Steven G. T in Pro Se
ABA No: 01853601
ACKNOWLEDGMENT
STATE OF OREGON)
County of Jackson)
On this%day of March before me the undersigned Notary Public in and for the said County and State appeared: Steven G. T, know to me to be the person described in and who executed the foregoing instrument and who acknowledged to that he did so freely and voluntarily and for the uses mentioned therein.
WITNESSETH my hand and official Seal
Notary Public
Attachment a
Attachment b
Certificate of Mailing
I certify on March 21 I filed and served the following Amended Petition to Domesticate by first class mail to the following addresses:
1st Circuit Court
100 South Oakdale
Medford, Oregon 97501
Amanda L. Ferguson
496-14th Avenue
Vero Beach, Florida 3296-2160
US DOJ
333 Las Vegas Blvd South
Las Vegas, Nevada 89101
Attn: Assistant US Attorney J. Gregory Damm
US DOJ
950 Pennsylvania Ave N.W.
Washington, D.C. 20530-0001
Attn: Ms. Theresa Weathers, Civil Rights Division
Department of Treasury
IRS
Ogden, Utah 84201
Kansas Department of Revenue
Docking State Office Building, Room 300
915 SW Harrison Street
Topeka, KS 66612
Stewart, Evans, Stewart & Emmons, P. A
Attorneys for Earl Tindol/Tindol Family Trust
P.O. Box 3345
Vero Beach, Florida 32964-3345
Department of Justice
Spousal Abuser Prosecution Program
1300 I Street, Room 1020
Sacramento, CA 95814
Florida Department of Law Enforcement
P.O. Box 1489
Tallahassee, FL 32302-1489
0 comments