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Plaintiff's Repsonse to County Defendants' Motion to Dismiss (Federal Court)

Plaintiff's Repsonse to County Defendants' Motion to Dismiss (Federal Court)

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Published by Janet and James
This document (doc 49) and the accompanying Addendum (doc 49-2), was removed from the Court docket. Plaintiff petitioned to have the docs 49 and 49-2 re-inserted. The Motion was neither granted nor denied it was ignored.
This document (doc 49) and the accompanying Addendum (doc 49-2), was removed from the Court docket. Plaintiff petitioned to have the docs 49 and 49-2 re-inserted. The Motion was neither granted nor denied it was ignored.

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Published by: Janet and James on Dec 02, 2008
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05/09/2014

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;
:
IN THE
UNITED
STATES DISTRICT COURT
FOR TIC NORTHERN DISTRICT OF GEORGIA
M
AR @ 5 2007
JAMES N
. HAFTtN, CLE
R~
BY'
ATLANTA,
DIVISION
JAMES
B STEGEMAN, )
Plaintiff )
v }
STATE OF
GEORGIA,
thru GOVERNOR )
SONNY
PERDUE,
In His Official Capacity
;)
STATE OF GEORGIA DEPARTMENT )
OF HUMAN RESOURCES
; )
DEKALB COUNTY, thru CEO VERN
O
N }
JONES In His Official Capacity )
DEKALB COUNTY DEPARTMENT }
OF FAMILY & CHILDREN SERVICES
; )
DEKALB COUNTY FIRE & RESCUE )
LT
. HUGHETT
-NO
581 In His Official )Individually and in His Official Capacity
; )
EMS MEDIC DENNIS OARLOCK )
Individually and in His Official Capacity
; }
STONE
MOUNTATIN
POLICE OFFICER)
R
.B
. PORTERBADGE, #
119, Individually )and in His Official Capacities
; }
DEKALB COUNTY PROBATE COURT
; }
PROBATE JUDGE JERYL DEBRA ROSH)
Individually and in Her Official Capacity
; j
GEORGIA SUPERIOR COURT, STONE )
MOUNTAIN
JUDICIAL
CIRCUIT
; )
STATE COURT OF GEORGIA
; )
DEKALB
COUNTY
SOLICITOR'S )
OFFICE
; )
ANE DOE 4
1
-100
; )
JOHN DOE O 1-100
; j
Defendants )
FILE NO
.
: 1
:06-cv-02954WSD
FILED IN CLEWS "
(
E
U
.
S
.
J
.
C
. Atlanta
CIVIL ACTION
Case 1:06-cv-02954-WSD Document 49 Filed 03/05/2007 Page 1 of 20
 
2
P
LA
I
NT
IFF'S
R
ESP
O
NSE AN
D OB
JECT
IO
N
TO
CO
UNTY
D
EFEN
D
ANT' S
MOTION
T
O DI
SMISS
COMES NOW, Plaintiff James B
. Stegeman and files his
Response
BriefObjection
To And Motion To DenCounty
e
f
endant
's
Motion to Di
s
m
ss
.
I
. FACTS
Plaintiff s complaint and accompanying evidence clearly shows that thedefendants named in this Civil Action violated Plaintiffs Civil and ConstitutionalRights, violated Plaintiff's Immunities, committed several different kinds of fraud,violated both United States Laws and Georgia Laws, are guilty of malicious abuseof process, malicious prosecution, negligent intentional infliction of emotionalabuse, and defamation, they conspired to do same, while under "Color of Law" or"Color of Authority" as well as other Counts. The defendants have violated theirOaths of Office
.
Further, Plaintiff, who is 100 percent legally disabled with multipledisabilities, has shown that he has been a victim of crime
. Due to the illegal acts
of the defendants, Plaintiff has suffered great financial loss, which has forced himinto proceeding as a Pro Se litigant against he wishes and against his better
judgment
. This Honorable Court has the power and authority to appoint legalSee complaint Exhibit 1
Case 1:06-cv-02954-WSD Document 49 Filed 03/05/2007 Page 2 of 20
 
3
1
'?
representation, or perhaps legal counsel which Plaintiff may ask legal questions, to
which Plaintiff would greatly welcome and would have no objections
.
I
I
. A
R
GUMENT AN
D
CITATION OF AUTHORITIES
A
.
Statute of Limitations Claims Fail
1
. Many Rights violations in the complaint are current and or on-going
.2
2. Civil and Constitutional violations by DeKalb County Courts are current,
are in the nature of "continuing" violations, or are within the statute of limitations
.
See complaint Exhibit 36, 37,39,40,42,43,45,47,48, showing current violations
.
3. Plaintiff is legally 100 percent Federally disabled with multiple disabilities
.3
4. Plaintiff suffered his claims due to actions recognized as crimes4 by the State
2 "County Defendants" Brief
..
.Motion To Dismiss, page 3, II
.A
. 1
: "
.
.
.hasfailed to allege
.
.
. occurred within
.
.
. limitations time period"
. Although all
defendants' counsel in this action contend the "statute of limitations" claim,Plaintiff has claimed that the violations are current, on-going, disguised byfraudulent acts which prohibited Plaintiffs discovery, the falsifications of
documents by defendants
. Plaintiff has shown as well as stated several times thatthe incidents occurred within the statute of limitations or should be tolled for
several reasons
.
3 Thomson * Gale Legal Encyclopedia
: "Tolling the Statute: Ifa party is under
more than one disability, the statute of limitations does not begin to run until all the
disabilities are removed." "In cases where a cause of action has been fraudulentlyconcealed, the statute of limitations is toll until the action is, or could have been
discovered
..
."
a T
ITL
E
18
,
U
.S
.C
.,
SECT
IO
N
241
: If two or more persons conspire to
injure, oppress, threaten, or intimidate any person in any State, Territory,
Case 1:06-cv-02954-WSD Document 49 Filed 03/05/2007 Page 3 of 20

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