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IN THE GENERAL COURT OF JUSTICE

DISTRICT COURT DIVISION


ROCKINGHAM COUNTY, NC
SARAH R. PALMER
On behalf of
NICHOLAS PALMER-BECK
(a minor child)
501 REDD ST.
REIDSVILLE, NC 27320
Pro Se Plaintiff

Case No. 15 CVD 2055

v.
WILLIAM M. SCHMALFELDT, SR
3209 S. Lake Drive, Apt. 108
Saint Francis, WI 53235
Pro Se Defendant
ANSWER TO CIVIL SUMMONS, NO CONTACT ORDER FOR STALKING, MOTION
FOR DISMISSAL OF PETITION
--------------------------------------------------------------------------------------------------------------------Now comes pro se defendant William M. Schmalfeldt to answer the above-titled
summons, and move for dismissal of the complaint. Defendant alleges as follows:
Defendant Does Not Meet Criteria of North Carolina Long-Arm Statute.
1.
2.
3.
4.

Defendant is not a natural person present in the state of North Carolina.


Defendant is not a natural person domiciled in the state of North Carolina.
Defendant is not a domestic corporation.
Defendant is not engaged in substantial activity within North Carolina, whether that

activity is wholly interstate, intrastate or otherwise.


5. As a result, Defendant does not rise to the level of an out of state person who can be
bound by the State of North Carolina under its long-arm Statute (NC ST 1-75.4), and this
honorable court does not have personal jurisdiction over this defendant.

Plaintiffs Petition for a No Contact Order is Rife with Mistruths and Omissions
6. Plaintiff fails to note that Defendant has never made contact with her grandson.
7. Plaintiff fails to note that the single photograph he has published of her grandchild

had his face blurred to make the child unrecognizable.


8. Plaintiff fails to note that the pictures Defendant posted on his website of her her nonparty daughter, Brianna, were taken from her Facebook page, where she made them available to
the world at large.
9. Plaintiff claims to have sent a cease and desist contact letter to defendant.
Defendant does not recall receiving any such letter, nor does Plaintiff establish any proof of said
letter in her petition.
10. In her descriptions of Defendants alleged stalking and harassing behavior, Plaintiff
fails to tell the court that she is the proprietor of a website that is responsible for daily taunting of
the defendant, using the defendants name against his stated wishes in the title of the website.
(EXHIBIT 1)
11. Defendant learned of the alleged incident which led her to become her grandsons
guardian from the Plaintiff herself in a series of e-mails Plaintiff sent to Defendant believing him
to be someone else. (EXHIBIT 2)
12. Plaintiff fails to note for the court that she is a defendant in a Federal Lawsuit filed
by Defendant in the U.S. District Court for the Eastern District of Wisconsin, Milwaukee
Division, alleging harassment, defamation per se, intentional infliction of emotional distress,
among other torts.
13. Plaintiff is aware that Defendant has suffered from Parkinsons disease for 16 years
and cannot walk more than a few yards without assistance. He has no drivers license and cannot
drive. Travel to North Carolina either to answer this petition or harm Plaintiffs grandson
would be impossible without significant assistance to Defendant.

THEREFORE, Defendant asks this honorable court to dismiss Plaintiffs petition with
prejudice due to this courts lack of personal jurisdiction over the Defendant.
In the alternative, Defendant asks this honorable court to review the evidence supplied in
this brief and come to the same conclusion this court made in Plaintiffs request for a temporary
order. The Plaintiff has failed to prove grounds for issuance of a temporary no-contact order.

December 31, 2015

Respectfully Submitted,

____________________________________
William M. Schmalfeldt, Sr., Pro Se
3209 S. Lake Dr., Apt. 108
Saint Francis, WI 53235
414-249-4379
Email: bschmalfeldt@twc.com

EXHIBIT 1
Plaintiff runs a hate-blog directed at defendant at the
website http://billysez.wordpress.com where she takes
things I may or may not have actually said and applies
her own defamatory spin to them. Defendant is suing
Plaintiff in Federal Court for her role in this.

On occasion, Plaintiff has served as a guest blogger for


an even more purulent hate-blog,
http://thinkingmanszombie.com, which is also
completely dedicated to defaming the Defendant.

EXHIBIT 2
Defendant learned about shaken baby charges
against Plaintiffs daughter from Plaintiff herself.