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1 Your name

Your address
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[City, ST ZIP Code]
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[COURT NAME]
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[PLAINTIFF'S NAME], Case No.: [Number]
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Plaintiff,
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NOTICE OF MOTION
vs.
9 OBJECTION
DEMAND DISMISSAL ON THE
[DEFENDANT'S NAME],
10 GROUNDS THAT STATEMENTS
Defendant/Father OF COUNSEL IN THEIR BRIEFS
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OR ARGUMENT WHILE
12 ENLIGHTENING TO THE COURT
ARE NOT SUFFICIENT FOR
13 PURPOSES OF GRANTING A
MOTION TO DISMISS
14 TAKE JUDICIAL NOTICE UNDER
FEDERAL RULE 201(c)(2) OF
15
EVIDENCE OF AN ADJUDICATED
16 FACT TRINSEY V PAGLIARO, 229
F. SUPP. 647 - DIST. COURT, ED
17 PENNSYLVANIA 1964
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NOTICE OF MOTION OBJECTION DEMAND DISMISSAL ON THE GROUNDS THAT
21 STATEMENTS OF COUNSEL IN THEIR BRIEFS OR ARGUMENT WHILE
ENLIGHTENING TO THE COURT ARE NOT SUFFICIENT FOR PURPOSES OF
22 GRANTING A MOTION TO DISMISS TAKE JUDICIAL NOTICE UNDER FEDERAL
RULE 201(C)(2) OF EVIDENCE OF AN ADJUDICATED FACT TRINSEY V
23 PAGLIARO, 229 F. SUPP. 647 - DIST. COURT, ED PENNSYLVANIA 1964 -
1 NOTICE OF MOTION
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OBJECTION
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DEMAND DISMISSAL ON THE GROUNDS THAT STATEMENTS OF
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COUNSEL IN THEIR BRIEFS OR ARGUMENT WHILE
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ENLIGHTENING TO THE COURT ARE NOT SUFFICIENT FOR
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7 PURPOSES OF GRANTING A MOTION TO DISMISS

8 TAKE JUDICIAL NOTICE UNDER FEDERAL RULE 201(c)(2) OF


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EVIDENCE OF AN ADJUDICATED FACT TRINSEY V PAGLIARO,
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229 F. SUPP. 647 - DIST. COURT, ED PENNSYLVANIA 1964
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Comes now, the Defendant/Father [type in your name, not in capital
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14 letters and remove brackets] is a living man with blood running through his body

15 and one of the people of the several states and it is an adjudicated fact that the
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people of the several states are unconditionally sovereign within the boundaries of
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this state.1
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"It will be admitted on all hands that with the exception of the powers granted to the states and
19 the federal government, through the Constitutions, the people of the several states are unconditionally sovereign
within their respective states." Ohio Life Ins. & Trust Co. v. Debolt, 57 US 416 - Supreme Court 1854.
20 2
NOTICE OF MOTION OBJECTION DEMAND DISMISSAL ON THE GROUNDS THAT
21 STATEMENTS OF COUNSEL IN THEIR BRIEFS OR ARGUMENT WHILE
ENLIGHTENING TO THE COURT ARE NOT SUFFICIENT FOR PURPOSES OF
22 GRANTING A MOTION TO DISMISS TAKE JUDICIAL NOTICE UNDER FEDERAL
RULE 201(C)(2) OF EVIDENCE OF AN ADJUDICATED FACT TRINSEY V
23 PAGLIARO, 229 F. SUPP. 647 - DIST. COURT, ED PENNSYLVANIA 1964 -
1 The undersigned defendant/father is moving a notice of motion on the
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grounds that a recent opposition pleadings for dismissal filed by [Type in the name
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of the attorney who filed for a dismissal against you and remove the brackets] must
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be dismissed.
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The dismissal is required on the grounds that statements of counsel in
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7 their briefs or argument while enlightening to the Court are not sufficient for

8 purposes of granting a motion to dismiss or summary judgment. 2


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THIS COURT AND ITS PRESIDING OFFICIAL ARE
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SANCTIONED AND LIMITED BY A WRITTEN STATE CONSTITUTION
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AND OATH OF OFFICE AND THEREBY ANY ACT NOT IN
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14 ACCORDANCE WITH THE STATE CONSTITUTION AND OATH OF

15 OFFICE IS LIABLE FOR PERSONAL DAMAGES


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2
“Statements of counsel in their briefs or argument while enlightening to the Court are not
19 sufficient for purposes of granting a motion to dismiss or summary judgment.” Trinsey v. Pagliaro, 229 F. Supp.
647 – Dist. Court, ED Pennsylvania 1964
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NOTICE OF MOTION OBJECTION DEMAND DISMISSAL ON THE GROUNDS THAT
21 STATEMENTS OF COUNSEL IN THEIR BRIEFS OR ARGUMENT WHILE
ENLIGHTENING TO THE COURT ARE NOT SUFFICIENT FOR PURPOSES OF
22 GRANTING A MOTION TO DISMISS TAKE JUDICIAL NOTICE UNDER FEDERAL
RULE 201(C)(2) OF EVIDENCE OF AN ADJUDICATED FACT TRINSEY V
23 PAGLIARO, 229 F. SUPP. 647 - DIST. COURT, ED PENNSYLVANIA 1964 -
1 1. This court is sanctioned and limited by the state constitution and thereby this
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court is required by duty to be watchful for the constitutional rights of the
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citizen, and against any stealthy encroachments thereon.3
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2. The presiding official is an officer of the court bound by oath of office to
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support and defend the state constitution as well as constitution for the
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7 United States of America.

8 3. Any act not in accordance with the oath of office is evidence of the presiding
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official vacating the office of a public official and losing immunity by acting
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in private capacity.
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INVOKING ARTICLE 4 SECTION 2 FULL FAITH AND CREDIT
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14 CLAUSE AND PRIVILEGES AND IMMUNITIES CLAUSE OF THE

15 CONSTITUTION FOR THE UNITED STATES OF AMERICA


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19 It is the duty of courts to be watchful for the constitutional rights of the citizen, and against any
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stealthy encroachments thereon” Byars v. United States, 273 U.S. 28 (1927)


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NOTICE OF MOTION OBJECTION DEMAND DISMISSAL ON THE GROUNDS THAT
21 STATEMENTS OF COUNSEL IN THEIR BRIEFS OR ARGUMENT WHILE
ENLIGHTENING TO THE COURT ARE NOT SUFFICIENT FOR PURPOSES OF
22 GRANTING A MOTION TO DISMISS TAKE JUDICIAL NOTICE UNDER FEDERAL
RULE 201(C)(2) OF EVIDENCE OF AN ADJUDICATED FACT TRINSEY V
23 PAGLIARO, 229 F. SUPP. 647 - DIST. COURT, ED PENNSYLVANIA 1964 -
1 1. It is a conclusion of law under the Full Faith and Credit Clause under
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Article 4 Section 2 The Citizens of each State shall be entitled to all
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Privileges and Immunities of Citizens in the several States.
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2. Under Full Faith and Credit Clause under Article 4 Section 1 of the U.S.
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Constitution this court must honor judgments by courts within the
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7 territories of the United States of America, especially the highest court on

8 the land The Supreme Court of the United States.


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3. The undersigned Defendant/Father is requiring this court to take judicial
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and administrative notice under federal rule 201(c)(2) of adjudicated fact
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Trinsey v. Pagliaro, 229 F. Supp. 647 – Dist. Court, ED Pennsylvania
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1964 which held “statements of counsel in their briefs or argument while
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14 enlightening to the Court are not sufficient for purposes of granting a

15 motion to dismiss or summary judgment.”


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4. Therefore, this adjudicated fact must be given full faith and credit by this
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court and requiring this court to dismiss the motion to dismiss filed by
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NOTICE OF MOTION OBJECTION DEMAND DISMISSAL ON THE GROUNDS THAT
21 STATEMENTS OF COUNSEL IN THEIR BRIEFS OR ARGUMENT WHILE
ENLIGHTENING TO THE COURT ARE NOT SUFFICIENT FOR PURPOSES OF
22 GRANTING A MOTION TO DISMISS TAKE JUDICIAL NOTICE UNDER FEDERAL
RULE 201(C)(2) OF EVIDENCE OF AN ADJUDICATED FACT TRINSEY V
23 PAGLIARO, 229 F. SUPP. 647 - DIST. COURT, ED PENNSYLVANIA 1964 -
1 the plaintiff’s attorney [type in the name of the attorney who filed motion
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to dismiss].
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THE DEFENDANT/FATHER IS NOT A LEGAL
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PROFESSIONAL AND THEREFORE HIS PLEADINGS MUST NOT BE
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7 HELD TO THE STANDARDS OF A LEGAL PROFESSIONAL AND

8 THEREFORE THE CLERKS OFFICE MUST ACCEPT POSSESSION OF


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PLEADINGS REGARDLESS OF LOCAL RULES
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1. The undersigned defendant/father is not a legal professional and therefore
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this court must not hold his pleadings to the standard of a legal professional.
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14 2. It is a fact hearsay by an unsworn officer of the court is not admissible and

15 must not be given consideration by this court and therefore this court must
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dismiss a notice of motion filed under affirmation.
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3. The clerk’s office must accept possession and file pleadings regardless of
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local rules and thereby cannot refuse to accept possession under the claim of
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NOTICE OF MOTION OBJECTION DEMAND DISMISSAL ON THE GROUNDS THAT
21 STATEMENTS OF COUNSEL IN THEIR BRIEFS OR ARGUMENT WHILE
ENLIGHTENING TO THE COURT ARE NOT SUFFICIENT FOR PURPOSES OF
22 GRANTING A MOTION TO DISMISS TAKE JUDICIAL NOTICE UNDER FEDERAL
RULE 201(C)(2) OF EVIDENCE OF AN ADJUDICATED FACT TRINSEY V
23 PAGLIARO, 229 F. SUPP. 647 - DIST. COURT, ED PENNSYLVANIA 1964 -
1 local rules. The standard for the clerk’s office to accept possession and file
2 pleadings can be found under United States v. Lombardo, 241 U.S. 73, 76-
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77, 36 S.Ct. 508, 60 L.Ed. 897 (1916).4
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THIS COURT IS PRESENTED WITH EVIDENCE OF ADJUDICATED
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8 FACTS THAT SUPPORT THE IMMEDIATE DISMISSAL OF

9 OPPOSITION PAPERS FILED BY PLAINTIFF’S ATTORNEY


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12 Dated this [day] of [Month], [year].

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TYPE IN Your Name AND SIGN
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“Lombardo has long been considered as establishing the "physical delivery" rule such that the
19 date of delivery is the date of filing for statutory purposes. See, e.g., Wiggins v. Internal Revenue Service, 59
A.F.T.R.2d 87-445, 87-1 USTC P 9180, 1986 WL 15574, *2 (D.Md.1986).
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NOTICE OF MOTION OBJECTION DEMAND DISMISSAL ON THE GROUNDS THAT
21 STATEMENTS OF COUNSEL IN THEIR BRIEFS OR ARGUMENT WHILE
ENLIGHTENING TO THE COURT ARE NOT SUFFICIENT FOR PURPOSES OF
22 GRANTING A MOTION TO DISMISS TAKE JUDICIAL NOTICE UNDER FEDERAL
RULE 201(C)(2) OF EVIDENCE OF AN ADJUDICATED FACT TRINSEY V
23 PAGLIARO, 229 F. SUPP. 647 - DIST. COURT, ED PENNSYLVANIA 1964 -

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