No.

23-126735-A
_______

IN THE
COURT OF APPEALS
OF THE
STATE OF KANSAS
_______

Washburn South Apartments LLC

Plaintiff –Appellee
vs.
Bo Zou
Defendant-Appellant
_______

BRIEF OF APPELLANT BO ZOU

_______

Appeal from the District Court of Shawnee County,

Honorable Teresa L. Watson, District Judge
District Court Case No. 2022-LM-008616

_______

Bo Zou
6000 SE 2nd Street
Tecumseh, KS 66542
Tel: (713)835-8655
E-mail: bzksls19@gmail.com

Appellant: pro se

Oral Argument: 15 minutes

 ii

Table of Contents
Nature of the Case ............................................................................................................ 1

Statement of the Issues .................................................................................................... 3

Statement of Facts ............................................................................................................ 3

Arguments and Authorities ............................................................................................12

Issue I: The district court erred massively by using an illegal and unenforceable
lease to grant Plaintiff for judgment regardless of Defendant’s objections and
allegations

K.S.A. 58-2550.................................................................................................... 13-15

K.S.A. 84-2a-201…..............................................................................................13-15
Hunter v. American Rentals, Inc. 189 Kan. 615, 371 P.2d 131............................14-15
State, ex rel. Hecht v. City of Topeka...................................................................14-15

Issue II: The district court erred massively by hearing and trying Plaintiff’s void
summary judgment ........................................................................................................ 16

Kan. Sup. Ct. R. 141.............................................................................................16-17

McCullough v. Bethany Med. Center, 235 Kan. 732, 736, 683 P.2d 1258
(1984)…………………………………………………………………………....16-17
Bus. Opportunities Unlimited, Inc. v. Envirotech Heating & Cooling, Inc.,
992 P.2d 1250………………………………………………………………….. 16-17
Issue III: The district court erred by hearing and trying the void eviction
case....................................................................................................................................17
K.S.A. 58-2553....................................................................................................18-20
K.S.A. 58-2571……………………………........................................................18-20
O'Neil v. Durham, 41 K.A.2d 540, 203 P.3d 68 (2009)……………………….18, 20

Issue IV: The district court erred massively by using the forged and inadmissible
“Final Account Statement-Revised” as the basis to grant Plaintiff void claim and
imposed the void financial liability on Defendant …………....................................... 20
 iii

K.S.A. 58-2550……………………......................................................21, 22, 24, 25

K.S.A. 58-2553……………………........................................................................21
K.S.A. 58-2571…………………………………………………………………....21
K.S.A. 21-3710……………………………………………………………...…22-23
K.S.A. 21-5823 ……………………..................................................................22-23
K.S.A. 58-2555…………………………………………………………………....22
Hunter v. American Rentals, Inc. 189 Kan. 615, 371 P.2d 131.........................22, 25
State v. Foster, 298 Kan. 348, 312 P.3d 364 …………………………………..…23
In re Ware, 279 Kan. 884, 889, 112 P.3d 155 (2005) ………………………….....24
In re Eastepp, 258 Kan. 766, 767-69, 907 P.2d 842 (1995) …………………...…24
Geiger v. Wallace, 233 K. 656, 657, 659, 660, 664 P.2d 848 (1983) …………….25
State, ex rel. Hecht v. City of Topeka ………..........................................................25

Issue V: The district court erred by not stating Defendant’s controverted facts
and factual evidence in the memorandum decision and order and further denying
the controverted facts and factual evidence without any reason in violation of the
Kan. Sup. Ct. R. 141 & 165, and K.S.A. 60-252........................................................... 25

Kan. Sup. Ct. R. 141 ……........................................................................... 25, 27, 28

Kan. Sup. Ct. R. 165 ……........................................................................... 25, 27, 28
K.S.A. 60-252……………………………………………………………...25, 27, 28
Burcham v. Unison Bancorp, Inc., 276 K. 393, 77 P.3d 130 (2003)………..….27-28
Schoof v. Byrd, 197 K. 38, 46, 415 P.2d 384………………………………..….27-28
Read v. Estate of Davis, 213 K. 128, 135, 136, 515 P.2d 1096………………...27-28
Froelich v. Adair, 213 K. 357, 359, 516 P.2d 993………………………………....28

Issue VI: The district court erred by failing to state the conclusion of law in
denying Defendant’s “Motion for Sanctions on Plaintiff’s perjury, forgery and
falsification on documents, and contempt of the court” and denying twice hearing
requests to cover up and help Plaintiff’s nefarious and criminal behaviors..............28

K.S.A. 21-3710……………………………………...…………………….29, 30, 35

 iv

K.S.A. 21-5823………………………………………………...……...29, 30, 34, 35

State v. Foster 46 Kan. App. 2d 233 264 P.3d 116…………………………….…..29
In re Ware, 279 Kan. 884, 889, 112 P.3d 155………………………………….29-30
K.S.A. 60-211……………………………………………………..…….…30, 34, 35
In re Marriage of Stockham, 23 K.A.2d 197, 199, 928 P.2d 104 (1996)………….34
McCabe v. Hoch, 42 K.A.2d 747, 216 P.3d 720 (2009)………………………...…34

Issue VII: The district court erred by violating the Kan. Sup. Ct. R. 360 to cheat
Defendant “No Audio Recording of Hearing” and depriving of Defendant’s equal
right in the proceedings in violation of Kan. Const. Bill of Rights §1……………….35

Kan. Sup. Ct. R. 360……………………………………………...………..35, 37, 38

Kan. Const. Bill of Rights §1………………………………………………35, 37, 38
Kan. Sup. Ct. R. 3.02(d)………………………………………………………...….37
Hodes & Nauser, MDs, P.A. v. Schmit 309 Kan.610 440 P.3d 461………........37-38

Conclusion …………................................................................................................. 38-39

 -1-

Nature of the Case

This is an appeal from a Shawnee County District Court summary judgment entered

by the memorandum decision and order (R. 2, 234--261) filed June 2, 2023. The district

judge Teresa L. Watson, a Chapter 60 judge, who never has the jurisdiction for the case,

completely ignored all of Defendant’s evidence, which rightfully proved Defendant’s

rights in legally breaking the lease and Plaintiff’s perjury, forgery and falsification on

documents, etc., and erred massively in granting Plaintiff for judgment by (1) using the

illegal and unenforceable lease to grant Plaintiff for judgment regardless of Defendant’s

objections and allegations on the illegal and unenforceable lease. On the lease, the

deposit was specified as $765, which is in excess of one month’s periodic rent $565 in

violation of K.S.A. 58-2550. Also, the lease involved in fraud by changing $20 per month

gas reimbursement to water bill. Defendant has the right to refuse to answer Plaintiff’s

void and illegal contentions in Plaintiff’s void motion for summary judgment because of

the illegal and unenforceable lease; (2) hearing and trying Plaintiff’s void motion for

summary judgment because Plaintiff did not pay $195 filing fee in violation of Kan. Sup.

Ct. R. 141; (3) hearing and trying the void eviction case. The pretext for Plaintiff to file

the eviction case is that Plaintiff did not pay the rent of September, 2022, and asserted

that the security deposit on lease was $765. After Defendant provided the evidence for

the district court, Plaintiff had to admit that the deposit was only $200, and Defendant

prepaid $565 for the rent of the last month in Plaintiff’s motion for summary judgment.

So, the basis and pretext of the eviction case is no longer existed. The eviction case must

be dismissed with prejudice. (4) using the void, illegal and inadmissible “Final Account
 -2-

Statement-Revised” as the basis to grant Plaintiff void claim and imposed the void

financial liability on Defendant. Plaintiff forged Defendant’s move-out date in the “Final

Account Statement-Revised” to claim more money. The “Final Account Statement-

Revised” must be deemed void, illegal and inadmissible in law because of the forgery

and void claims; (5) not stating Defendant’s controverted facts and factual evidence in

the memorandum decision and order and further denying the controverted facts and

factual evidence without any reason in violation of the Kan. Sup. Ct. R. 141 & 165, and

K.S.A. 60-252. Defendant’s all controverted facts and factual evidence are marked

numbers, no contents in the memorandum decision and order, and further were denied

without reasons; (6) failing to state the conclusion of law in denying Defendant’s

“Motion for Sanctions on Plaintiff’s perjury, forgery and falsification on documents, and

contempt of the court” (R. 2, 150--171) and denying twice hearing requests (R. 2, 214--

215) (R. 2, 231--233) to cover up and help Plaintiff’s nefarious and criminal behaviors.

District judge Teresa L. Watson denied Defendant’s motion for sanctions by knowingly

ignoring the factual evidence and asserting that Defendant did not set forth any evidence

and did not provide an affidavit in the motion for sanctions. But, judge Watson could not

state which Kansas law to support her denial; (7) violating the Kan. Sup. Ct. R. 360 to

cheat Defendant “No Audio Recording of 12/07/22 Hearing” (R. 6, 5) and later refuse to

release the audio recording to Defendant. The district court deprived of Defendant’s

equal rights granted by the Kansas Constitution Bill of Right §1 in the proceedings.

On June 15, 2023, Plaintiff timely filed notice of appeal from the District Court’s

memorandum decision and order.

 -3-

Statement of the Issues

Issue I: The district court erred massively by using an illegal and unenforceable
lease to grant Plaintiff for judgment regardless of Defendant’s
objections and allegations.

Issue II: The district court erred massively by hearing and trying Plaintiff’s void
motion for summary judgment.

Issue III: The district court erred by hearing and trying the void eviction case.

Issue IV: The district court erred massively by using the void, illegal and
inadmissible “Final Account Statement-Revised” as the basis to grant
Plaintiff void claim and imposed the void financial liability on
Defendant.

Issue V: The district court erred by not stating Defendant’s controverted facts
and factual evidence in the memorandum decision and order and
further denying the controverted facts and factual evidence without any
reason in violation of the Kan. Sup. Ct. R. 141 & 165, and K.S.A. 60-252.

Issue VI: The district court erred by failing to state the conclusion of law in
denying Defendant’s “Motion for Sanctions on Plaintiff’s perjury,
forgery and falsification on documents, and contempt of the court” and
denying twice hearing requests to cover up and help Plaintiff’s
nefarious and criminal behaviors.

Issue VII: The district court erred by violating the Kan. Sup. Ct. R. 360 to cheat
Defendant “No Audio Recording of 12/7/22 Hearing” and depriving of
Defendant’s equal rights in the proceedings in violation of Kansas
Constitution Bill of Right §1

Statement of Facts

1. Defendant rented the unfurnished apartment, which is located at 2114 SW

Wayne Ave. #5, Topeka, KS 66611, from Plaintiff on May 23, 2022. The lease was six
 -4-

months lease from May 23, 2022 to November 30, 2022.

2. The rent fee per month was $565, gas reimbursement $20 per month, and the

deposit $200 (R. 1, 220-221). However, after Defendant moved in, Defendant found no

gas service. Gas reimbursement $20 per month was changed and specified as water bill

on the lease.

3. Plaintiff asked Defendant to prepay $565 for the last month rent plus $200

Deposit, total $765, before moving in. (R. 1, 20). However, Plaintiff wrote and specified

$765 as deposit on the lease (R. 1, 12) in violation of K.S.A. 58-2550 and had been

asserting $765 to be the security deposit in the proceedings (R. 1, 33) & (R. 1, 168). The

lease must be deemed illegal and as a result, is generally not enforceable.

4. Around June 6, 2022, Plaintiff entered the rental apartment without a notice.

Plaintiff contacted Defendant’s personal items and foods, and turned on the air

conditioner until Defendant returned to home to turn it off around 6:10 PM. Defendant

had to trash all the foods, including the foods in the refrigerator. The door handler of the

refrigerator was not replaced.

5. The next day (06/07/2022), Defendant asked Plaintiff why they entered

the rental room without notice. The leasing office employee Ms. Crystal Orcutt told

Defendant that she did not believe the maintenance employees entered the rental room

because Defendant did not request any maintenance, and also they were very busy on

Monday (06/06/2022). Ms. Crystal Orcutt checked the work orders issued to maintenance

and could not find any maintenance work order was issued for the rental apartment.

Plaintiff promised to change the door locker after Defendant requested to replace it.
 -5-

6. The next day (06/08/2022), the deputy manager Ms. Glenda called and told

Defendant that it is the manager Julie to let maintenance enter the rental apartment and

fix the door handle of the refrigerator. Plaintiff would not change the door locker. It was

absolutely not true because Defendant never requested the maintenance in writing per

lease (R. 1, 13--14) and no maintenance work order was issued. After Defendant went

back to home, Defendant found that the door handler of the refrigerator was replaced.

7. On August 22, 2022, Defendant found that somebody or some people entered the

rental apartment again with passcode and key. The thieves stole Defendant’s confidential

private notebook, which recorded all Defendant’s private information, including the bank

and credit card information, the email addresses, and friends contact information, etc.

8. Defendant immediately called 911. A Police officer came to the rental apartment

to check the theft, and suggested Defendant move out because thieves could enter the

rental room with passcode and key, and the apartment was invaded twice in two months,

and unsafe to live inside. Defendant provided the “Police Report” (R. 1, 18) for Plaintiff

on September 7, 2022.

9. Defendant reported the theft to Plaintiff immediately, too (08/22/2022).

Defendant asked Plaintiff how the thieves may enter the rental room with passcode and

key. Plaintiff could not answer Defendant’s questions. And then, Defendant notified

Plaintiff that Defendant would break the lease and move out in 30 days. Defendant would

use the prepaid last month rent $565 to pay the rent of September. Plaintiff admitted and

confirmed the notification in Plaintiff’s email. (R. 1, 51) & (R. 1, 59). Also, Defendant

asked Plaintiff to change the passcode and the door locker. But, Plaintiff refused
 -6-

Defendant’s request.

10. Around 9:04 PM of September 5, 2022, two suspicious guys used passcode to

enter the unit of the apartment building, and tried to break in the rental

apartment. The suspicious guys used their bodies to hit and impact the door.

Hopefully, two police officers arrived in time and stopped them after Defendant called

911. The failed break-in accident happened after Plaintiff refused to change passcode and

door locker for Defendant. Plaintiff must take the responsibility for its refusal. The

“Police Call Note” was provided for the district court. (R. 1, 229--231)

11. The next day 09/06/2022, Defendant notified Plaintiff that two suspicious guys

tried to break in the rental apartment, and Defendant would break the lease and move out

soon once again. At the same time, Defendant requested Plaintiff to change passcode and

door locker again. But, Plaintiff refused to change passcode and door locker once again.

Plaintiff promised to ask Plaintiff’s corporate office for approval of breaking lease and

move-out. But, later Plaintiff violated the promise to send Defendant a notice to ask

Defendant to pay the rent of September.

12. Based on Plaintiff’s cheat, illegal entry without a notice and negligence of

Defendant’s life safety, on September 9, 2022, Defendant filed the small claim case

against Plaintiff at Shawnee County District Court (Case No. 2022-SC-000129).

13. On September 11, 2022, Defendant hand delivered the “Notice of Breaking

Lease and Moving out” to Plaintiff. (R. 1, 22--23). Defendant notified Plaintiff that

Defendant would move out before the end of September because other people may enter

the rental apartment with passcode and key, and Defendant’s life safety was seriously
 -7-

threated based on Plaintiff’s negligence of Defendant’s life safety to refuse to change

passcode and the door locker over and over.

14. Although Defendant had notified Plaintiff three times on August 22, September

6 and September 11, 2022, respectively that Defendant would move out before the end of

September, 2022, and Defendant would use the prepaid $565 to pay the rent of

September, Plaintiff still filed the frivolous limited action case against Defendant on

September 20, 2022. (R. 1, 1--4).

15. On September 21, 2022, Defendant hand delivered the “Moving out Notice and

Refund request” (R. 1, 25) to Plaintiff and notified that Defendant would move out and

return key to Plaintiff on September 23, 2022. Also, Defendant requested Plaintiff to

walk through and check the apartment with Defendant at 4:20 PM on September 23, 2022.

But, Plaintiff refused to accept the moving out notice. So, both parties called 911. A

Police officer came to solve the issue. Finally, Plaintiff had to accept Defendant’s notice.

The “Police Call Note” was provided for the district court (R. 2, 136).

16. On September 22, 2022, Defendant moved out from the apartment and returned

the key to Plaintiff on September 23, 2022 (R. 1, 34). But, Plaintiff refused to walk

through with Defendant to check the apartment.

17. On September 26, 2022, Defendant hand delivered the “Request to check Apt.

(2114 building #5) and Refund Correction” (R. 1, 225) to Plaintiff to request Plaintiff to

walk through and check the apartment and refund Defendant once again. But, Plaintiff

refused Defendant’s request again.

18. After Plaintiff filed the limited action case against Defendant, and claimed total
 -8-

$630. (R. 1, 1), the limited action case was assigned to Pro Tem. judge Diane Glynn.

19. On October 4, 2022, Defendant filed counterclaim against Plaintiff. (R. 1, 7-25).

20. On October 5, 2022, Defendant filed “Request for Continuance” (R. 1, 26-28).

But, a copy of Request for Continuance was sent to district judge Teresa L. Watson, a

Chapter 60 judge. (R. 6, 2)

21. On October 7, 2022, district judge Teresa L. Watson openly intervened in the

limited action case by issuing the minute order (R. 1, 29) to re-set the hearing when Pro

Tem. judge Diane Glynn was still the presiding judge. Especially, the hearing was re-set

to Shawnee County Courthouse room 3H from previous location Agricultural

Hall/Stormont Vail Events Center, Corner of Topeka Blvd & 17th Street, Topeka, KS

66604. The change is quite abnormal because all the limited action cases are heard at

Agricultural Hall/Stormont Vail Events Center, Corner of Topeka Blvd & 17th Street,

Topeka, KS 66604.

22. At the hearing of October 25, 2022, Pro Tem. judge Diane Glynn did not ask

any facts and evidence and wrongfully transferred the limited action case to district judge

Teresa L. Watson, who is a Chapter 60 judge without the jurisdiction and authority to

review the Chapter 61 cases. (R. 1, 92). Especially, district judge Teresa L. Watson heard

and tried a lot of Plaintiff’s eviction cases before the case. As a Chapter 60 judge, Judge

Watson should never have appeared Plaintiff’s any eviction cases.

23. On October 31, 2022, Defendant filed “Request for Audio Recording” and paid

$40 fee for the audio recording. (R. 1, 93).

24. On November 3, 2022, the district court answered “no audio recording
 -9-

available.” (R. 1, 94). However, the docketing record clearly shows that the hearing of

October 25, 2022 was digitally recorded. (R. 6, 3)

25. On November 28, 2022, pursuant to K.S.A. 60-245, Defendant requested a

subpoena to inspect, copy (1) Service request 3679-1; (2) Activity for Zou, Bo (Unit:

2114-5); (3) video and camera and emails involving in the case (R. 1, 116--118), because

Plaintiff forged and falsified “Service request 3679-1” and “Activity for Zou, Bo (Unit:

2114-5)”, and video and camera and emails could demonstrate Plaintiff’s forgery and

falsification.

26. On November 29, 2022, judge Teresa L. Watson immediately intercepted the

subpoena without Plaintiff’s request in violation of K.S.A. 60-245. (R. 1, 120)

27. At the same day, Defendant filed “Emergency Motion for Recusal” to disqualify

judge Teresa L. Watson. (R. 1, 121--128)

28. On December 2, 2022, only two days after Defendant filed “Emergency Motion

for Recusal” to disqualify judge Teresa L. Watson, judge Watson immediately ordered

the Sheriff in the Courthouse to limit Defendant’s freedom and activity that Defendant

was only permitted to go the clerk office, and even prohibited from going the district

attorney office in the same building. It’s blatant infringement on Defendant’s civil rights

and equal rights without a paper order being issued and the due process.

29. On December 2, 2022, Defendant filed “Request for Court Reporter and

Language Interpreter” (R. 5, 6--7). In the request, Defendant requested that the hearing

of 12/7/22 must be digitally recorded.

30. On December 5, 2022, Defendant filed “FOIA Request to Disclose the Order or
 - 10 -

Warrant for Monitoring and Limiting Defendant in the Building of the District Court of

Shawnee County; and Motion to Rescind the Limitation and Monitor to Defendant”

(R. 1, 140--153) to ask judge Watson to release any order or warrant for the infringement

on Defendant’s civil and equal rights.

31. On December 6, 2022, Plaintiff filed “Notice of Service” to notify the district

court that Plaintiff sent the “Final Account Statement-Revised” to Defendant on

December 5, 2022. In the “Final Account Statement-Revised”, the deposit was still

asserted and specified as $765. Also, Plaintiff forged and falsified Defendant’s move-out

date as October 17, 2022, instead of the actual move-out date September 23, 2022, to

claim more money. (R. 1, 168) or (R. 1, 203)

32. On December 7, 2023, the district court held a hearing. District judge Teresa L.

Watson had shown huge prejudice against Defendant in the hearing. Defendant was not

given 15 minutes oral argument, etc. (R. 4, 1--40)

33. On December 8, 2023, Defendant filed the “Request for Audio Recording” and

“Request for Transcript”. (R. 1, 177--178).

34. On December 12, 2022, Plaintiff filed “Motion for Leave to Amend” (R. 1, 188-

-203). Plaintiff filed the void, illegal and inadmissible “Final Account Statement-

Revised” (R. 1, 168 or 203). to the district court.

34. On December 15, 2022, the district court answered Defendant’s request for

audio recording by “No Audio Recording of 12/7/22 Hearing”. (R. 6, 5)

35. On December 16, 2022, Defendant immediately filed the “Request for

Electronic Recording of the Hearing” (R. 1, 205-207). In the request, Defendant clearly
 - 11 -

stated that “After the Court admitted that NO audio recording existed for the hearing,

now, Ms. Hoff said that the transcript may be produced. If so, there must be an electronic

recording existing for the hearing because Ms. Hoff did not type or write by pen or other

tools during the hearing of December 7, 2022.” (R. 1, 206). But, the Request has never

been ruled or answered by the district court since then.

36. On December 21, 2022, Defendant filed “Affidavit of Disqualification” (R. 1,

234--250), to disqualify judge Watson again.

37. On January 19, 2023, Defendant filed “Petition for Writ of Mandamus and

Request immediate Relief” to the Kansas Supreme Court. Case No. 23-125970-S

37. On February 2, 2023, the Chief judge Steven R. Ebberts had to rule on

Defendant’s “Affidavit of Disqualification” after Defendant filed “Petition for Writ of

Mandamus and Request Immediate Relief”, but denied “Affidavit of Disqualification”

without facts and reasons. (R. 2, 4--6).

38. On March 20, 2023, Plaintiff filed the frivolous “Plaintiff Motion for Summary

Judgment” (R. 2, 105--106), and the “Memorandum in support of Washburn South

Apartments. LLC. Motion for Summary Judgment” (R. 2, 56--104).

But, Plaintiff did not pay $195 filing fee for the motion for summary judgment in

violation of Kan. Sup. Ct. R. 141. Plaintiff’s motion for summary judgment must be

deemed void.

39. On April 6, 2023, Defendant filed “Defendant’s Response in opposition to

Plaintiff’s Motion for Summary Judgment” (R. 2, 107--109), and the “Memorandum in

support of Defendant’s Response in opposition to Plaintiff’s Motion for Summary

 - 12 -

Judgment” (R. 2, 110--142).

40. On April 21, 2023, Defendant filed “Motion for Sanctions on Plaintiff’s perjury,

forgery and falsification on documents, and contempt of the court” (R. 2, 150--171) to

request the district court sanctioned Plaintiff and granted judgment for Defendant.

41. On May 18, 2023, Defendant filed “Motion for on-site Hearing”. (R. 2, 214--

215). But, judge Watson immediately denied Defendant’s “Motion for on-site Hearing”.

(R. 2, 225--227)

42. On May 18, 2023, Defendant filed the objection and request the district court

reconsider the on-site hearing. (R. 2, 231--233)

43. On June 2, 2023, judge Watson issued the “Memorandum decision and order”

(R. 2, 234--261) to grant Plaintiff for summary judgment, and deny Defendant’s motion

for sanctions by completely ignoring the factual evidence and without conclusions of law.

42. On June 15, 2023, Defendant timely filed the Notice of Appeal. (R. 2, 264--265)

Arguments and Authorities

Issue I: The district court erred massively by using an illegal and unenforceable
lease to grant Plaintiff for judgment regardless of Defendant’s objections and
allegations.

Introduction

Defendant rented the unfurnished apartment, which is located at 2114 SW Wayne

Ave. #5, Topeka, KS 66611, from Plaintiff on May 23, 2022. The rent fee per month was

$565, gas reimbursement $20 per month, and the deposit $200. (R. 1, 220--221)

Plaintiff asked Defendant to prepay $565 for the last month rent (R. 1, 222) plus
 - 13 -

$200 Deposit, total $765 before moving in. However, Plaintiff wrote and specified

$765 as security deposit on the lease regardless of Defendant’s objection in violation of

K.S.A. 58-2550. Also, Plaintiff had been asserting $765 to be the security deposit in the

proceedings.

5. In response to Paragraph 5 of the Counterclaim, states that

Plaintiff [sic] paid an amount equal to one month rent [sic] as
part of his security deposit at the time he moved into the apartment,
but denies that such deposit constitutes the prepayment of rent
for any given month until after the tenant has vacated the apartment.
(Emphasis added) (R. 1, 33)

Furthermore, when Defendant inquired Plaintiff about the apartment charges before

moved in, Plaintiff told Defendant that water was free, and Defendant needed to pay $20

per month gas reimbursement (R. 1, 220--221). But, when Defendant moved in,

Defendant found no gas in the rental apartment. $20 per month gas reimbursement was

changed and specified as water bill on the lease (R. 1, 12). The lease involved in the fraud

in violation of K.S.A. 84-2a-201. Defendant has the right to refuse to answer Plaintiff’s

void contentions based on the illegal and unenforceable lease in Plaintiff’s motion for

summary judgment.

Standard of review and Preservation of the Issue

Plaintiff specified $765 as security deposit on the lease regardless of Defendant’s

objection. The deposit $765 is in excess of one month’s periodic rent $565 in violation of

K.S.A. 58-2550. The lease not only violated K.S.A. 58-2550 on deposit but also involved

in fraud on gas reimbursement in violation of K.S.A. 84-2a-201. “No action may be

maintained, either at law or in equity, to enforce a contract or agreement made in

 - 14 -

contravention of law.” Hunter v. American Rentals, Inc. 189 Kan. 615, 371 P.2d 131

The lease must be deemed illegal and not enforceable by this Court. State, ex rel. Hecht v.

City of Topeka

Analysis

K.S.A. 58-2550 states that “A landlord may not demand or receive a security

deposit for an unfurnished dwelling unit in an amount or value in excess of one month's

periodic rent.”

K.S.A. 84-2a-201 provides that “A writing is not insufficient because it omits or

incorrectly states a term agreed upon, but the lease contract is not enforceable under

subsection (1)(b) beyond the lease term and the quantity of goods shown in the writing.”

(Emphasis added)

The lease with the security deposit of $765 is clearly in violation of K.S.A. 58-2550.

Moreover, in Plaintiff’s void, illegal and inadmissible “Final Account Statement-

Revised”, Plaintiff specified and asserted that $765 was the security deposit. (R. 1, 168).

See following snapshot：

So, it is not material dispute for the lease to specify $765 as the security deposit.

Any lease or contract in violation of the state or federal laws must be deemed illegal and

not enforceable. “The Contract pleaded, being in contravention of Statute and the public

policy of this state, is void and unenforceable and constitutes no defense to Plaintiff’s
 - 15 -

course of action.” “No action may be maintained, either at law or in equity, to enforce a

contract or agreement made in contravention of law.” Hunter v. American Rentals, Inc.

189 Kan. 615, 371 P.2d 131. The lease in violation of K.S.A. 58-2550 must be deemed

illegal and not enforceable.

Furthermore, the lease involved in the fraud because Plaintiff changed $20 per

month gas reimbursement as water bill when Defendant moved in, other than the gas

service as Plaintiff promised in answering Defendant’s inquiry for the expenses of the

rental apartment (R. 1, 220--221). Before Defendant moved in, Plaintiff told Defendant

that water was free, and Defendant needed to pay gas. But, when Defendant moved in,

Defendant found that no gas service in the rental apartment. And, the gas reimbursement

was changed as water bill on the lease by Plaintiff. So, the lease must be deemed void

and illegal, not enforceable in violation of K.S.A. 84-2a-201, either. State, ex rel. Hecht

v. City of Topeka. All contentions based on the illegal and unenforceable lease in

Plaintiff’s motion for summary judgment are void.

In Defendant’s “Memorandum in support of Defendant’s Response in opposition to

Plaintiff’s Motion for Summary Judgment” (R. 2, 110--142), Defendant had clearly stated
that
“Plaintiff asked Defendant to prepay $565 for the last month rent plus
$200 deposit before moving in, total $765. However, Plaintiff wrote $765
as deposit on the lease in violation of the Kansas laws. The lease should be
deemed illegal and as a result, is generally not enforceable.” (R. 2, 110--111)

So, it is in compliance with the Kansas laws and court rules for Defendant not to

answer Plaintiff’s void contentions, which were based on the illegal and unenforceable

lease in Plaintiff’s motion for summary judgment.

 - 16 -

Conclusion

Any lease or contract in violation of the state or federal laws must be deemed illegal

and not enforceable. Defendant has the right not to answer Plaintiff’s void contentions in

its motion for summary judgment. The judgment granted for Plaintiff by the district court

based on the illegal and not enforceable lease must be overturned by this Court.

Issue II: The district court erred massively by hearing and trying Plaintiff void
summary judgment.

Introduction

On March 20, 2023, Plaintiff filed the “Motion for Summary Judgment” (R. 2, 105--

106), and the “Memorandum in support of Washburn South Apartments LLC Motion for

Summary Judgment” (R. 2, 54--104). However, Plaintiff did not pay $195 filing fee for

motion for summary judgment in violation of Kan. Sup. Ct. R. 141. Plaintiff’s motion for

summary judgment must be deemed void due to the violation.

Standard of review and Preservation of the Issue

It’s the material fact for Plaintiff NOT to pay $195 filing fee when Plaintiff filed its

motion for summary judgment. Plaintiff’s motion for summary judgment must be deemed

void. The motion for summary judgment could not be heard by the district court.

Kan. Sup. Ct. R. 141 on summary judgment is not just fluff. McCullough v. Bethany Med.

Center, 235 Kan. 732, 736, 683 P.2d 1258 (1984). Bus. Opportunities Unlimited, Inc. v.

Envirotech Heating & Cooling, Inc., 992 P.2d 1250.

Analysis

Kan. Sup. Ct. R. 141 (a) states that “A motion for summary judgment must be
 - 17 -

accompanied by a filing fee and a memorandum or brief”. (Emphasis added)

Kan. Sup. Ct. R. 141 (f) provides that “A motion for summary judgment may be

heard only when the movant has complied with subsection (a), …..”. (Emphasis added)

Plaintiff did not pay $195 filing fee when Plaintiff filed its motion for summary

judgment in violation of Kan. Sup. Ct. R. 141 (a). So, the district court could not hear

Plaintiff’s motion for summary judgment based on Kan. Sup. Ct. R. 141 (f). Kan. Sup. Ct.

R. 141 on summary judgment is not just fluff--it means what it says and serves a

necessary purpose. McCullough v. Bethany Med. Center, 235 Kan. 732, 736, 683 P.2d

1258 (1984). Bus. Opportunities Unlimited, Inc. v. Envirotech Heating Cooling, Inc., 992

P.2d 1250.

Plaintiff’s motion for summary judgment must be deemed void. The judgment

granted for Plaintiff must be overturned and overruled.

Conclusion

Plaintiff did not pay the filing fee for its motion for summary judgment in violation

of Kan. Sup. Ct. R. 141. Plaintiff’s motion for summary judgment must be deemed void.

Issue III: The district court erred by hearing and trying the void eviction case.

Introduction

Plaintiff filed the eviction case based on the fake assertion that Defendant did not

pay the rent of September, 2022 (R. 1, 1), and the amount $765 on the lease is only

security deposit. (R. 1, 33), (R. 1, 168) & (R. 1, 203)

After Defendant showed the district court the evidence that Defendant prepaid $565

for the rent of last month, and the deposit is only $200 (R. 1, 220--222), Plaintiff had to
 - 18 -

acknowledge the fact that the deposit is only $200, and Defendant prepaid $565 for the

rent of last month in Plaintiff’s Memorandum in support of motion for summary

judgment. (R. 2, 58)

3. In addition, Mr. Zou agreed to pay a $200 security deposit and

pre-pay last month’s rent, for a total initial payment of $765. Orcutt
decl., ⁋ 5, Ex. A, Lease Agreement, P.1.

So, the pretext for Plaintiff to file the eviction case was no longer existed after

Plaintiff admitted that Defendant had prepaid the rent of the last month, and the deposit

was only $200, instead of $765. The eviction case must be dismissed with prejudice.

Standard of review and Preservation of the Issue

Plaintiff could not comply with the landlord duties imposed by Kansas residential

landlord and tenant act. O'Neil v. Durham, 41 K.A.2d 540, 203 P.3d 68 (2009).

K.S.A. 58-2553 & 58-2571 authorize Defendant terminated the lease due to the unsafe

rental apartment and Plaintiff’s unlawful entry. Plaintiff filed the eviction case based on

the fake assertion that Defendant did not pay the rent of September, 2022. After the

assertion was demonstrated being fake and wrong and Plaintiff had to admit that

Defendant prepaid the rent of the last month $565 and the security deposit only $200,

instead of $765, the wrongful eviction case must be dismissed with prejudice.

Analysis

K.S.A. 58-2553 states that “Comply with the requirements of applicable building

and housing codes materially affecting health and safety. If the duty imposed by this

paragraph is greater than any duty imposed by any other paragraph of this subsection,

the landlord's duty shall be determined in accordance with the provisions of this
 - 19 -

paragraph.” (Emphasis added)

K.S.A. 58-2571 provides that “If the landlord makes an unlawful entry, or a lawful

entry in an unreasonable manner, or makes repeated demands for entry otherwise lawful

but which have the effect of unreasonably harassing the tenant, the tenant may obtain

injunctive relief to prevent the recurrence of the conduct, or may terminate the rental

agreement. In either case, the tenant may recover actual damages.” (Emphasis added)

An eviction case may be filed only when a tenant violated the lease. However, in

this case, Defendant never violated the lease. K.S.A. 58-2571 authorizes Defendant could

terminate lease after Plaintiff entered Defendant’s rental apartment without a notice, and

infringed on Defendant’s privacy. Secondly, Defendant’s notebook was stolen by thieves

with passcode and key entrance on August 22, 2022 (R. 1, 18). Plaintiff refused to change

passcode and replace door locker over and over leading to the unsuccessful break-in

happened on September 5, 2022 by passcode entrance (R. 1, 229--231). K.S.A. 58-2553

authorizes that Defendant has a right to terminate lease when Defendant’s safety is

seriously threatened by the unsafe apartment provided by Plaintiff. On August 22, 2022,

Defendant notified Plaintiff that Defendant would break lease and move out by the end of

September, 2022. Defendant would use the prepaid $565 to pay the rent of September,

2022. Plaintiff had admitted that Defendant notified Plaintiff to break lease and use

prepaid $565 to pay the rent of September, 2022 in the “Activity for Zou, Bo (Unit 2114-

5)” (R. 1, 51) and Ms. Crystal Orcutt’s email to Plaintiff’s management. (R. 1, 59)

“I asked if he filed a police report. He wants to break his lease.” (R. 1, 51)

“Mr. Zou paid fist and last month’s rent and deposit upon move-in.
 - 20 -

He would like to use that last month’s rent to pay for September and
he will bring in the water payment. He also expects his deposit back.” (R. 1, 59)

So, Defendant never owed Plaintiff the rent of September, 2022. Plaintiff failed to

comply with the landlord duties imposed by Kansas residential landlord and tenant act.

O'Neil v. Durham, 41 K.A.2d 540, 203 P.3d 68 (2009). Defendant has a right to terminate

the lease pursuant to K.S.A. 58-2553 and K.S.A. 58-2571. Plaintiff’s eviction case must

be dismissed with prejudice.

Conclusion

The district court made a huge error to hear and try a void eviction case. The

eviction case must be dismissed with prejudice.

Issue IV: The district court erred massively by using the illegal, void and
inadmissible “Final Account Statement-Revised” as the basis to grant Plaintiff void
claim and imposed the void financial liability on Defendant.

Introduction

On September 20, 2022, Plaintiff filed the frivolous limited case against Defendant.

In the “Petition for Eviction and Immediate Possession” (R. 1, 1), Plaintiff claimed the

rent in the amount of $630. Defendant moved out on September 22, 2022, and returned

the key on September 23, 2022. So, Plaintiff may not claim over $630 later.

However, on December 5, 2022, Plaintiff sent Defendant a copy of “Final Account

Statement-Revised” via email (R. 1, 168), and noticed the district court by filing “Notice

of Service” on December 6, 2022. (R. 5, 9--10). The district court granted Plaintiff

judgment based on the void, illegal and inadmissible “Final Account Statement-Revised”

regardless of Defendant’s objections and allegations over and over (R. 1, 162--171), (R. 2,
 - 21 -

49--52) & (R. 2, 53--55). The “Final Account Statement-Revised” is void, illegal and

inadmissible because of the following reasons:

(a). The move-out date in the “Final Account Statement-Revised” was forged and

falsified as October 17, 2022 by Plaintiff, instead of actual move-out date September 23,

2022, in order to claim more money. Plaintiff had admitted that Defendant moved out on

September 23, 2022 in “Plaintiff’s Answer to Defendant’s Counterclaim”. (R. 1, 34)

“Plaintiff admits that Defendant returned the

key to Plaintiff on September 23, 2022.” (R. 1, 34)

(b). The “Final Account Statement-Revised” was delivered to Defendant past 30 days

after Defendant moved out in violation of K.S.A. 58-2550.

(c). The “Final Account Statement-Revised” to claim $1,925.16 was void because

Plaintiff had claimed $630 for the rent when Plaintiff filed the eviction case.

(d). The “Final Account Statement-Revised” was void because the security deposit was

specified as $765 in excess of one month’s periodic rent $565 in violation of K.S.A. 58-

2550.

(e). The claim for the rent and late fee of September, October and November is void

because Defendant had notified Plaintiff over and over since August 22, 2022 that

Defendant would break the lease and move out before the end of September, and use

prepaid $565 to pay the rent of September. Defendant’s breaking lease and move-out are

in compliance with K.S.A. 58-2553 & 58-2571 due to Plaintiff’s illegal entry and

negligence of safety.

(f). The claim for clean and damage is void because Plaintiff refused to walk through to
 - 22 -

check the rental apartment twice on September 23 & 26, 2022, respectively.

Standard of review and Preservation of the Issue

How may Plaintiff send the written, itemized list of any amounts it withholds after

Defendant moved out 73 days later? Whether Plaintiff may forge and falsify Defendant’s

move-out date to claim more money. How may Plaintiff claim clean and damage charges

after Plaintiff refused to walk through to check the rental apartment twice on September

23 & 26, 2022, respectively? Whether the district court may use the void and illegal

“Final Account Statement-Revised” with $765 security deposit to grant Plaintiff

judgment. The “Final Account Statement-Revised” is in violation of K.S.A. 58-2550,

K.S.A. 21-3710 and K.S.A. 21-5823. Hunter v. American Rentals, Inc. 189 Kan. 615, 371

P.2d 131.

Analysis

K.S.A. 58-2550 states that “(b) Upon termination of the tenancy, any security

deposit held by the landlord may be applied to the payment of accrued rent and the

amount of damages which the landlord has suffered by reason of the tenant's

noncompliance with K.S.A. 58-2555, and amendments thereto, and the rental agreement,

all as itemized by the landlord in a written notice delivered to the tenant. If the landlord

proposes to retain any portion of the security deposit for expenses, damages or other

legally allowable charges under the provisions of the rental agreement, other than rent,

the landlord shall return the balance of the security deposit to the tenant within 14 days

after the determination of the amount of such expenses, damages or other charges, but in

no event to exceed 30 days after termination of the tenancy, delivery of possession and
 - 23 -

demand by the tenant. If the tenant does not make such demand within 30 days after

termination of the tenancy, the landlord shall mail that portion of the security deposit due

the tenant to the tenant's last known address.

(c) If the landlord fails to comply with subsection (b) of this section, the tenant may

recover that portion of the security deposit due together with damages in an amount

equal to 1½ the amount wrongfully withheld.”

Under K.S.A. 21-3710 (a), one commits forgery by “(1) Making, altering or

endorsing any written instrument in such manner that it purports to have been made, ….;

(2) issuing or delivering such written instrument knowing it to have been thus made,

altered or endorsed; or”; (3) possessing, with intent to issue or deliver, any such written

instrument knowing it to have been thus made, altered or endorsed.

Under K.S.A. 21-3710 (b) (1), “Forgery is a severity level 8, nonperson felony.”

K.S.A. 21-5823 provides that “(a) Forgery is, with intent to defraud (1) Making,

altering or endorsing any written instrument in such manner that it purports to have been

made, altered or endorsed by another person, either real or fictitious,…….”

In the “Final Account Statement-Revised”, Plaintiff blatantly forged and falsified

Plaintiff’s move-out date as October 17, 2022, instead of actual move-out date September

23, 2022, in order to claim more money. Plaintiff’s forgery happened during the

proceedings. So, both K.S.A. 21-3710 and K.S.A. 21-5823 was triggered. That Plaintiff

and its attorneys knowingly delivered a forged written instrument, by themselves, was

sufficient to support forgery conviction. State v. Foster, 298 Kan. 348, 312 P.3d 364.

Kansas Supreme Court cases had concluded an individual had falsified documents based
 - 24 -

on evidence that he or she had created or altered a document. See In re Ware, 279 Kan.

884, 889, 112 P.3d 155(2005). (disciplining attorney/employee in part for tampering with

company’s internal records to make it appear she was working on a matter when she had

not); In re Eastepp, 258 Kan. 766, 767-69, 907 P.2d 842(1995). (disciplining

attorney/employee in part for having car titles modified to appear that company cars had

been sold to private individuals where no sale occurred). So, Plaintiff and its attorneys

must be sanctioned by this Court. The “Final Account Statement-Revised” must be

deemed illegal and unenforceable.

Moreover, the “Final Account Statement-Revised” to claim $1,925.16 was void

because Plaintiff had claimed $630 for the rent and loss when Plaintiff filed the eviction

case on September 20, 2022. Defendant moved out on September 23, 2022. Plaintiff

cannot change the eviction claim again. Also, the clean and damage charges are void

because Plaintiff refused to walk through to check the rental apartment twice on

September 23 & 26, 2022, respectively. (R. 1, 224--225)

Furthermore, Plaintiff sent the “Final Account Statement-Revised” to Defendant

after Defendant moved out 73 days later. It is clearly in violation of K.S.A. 58-2550,

which states that “all as itemized by the landlord in a written notice delivered to the

tenant” in 30 days. Otherwise, “the tenant may recover that portion of the security

deposit due together with damages in an amount equal to 1½ the amount wrongfully

withheld.” Plaintiff never delivered Defendant a written, itemized list of any amounts it

withholds in 30 days after Defendant moved out on September 23, 2022, until December

5, 2022. So, the “Final Account Statement-Revised” must be deemed void and
 - 25 -

unenforceable. Defendant must be granted 1½ times amounts of the security deposit, total

$300 recovery on the security deposit pursuant to K.S.A. 58-2550(c). Geiger v. Wallace,

233 K. 656, 657, 659, 660, 664 P.2d 848 (1983)

Also, the “Final Account Statement-Revised” is in violation of K.S.A. 58-2550 by

stating and specifying the security deposit as $765 in excess of one month’s periodic rent

$565. The “Final Account Statement-Revised” must be deemed void and unenforceable.

Hunter v. American Rentals, Inc. 189 Kan. 615, 371 P.2d 131. State, ex rel. Hecht v. City

of Topeka.

Conclusion

Plaintiff’s “Final Account Statement-Revised” is illegal, void and inadmissible. The

district court wrongfully used Plaintiff’s “Final Account Statement-Revised” as the basis

to grant Plaintiff void claim and imposed the void financial liability on Defendant. The

wrongful judgment granted for Plaintiff by the district court based on the illegal, void and

inadmissible “Final Account Statement-Revised” must be overturned and deemed void.

Issue V: The district court erred by not stating Defendant’s controverted facts and
factual evidence in the memorandum decision and order and further denying them
without any reason in violation of the Kan. Sup. Ct. R. 141 & 165, K.S.A. 60-252.

Introduction

In the memorandum decision and order (R. 2, 234--261) filed June 2, 2023, district

judge Teresa L. Watson did not state Defendant’s controverted facts and factual evidence.

Defendant’s all controverted facts and factual evidence are marked numbers, no contents

in the memorandum decision and order, and further were denied without reasons. (R. 2,
 - 26 -

245--247). The followings are excerpts of Defendant’s controverted facts and factual

evidence listed in the memorandum decision and order: (R. 2, 245--247).

1. This fact is duplicative of Washburn South’s facts 1 and 2

and is not supported by a cite to the record.
2. This fact is duplicative of Washburn South’s fact 2 and is not
supported by a cite to the record.
3. This fact is, in large part, duplicative of Washburn South’s
fact 3 and the balance is not supported by a cite to the record.
Zou alleges that a representative of Washburn South entered
his apartment without notice, “contacted” his personal items
and foods, and turned on the air conditioner. He says the
affidavit of Jones attached to Washburn South’s motion
“forged the pretext” that Jones gave him notice of the
maintenance visit. Zou’s cite to his Exhibit 1 does not
support his allegations.
5. This fact is not supported by a cite to the record.
6. This fact is not supported by a cite to the record.
7. This fact is not supported by a cite to the record.
8. Zou alleges the contents of a conversation with a police
officer to the effect that he should move out of the apartment.
The fact is not supported by the cite to Zou’s Exhibit 2, which
is a police report, not evidence of the police officer’s alleged
comments.
9. Zou alleges the contents of some of his conversations with
Washburn South’s representative. Zou’s version is not supported
by the cite to his Exhibits 1 and 3.
10.Zou describes an incident in September where people were
knocking on his door asking for “Susan” and Zou called the
police multiple times.
11.Zou alleges that on September 6, 2022, he notified
Washburn South of an attempted break in at his apartment and
that he planned to break the lease and move out. The rest of his
allegations are not supported by his cite to Exhibit 3.
12.Zou states that he filed a related small claims case against
Washburn South, 2022-SC129.
13.Zou alleges he filed a written “Notice of Breaking Lease
and Moving Out” on September 11, 2022. This is duplicative of
Washburn South’s fact 48.
14.Zou states the amount of damages initially sought in the instant
case by Washburn South and the amount of damages he seeks in his
counterclaims.
15.Zou alleges that he submitted a moving out notice and refund
 - 27 -

request on September 23, 2022. Zou’s cite to his Exhibit 7 does not
support the balance of his allegations.
16. This fact is not supported by a cite to the record.
17. Zou alleges that on September 26, 2022, he requested in writing
that Washburn South check his apartment again and asked for a
refund of $320.34. Zou’s cite to his Exhibit 8 does not support the
balance of his allegations.

Standard of review and Preservation of the Issue

Defendant’s controverted facts and factual evidence were not stated in the

memorandum decision and order, instead of being shown by number, and further denied

without reasons. The district court violated Kan. Sup. Ct. R. 141 & 165 and K.S.A. 60-

252. Burcham v. Unison Bancorp, Inc., 276 K. 393, 77 P.3d 130 (2003). The summary

judgment must be overturned and overruled by this Court. Schoof v. Byrd, 197 K. 38, 46,

415 P.2d 384; Read v. Estate of Davis, 213 K. 128, 135, 136, 515 P.2d 1096.

Analysis

Kan. Sup. Ct. R. 141 states that “When granting a motion for summary judgment,

the court must state its findings of fact and conclusions of law in compliance with Rule

165.”

Kan. Sup. Ct. R. 165 provides that “In a contested matter submitted to the court

without a jury—and when the court grants a motion for summary judgment—the court

must state its findings of fact and conclusions of law in compliance with K.S.A. 60-252”

K.S.A. 60-252 states that “In an action tried on the facts without a jury or with an

advisory jury or upon entering summary judgment, the court must find the facts specially

and state its conclusions of law separately. The findings and conclusions may be stated

on the record after the close of evidence, or may appear in an opinion or a memorandum
 - 28 -

of decision filed by the court.”

District judge Teresa L. Watson failed in stating Defendant’s controverted facts and

factual evidence in the memorandum decision and order. Defendant’s controverted facts

and factual evidence were listed as numbers without contents, and further denied without

findings and reasons. Judge Watson failed to make findings of fact necessary to correctly

apply law. Froelich v. Adair, 213 K. 357, 359, 516 P.2d 993. The denials of Defendant’s

controverted facts and factual evidence without findings are in violation of Kan. Sup. Ct.

R. 141 & 165, and K.S.A. 60-252. Burcham v. Unison Bancorp, Inc., 276 K. 393, 77 P.3d

130 (2003). The summary judgment must be overturned and overruled by this Court.

Schoof v. Byrd, 197 K. 38, 46, 415 P.2d 384; Read v. Estate of Davis, 213 K. 128, 135,

136, 515 P.2d 1096.

Conclusion

The district court failed in stating Defendant’s controverted facts and factual

evidence in the memorandum decision and order, and further denied the controverted

facts and factual evidence without finding in violation of Kan. Sup. Ct. R. 141 & 165,

and K.S.A. 60-252. The judgment granted for Plaintiff must be overturned and overruled.

Issue VI: The district court erred by failing to state the conclusion of law in denying
Defendant’s “Motion for Sanctions on Plaintiff’s perjury, forgery and falsification on
documents, and contempt of the court” and denying twice hearing requests to cover
up and help Plaintiff’s nefarious and criminal behaviors.

Introduction

Defendant’s “Motion for Sanctions on Plaintiff’s perjury, forgery and falsification

on documents, and contempt of the court” (Hereinafter “Motion for Sanctions”) is the
 - 29 -

key and very important document in denying Plaintiff’s motion for summary judgment

and seeking judgment in favor of Defendant. Defendant had provided the following

factual evidence for the district court.

A. Plaintiff forged and falsified “Service request 3679-1” and “Activity for Zou, Bo (Unit:

2114-5)” in “Plaintiff’s Response in opposition to Defendant’s Request for Continuance”.

(R. 1, 151--154)

B. Plaintiff committed perjury and was in contempt of the court.

1. Plaintiff committed perjury for the security deposit $765 on lease. (R. 1, 154--155)

2. Plaintiff forged and falsified the fake declarations made by Plaintiff’s former manager

Julie Jones; (R. 1, 155--156)

3. Ms Crystal Orcutt committed perjury and was in contempt of the court; (R. 1, 156--158)

4. Plaintiff committed perjury by asserting Defendant submitted a maintenance request

for the repair of the refrigerator door handler on May 26, 2022. (R. 1, 158)

However, district judge Teresa L. Watson knowingly and completely ignored and

never considered the factual evidence, and further denied Defendant’s motion for

sanction with the pretext which is not existed in law.

Standard of review and Preservation of the Issue

It is material facts for Plaintiff to forge and falsify the documents in violation of

K.S.A. 21-3710 and K.S.A. 21-5823. In Kansas, forgery is the making, altering, or

endorsing of a written instrument, with intent to defraud; issuing or delivering such

written instrument knowing it to have been thus made, altered or endorsed.

State v. Foster 46 Kan. App. 2d 233 264 P.3d 116. In re Ware, 279 Kan. 884, 889, 112
 - 30 -

P.3d 155. Plaintiff’s forgery happened in the proceedings. So, both K.S.A. 21-3710 and

K.S.A. 21-5823 are triggered. The district court denied Defendant’s “Motion for

Sanctions” in violation of K.S.A. 60-211, K.S.A. 21-3710 and K.S.A. 21-5823.

Analysis

K.S.A. 60-211 (b)(2) provides that “the claims, defenses and other legal contentions

are warranted by existing law or by a nonfrivolous argument for extending, modifying or

reversing existing law or for establishing new law;”

K.S.A. 60-211 (c) states that “If, after notice and a reasonable opportunity to

respond, the court determines that subsection (b) has been violated, the court may impose

an appropriate sanction on any attorney, law firm or party that violated the statute or is

responsible for a violation committed by its partner, associate or employee.”

K.S.A. 21-3710 provides that “(1) Making, altering or endorsing any written

instrument in such manner that it purports to have been made, ….; (2) issuing or

delivering such written instrument knowing it to have been thus made, altered or

endorsed; or”.

K.S.A. 21-5823 provides that “(a) Forgery is, with intent to defraud (1) Making,

altering or endorsing any written instrument in such manner that it purports to have been

made, altered or endorsed by another person, either real or fictitious,……..

(2) issuing or distributing such written instrument knowing it to have been thus made,

altered or endorsed; or ………………………….

(b) (1) Forgery is a severity level 8, nonperson felony.”

 - 31 -

Defendant had provided the factual evidence on Plaintiff’s forgery, perjury and

contempt of the court for the district court, including forgery and falsification on

A. “Service request 3679-1”. (R. 1, 50)

1. Plaintiff falsified and forged the document “Service Request #3679-1”,

which was submitted to the Court by Plaintiff. See Exhibit 1.
The “Service Request #3679-1” was falsified and forged as follows:
(a). From the “Service Request #3679-1”, the Court can see that the
request is unassigned. Nobody was assigned to do the work.
(b). The “Service Request #3679-1” was signed by the former manager
Ms. Julie, not by maintenance employee. Plaintiff cannot show who was
assigned for the job.
(c). Plaintiff may arbitrarily falsify and forge any service requests.
For example, even if Plaintiff moved out on September 22, 2022, and
returned the key on September 23, 2022, but, Plaintiff forged
#3998-1 for sink leak maintenance on September 29, 2022. See Exhibit
2. It demonstrates that Plaintiff may arbitrarily falsify and forge a service
request using Defendant’s name. (d). The “Service Request #3679-1”
was created by Kelly Jestice on May 26, 2022. But, Defendant just moved in
on May 23. 2022. Defendant finished the check list and submitted the issues
of the apartment, including photos to Plaintiff on May 31, 2022. See Exhibit 3.
Defendant never requested any maintenance jobs. Plaintiff forged the date and
the document for maintenance. Moreover, on Plaintiff’s records “Activity for
Zou, Bo (2114-5)” (See Exhibit 4), there is not any records for Defendant to
go Plaintiff’s leasing office on May 26, 2022. Defendant never went to
Plaintiff’s leasing office on May 26, 2022. Defendant never submitted any
requests to ask Kelly Jestice to fix the refrigerator door handle, either.
(e). Plaintiff cannot provide for the Court Defendant’s written request.
According to Paragraph 9 “REPAIRS AND MALFUNCTIONS” of
“ADDITIONAL LEASE PROVISIONS” of the lease signed by both parties,
it’s a must for tenant to make all requests for repairs and services in
writing to Landlord’s designated representative. (f). Plaintiff cannot provide
for the Court the work order assigned to the maintenance employee Mr. James.
The size of work order is about one third of A4 paper. Plaintiff only showed
the Court a maintenance employee to do the job. Who is the maintenance
employee to enter Defendant’s apartment? This is the most key figure to
demonstrate Plaintiff’s illegal entry. The maintenance employee Mr. James
clearly told Defendant that no maintenance employee entered Defendant’s
apartment to fix the refrigerator handle on June 6, 2022. Defendant has been
asking Mr. James to appear as witness. But, Plaintiff refused the request and
refused to provide Mr. James’ any contact information. Defendant asked Plaintiff
to permit Mr. James appears as witness, or provide Mr. James’ contact information.
 - 32 -

(g). Plaintiff cannot show the Court Defendant’s signature on the

completed work order. A completed work order needs the tenant to sign
on it to confirm maintenance job finished.
So, Plaintiff forged the document “Service Request #3679-1” without any
questions. (R. 2, 151--152)

B. “Activity for Zou, Bo (Unit: 2114-5)” for the district court (R. 1, 51--52).

2. Plaintiff modified and forged Plaintiff’s records “Activity for Zou, Bo (2114-5)”.
See Exhibit 4.
(a). On the Plaintiff records “Activity for Zou, Bo (2114-5)”, Plaintiff blatantly
forged the record for Ms. Crystal Orcutt worked on Sunday (05/22/2022).
See Exhibit 4.

May 22, 2022 is Sunday. But, Ms. Crystal Orcutt never worked
on that day or weekend. The employee worked on that day is Plaintiff’s weekend
employee Ms. Yvett Hobson. When Defendant came to Plaintiff’s leasing office
on May 22, 2022, Defendant asked Ms. Yvett Hobson to show Defendant the
unit 2114-5 first. When Defendant found that the unit is too dirty, Defendant
refused to sign the lease. Defendant’s activity was recorded on Plaintiff’s
weekly report by Ms. Yvett Hobson. See Exhibit 5, Pg. 2.

(b). Defendant went to Plaintiff’s office to ask why Plaintiff illegally entered
Defendant’s rental apartment without a notice on June 7 & 8, 2022, respectively.
However, on the Plaintiff records “Activity for Zou, Bo (2114-5)”, Plaintiff
could not show any Defendant’s activities between June 7, 2022 and July 3, 2022.
(c). Plaintiff deleted Defendant’s activities between August 23, 2022 and
September 6, 2022. Defendant had gone to Plaintiff’s office several times
to notify Plaintiff to break lease since August 22, 2022. Plaintiff also
mentioned Defendant’s activities to go Plaintiff’s leasing office between
August 29, 2022 and September 6, 2022 in the property manager Ms. Crystal
Orcutt’s email dated on September 6, 2022. See Exhibit 6.
“Honestly, Mr. Zou has been in the office almost every
day for the last week and comes in on weekends and
harasses the weekend agent. I would like to get the issue
 - 33 -

resolved and let him get on his way” (Emphasis added)

But, there are not any Defendant’s activities between August 29, 2022
and September 6, 2022 on Plaintiff’s records “Activity for Zou, Bo (2114-5)”.
Plaintiff deleted all the records from August 23 to September 7, 2022.
(d). On September 11, 2022, Defendant went to Plaintiff’s office by hand
delivering Defendant’s “Notice for Breaking lease and Moving out”.
See Exhibit 7. But, in Plaintiff’s records “Activity for Zou, Bo (2114-5)”,
Plaintiff deleted Defendant’s activity to go Plaintiff’s leasing office to hand
deliver Defendant’s notice. Plaintiff modified, deleted and forged the
records. Plaintiff should be sanctioned by the Court. (R. 2, 153--154)

Also, Plaintiff committed perjury for the security deposit $765 on lease. Plaintiff

forged and falsified the fake declarations by Plaintiff’s former manager Julie Jones (R. 2,

155--156). Ms. Crystal Orcutt committed perjury and was in contempt of the court (R. 2,

156--158). Plaintiff committed perjury by asserting Defendant submitted a maintenance

request for the repair of the refrigerator door handler on May 26, 2022 (R. 1, 32). But,

Plaintiff could not provide the written maintenance request signed by Defendant for the

district court.

1. In response to Paragraph 1 of the Counterclaim, states that

Defendant submitted a maintenance request for the repair of his
refrigerator door handle on May 26, 2022. A maintenance technician
made the repairs on June 13, 2022. (Emphasis added) (R. 1, 32)

However, district judge Teresa L. Watson knowingly ignored and never considered

the factual evidence, by asserting that “Zou did not set forth any evidence that supported

his allegations.”; and further denied the “Motion for Sanctions” by asserting that “He

made various claims about the nefarious activity of Jones and Orcutt in his motion for

sanctions but did not attach an affidavit from him or anyone else with facts supporting
 - 34 -

his allegations. He did not set forth any legal authority for imposing sanctions other than

a criminal statute which does not authorize sanctions in a civil case. Zou’s motion for

sanctions is denied.” (R. 2, 258) (Emphasis added)

Judge Watson openly ignored Defendant’s factual evidence and asserted “Zou did

not set forth any evidence that supported his allegations.” to help Plaintiff.

Moreover, judge Watson could not state which Kansas law needs an affidavit in

support of motion for sanction. So, judge Watson’s denial evidently violated K.S.A. 60-

211 and K.S.A. 21-5823. In re Marriage of Stockham, 23 K.A.2d 197, 199, 928 P.2d 104

(1996)

District judge Teresa L. Watson should be the first district judge openly help and

cover up the forgery, perjury and contempt of the court in the United States.

Judge Watson failed to state the conclusion of law against Defendant’s numerous

facts to allege Plaintiff’s forgery and falsification on documents, perjury and contempt of

the court. Plaintiff must be sanctioned for its misconducts and criminal behaviors.

McCabe v. Hoch, 42 K.A.2d 747, 216 P.3d 720 (2009).

Furthermore, District judge Teresa L. Watson denied Defendant’s twice hearing

requests to deprive Defendant of the factual evidence heard by the district court.

Conclusion

District judge Teresa L. Watson knowingly ignored the factual evidence to allege

Plaintiff on documents forgery, perjury and contempt of the court, and failed to state

conclusion of law to deny Defendant’s motion for sanctions. District judge Teresa L.

Watson’s denial order must be overturned by this Court. Plaintiff must be sanctioned
 - 35 -

pursuant to K.S.A. 60-211, K.S.A. 21-3710 and K.S.A. 21-5823.

Issue VII: The district court erred by violating the Kan. Sup. Ct. R. 360 to cheat
Defendant “No Audio Recording of 12/7/22 Hearing” and depriving of Defendant’s
equal rights in the proceedings in violation of Kan. Const. Bill of Rights §1.

Introduction

On December 2, 2022, Defendant filed “Request for Court Reporter and Language

Interpreter” (R. 5, 6--7) to request the hearing of December 7, 2022 should be recorded.

“Moreover, Defendant requests that the hearing should be

recorded digitally. Defendant will request the digital recording
and the transcripts after the hearing” (R. 5, 6)

On December 7, 2022, the district court held a hearing for the case. During the

hearing, district judge Teresa L. Watson had shown huge prejudice against Defendant.

Defendant was prohibited from speaking English to judge Watson. Defendant may only

speak his native language to the interpreter Jinhua Zhu. Defendant was not given 15

minutes oral argument. Especially, Judge Watson actively extended the discovery without

any requests from both parties in order to let Plaintiff amend petition. And, Judge Watson

actively asked whether Plaintiff would file motion for summary judgment, etc.

On December 8, 2022, Defendant requested the audio recording pursuant to Kan.

Sup. Ct. R. 360. A party to request audio recording is granted by the district court, too.

The request form was made by the district court. (R. 1, 177).

On December 15, 2022, the clerk of the district court told Defendant that district

judge Teresa L. Watson said the hearing was not recorded. The docketing record of the

district court shows “No Audio Recording of 12/7/22 Hearing” (R. 6, 5).
 - 36 -

On December 16, 2022, Defendant immediately filed “Request for Electronic

Recording of the Hearing” (R. 1, 205--207). In the request, Defendant stated as follows:

“On December 7, 2022, the Court reporter Ms. Shawn Hoff

appeared the hearing. However, there was not a computer or
recording equipment set on her table. Ms. Hoff did not type or
write by pen or other tools. Ms. Hoff only sat on the chair and
did nothing.” (R. 1, 205)
“After the Court admitted that NO audio recording existed
for the hearing, now, Ms. Hoff said that the transcript may
be produced. If so, there must be an electronic recording
existing for the hearing because Ms. Hoff did not type or
write by pen or other tools during the hearing of December
7, 2022.
The electronic recording for the hearing is very important for
the case. The electronic recording for the transcript will
demonstrate how huge prejudice Judge Watson had against
Defendant, how Defendant’s motions were denied without any
reasons and the law, and verify whether the transcript is authentic
and accurate. Defendant needs the recording to file Defendant’s
objections to Judge Watson’s rulings by December 21, 2022.” (R. 1, 206)

The district court never ruled Defendant’s “Request for Electronic Recording of the

Hearing”. Defendant’s “Request for Electronic Recording of the Hearing” is still

pending in the district court. It means that the district court does not finish the case, yet.

The judgment must be overturned by this court.

Around January 26, 2023, Defendant received the transcripts mailed by court

reporter Shawn Hoff on January 23, 2023. (R. 6, 6). Defendant found that a lot of key

contents of 12/7/22 hearing were modified or forged. So, Defendant filed a complaint

against court reporter Shawn Hoff to the Kansas Board of Examiners of Court Reporter

on February 15, 2023. The Kansas Board of Examiners of Court Reporter found that the

audio recording of 12/7/22 hearing had been existing in the district court.
 - 37 -

On July 28, 2023, Defendant filed “Request for Audio Recording” to the district

court again. (R. 2, 266). But, the district court never answered Defendant and refused to

release the audio recording to Defendant without reason.

On August 17, 2023, Defendant filed “Request for Audio Recording on Appeal” (R.

2, 288--289) to request that the audio recording is added in the Record on Appeal

pursuant to Kan. Sup. Ct. R. 3.02(d).

Standard of review and Preservation of the Issue

The district court cheated Defendant by asserting “No Audio Recording of 12/7/22

Hearing” in violation of Kan. Sup. Ct. R. 360 and was without basic judge professional

moral. Also, the district court violated Kan. Const. Bill of Rights §1 to deprive of

Defendant’s equal rights in the proceedings. Hodes & Nauser, MDs, P.A. v. Schmit 309

Kan.610 440 P.3d 461.

Analysis

Kan. Sup. Ct. R. 360 states that “A district court may provide for the electronic

sound recording of court proceedings by use of equipment that meets specifications

approved by the Supreme Court.”

Kan. Const. Bill of Rights §1 provides that “All men are possessed of equal and

inalienable natural rights, among which are life, liberty, and the pursuit of happiness.”

The district court cheated Defendant by asserting that “No Audio Recording of

12/7/22 Hearing” to cover up the huge prejudice against Defendant, and the misconducts

to actively extend the discovery without any requests from both parties in order to let

Plaintiff amend petition. And, Judge Watson actively asked whether Plaintiff would file
 - 38 -

motion for summary judgment, etc.

Moreover, the district court let the court reporter Shawn Hoff modify and forge

some key contents of the transcripts to cover up the misconducts of judge Watson and

make Defendant lose the lawsuit.

The district court has seriously infringed on and deprived of Defendant’s equal

rights in the proceedings. The judgment for Plaintiff must be overturned and overruled by

this Court because the district court refused to release the audio recording to Defendant,

and modified and forged the transcripts which were relative to the judgment decision, and

infringed on and deprived of Defendant’s equal rights in the proceedings. Hodes &

Nauser, MDs, P.A. v. Schmit, 309 Kan.610 440 P.3d 461.

Any order or judgment in violation of the Kansas Constitution must be overturned.

Conclusion

The district court refuses to provide audio recording for Defendant in violation of

Kan. Sup. Ct. R. 360 and deprived of Defendant’s equal rights in the proceedings in

violation of Kansas Constitution Bill of Right §1. The judgment based on the forged and

modified transcripts must be overturned and overruled by this Court.

Conclusion

For the aforementioned reasons, Plaintiff respectfully requests and prays that this

Court (1) overturn and overrule the judgment granted for Plaintiff; (2) dismiss the

frivolous and void eviction case with prejudice; (3) sanction Plaintiff and its attorneys on

perjury. documents forgery and contempt of the court; (4) grant Plaintiff judgment for

$497.83 refund and counterclaim $24,670.00 plus court cost and other expenses. (R. 2,
 - 39 -

123--124)

Respectfully Submitted,

Bo Zou

6000 SE 2nd Street

Tecumseh, KS 66542
Tel: (713)835-8655
E-mail: bzksls19@gmail.com

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the Brief of Appellant was sent by United
States Mail, postage prepaid, and by email on the 20th day of October 2023, to:

Sarah E. Stula
7500 College Blvd. Suite 1400
Overland Park, KS 66210
sstula@foulston.com

Amy S. Lemley
1551 N. Waterfront Parkway, Suite 100
Wichita, KS 67206
alemley@foulston.com

Name: Bo Zou
 APPENDIX
APPENDIX OF CRITICAL DOCUMENTS CITED
IN DEFENDANT'S BRIEF

Defendant submits copies or excerpt of the following critical documents which are
cited in its Brief to facilitate this Court for review.

1. A true and correct copy of the “Notice of Breaking Lease and Moving Out” dated
09/11/2022. (R. 1, 22--23)

2. A true and correct copy of the “Moving out Notice and Refund Request” dated
09/21/2022. (R. 1, 25)

3. A true and correct copy of the “Request to Check Apt. (2114 building #5) and Refund
Correction” dated 09/26/2022. (R, 1, 171)

4. A true and correct copy of the “Police Report” dated 08/22/2022. (R, 1, 18)

5. A true and correct copy of the “Police Call Note” dated 09/05/2022. (R. 1, 229--231)

6. A true and correct copy of requiring Defendant to prepay the last month rent (R. 1,
220--222). And “Petition for Eviction and immediate Possession” (R. 1, 1) by Plaintiff.

7. A true and correct copy of “K.S.A. 60-245 Subpoena to Produce Documents,

Information, or….” (R. 1, 117--118) and Judge Watson’s order to intercept the Subpoena.
(R. 1, 120)

8. A true and correct copy of “Final Account Statement-Revised” (R. 1, 168) by Plaintiff.

9. A true and correct copy of the “Request for Electronic Recording of the Hearing”
(R. 1, 205--206) filed by Defendant.

10. A true and correct excerpt of “Motion for Sanctions on Plaintiff’s perjury, Forgery
and Falsification on Documents, and contempt of the Court” (R. 2, 150-158) filed by
Defendant.

11. A true and correct copy of “Motion for on-site Hearing.” (R. 2, 214)

12. Three true and correct copies of “Request for Audio Recording”, three times requests
for two hearings dated 10/25/2022, 12/07/2022. (R. 1, 93), (R. 1, 177), (R. 2, 266)
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