COMES NOW Plaintiffs Janet D. McDonald and James B. Stegeman and file Plaintiffs’ Reply to Defendants’ Response to Motion to Void This Court’s June 11, 2008 Order Dismissing Plaintiffs’ Case With Prejudice. Counsel for Georgia Power, infamous for changing Plaintiffs’ pleadings and requests, has attempted to change Plaintiffs’ Motion and Brief In Support of Motion To Void This Court’s June 11, 2008 Order Dismissing Plaintiffs’ Case With Prejudice into a Motion to Recuse. The complaint Plaintiffs filed stated on the first page, second ¶ stated that Plaintiff Stegeman is “100% Federally disabled”; page 17 ¶127: “…Stegeman is a Federally disabled individual, a member of a protected class”; page 17 ¶128: “Plaintiffs informed “Georgia Power” as well as the State Troopers that he is a disabled individual”; Plaintiffs have repeatedly requested that Judge Becker and Superior Court abide by the law. It is

oversees and reviews title examinations. 4. before Georgia Power Nancy Huddleston’s letters to Plaintiffs and before the cutting of Plaintiffs’ trees. c. thus assuring that Summary Judgment will be granted in favor of Defendants/counterclaimants. 8. see Exhibit 1” showing the Docket Report for March 6. 2009.". Marcus Calloway. a reformation of the handwritten 1941 easement document was performed in further violation of Georgia law.G. LLC. returned Plaintiffs’ stamped “Filed” copies to them. in August 2007. Plaintiffs’ presented the documents. Defendants’ responsive objections overlook several facts: 1.not necessary for a disabled individual to file with the Court Judicial Notice for a party’s ADA Title II Rights to be observed by a Judge. and the Georgia and United States Constitutions. they must assume that nothing was filed. 13. 2008 Order Dismissing Plaintiffs’ Case With Prejudice Judicial Notice of Plaintiff Mr. Plaintiffs’ Motion and Brief In Support of Motion To Void This Court’s June 11. Managing attorney of Calloway Title and Escrow. The Ruling was the direct result of fraud and fraud upon the Court. the clerk stamped the documents.C. had already performed an examination/investigation into the documents and at that same time. Title II Plaintiffs’ Brief In Opposition to Defendants/Counterclaimants’ Motion for Summary Judgment b. Stegeman’s Invocation of His Rights Under American’s With Disabilities Act. The documents did not show on the docket until on or around March 25. who performs title searches. 2. Judge Becker failed to follow legal procedure set out in O. The Court conveniently refused to file the following documents for a period of time 1: a. Records together with Affidavit of Affidavit S. 1 2 . See “Exhibit 1” The documents were hand delivered. Plaintiffs have no way of knowing what is actually filed at this point. §44-2-40 “The Land Registration Law. 5. 3.A. Judge Becker violated her Oath of Office. a Ruling in violation of due process of law. In violating “The Land Registration Law”. 25.

Plaintiffs’ Statements for the Record and Judicial Notice. REFUSAL TO FILE PLAINTIFFS’ PLEADINGS Plaintiffs on more than occasion approached the Court/Judge Becker on the matters concerning the filing of their pleadings.2 Plaintiffs began having to hand deliver everything they filed to get their pleadings filed the day the Court received them. not the Judge. this case was a done deal as soon as the illegal reformation was performed August 2007. on February 24. yet there is no stamped survey included with the Affidavits. b. 7. a. only a Jury can make a determination. Plaintiffs more thoroughly discuss these issues. that Judge Becker gave the Order to perform the reformation August 2007. yet defendants/counterclaimants documents were and continue to be filed the same day they are mailed to the Court. docketing.. not that it will matter. but the Exhibits included are after the photos have been manipulated. 2 See Petition to Correct the Docket. Judge Becker refused to allow the filing of Plaintiffs’ Objections to Video depositions until after the date of the depositions then mailed them back to Plaintiffs unfiled. One can only come to the most logical conclusion…since according to “The Land Registration Law”. and c. 3 . The Court withheld knowledge. from back to front is enclosed with a fence and the property is gated. Affidavits indicate that two different entities claim to have surveyed. the handwritten 1941 easement document could not be changed without a Superior Court Judge signing an Order. Two different entities make claims about aerial photos of Plaintiffs’ property. 8. and opposition continues to specify the “handwritten 1941” document. which were hand delivered to the Court. and not one of them show or mention that Plaintiffs’ entire property. and mailing of its’ Orders for ten or more days. In the following.. For the relief sought by defendants/counterclaimants. there is a 6-12’ tall x 100’ wide granite wall at the very front of Plaintiffs property.6. 2009 Plaintiffs hand delivered the documents listed in 1. I. And lately. above. or that there are “No Trespassing” signs.

The document with the 4 .G. Stegeman’s Invocation of His Rights Under American’s With Disabilities Act. who shall discharge the duties provided for the examiner in this article but whose relation and accountability to the court shall be that of an auditor in the general practice existing in this state. §442-100: The judge of the superior court of each judicial circuit shall appoint at least one auditor.G. Stegeman is a protected class. whether the opposition. Furthermore. the Affidavit signed January 2009 for acts performed in August 2007 shows fraudulent concealment. §44-2-61: all proceedings in the court in relation to registered land shall be proceedings in rem against the land. Especially note the Certification date on the Certified document. An Affidavit by an entity paid by the opposing party does not excuse Judge Becker from appointing the examiner of title as provided for in Georgia’s “Land Registration Law”. He is protected under The American’s With Disabilities Act as well as several other civil rights protections that opposition.C. or the whole of Superior Court approves or not. He does not have to file Judicial Notice of Plaintiff Mr. Judge Becker failed to appoint an examiner of title as mandated in O. see O. “Exhibit 1” contains the rest of the pertinent statute involved in requests for relief of the kind requested by defendants/counterclaimants. not all of the documents were provided with the affidavit. II. who shall be known as the examiner.A.C. There is only one logical explanation: prejudice/bias/discrimination. Plaintiffs’ land has not been brought under jurisdiction of the Court. Judge Becker.A. and the outcome of the case was determined from the beginning. “Exhibit 2” contains documents provided to Plaintiffs by Nancy Huddleston. Title II for his Rights to be enforceable. THE LAND REGISTRATION LAW Judge Becker and her infinite wisdom does not replace Georgia’s “Land Registration Law”. and does not excuse to process required. then notice the signature of the Superior Court clerk as pointed out on the other documents. Judge Becker and Superior Court as a whole wants to ignore. and he does not have to put the entities on Notice of the fact.Plaintiff Mr.

Logically. were perjury. One such result manifested just recently when a prominent cancer researcher was murdered by a multiple criminal offender Judge Becker allowed out of jail as a first-offender on “time served” when he legally should have been in jail for several years. not only concerning Plaintiffs’ case.Certification by Superior Court August 2007 clearly shows that the 1941 handwritten document has been reformed. Judge Becker has shown a pattern of ignoring Georgia’s Law. and Amendments thereto show that they knew when they swore that their answers had been thoroughly investigated. see “Exhibit 3” Clearly Judge Becker’s Judgment is VOID. and the Court ignored that if there is a legal. but by many others as well concerning Plaintiffs’ property. but other cases as well. COUNTERCLAIM AND AMENDMENT Defendants/counterclaimants’ Verified Answers. 5 . it is not merely voidable. but they are not stupid either. a party does not ask for the granting of every kind of easement known to man. All one has to do is look at the relief requested. but fails to shows on whose authority. Counterclaims. having no legal effect and Plaintiffs are not required to recognize the Ruling. Plaintiffs’ case had to be dismissed by Becker with prejudice. Plaintiffs have pointed out to the Court. Plaintiffs may not be attorneys. III. VERIFIED ANSWERS. Clearly not only has Georgia Law been repeatedly violated by Georgia Power. but VOID. and that all of their claims were true. valid express easement.

oversee and review title examinations.9. thus the reason she had to throw out the case? 6 . 10. Did Becker give the Order August 2007. Title searches. Guilty of fraudulent concealment. already had the reformation performed. Performed work August 2007 before tree cutting 11.

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