![]() Filing as much on Mapursuant to Rule 12 Fed. That attorney’s first order of business was a dismissal request. Soon thereafter, an attorney appeared on Defendant’s behalf.ģ. Acts which included – but were not limited to – (a) destruction of evidence (b) perjury and (c) bribery.Ģ.Ělmost one year later – and after an 11th Circuit mandate – Plaintiff served Defendant with the requisite summons (2/23/22). Suing him under 42 USC §1983 (‘ Ku Klux Klan Act of 1871’) and 42 USC §1985 for violating Plaintiff’s constitutional rights ( 1st, 5th, 7th, and 14th amendments) while Defendant acted under the ‘ color of state law’. On-or-around January 31, 2021, Plaintiff initiated this lawsuit against Defendant. USFLND US District Court, Florida, Northern Districtġ. USFLMD US District Court, Florida, Middle District “When there is an actual controversy and a declaratory judgment would settle the legal relations in dispute and afford relief from uncertainty or insecurity, in the usual circumstance the declaratory action is not subject to dismissal.” (6) failure to state a claim upon which relief can be granted ” But a party may assert the following defenses by motion. Every defense to a claim for relief in any pleading must be asserted in the responsive pleading if one is required. ![]() A pleading that states a claim for relief must contain: (1) a short and plain statement. Request: This Court denies Defendant’s motion Problem: Defendant moved to dismiss the case May this court deny admission into his buffet of neverending lies//īackground: Defendant got sued for his perjury ( inter alia) copious pastries from boilerplate bakeries/ Like cookie-cutting like copying & pasting./ Immunity is unavailable against declaratory reliefĭefendant solved nothing yet claimed that all was solved/įormulaic recitations without similar value at all/.Defendant authored another material lie.Defendant had zero factual/ precendential support.Plaintiff, ELIAS MAKERE, on this 28th day of March 2022, respectfully asks this Court to deny “ Defendant Judge Early’s Motion to Dismiss and Strike” (hereinafter “That Motion”). NORTHERN DISTRICT OF FLORIDA, TALLAHASSEE DIVISION G | ALJ PERJURY | PLAINTIFF'S RESPONSE TO DEFENDANT JUDGE EARLY'S MOTION TO DISMISS
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