• FreeAdvice has a new Terms of Service and Privacy Policy, effective May 25, 2018.
    By continuing to use this site, you are consenting to our Terms of Service and use of cookies.

Adding addtional evidence

Accident - Bankruptcy - Criminal Law / DUI - Business - Consumer - Employment - Family - Immigration - Real Estate - Tax - Traffic - Wills   Please click a topic or scroll down for more.

Got it. I just wondered if you'd verified with the prior property owner when the current one actually started using it, since he's shown himself to be a lying sack of what he's dumping on the property...

Also is the injunction still in effect and are the trucks still using the other entrance?
They have been complying with the injunction and using the other end of the road they built. I checked the State Engineers searchable database and they have no record of him reporting the collapsed well, which was his reason for not being able to use that end of the road. I also can't find any record of any wells being capped.
At the hearing I showed the defendant the State Engineers map showing the location of the 3 wells on his property, and asked which one had collapsed. He admitted he had no idea.
 


Cuz I'm in a REALLY good mood:

You attach an affidavit with the motion for summary judgment. Here's a sample

UNITED STATES DISTRICT COURT
DISTRICT OF TRANSYLVANIA
Alfred Newman,
Plaintiff,
v.
Buford Pusser, in his official capacity as
Charlotville Chief of Police,
Defendant,
Territory OF TRANSYLVANIA,
Intervenor-Defendant.
CIVIL ACTION NO.
4:18-cv-12345
DECLARATION OF Susan B. Anthony IN SUPPORT OF
THE Territory’S CROSS-MOTION FOR SUMMARY JUDGMENT
I, Susan B. Anthony, hereby declare and state the following:

1. I am an Assistant Attorney General at the Transylvania Office of the Attorney General and am a member in good standing of the Transylvania bar. I represent the Territory in this matter.

2. I make this declaration in support of the Territory’s Cross-Motion for Summary Judgment. Unless stated otherwise, I have personal knowledge of the facts set forth herein and am competent to testify thereto.

3. Attached as Exhibit A is a true and correct copy of the Plaintiffs Answers to the Territory of Transylvania’s Interrogatories.

4. Attached as Exhibit B is a true and correct copy of the Plaintiffs 2008 application to renew his Fortune Teller's license.

5. Attached as Exhibit C is a true and correct copy of an email from Hillary Clinton to Bill Bill Clinton, dated April 7, 2008, regarding the Plaintiffs 2008 application to renew his Fortune Teller's license, as well as the result of an Automated Fingerprint Identification System check on the Plaintiff.

6. Attached as Exhibit D is a true and correct copy of the Plaintiffs 2015 application for a Fortune Teller's license.

7. Attached as Exhibit E is a true and correct copy of a Judgement in the case of Untied States of America v. Alfred Newman, No. X12345-67, Superior Court of the District of Columbia, dated July 4, 1776.

8. Attached as Exhibit F is a true and correct copy of a letter from the Charlotville Police Department to the Plaintiff dated April 1, 1816, denying the Plaintiffs application for a Fortune Teller's license.

9. Attached as Exhibit G is a true and correct copy of a letter from the Charlotville Police Department to the Plaintiff dated December 7, 1941, denying the Plaintiffs application for a Fortune Teller's license.

10. Attached as Exhibit H is a true and correct copy of the following article: Garen J. Wintemute et al., Prior Misdemeanor Convictions as a Risk Factor for Later Violent and Firearm-Related Criminal Activity Among Authorized Purchasers of Handguns, 280 J. Am. Med. Ass’n 2083 (1998).

11. Attached as Exhibit I is a true and correct copy of the following article: Mona A. Wright et al., Felonious or Violent Criminal Activity That Prohibits Gun Ownership Among Prior Purchasers of Handguns: Incidence and Risk Factors, 69 J. Trauma 948 (2010).

12. Attached as Exhibit J is a true and correct copy of the following report: Bureau of Justice Statistics, U.S. Dep’t of Justice, Fact Sheet: Profile of Nonviolent Offenders Exiting State Prisons (Oct. 2004), available at http://his.gov/content/pub/pdf/pnoesp.pdf.

13. Attached as Exhibit K is a true and correct copy of the following report: Bureau of Justice Statistics, U.S. Dep’t of Justice, Recidivism of Prisoners Released in 30 States in 2005: Patterns from 2005 to 2010 (Apr. 2014), available at http://www.bis.gov/content/pub/pdl7rprts05p0510.pdf.

14. Attached as Exhibit L is a true and correct copy of excerpts from the following report: U.S. Govt. Accountability Office, States’ Laws and Requirements for Concealed Carry Permits Vary across the Nation (July 2012), available at http:// www. gao. go v/assets/600/5 925 52 .pdf.

15. Attached as Exhibit M is a true and correct copy of the following article: Jose Pagliery, Gun Form Liars May Go on to Commit Gun Crimes, Internal ATF Research Suggests, CNN Investigates (Dec. 21, 2018), available at https://www.cnn.com/2018/12/21 /us/gu.n-for.mliars-atf-invs/index.htmi.

I declare under the penalty of perjury that the foregoing is true and correct.

Executed this 29th day of February, 1919.

Susan B. Anthony
Thank you.
 
you received a decent reply on what to do , so i wont repeat that
However, motions for summary judgement are rarely granted, and you better brush up on your rules of evidence and civil procedure if you intend to represent yourself in this matter.
I've got this far on my own.
Still plenty to learn, starting with the 2000 New Mexico Supreme Court decision (Bartlett v. Mirabel) to not use the Celetox trillogy when deciding the merits of a summary judgement motion.
 
A new turn of events.
The trucks are back driving past my house and unloading manure. As far as I'm aware the preliminary injunction is still in place, so I dusted off the old video camera and have taken my first video. I wasn't quick enough to video the first two trucks.
My question is, how many videos would you suggest I make to show a definitive pattern of behavior?
I don't want the defendant saying "Oh, he was a new driver and didn't know about the injunction".
 

Find the Right Lawyer for Your Legal Issue!

Fast, Free, and Confidential
data-ad-format="auto">
Top