Update: My answer and counterclaims against Hollander, Hilton, Johnson and Pryor, Johnson, Carney, Karr, Nixon P.C. and their contempt motion

I’m sorry it took so long to update and I will be posting the filings ASAP, but I had a lot to catch up on after researching and writing my filings for over a week and it’s very hard to work on my old notebook.  It’s very slow as soon as I have a few windows open.

After my computer died a week before my answer was due on Thursday the 12th, I barely got done and it’s far from what I’d like it to be, but it’s a good start.

I modeled my filings a bit after the filings at  http://www.graceststephensepiscopal.org/Legal.html 

There’s nothing like sample filings to work off.   But my head was still spinning to grasp the concepts of 3rd party defendants and counterclaim defendants, counterclaimants, …

I added Mathew Hilton, Hollander attorney Irving Johnson and his firm Pryor, Johnson,  Carney, Karr, Nixon P.C. as 3rd party defendants.

As I understand it, 3rd party defendants are the people at least in part responsible for the plaintiff’s damages.

Doctor Hollander sued me, claiming that my allegedly defamatory statements caused her to suffer damages.  In fact, if nobody had contacted me about the sidebar link to the Baileys’ site, most likely I would have deleted it without ever posting about it.  It could have DISSAPEARED without a trace like MANY other links in the sidebar that went bad or became irrelevant.  I’m a VERY busy person, involved in credit reporting litigation and trying to finish my house,  earning a living, starting a new currency and changing the world.

When doctor Hollander and her attorney Johnson CONTACTED me and threatened me with a defamation suit, I posted their submissions and my comments, including the request for specific libelous statements on my site.  Many THOUSANDS of posts and comments are at the still shut down CreditSuit.org, so I’m working off memory and not sure whether I or a reader posted anything else, but probably NOT since they never provided ANY documentation regarding  my site.

And when they SUED me and the process server harassed me, I exercised my right to publish the filings and all the information about the lawsuit and I posted at other sites, trying to find a lawyer and to expose their tactics.

Next, it got REALLY ugly when Matthew Hilton started to submit his abusive, threatening and harassing comments and emails, he didn’t quit when I asked him to, when I imposed a fee and when I pleaded with him not to contact me again.  

I finally filed a complaint with the sheriff after Hilton sent me the composite picture of my house, car, camper and laundry on the clothesline, obviously taken by the process server while trespassing on my property. The gruesome details are in my filing and it got quite long.  

My counterclaims

My counterclaims against all 4 (including Hollander) are for libel/defamation (the complaint, Hilton’s posts and blog with false fraud allegations about me), intentional infliction of emotional distress and tortuous interference with my business.  I made a total of $250 since I had to shut down CreditSuit.org and I’m lucky I didn’t have a heart attack due to the emotional distress.

I pretty much copied the Hollander’s complaint for the causes of action.

And for Johnson, Pryor Johnson and Hollander I added malicious prosecution, perjury and subornation of perjury.

Getting my filings mailed wasn’t easy.

As I was printing the final version of my answer, affirmative defenses and counterclaims, motion to vacate the TRO, exhibits, etc.,  my printer had the first paper jam ever and it sounded like something broke.   Fortunately, I got it going again.

Then I ran out of ink.  Fortunately, I had a new Canon replacement cartridge so I didn’t have to change the microchip for the refills I normally use.

It was after 2:30 pm when I finally left. On the way to Kingman, some tourists flagged me down for direction to the Skywalk.  I tried to talk them out of it, it was way too late to take that crummy dirt road up to Grand Canyon West.

I still had to get the answer and my affidavit notarized and my main bank closed at 4 pm.  Fortunately, my “spare” bank is open till 5 pm and the lady was nice enough to make copies for me.

And I had to pawn my gold ring and a little nugget to cover my phone/DSL bill.  Fortunately, no long wait at the pawnshop.

At the post-office it took me a long time to get everything in order.  I had brought my stapler and I had prepared the envelopes to Pryor Johnson and to return filed copies to me with printed address labels and I brought labels for the court express mailing since I didn’t have a flat rate envelope at home.

I also brought all these old stamps I’ve had for years, many for 37 cents or without any printed value.  I normally print all my postage online, but I figured this was the time to use up those stamps, broke as I am.

Then I had to fill out 4 mailing forms for the express mail (couldn’t use my printed labels) before I got the court address right.  I asked the guy to help someone else while I completed the express form, but he didn’t want to.  And 3 times we started talking while I was writing and I made a mistake.  I didn’t think I’d ever get that form done. 

The flat rate express envelope was COMPLETELY covered with stamps.  I should have taken a picture. 

And then he told me that next day delivery wasn’t guaranteed, but it would PROBABLY get there on Thursday.  $17.50 for THAT.

The Hollander CONTEMPT MOTION

I picked up a contempt motion from Pryor Johnson in Kingman while in town and I will scan and post that next.

On Friday afternoon I called the court and they hadn’t received the mailing yet, but they also hadn’t received ANY mail yet.

And they mentioned something about a call from Hollander attorney Johnson requesting an expedited ruling on the contempt motion and that a minute order was mailed to me. 

So I planned on going back to Kingman tomorrow (almost 120 mile round trip) to pick that up, but apparently the post-office is closed for Presidents Day.

I also filed an address change with the court to a mailbox by the side of the road a few miles from my house.  There’s a lot of mail theft and misdeliveries, but I just can’t drive to Kingman all the time to get the mail.

I tried to talk to someone at the court again about getting at least electronic notices and delivery of filings even if I can’t file electronically, but I only got a VM and didn’t get a return call yet.   Don’t know if CO state court is open tomorrow.

There are more updates and I do have a plan, but first I’m going to make some bread and this post is long enough as it is.



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