Академический Документы
Профессиональный Документы
Культура Документы
v.
WILLIAM M. SCHMALFELDT, SR
3209 S. Lake Drive, Apt. 108
Saint Francis, WI 53235
Pro Se Defendant
ANSWER TO CIVIL SUMMONS, NO CONTACT ORDER FOR STALKING, MOTION
FOR DISMISSAL OF PETITION
--------------------------------------------------------------------------------------------------------------------Now comes pro se defendant William M. Schmalfeldt to answer the above-titled
summons, and move for dismissal of the complaint. Defendant alleges as follows:
Defendant Does Not Meet Criteria of North Carolina Long-Arm Statute.
1.
2.
3.
4.
Plaintiffs Petition for a No Contact Order is Rife with Mistruths and Omissions
6. Plaintiff fails to note that Defendant has never made contact with her grandson.
7. Plaintiff fails to note that the single photograph he has published of her grandchild
THEREFORE, Defendant asks this honorable court to dismiss Plaintiffs petition with
prejudice due to this courts lack of personal jurisdiction over the Defendant.
In the alternative, Defendant asks this honorable court to review the evidence supplied in
this brief and come to the same conclusion this court made in Plaintiffs request for a temporary
order. The Plaintiff has failed to prove grounds for issuance of a temporary no-contact order.
Respectfully Submitted,
____________________________________
William M. Schmalfeldt, Sr., Pro Se
3209 S. Lake Dr., Apt. 108
Saint Francis, WI 53235
414-249-4379
Email: bschmalfeldt@twc.com
EXHIBIT 1
Plaintiff runs a hate-blog directed at defendant at the
website http://billysez.wordpress.com where she takes
things I may or may not have actually said and applies
her own defamatory spin to them. Defendant is suing
Plaintiff in Federal Court for her role in this.
EXHIBIT 2
Defendant learned about shaken baby charges
against Plaintiffs daughter from Plaintiff herself.