Luis A. del Mazo, Jr.. pro se,
Plaintife
vs.
STATE OF TENNESSEE and/or
CITY OF MOUNT JULIET,
MOUNT JULIET POLICE,
DEPARTMENT,
MATHEW MANG,
KRIS ELLIOTT
Defendants
‘Case #2015CR1108
FILED |
A.M, MAY 122015
DEBBIE Moss
General Sessions Court Clerk
o4
WILSON COUNTY, TH!
WRIT OF MANDAMUS
NOTICE TO CLERK: NOTE FOR HEARING, 14th day of May, 2015.
1 Defendants, having received Plaintiffs Affidavit of Specific Negative Averment,
Counterclaim and opportunity to cure on. or about 25th day of March, 2015, and Defendants
Notice of Default and Three Day Notice to Cure on, or about 16th day of April, 2015, and
defendants Final Default and Dismissal of Defendants complaint on, or about 23rd day of April,
2015, and defendants Writ of Praecipe on, or about 23 rd day of April, 2015, as filed in the
record, and having failed to plead, with time now expired to do so.
2. The CLERK of the court has been respectfully ordered to enter a default judgment
against the Defendants and prepare a Certificate, with seal of the court, declaring that the
defendants have failed to join the correct party in this suit and therefore the case is dismissed for
failure to state a claim, and lack of jurisdiction, and order defendants to pay Plaintiff Ten
‘Thousand dollars in damages and restitution and send to parties of interest within 3 days.
3. __ Said CLERK now liable having neglected or refused to enter the default and prepare and
send the Certificate, now therefore the Plaintiff demands that the writ of mandamus issue forth to
mandate the ministerial duty of the clerk as required by law to enter the default immediately.
CONCLUSION
Because of your superior knowledge of the law, and your witnessing a constitutional
‘wrong through fraudulent violation of rights, privileges and immunities, equating to felony
perjury of oath, and obstruction of justice your injury to the rights of said Citizen constitutes an
actionable offense with no immunity, by failure to act upon a ministerial duty.
WRIT OF MANDAMDS
ZeVERIFICATION
In Witness, Whereof, knowing the law of bearing false witness before God and men I
solemnly affirm, that, I have read the foregoing, and know the contents thereof to be true to the
best of my knowledge, except as to the matters which are therein stated on my information or
belief, and as to those matters, I believe them to be true, These instruments are submitted upon
good faith belief that they are grounded in fact, warranted by existing law or a good faith
argument for the modification or reversal of existing law and are submitted for proper purposes,
and not to cause harassment and unnecessary delay or costs.
Submitted this 12th day of May, 2015.
Affiant,
(signature)
1, Luis A. del Mazo certify that I have served the Office of the Prosecuting Attomey a
true and correct copy of this legal document on this 12 th day of May, 2015, and that I also filed
a copy of this legal document with the Court Clerk on the above specified date.
Submitted, on this 12th day of May, 2015.
Affiant,
(signature)
WRIT OF MANDAMUS