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CRIMINAL DIVISION
DEFENDANTS OMNIBUS PRE-TRIAL MOTION FOR RELIEF WITH CITATIONS TO AUTHORITY AND NOW COMES the Defendant, Tanuja Singh Murray, a member of THE THOROUGHBRED TEAM which was engaged in a contract with another legal entity (as per contract terms and as party p ayable by the alleged bad check in question), by herself pro se and as an attorney not admitted to this states bar but a member of the National Patent Bar and formerly the state bars of NJ and NY, hereby files the following pre-trial motions, stating in support thereof as follows:
INTRODUCTION
On _____, a Criminal Complaint was filed against defendant, based upon affidavit of Mike Jester, owner of Penn Ridge Farms. Despite the numerous defects upon the face of this private criminal complaint, it has proceeded to this point, and since the Magistrate court evidenced extreme bias and prejudice in this matter (pronouncing the bounced check as a bad check within one minute of the initial preliminary hearing and ignoring mitigating evidence and information that would cause any reasonable person to re-examine the validity of the alleged crime). STANDING NO DEBT NO INJURY NO ENRICHMENT CHECK FROM LLC TO LLC PRECLUDES INDIVIDUAL (Jester) FROM FILING COMPLAINT AGAINST MEMBER POST DATED CHECK JURISDICTION INCOMPLETE PRIVATE COMPLAINT LACK OF DUE PROCESS / INVESTIGATION SPECIFICITY S.O.L. DA DATING OF APPROVAL INCORRECT IDENTIFICATION OF INDIVIDUAL INCORRECT INDIVIDUAL INCORRECT VENUE CHOICE OF LAW AND VENUE CLAUSE CONFLICT OF PLAINTIFF (Real Party Of Interest) The complaint alleged a bad check with NO EVIDENCE or BILL OF PARTICULARS