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EPPS
208 COLONIAL CT
GALLOWAY NJ08205-3642
BAXTER FINANCAIL, LLC SUPERIOR COURT OF NEW JERSEY
AS ASSIGNEE OF LAW DIVISION-ATLANTIC COUNTY
HOUSEHOLD BANK SPECIAL CIVIL ACTION
I Rodney K. Epps move the court to dismiss the order to turn over, and to dismiss all
civil actions
against and to give me a full and detail explanation as to why counsel for the
plaintiff can get a summary
judgment by just filing paper work. Also I move the court to explain why the clerk
allowed a summary
judgment to the plaintiff without first being fully assured that at least one of the
parties had shown up in
trial. Here are the following reasons for my objections. To the order to turn over (1.)
Failure to prosecute
Civ. Rule 41.1, (2.) Lack of subject matter jurisdiction. (subject matter jurisdiction
can never be waived,
A party to a civil action can raise the jurisdiction matter at any time, even after
judgment. A party must have standing in order for the court to hear the case, this
can only be done
by the plaintiff being sworn in open court and swearing to the facts of the case. The
counsel for
are not
Sufficient for motion to dismiss or for summary judgment see, Trinsey v. Pagliaro,
D.C. Pa. 1946, 229 f.
Supp. 647.Fed. Rules Civ. Proc. (12b) (6), 56(d), 28 u.s.c.a. Your Honor, the
point is this, it would be
because I did not appear in court, when neither COMMERCE BANK or BAXTER
FINANCAIL LLC,
43. In every trial, the testimony of witnesses shall be taken in open court ……
………If I can lose the case
because I did not appear in court then surely the plaintiff (not there counsel) should
not be given
special treatment solely on paper work, the plaintiff should be penalized also If the
plaintiff could not be
they would have to submit AFFIDAVITS OR DEPOSITIONS to show just cause as why
they could not
appear and be sworn. How can a court proceed to judgment without a sworn
witness? I have been
denied my civil rights to doprocess and the case against me is void on its face. For
these’s
Signed____________________
__