2016
01.26

(Filed in Bucks County PA)

1. The Plaintiff has failed to demonstrate a proper and lawful standing to bring this matter before the Court.

2 The Defendant has raised the issue of the Plaintiff’s lack of standing in every filing, response, petition and motion.

3. The Plaintiff has failed to demonstrate proper and lawful standing and has caused the Court to be without jurisdiction in this matter.

4. The Defendant STRONGLY CHALLENGES the jurisdiction of this Court with the responsibility on the Plaintiff to provide evidence which supports jurisdiction.

FRAUD UPON THE COURT

5. Nicole Plank, Esq. now presents a thirty-nine (39) page Motion for the purpose of becoming Receiver by referring to collateral documents; her extensive plans for disposing of the property; referring to her prior attempts to become Receiver; listing events which have occurred in other courts; … The logical fallacy suggesting that either she or her clients are the recipients of a judgment entered in their favor.

6. NICOLE PLANK, ESQ. HAS NEGLECTED TO INCLUDE THE “JUDGMENT” WHICH PROVIDES THE BASIS FOR HER ARGUMENT.

7. Nicole Plank, Esq. has neglected to provide the ‘judgment’ knowingly and in this deliberate manner attempts to mislead this Court.

8. Nicole Plank, Esq. has neglected to provide the ‘judgment’ to avoid sanctions, penalties, or criminal prosecution for presenting a fraudulent document to the Court.

9. The failure and negligence to provide the ‘judgment’ suggests that Nicole Plank Esq. is cognizant of the defective and void nature of the document which purportedly supports her Motions regarding her being appointed as Receiver.

10. Defendant believes the request to provide the document(s) alleged to support the plaintff’s motion is reasonable and timely and directly affect the matter before this Honorable Court.

WHEREAS, the Defendant respectfully requests this Honorable Court to IMMEDIATELY REQUIRE the attorney for the Plaintiff, Nicole Plank, Esquire, to present the ‘Judgment’ referred to in Plaintiff’s Paragraph 4 which is the basis for the Petition which Plaintiff has brought before the Court; with evidence of proper standing and jurisdiction.

Respectfully,

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