Sarah is afraid I'm Coming for her Grandbaby

8/20/2019 Sarah is afraid I'm Coming for her Grandbaby

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IN THE GENERAL COURT OF JUSTICE

DISTRICT COURT DIVISION

ROCKINGHAM COUNTY, NC

SARAH R. PALMER

On behalf f

NICHOLAS PALMER!"ECK #a $%n& 'h%l()

*+ REDD ST.

REIDSVILLE, NC -/-+

Pro Se Plaintiff Ca0e N. * CVD -+**

1.

2ILLIAM M. SCHMALFELDT, SR

/-+3 S. La4e D&%1e, A56. +7

Sa%n6 F&an'%0, 2I */-/*

Pro Se Defendant

ANS2ER 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:

Defen(an6 De0 N6 Mee6 C&%6e&%a f N&6h Ca&l%na Ln8!A&$ S6a696e.

1. Defendant is not a natural person present in the state of North arolina.

!. Defendant is not a natural person domiciled in the state of North arolina.

". Defendant is not a domestic corporation.#. Defendant is not engaged in substantial activit$ within North arolina, whether that

activit$ is wholl$ interstate, intrastate or otherwise.

%. &s a result, Defendant does not rise to the level of an out of state person who can be

bound b$ the State of North arolina under its long-arm Statute 'N S( ) 1-*%.#+, and this

honorable court does not have personal urisdiction over this defendant.

Pla%n6%ff:0 Pe6%6%n f& a N Cn6a'6 O&(e& %0 R%fe ;%6h M%06&96h0 an( O$%00%n0

. laintiff fails to note that Defendant has never made contact with her grandson.

*. laintiff fails to note that the single photograph he has published of her grandchild



had his face blurred to ma/e the child unrecogni0able.

. laintiff fails to note that the pictures Defendant posted on his website of her her non-

part$ daughter, 2rianna, were ta/en from her 3aceboo/ page, where she made them available to

the world at large.

4. laintiff claims to have 5sent6 a cease and desist contact letter to defendant.

Defendant does not recall receiving an$ such letter, nor does laintiff establish an$ proof of said

letter in her petition.

17. 8n her descriptions of Defendant9s alleged stal/ing and harassing behavior, laintiff

fails to tell the court that she is the proprietor of a website that is responsible for dail$ taunting of

the website, using the plaintiff9s name against his stated wishes in the title of the website.

#E<HI"IT )

11. Defendant learned of 5the alleged incident6 which led her to become her grandson9s

guardian from the laintiff herself in a series of e-mails laintiff sent to Defendant believing him

to be someone else. #E<HI"IT -)

1!. laintiff fails to note for the court that she is a defendant in a 3ederal awsuit filed

b$ Defendant in the ;.S. District ourt for the <astern District of Wisconsin, Milwau/ee

Division, alleging harassment, defamation per se, intentional infliction of emotional distress,

among other torts.

1". laintiff is aware that Defendant has suffered from ar/inson9s disease for 1 $ears

and cannot wal/ more than a few $ards without assistance. =e has no drivers license and cannot

drive. (ravel to North arolina > either to answer this petition or harm laintiff9s grandson >

would be impossible without significant assistance to Defendant.

!



(=<?<3@?<, Defendant as/s this honorable court to dismiss laintiff9s petition with

preudice due to this court9s lac/ of personal urisdiction over the Defendant.

8n the alternative, Defendant as/s this honorable court to review the evidence supplied in

this brief and come to the same conclusion this court made in laintiff9s reAuest for a temporar$

order. 5(he laintiff has failed to prove grounds for issuance of a temporar$ no-contact order.6

December "1, !71% ?espectfull$ Submitted,

BBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBBB

William M. Schmalfeldt, Sr., ro Se"!74 S. a/e Dr., &pt. 17

Saint 3rancis, W8 %"!"%

#1#-!#4-#"*4<mail: bschmalfeldtCtwc.com

E<HI"IT

Pla%n6%ff &9n0 a ha6e!bl8 (%&e'6e( a6 (efen(an6 a6 6he

;eb0%6e h665=>>b%ll?0e@.;&(5&e00.'$ ;he&e 0he 6a4e0

6h%n80 I $a? & $a? n6 ha1e a'69all? 0a%( an( a55l%e0

he& ;n (efa$a6&? 05%n 6 6he$. Defen(an6 %0 09%n8

Pla%n6%ff %n Fe(e&al C9&6 f& he& &le %n 6h%0.

"

mailto:[email protected]

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On ''a0%n, Pla%n6%ff ha0 0e&1e( a0 a 89e06 bl88e& f&an e1en $&e 59&9len6 ha6e!bl8,

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'$5le6el? (e(%'a6e( 6 (efa$%n8 6he Defen(an6.

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Sarah is afraid I'm Coming for her Grandbaby