F a x S e r v i c e

To: Jefferson County District Court From: Steve Douglas, Gartin

Fax: Relay: 739-9824 Pages: 5

Phone: Message: 364-0403 Date: August 21, 1996

Re: Verified Motion to Render Void CC: See Certificate of sending via FAX page 5

¨

Urgent Plaintiff Children are now being sequestered in contempt of Court Orders

l Comments: Following is Plaintiff’s Motion to Render Void. This pleading is filed VIA FAX, pursuant to and in compliance with, Colorado law, with references included for the Court’s convenience.

Colorado Court Rules Section 1-25 FACSIMILE COPIES

1. Facsimile copy, defined. A facsimile copy is a copy generated by a system that encodes a document into electrical signals, transmits these electrical signals over a telephone/data line, then reconstructs the signals to

print an exact duplicate of the original document at the receiving end.

2. Facsimile copies which conform with the quality requirements specified in C.R.C.P. 10(d)(1) may be filed with the court in lieu of the original document. Once filed with the court, the facsimile copy shall be treated as an original for all court purposes. If a facsimile copy is filed in lieu of the original document, the attorney or party filing the facsimile shall retain the original document for production to the court, if requested to do so.

3. The court is not required to provide confirmation that it has received a facsimile transmission.

4. Any facsimile copy transmitted directly to the court shall be accompanied by a cover sheet which states the title of the document, case number, number of pages, identity and voice telephone number of transmitter and any instructions. This rule shall not require courts to have a facsimile machine nor shall the court be required to transmit orders or other material to attorneys or parties via facsimile transmission.

Colorado Court Rules Rule 10. Form and Quality of Pleadings, Motions and Other Papers

  1. General Rule Regarding Paper Size, Format, and Spacing.

All documents originated after the effective date of this rule shall meet the following criteria:

  1. Paper Size and Quality: Only documents which are clear and legible and are on permanent

plain 8 1/2 by 11 inch paper shall be filed.

(38) "Send" in connection with any writing or notice means to deposit in the mail or deliver for transmission by any other usual means of communication with postage or cost of transmission provided for and properly addressed and in the case of an instrument to an address specified thereon or otherwise agreed, or if there be none to any address reasonable under the circumstances. The receipt of any writing or notice within the time at which it would have arrived if properly sent has the effect of a proper sending.

 

District Court, Jefferson County, state of Colorado

Case # 95-DR-2718 & 96C7386 - 96C7387 - 96C7388

Motion to Render Void Chief Judge Nieto’s Order

April Rose, Gartin

Elijah Rock, Gartin

Steve Douglas, Gartin a Colorado Citizen

v.

Tamara Ann Zehnder, alias TAMARA A. GARTIN (a nom de guerre)

Markus Bernard Merritt, a.k.a. Michael Thomas

Pastor Robert Victor Zehnder & Dolores Jean Zehnder

and as agents for the Lutheran Church, Missouri Synod

Karsh & Fulton, P.C. "Legal Team" in the persons of:

Alan E. Karsh

Seymour Joseph

Fred Gabler

Valerie Krogman

Larry Fulton

A. Troy Ciccarelli

J. Terry Wiggins

 
  1. I, Steve Douglas, Gartin, the moving party and the Party Injured inform the court that Chief Judge Henry Nieto has made a mistake in judgment.
  2. Chief Judge Henry Nieto states in the first paragraph of his Order dated August 15th, 1996 "The Court has read and reviewed the Motion, has read and reviewed the documents on file with this Court, and being fully advised in the premises,. . . "
  3. The Honorable Henry Nieto received my Motion for Summary Judgment in case # 96-CV-1478 on August 15th, 1996 which was filed by FAX direct to Mr. Nieto’s office and is contained within the Court’s record.
  4. Mr. Nieto either did NOT read my motion, or he ignored it when making his decision to grant this Prevaricator, A. Troy Ciccarelli, Esquire his fraudulent and perjurious motion. Either scenario is unacceptable performance for a man in such an exalted position.
  5. A. Troy Ciccarelli, Esquire lied to the Court intentionally! He said that I did not return his phone message. His secretary and my witnesses will testify to the contrary.
  6. I very directly spoke with Mr. Ciccarelli that day, but his agenda was to molest, slander, libel and harass me, and deny me my Rights as a Father. This action is in criminal contempt of the order of the Court and in conspiracy with listed defendants and others unknown at this moment.
  7. Karsh & Fulton, P.C., a.k.a. "Legal Team" has committed perjurous instruments and documents to the court. This Legal Team has encouraged it’s clients to commit perjury in direct defiance of all law. This Legal Team has encouraged and suborned its clients to defy the Court’s Orders.
  8. This Legal Team has conspired and colluded with Magistrate Russell Stuska and Judge William DuMoulin to defy and defile every Constitutional Guarantee and Due Process and in conspiracy to deprive me of my Rights and the Rights of my Children.
  9. My ONLY concern is for my Children. They are now in an environment that encourages deceit, larceny, adultery, drunkenness, arrogance, violence, ignorance of Biblical principles, and all of the evils I do not want my Children exposed to. It is my Right as Father to protect my Children from what I perceive to be an extremely volatile and dangerous situation.
  10. The Plaintiffs have recently became aware pursuant to F.R.C.P. 26, (e) of the Law; aware of the requirements of a professional’s Oath of responsibility, and have become aware of a progress of:

by the Defendants, Pastor Robert V. Zehnder & Delores Jean Zehnder, and legal counsel; A. Troy Ciccarelli, J. Terry Wiggins, Markus Bernard Merritt, Valerie Krogman, Alan Karsh, Fred Gabler, Larry Fulton, Seymour Joseph, and other parties unknown to the Plaintiffs at this moment in time.

  1. Now we have become aware of the contempt of Karsh & Fulton, P.C. for the order and direction in order of the Honorable Court as defined in Magistrate Norton’s Order of January 19th, 1996 to facilitate equal shared parenting.
  2. The Honorable Court has had official notice of several fraudulent documents submitted and perjuries made by A. Troy Ciccarelli. These are now within the Court’s Record and a matter of prima facie evidence of gross perjury in all of Mr. Ciccarelli’s dealings with the Court in which Plaintiff is a Party.
  3. Presently the parties at Karsh & Fulton, P.C.; J. Terry Wiggins, A. Troy Ciccarelli and such others and their clients, Tamara Ann Zehnder (alias Tamara A. Gartin), Robert & Dolores Zehnder and Markus Bernard Merritt, are all in conspiracy, in malicious contempt of the orders of the Court in Cases 95-DR-2718, #96CO3788, #96CO3787, #96CO3786.
  4. To allow such brazen prevarication and flagrant contempt for all that is righteous and proper and lawful and truthful cannot be rewarded by constant approval. I have observed this Court, in the person’s of Magistrate Stuska, Judge DuMoulin, and Chief Judge Henry Nieto operate in conspiracy and collusion with this legal team of Karsh & Fulton, P. C. for over a year now.
  5. I have observed outright lies and perjuries, in conspiracy, go unpunished and even rewarded.
  6. I demand to know if this Jefferson County District Court is operating in Conspiracy with Karsh & Fulton P. C. to deprive me and my Children of our God-Given Rights to Life, Liberty, and the Pursuit of Happiness in direct violation of the Constitution of the state of Colorado and the united States of America.

 

 

 

WHEREFORE, the Plaintiffs, and them all, move this Honorable Court to Render Void and of no effect the Order of Chief Judge Henry Nieto of August 15th, 1996 granting Karsh & Fulton, P.C. on the face of perjurous testimony to receive and extra 20 days to reply and to issue an Order of Contempt against each and every of the Defendants Legal Team and further relief as the court deems just and proper in the premises.

Steve Douglas, Gartin, in his True Name and as the Proper Party Injured, avails himself of all the provisions of the laws and statutes of the state of Colorado and of the united States of America, which have been made and provided for relief and restoration of tortious actions by Defendants, and them all, and for cause, and other such statutes, made and provided, in protection of the unalienable rights of the Citizens.

I claim all Rights and Privileges under the Constitutions of the state of Colorado and the united States of America and at no time waive any right or privilege of my free will.

Dated this 21st day of August, 1996.

Steve Douglas, Gartin

PO Box 114 Message Phone: 364-0403

Golden, Colorado Zip Exempt Message FAX: 739-9824

Plaintiff is Homeless and Indigent

Allow an extra 10 Days for delivery to PO Box and subsequent pickup

Please FAX for quicker response.

 

I hereby certify that a true and correct copy of the forgoing

Motion to Void Chief Judge Nieto’s Order was placed into queue

for delivery via FAX on August 21st, 1996

to the following Persons & Parties at the listed FAX number.

______________________

PO Box 114 Message Phone: 364-0403

Golden, Colorado Zip Exempt Message FAX: 739-9824

CC: VIA FAX Numbers Listed_______________________________________

Jefferson County Court Chief Judge Henry Nieto FAX: 303-271-6270

Karsh & Fulton, P.C. Alan Karsh FAX: 303-782-0902

Bethlehem Lutheran, Inc. David Langewisch FAX: 303-238-7691

Timothy & Francisca Zehnder FAX: 303-932-2465

Federal District Court Judge Lewis T. Babcock FAX: 303-861-2233

U.S. Attorney FAX: 303-844-0098

  1. S. Supreme Court Grievance Committee FAX: 303-893-2443

U S West, Inc. Elizabeth Kiovsky FAX: 303-295-7046

 

Hard Copy available upon Request.

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