Kansas Commission on Judicial Qualificalions

301 S.W. Tenth Avenue

Topeka Ks 66612 Re: 15CV38P

THIS COMPLAINT ISAGAINST 11THDISTRICT JUDGESA.J. WACHTER AND KURT LOYFOR USURPATION OF OFFICE UNDER K.S.A. 60-1201. K.S.A. 60-1202(1)(2)(4)(5),K.S.A. 60-1205, K.S.A. 60-1206(a)(b), K.S.A. 60-1207 and for violations of RULESRELATING TO JUDICIAL CONDUCT CODE OF JUDICIAL CONDUCT Rule 601A, andRule 5.4 of The Uniform Bonding Code.

I recently signed a grand jury petition that was going around to oust all 11th judicial district j4dges due toconflicts of interest between them which was filed in case number 2015MR2P. During the pefition drive totry to'get the signatures a radio ad was ran on 100.7 ESPN My Town Media which is owned by attorney BillWachter. After just 2 days of running on the air Judge Lori Fleming took it upon herself to use her powerinappropriately as a judge and to usurp/intrude into a private business contract between SummaryJudgment Group and My Town Media. She wrote a private email on her regular job time-as a publicservant judge and she then had the nerve to profile the Summary Judgment Group and make slanderous,demeaning nicknames by calling anyone who signed it including "myself' "posse cometaut" because ofmy political views to simply sign a constitutional grand jury petition.

What Lori Fleming called anyone that signed the grand jury petition is really "posse comitatus", The factthat Lori Fleming made typos in her slanderous insulting remarks or the fact that she can't simply spell theword "posse comitatus" doesn't change the fact she insulted anyone who signed the petition and labeled usin a political box now! Who is Kurt in the email? ls it Judge Kurt Loy was he in on this too?? I think sincethe copy of the message sent to 100.7 ESPN was from the email address of is froma public judicial courthouse emait address that the computer this was sent from needs to b~ taken duringthe investigation and see how many other messages and emails were sent ex parte and about privatematters as well. I have included a copy of the picture going around the 11th judicial district which shows LoriFleming contacting 100.7 ESPN at 1:43 P.M. on February 19, 2015. Is this why the state has to havefurloughs is because our public servants are conducting private business on taxpayers time. The stateshould now have a permanent furlough and decrease about 70% of these government job~ since the publicservants don't want to perform their public job duties. I will be signing a class-action lawsuit now againstLori Fleming in her private capacity since she was not performing her public ministerial duties or jobdescriptions by interfering in a radio ad and damaging the summary judgment group and not getting therequired voters due to her interference in a private business matter and constitutional grand jury petition.

Since the "GRAND JURYPETITON' was for the purpose to impeach the 11thdistrict judgesI feel Lori Fleming violated Rule 4.1 since she is making speeches in her email to attorneyBill Wachter about the possibility of losing her political job and she should not be callingpeople "POSSECOMITATUS" "WHICH ISA RACIALNAZI SLUR"which the court of

Crawford County has been known to do in the past according to attorney Mark Fern in my

public court case number 14CV14P where attorney Mark Fern filed a "MOTION TO STRIKETHIRD-PARTY PETITION AGAINST DEFENDANTS FERN & ANGERMAYER LLC AND

STEPHEN B. ANGERMA YER AND FOR SANCTIONS" and he says on statement S page 2

comparing the Pro Se client to something called "Kansas Militia Members" and on statement

14 of page 6 says that the Pro Se clients tactics are what "THIS COURT" meaning"CRAWFORD COUNTY" that this court commonly associates with the "KANSASMIUTIA"!!!! The statement of people representing themselves being "MILITIA" by the 11thjudicial district court is just one of the bias and prejudices under Rule 2.3, and due process

violations that led to the "GRAND JURY PETITION" to impeach all 11thdistrict court judges.Maybe attorney Mark Fern had spoken with Judge Lori Fleming since she was one of three(3) district judge members of "the court" in the 11thjudicial district in Crawford County in

2014 when that statement was made public when it was filed.

I don't feel confident going in front ofJudge A.I. Wachter in case number ISCY38P since hisbrother is the attorney that Lori Fleming was making "NAZI RACIAL SLURS" with andcalling me "posse comeataut". All judges in the 11thdistrict have now showed proof of biasand prejudice against Pro Se litigants and Judge Wachter is the chief judge which shouldviolate Rule 2.12 for not properly supervising his employees. I also don't feel A.J. Wachtershould hear this case because Steve Stockard of Wilbert and Towner is an attorney in this

case and A.I. Wachter used to own Wilbert and Towner and Wilbert and Towner is the lawfirm that is owned by My Town Media owner, attorney Bill Wachter who receives e-mailsfrom Lori Fleming which is unethical. Please investigate this matter and assign a judge fromout of the 11thjudicial district to hear this case under Rule 2.11 (A) Disqualification.

Very truly yours, f~~.~ '1~James Beckley Jr. 30 ~ w. vVl. c..-f(G'-I'1 ,c(-" Idel"l4 C 1

MINTER & POLLAK545 N. WoodlawnWichita, Kansas 67208(316) 265-0797

DISTRICT COURT, CRAWFORD COUNTY, KANSASCIVIL DEPARTMENT

COMMUNITY NATIONAL BANK & TRUST, ))

Plaintiff, ))

v. ))

JAMES A. BECKLEY, SR., deceased, )JAMES A BECKLEY, JR., )MICHAEL ANDREW EDWARDS, )UNKNOWN SPOUSE OF MICHAEL ANDREW )EDWARDS, UNKNOWN TENANT(S), )JESUS PIEDRA-SEGOVIA A/KiA JESUS PIEDRA, )MARIA LOPEZ, JUAN LOPEZ, )KANSAS DEPARTMENT OF REVENUE, )BOARD OF COUNTY COMMISSIONERS FOR )CRAWFORD COUNTY et al. )

)Defendants. )

----------------------------------)

CASE NO. 15 CV 38-P

TITLE iNVOLVINGREAL ESTATE

OGo~yFILE BY FAX

Pursuant to K.S.A. Chapter 60(REAL ESTATE FORECLOSURE ACTION)

MOTION TO DISMISS COUNTERCLAIMS AGAINST PLAINTIFF

COMES NOW, the Plaintiff, Community National Bank & Trust for its Motion to

dismiss the counterclaims asserted by the Defendant James A. Beckley, Jr. pursuant to

K.S.A. 60-212(b) and in support of said request states as follows:

1) Plaintiff is entitled to judgment on all counterclaims and defenses

In this matter the Defendant James Beckley, Jr. has asserted numerous

defenses and counterclaims which have no basis under Kansas law and should be

dismissed pursuant to K.S.A. 60-212(b)(1) for lack of subject-matter jurisdiction or 60-

212(b)(6) for failure to state a claim upon which relief can be granted. Given the nature

CERTIFICATE OF MAILING

The undersigned hereby certifies that on this 20th day of May, 2015 the original

above and foregoing Motion to Dismiss Counterclaims Against Plaintiff was deposited in

the United States Mail, postage prepaid and properly addressed to:

James A. Beckley, Jr.302 W. McKayFrontenac, KS 66763

Kip SagehornLoy & Sagehorn, LLCP.O. Box BPittsburg, KS 66762

/l .{~IcCreath Pollak, #21681

Steve StockardWilbert & Towner, PA506 N. PinePittsburg, KS 66762

COil (I: C-tRu\~'l \\ ~

'))~fi"iI'C~S~'(Mo~~~e~dIeClOSIl;~} '.Case 201S.CV.000038,P

Judge'

Filing date:Case subtype:

Repository

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Under ad...~sement:

Discovery conf.:

Pretrial conf.:

Trial start:

Trial eno:

Comment:

Previous cass:

Next hearing: 0710212015 09:00 AM, Needs Set Discovery

Source: .9!.~~t~!.~~_~_.Termination date: ,00;0010000 ". Termination typs: ""r::J Filing stats sent:Nature of judgment Re.instatement date: DOIDO/Oo-OO Term. slats sent:

Created by: KV on 041061201510:15 AM Updated by: KV on 04f06l2015 10:21 AM

I" 'Plaintiff !:g~f~n~a,~nO.~~b!~t~l? Other part'.~~. ]Le.~e~ o .RemindersPlaintiff 1 of 1

..........., _40RQA_'s -lStatus History

Send to Pros-ecUlor'

o WitnessesCommunity Natlcnat Bank & Trust

Attorney: Pollak, Creath L

Send notices: f~1 Post-active: C:=, litigant Options

I.~;~;:g~~~=:~~~jiU Bonrls(AltQ)

Comment:

Journal entri required: ~i Journal -entry date:Created by: KV on 0410612015 10:16 AM

M/OOfOUODUpdated by: KV on 04i0612015 10:16 AI.",

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INTHEDISTRICTCOURTOFCRAWFOfo tbfr~NSAS

14 MAR14 P2 :04)) I! I-.i II r - I', . .

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) C~'fl,W:1 ~ ~ '. I.,)5 Y Case No. 14 CV 14 P)

James A. Beckley, Jr., and the unknown )heirs, executors, administrators, devisees, )trustees, creditors and assigns of such of )the defendant as may be deceased and )the unknown spouses of the defendant; )the unknown officers, successors, trustees,)creditors and assigns of such defendant )as are existing, dissolved or dormant )corporations; the unknown executors, )administrators, devisees, trustees, }creditors, successors and assigns of such )defendant as are or were partners or in )partnership; and the unknown guardians, }conservators, and trustees of such of the )defendant as are minors or are in }anywise under legal disability; and the )unknown heirs, executors, administrators, )devisees, trustees, creditors, and assigns of)any person alleged to be deceased. )

)}

-------------------------------)PURSUANT TO CHAPTER 60 OFKANSAS STAlUTES ANNOTATED

Community National Bank & Trust,Plaintiff,

VS.

Defendants.

MOTION TO STRIKE THIRD-PARTY PETITION AGAINST DEFENDANTSFERN & ANGERMAYER LLC AND STEPHEN 8. ANGERMAYER

AND FOR SANCTIONS

Come now third-party defendants Fern ~ Angermayer, LLC and Stephen B.

Angermayer by and through their attorney Mark E. Fern and for their motion to strike

the third-party petition against them and for sanctions state:

1. Plaintiff, Community National Bank & Trust, a financial institution, organized

existing, and doing business under and by virtue of law, filed a petition in this action

against the defendant James A. Beckley Jr. for defaulting on a promissory note and to

foreclose a security interest.

2. The defendant, James A. Beckley, Jr., was properly served and filed a pro-se

answer to the plaintiff's petition.

3. Defendant Beckley filed a pro-se, third-party complaint against all parties he

believed were involved in the suit. He made third-party allegations against the attorney

for the plaintiff bank, Stephen B. Angermayer and his firm, the president of the bank,

Tony Stonerock, and the sheriff's deputy, Robert Peters, who served the defendant with

the summons and petition.

4. The third-party defendant also filed complaints against all third-party

defendants with various regulatory authorities. He filed a complaint against bank's

County Sheriff's Department.

:j--- 5. Third-party defendant tactics, as set auf abovereceived in prior cases from Kansas Militia members.--------------~

counsel with the Kansas Office of Disciplinary Administrator, against the Bank President

with the Comptroller of Currency, and against the sheriff's deputy with the Crawford L-O(: ,f l~~,-7 \J+;J. weul)U

m irr-o-r-w-h-a-t-th-is~co-u-rt-h-a-s- ~vr t- td't(A{~

+'''~+-C).>t"\6. The statute on third-party practice states as follows:Statute 60-214: Third-party practice. (a) When defendant may bring in thirdparty. At any time after commencement of the action a defending party, as athird-party plaintiff, may cause a summons and petition 10 be served upon aperson not a party to the action who is or may be liable to the third-party plaintifffor all or part of the plaintiff's claim against the third-party plaintiff. The third-partyplaintiff need not obtain leave to make the service if the third-party plaintiff filesthe third-party petition not later than 10 days after serving the original answer.Otherwise the third-party plaintiff must obtain leave on motion upon notice to allparties to the action. The person served with the summons and third-party

2

14. The Third-party plaintiff has interposed the third-party claim for the purpose

harassment and delay. His tactics are what this court commonly associates with theI Kansas Militia. Their pleadings are typically filed p;o-se with a convoluted reference to..'-----

Kansas statutes. Often the alleged facts are untrue, and the Militia's hallmark is an-extreme anti-government ideology along with elaborate conspiracy theories.----------

15. In Wood v. Groh, 269 Kan. 420, 431,7 P.3d 1163 (2000) the court listed the

following factors to be considered by the court when awarding sanctions against a party

who violates KSA 60-211 :

(1) whether the improper conduct was willful or negligent;(2) whether it was part of a pattern of activity or an isolated event;(3) whether it infected the entire pleading or only one particular count ordefense;(4) whether the person has engaged in similar conduct in other litigation;(5) whether it was intended to injure;(6) what effect it had on the litigation process in time orexpense:(7) whether the responsible person is trained in the law;(8) what amount, given the financial resources of the responsible person, isneeded to deter that person from repetition in the same case; and(9) what amount is needed to deter similar activity by other litigants.

/d.

16. The movants request that the court find the Third-party plaintiff has filed his

third-party claim in violation of KSA 60-211, and awards them attorney's fees for filing

this response and attending any subsequent hearings in this matter.

WHEREFORE, Third-Party Defendants, by reason of the matters above set forth

above, are entitled to have the third-party claims against them dismissed with prejudice.

The movants are entitled to an award of attorney's fees for defending this action and for

any subsequent hearings, and for such other relief that the court deems proper.

6