IN THE DISTRICT COURT OF CRAWFORD COUNTY, KANSAS

WILMINGTON TRUST N.A,

Plaintiff, )

) Case No. 14-CV-86P

vs. ) Division

) KS.A Chapter 60

ERIC MUATHE, )

Defendant, )

MOTION TO STRIKE PLAINTIFF'S PLEADINGS

AND REQUEST FOR ORAL ARGUMENTS

COMES NOW, the Defendant, Eric M. Muathe, as himself and Pro-Se who files this

motion alleging and stating as follows:

1. It has come to Defendant's attention that since January 25th, 2018 Plaintiff has filed

several pleadings with this court WITHOUT ANY SUCH PLEADINGS/FILINGS BEING

MAILED TO DEFENDANT.

2. Defendant just became aware of the filing of these pleadings, around June 12th,

2018, when a case summary docket print out of this case was attached to a pleading

Page 10f7
 in a currently pending federal court case styled Eric Muathe vs. Wells Fargo Bank

N.A. et al. CASE NO. 2:18-cv-02064-CM-JTT.

3. The said docket printout - labeled "Exhibit B" - is attached to this motion. Defendant

is not aware if any other pleadings have been filed by the Plaintiff, or the Court,

since the June 1st, 2018 date of the above mentioned docket print out.

4. Since January 25th, 2018 it appears that the Plaintiffs counsel have filed the

following pleadings: [April 20th, 2018] Motion to Amend Scheduling Order, [April

27th, 2018] Proposed Second Amended Scheduling Order, [May 1st, 2018] Proposed

Second Amended Scheduling Order, [May 30th, 2018]PlaintiffWilmington Trusts

Motion For Summary Judgment on Muathe's Counterclaim, and [May 31st, 2018]

Plaintiffs Memo in Support of its Motion for Summary Judgment.

5. Since January 25th, 2018 no service, or notice, of Plaintiffs pleadings have

been sent to Defendant.

6. Defendant strongly objects to this practice by Plaintiffs counsel.

7. Defendant requests this court to strike all pleadings filed by Plaintiff, and Plaintiffs

attorneys, since January 25th, 2018 and bar the Plaintiff from refilling the same.

8. This is not the first time that pleadings have not been sent to Defendant.

Attorney Matthew Hubbard similarly had not been mailing hard copy Pleadings to

Defendant as per his certificate of services. Attorney Matthew Hubbard does not

dispute this fact. The difference being that attorney Matthew Hubbard had sent

Defendant a copy of his court fillings via email but neglected to send hard copies as

per his certificate of service. See attached email communication.

Page 2 of7
9. Here no service of filed pleadings of any kind have been sent to Defendant since

January 25th, 2018.

10. KS.A 60-205 States:

Service and filing of pleadings and other papers. (a) Service; when required.
(1) In general. Except as otherwise provided in this chapter, each of the
following papers must be served on every party:
(A) An order stating that service is required;
(B) a pleading filed after the original petition, unless the court orders
otherwise under subsection (c) because there are numerous defendants;
(C) a discovery paper required to be served on a party, unless the court
orders otherwise;
(D) a written motion, except one that may be heard ex parte; and
(E) a written notice, appearance, demand, offer of judgment or any similar
paper.

11. KS.A 60-205 (b)(2)(C) (b) States:

Service; how made [] (2) Service in general. A paper is served under this
section by 0 (C) mailing it to the person's last known address, in which event
service is complete upon mailing;

12. KS.A 60-205 states "papers must be served on every party".

13. Defendant's mailing address has not changed. Even though Defendant would prefer

hard copies of pleadings - Defendant's email address has not changed.

14. In sum, Defendant has a statutory right to receive a copy of the motions/pleadings

Plaintiff filed. This also incorporates the basic constitutional due process

requirement of notice. Defendant has a right to respond and to request oral

argument on any pleading prior to a judge ruling on it. Failure of Plaintiff to serve

copies ofthe above mentioned pleadings since January 25th, 2018 violates

Defendant's statutory rights. Such a violation is not harmless because it is done in

bad faith and subjects Defendant to losing his property and counterclaims without

Page 3 of7
 the constitutional right of due process and with no opportunity to present his

disagreement to the district court.

15. Too many pleadings, stretching a period of many months, have not been sent to

Defendant and assuming the certificates of service stated that pleadings were sent

to Defendant then no excusable neglect argument should be entertained by this

court.

16. Without being given notice, as per K.S.A60-205, Defendant would have no way of

knowing the up-to-date status of the pending case and that it causes substantial

prejudice in the litigation.

17. The basic elements of procedural due process are notice and an opportunity to be

heard at a meaningful time and in a meaningful manner. Winston v. Kansas Dept. of

SRS, 274 Kan. 396,409,49 P.3d 1274, cert. denied 537 U.S. 1088 (2002)

18. The Due Process Clause of the Fifth Amendment prohibits the United States-as the

Due Process Clause of the Fourteenth Amendment prohibits the States-from

depriving any person of property without due process of law. U.S. Const. Amends. V,

XIV; see Dusenbery v. United States, 534 U.S. 161, 167 (2002).

19. As stated by the United States Supreme Court in Piper v. Pearson, 2 Gray 120, cited in

Bradley v. Fisher, 13 Wall. 335, 20 L.Ed. 646 (1872), '[w] here there is no jurisdiction,

there can be no discretion, for discretion is incident to jurisdiction.'

20. Subject matter jurisdiction is vested by statute or constitution and establishes the

court's authority to hear and decide a particular type of action. Parties cannot confer

subject matter jurisdiction upon the courts by consent, waiver, or estoppel. Parties

cannot confer subject matter jurisdiction by failing to object to the court's lack of

Page 4 of7
 jurisdiction. If a trial court determines that it lacks subject matter jurisdiction, it has

absolutely no authority to reach the merits of the case and is required as a matter of

law to dismiss it. Kingsley v. Kansas Dept. of Revenue, 288 Kan. 390, 395, 204 P.3d

562 (2009).

21. Defendant also believes that failure to follow K.S.A 60-205 violates the Kansas rules

of professional conduct - in particular rule 226 - 3.4 Advocate: Fairness to Opposing

Party and Counsel.

22. This Court should consider sanctions on Plaintiffs attorneys since this practice of

failure to notice Defendant has been going on ever since Lathrop Gage LLP joined

the case.

23. It is apparent that severe sanctions are needed due to failure to serve defendant

even after Defendant filed attorney ethics complaints against Lathrop Gage LLP

attorneys where this failure to follow the certificate of service issue was brought up .

This is an abuse of the process and is calculated willful, bad faith, practice aimed at

winning the case without affording the opposing party an opportunity to respond.

REQUEST FOR ORAL ARGUMENTS

Plaintiff requests oral arguments pursuant in part to Supreme Court Rule 133 (c) (1).

Supreme Court Rule 133(c)(1) (2017 Kan. S. Ct. R. 198) provides: "A party may

request oral argument-either in the motion or in a response filed by the adverse

party."

Page 5 of7
WHEREFORE, Defendant Prays for an order striking ALL of Plaintiffs filings since

January 25th, 2018, and bar Plaintiff from refilling said pleadings, or for any other

just and proper order.

Respectfully submitted,
BY:.bnC/~
Eric M. Muathe
1410 Bitner Terrace, Pittsburg, Kansas, 66762
(913) 980-7286 < muathedotcom@gmail.com >

Page 60f7
 CERTIFICATE OF SERVICE

I certify that on June 13, 2018 the foregoing was mailed via PRIORITY mail- with
tracking - to the following address:

CLERK OF THE COURT

602 NORTH LOCUST
PITTSBURG, KS 66762

I certify that on June 13, 2018 the foregoing was mailed via first class mail to the
following address:

JEHAN K. MOORE,
C/O LATHROP GAGE LLP,
2345 GRAND BLVD., STE. 2200
KANSAS CITY, MO 64108-2618

BY:~
Eric M. Muathe
1410 Bitner Terrace, Pittsburg, Kansas, 66762
(913) 980-7286
muathedotcom@gmail.com

Page 70f7
Case 2:18-cv-02064-CM-TJJ Document 11-2 Filed 06/01118 Page 1 of 4

EXHIBITB
 Case 2:18-cv-02064-CM-TJJ Document 11-2 Filed 06/01/18 Page 2 of 4
5131/2018 Case Summary

2014-C:V-ODOCl86-P : WilminqtOll Trust Company \IS. Eric jvj "iuathe, etal,

DISTRICT COURTS - Crawford-~t!:tsbufg Di5~r;d Conri

Case Number 2014-CV-000086-P Plaintiff Wilmington Trust Company

Case Type Mortgage Foreclosure Defendant Eric M Muathe et al
Opened Judge Richard M Smith - Division SMITHR
Status Active

8 Show/Hide Participants
Plaintiff[s] Counsel of Record
Wilmington Trust Company Jehan Kamil Moore
1270 Northland Dr #200 2345 Grand Ave Suite 2200
Mendota Heights, MN 55120 Kansas City, MO 64108-2684
(816) 292-2000

Michael J Abrams
2345 Grand Blvd., Suite 2800
Kansas City, MO 64108-2684
(816) 292-2000

Defendant[s] Counsel of Record

Eric M Muathe Pro Se
1410 Bitner Terrace
Pittsburg, KS 66762
(913) 980-7286
muathedotcom@gmail.com

Mortgage Electronic Registration Systems Inc

1901 E Vorhees Street, Suite C
Danville, IL 61834

Citimortgage Inc
C/O The Corporation Company

GB Home Equity LLC

CIa National Registration Agents Inc Of KS

File Date Case History

C••q-ll<~LH4 Petition Filed Document ID Number: 249079
03·1i.-2i}~:1 2 Request For Service Form Document ID Number: 249081
('811-2ft.l4 3 Summons Issued to Crawford County SODocument ID Number: 249083
3 Summons Issued Back to Attny for ServiceDocument ID Number: 249090
Summons Served/Returned Personal Service on Unknown Occupant on August 13 2014Document ID Number: 249575
Summons Served/Returned Personal Service on Eric Muathe on August 13 2014Document ID Number: 249576
C3- f
·'•• 2iU~ Summons Returned/No Service on Unknown Spouse of Eric Muathe Document ID Number: 249577
MemorandumDocument ID Number: 250021
Assignment OrderDocument ID Number: 250022
08-2:-2014 Clerks Fourteen Day Extention of Time to Respond to Plaintiffs Petition Document ID Number: 250299
oa~:;-·,~o:;.4 Mail Returned On GB Home Equity LLC Updated Address in Full Court and Remailed Assignment OrderDocument ID Number: 250525
08 'v2:i' ~.~(} 1.:i- Defendants Objection To Judicial Assignment Document ID Number: 251057
O~"s.,·"'2('J.L<! Defendants Motion To Dismiss WIth Memorandum IncorporatedDocument ID Number: 252730
Request For Service Form Document ID Number: 253076
09-1f.-20;.4 Alias Summons Issued Back to Attny for Service Document ID Number: 253077
10-1 ~-2'H.4 Certificate of Service Document ID Number; 255353
10--1--2014 Alias Summons Returned Served By Certified Mail on GB Home Equity on Sept 26 2014Document ID Number: 255354
11-17-21)1.'1 Plaintiffs Request For Additional Time to Respomd to Defendants Motion to DismissDocument ID Number: 258466
Defendants Objection to Plaintiffs Untimely Request for Additional Time to Respond to Defendants Motion to DismissDocument ro
Number: 259867
Certificate of Service Document ID Number: 259942 EXHIBIT B
12-iJl-.:tCr;4 Certificate of Service Document ID Number: 259941
1;~-D3-2D~4 Plaintiffs Request for Additional Time to Respond to Def. Motion to DismissDocument ID Number: 260240
12-0:';·~OH Order Granting Plaintiffs Request for Additional Time to Respond to Defendants Motion to DismissDocument ro Number: 260241
12-Q3-21Y!~ SUpplemental Objection to Plaintiffs Untimely Request for Additional Time to Respond to Defendants Motion to DismissDocument ID

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 Case 2:18-cv-02064-CM-T JJ Document 11-2 Filed 06101/18 Page 3 of 4
5/31/2018 Case Summary

Number: 260402
12-09-2('-14 Designation of Lead CounselDocument ID Number: 261178
12-i1-2!Jl4 Plaintiffs Suggestions in Opposition To Defendants Motion to Dismiss Plaintiffs Petition Document ID Number: 261278
12-19-20t-l Defendants Reply in Support of Defendants Motion to Dismiss for Lack of Standing Document ID Number: 262228
02-D9-2015 Generated from document Case Mgmt Conf filed Feb 9, 2015
02-20-ZfJ15 Assignment Order-Hen. Janice RusseliDocument ID Number: 268657
02-23-2015 Letter From Elaine BradshawDocument ID Number: 268679
04-02-2015 Letter from Judge RusseliDocument ID Number: 273382
05-06-201.5 Motion For Disqualification of Judge Plus Request For Oral ArgumentsDocument ID Number: 277243
OS-U:5-2D1S Motion For Telephonic Hearing Document ID Number: 276733
OS--D8-2'}15 Objection to Hearing Document ID Number: 277678
05-08-2015 Notice of Filing of Motion of Disqualification Which is AttachedDocument ID Number: 277680
05-12-2015 Letter from Judge Wachter Document ID Number: 277842
05-i8-2015 Motion For Disqualification fo Judge Plus Affidavit in SupportDocument ID Number: 278982
05-26-2015 Letter From Judge Robert Fleming Document ID Number: 280019
06-01-1015 Assignment No. 14 (Ward Iimited)Document ID Number: 280790
OG-O:,-20l5 Order Granting Change of JudgeDocument lD Number: 281703
06-15-2015 Designation of Lead Counsel Document ID Number: 282546
06-1;;-2015 Assignment No 21 - Hon. Richard Smith Document ID Number: 282840
G7-B-1015 Notice Of HearingDocument ID Number: 285712
07-2+1015 Motion For Continuance Document lD Number: 287139
07-24·2015 Motion For Disqualification of Judge Plus Request for Oral ArgumentsDocument ID Number: 287140
07-2+201.5 Motion To Determine Jurisdiction Plus Request For Oral ArgumentsDocument lD Number: 287141
07-27-20(5 Order Denying Change of Judge And Granting Request For Continuance. Copies Mailed to all parties. Document ID Number: 287332
08-10-7.015 Motion For Disqualification of Judge Plus Affidavit in Support Document ID Number: 288949
H!-(lS-2015 Designation of Lead Counsel Document ID Number: 295032
1.2-11-2015 OrderDocument ID Number: 302145
12-23-2015 Assignment No. 15 (Creitz Iimited)Document lD Number: 303278
01-0<-2016 Certificate of Service Document lD Number: 303884
01-()---J(rt6 Order For Further Findings And Counterclaim Document ID Number: 303885
01-21-2uI6 Letter From Eric MuatheDocument ID Number: 305710
01-2.3-2016 Response to Requet For Clarification Document ID Number: 306073
01-21-2016 Letter Pursuant to KSA 60 237 Objecting Premature Discovery Document ID Number: 306510
OHJl-2;)16 Supplemental Motion For Disqualifiction Of Judge Richard Smith Document ID Number: 306970
02-16-2016 Defendants Motion to Stay Discovery Document ID Number: 308550
02~29-2016 Order Overruling Defendants Motion For Disqualification Document ID Number: 309806
02-2"-1016 Plaintiffs Memorandum In Opposition To Defendant Eric Muathe's Motion To Stay Discovery Document ID Number: 309807
04-05-2016 Notice Of HearingDocument ID Number: 313856
04-07-2016 Letter From Eric Muathe to Elaine BradshawDocument ID Number: 313928
0·1-07-2016 Motion For ContinuanceDocument ID Number: 313930
O~-07-2.G16 Letter From Eric Muathe to Elaine Bradshaw Document ID Number: 313932
04-07-101.6 Motion For ContinuanceDocument ID Number: 313933
04C11-20i6 Plaintiffs Response To Defendants Motion For ContinuanceDocument ID Number: 314232
O'H";·20.t6 Plaintiffs Response to Defendants Motion For Continuance Document ID Number: 315662
04-28-2016 Order on Pending Motion Document ID Number: 316128
05-06-201.6 Letter Requesting Clarification and Request For 30 Day Extension to File Answer and/or Counterc/aimDocument ID Number: 317492
05...10<i016 Clerks Fourteen Day Extention of Time To File An Answer and/or CounterdaimDocument ID Number: 317445
05-12-201.6 Letter From Eric Muathe Requesting "Answer/Counterclaim" To Be Filed In The Case FileDocument ID Number: 318084
05-12-20.!.6 Answer to Petition + Counterclaim Document ID Number: 318087
Order On Letter Requesting Clarificaton and Request for 30 day extension to Fife Answer/or CounterclaimDocument ID Number:
05-19-201()
318816
06-02.-2016 Plaintiff's Motion to Strike Eric Muathe's Answer/Counterclaim MOT: Motion (Generic)
06-02·2016 Memorandum in Support of Motion to Strike Answer and Counterclaim INF: Memorandum
(l6-14·1016 Notice of Hearing Motion to Strike NOT: Notice - No Service Required
06·22,-2OJ.6 Letter Dated June 21 2016 to Clerk of the CourtDocument ID Number: 323166
06·2]:-:1016 Response to Plaintiffs Motion to Strike Defendants Answer/Counter Claim Document ID Number: 323168
06··27 '20").6 Letter Dated June 272016 To Clerk of the CourtDocumentID Number: 323170
06-27-2016 Amended Answer to Petition + Counterclaim Document ID Number: 323172
06-29-2DI6 Military Service Affidavit AFF: Affidavit (Generic)
06-3[)-2016 Plaintiff's Motion for Summary Judgment MOT: Summary Judgment
07-07-2{1l6 Scheduling OrderDocument ID Number: 323998
07-i1-201.6 Letter Dated July 7th 2016 to Clerk of the CourtDocument lD Number: 324258
07·ll 20t6 Objection to Proposed Scheduling OrderDocument ID Number: 324259

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 Case 2:18-cv-02064-CM-T JJ Document 11-2 Filed 06/01/18 Page 4 of 4
5/3112018 Case Summary

Second Amended Answer to Petition + Counterclaim Document ID Number: 324260

Gl-25-20i.6 Letter From Eric MautheDocument lD Number: 325920
Defendants Response to Plainiffs Motion for Summary Judgment Requesting Continuance or Extension of Time to Respond Under
KSA 60-256(f) with Affidavit IncorporatedDocument ID Number: 325921
Plaintiffs Motion to Dismiss Counterclaims MOT: Dispositive
Plaintiffs Memorandum in Support of Mtn to Dismiss Counterclaim INF: Memorandum
Request for Statement of Monetary Damages MOT: Motion (Generic)
Certificate of Service INF: Information (Generic)
GS-'i:l-?OE Motion For Sanctions and Request For Oral ArgumentsDocument ID Number: 328471
Motion To Determine the Nature and Cause of Summons and Request For Oral ArgumentsDocument ID Number: 328473
Defendant's Response to Plaintiffs Motion to Dismiss Defendant Eric Muathe's Counterclaims and Request for Oral
ArgumentsDocument ID Number: 329154
Notice of Withdrawl of Counsel And Entry of Appearance of Substituted CounselDocument ID Number: 329343
Motion for Extension of Time MOT: Motion (Generic)
OS-30-201f Response To Plaintiffs Request For Statement of Monetary Damages And Request for Oral ArgumentsOocument ID Number: 329637
Notice Of HearingDocument ID Number: 330982
09-1-1-2016 Motion for Extension of Time to Answer or Otherwise Respond to Discovery Request MOT: Motion (Generic)
09"lS';2D16 Motion to Amend Scheduling Order MOT: Motion (Generic)
OJ-3'>2fJ.L6 Plaintiffs Second Motion for Extension of Time to Answer or Otherwise Respond MOT: Motion (Generic)
Order Granting Motion for Extension of Time ORO: Order - No Service Required
Order Granting Extension of Time to Respond to Discovery Requests ORO: Order - No Service Required
Order Granting Second Motion for Extension of Time to Answer or Otherwise Respon ORD: Order - No Service Required
Amended Scheduling Order ORD: Order - No Service Required
Plaintiffs Unopposed Third Motion for Extension of Time to Answer or Otherwise MOT: Motion (Generic)
Amended Assignment Order ORO: Order Originated by Judge
jJ-03-1016 Order Granting Extension of Time to Respond ORO: Order - No Service Required
!1-16-<')16 Certificate of Service 015: Discovery (Generic)
Plaintiffs Unopposed Motion to Amend the October 6, 2016, Scheduling Order MOT: Motion (Generic)
Second Amended Scheduling Order ORO: Order (Generic)
Certificate of Service DlS: Discovery (Generic)
Motion To Strike All of Plaintiffs Out of Tlrne Second Discovery ResponsesDocument ID Number: 366658
Notice of Hearing NOT: Notice - No Sheriff Service Required
(j7 ...1+1fi17 Motion to Compel Response to Discovery Document ID Number: 367924
'.)7-24~2017 Plaintiffs Response to Oefendant's Motion to Compel MOT: Response
m~-lS..,,?017 Defendants Objection to Proposed Order Document ID Number: 372850
10-17 -2{}1 '] Notice of Withdrawal of Counsel and Entry of Appearance of Substituted Counsel NOT: Notice - No Sheriff Service Required
Motion to Amend Scheduling Order MOT: Motion (Generic)
Amended Scheduling Order ORO: Order (Generic)
Defendant's Response to Plaintiffs Motion To Amend Scheduling OrderDocument ID Number: 395135
O~-·1i}~2[Hg Motion to Amend Scheduling Order MOT: Motion (Generic)
O/i"27~20i8 Proposed Second Amended Scheduling Order ORO: Order (Generic)
Proposed Second Amended Scheduling Order ORO: Order (Generic)
Plaintiff Wilmington Trusts Motion for Summary Judgment on Muathe's Counterclaim MOT: Summary Judgment
Plaintiff's Memo in Support of its Motion for Summary Judgment INF: Memorandum
A INF: Exhibit
B INF: Exhibit
C INF: Exhibit
o INF: Exhibit
05··3~-)U_lB E INF: Exhibit
~}5-3 oj. -2DU3 F INF: Exhibit

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6/12/2018 Gmail - Wilmington v. Muathe: WF rfa answers, WF rfp responses, WF irog answers pdf

M Gmail Eric Muathe <muathedotcom@gmaiLcom>

Wilmington v. Muathe: WF rfa answers, WF rfp responses, WF irog answers pdf

Eric Muathe <muathedotcom@gmail.com> Wed, Nov 16, 2016 at 1:05 PM

To: "Hubbard, Matthew (LG)" <MHubbard@lathropgage.com>

Good Afternoon Matt,

I have been waiting for your discovery responses via regular mail over the last few days I have NOT yet received anything* via regular mail as per your November 11th,
2016 certificate of service.

*The mailman just came by today - November 16th, 2016.

I have to, and will, object that there is a disturbing pattern you have now established right from the beginning where your certificates of service say you mailed a
pleading but it never arrives via regular mail, or even worse in one instant it was mailed several days well after the date stated on the certificate of service.

This is improper!

I have been busy with two federal cases and two Kansas court appeals (one moving to the KSC soon) so would like to take a look at your discovery responses but they
have NOT arrived in the mail as per your certificate of service.

Could you send the discover pleadings since I haven't received them.

Thanks for your cooperation.

Eric Muathe
[Quoted text hidden]

"And therefore our contemplation of this source, as the power which we want, gives us the ability to use that power. And the way we use this process is to contemplate
ourselves as surrounded by the conditions which we want to produce." - Thomas Troward.

Namaste,
Eric Muathe
CEO / Founder
Encare Financial Inc.
http://www.muathe.com
6/12/2018 Gmail - Wilmington v. Muathe: WF rfa answers, WF rfp responses, WF irog answers pdf

Gmail Eric Muathe <muathedotcom@gmail.com>

------ -------- --- ._----------_._-

Wilmington v. Muathe: WF rfa answers, WF rfp responses, WF irog answers pdf

Hubbard, Matthew (LG) <MHubbard@lathropgage.com> Wed, Nov 16, 2016 at 1:13 PM

To: Eric Muathe <muathedotcom@gmaiLcom>

~ ~
We are fed-exing you the hard copies of the discovery pleadings and documents for overnight delivery. We get used to emailing everything these days and
sometimes forget that you have requested hard copies. Let me know if you have any questions.

Thanks,

Matt

From: Eric Muathe [mailto:muathedotcom@gmail.com]

Sent: Wednesday, November 16, 2016 1:05 PM
To: Hubbard, Matt
Subject: Re: Wilmington v, Muathe: WF rfa answers, WF rfp responses, WF irag answers pdf

[Quoted text hidden]