this is not a public blog, just a place hwere i can leave myself notes. nothing to see here folks, move along.
Parties to the Case Hide all party details Respondent Russell, James Address 403 Jackson Street Shelburn, IN 47879 Attorney Pro Se
Petitioner Russell, Michelle Address C/O Johnson County Jail DOC 550077 1091 Hospital Road Franklin, IN 46131 Attorney Pro Se
| Defendant | Russell, Michelle | ||||||||||||
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Address
8425 E42nd St Indianapolis, IN 46226 ABT Partners LLC v. Michelle Russell
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this is private property.
unless you have written permission from the property owner to be here
you are trespassing and have been asked to leave.
we are prepared to use reasonable force to repel trespassers.
It generally hasn't worked out well for people who try to steal from me or trespass.
Lonnie Hall - had done the first 20 years of his 120 year sentence.
Jordan Dennison: doing 3 years.
Mighty - doing 3 years.
TJ - dead, murdered.
Honesty Rady - dead.
Michelle Russel - hospital, currently being evicted.
Lydia Bailey-getting away with it so far.
LilBit Schmidt - being prosecuted for trespassing here.
Small rewards will be paid for information leading to the conviction or trespassers or thieves.
Rules: 1. do not bring murdered animals aka meat.
2. All cigarette butts must be picked up for any visitors to be allowed.
If you are here and there are cigarette butts on the ground, you are trespassing.
3. I am recovering mental patient. I need my peace and quiet.
4. Appointments cost $40 minimum in advance and are billed at $235/hr. Because our law office is now closed, it would not make sense to spend that money for nothing. Please go away and leave us alone.
10 side hustles.
1. bank bonus
2. class actions
3. dumpster dive
4. attend auctions help load. learn to auctioneer.
5. real estate. study for broker's exam. invest.
6. stocks. tesla spcx
7. learn to use lawn mower pressure washer snowblower.
8. farmers market. buy seeds by pound, sell by gram. sell weeds. scrumping. don't sell weed but collect customer information.
you can sell dumpster div4ed stuff found art. craft fairs etc.
9. get a garage. have a garage sale. free sunday open house.
10 plasma
11 medical studies.
12 online membership site/youtube/affilaiate links
13 the edward r green letter.
14 tshirts. make for $2 sell online for $20.
15 modeling. start w the tshirts.
39 s denny.
issue: depressed guy a year behind on his mortgage, squatters, rehab didnt take.
hoarder, house needs cleaned. i get to do the front lawn.
idea get a title report. $159 ish. those folks who closed on the chiurch.
To do: notice of lis pendens.
My name is Dustin __ I am the tenant in possession at 39 S Denny. I have been making the morggage payments of $419/mo. I made a downpyament of $_. I have equity. My verbal contract is worth. nothing, but I point to a many years course of dealings.
No eviction is proper; a full foreclosure would be required. We are willing anbd able to pay off th emortgage. if a fair split pf the equity can be agreed to or determined by the court.
The point if this filing is to put the world on notice so there can be no innocent holder in due course, if the legal owener were to try to sell or encumber the property. cost around $25. record w faith kimbro soonest.
motions to file monday
motion to dismiss. comes now d and for his motion to dismiss says pursuant to rule 1, if this court has the jurisdiction and discretion to dismiss the case, defendants moves that it do so, so as not to clog the docket. this case is much ado about nothing. a simple solution would be to dismiss, with or without prejudice.
perhaps the court lacks discretion to grant such a motion at this stage; at least we made the motion. it is not the intent of defendant to complicate the court's workload. similarly, we are open to formal or informal mediation or settlement discussions whether in chambers, open court, or elsewhere. respectfully submitted
suggestion for status conference
This court currently has the matter set for _. I suggest we use this time for a status conference to discuss the motions filed, or reset for a later time.
notice regarding recusal
motion for jury trial
Defendant, Robbin Stewart, on behalf of Chico, a real party in interest, timely moves for trial by jury as of right per Article I section 20. Gates v Indianapolis 2013 is binding authority on this point see also Cunningham 2013.
Additionally defendant on behalf of the dog chico, a real party in interest, moves for trial by jury as of right per article I secction 19. Normally section 19 applies only to criminal trials, while this case is civil. But here where the ordinance is quasi criminal, the protections of section 19 also apply at least to some extent.
Additionally defendant moves for trial by jury under the 7th amendment, as incorporated by the 14th Amendment. This motion is to preserve the record. I do not the expect the trial court to grant on this issue. It is so that Chico has something to go to the Supreme Court with if needed. There is no recent case law on the 7th at scotus, or at least about incorporation. Cases from the 1880s are not controlling or persuasive. In Timbs, an 8th amendment claim of excess fines was incorporated. Chico would be willing to be represented by ij.org at scotus, or by ken faulk. In the event that this motion is denied, a ruling on facts and law is requested.
motion setting standard of review/
Plaintiff's counsel has indicated that she seeks to obtain a judgment based on preponderence of the evidence. The preponderence test is set out by statute as a floor not a ceiling. Here; where the ordinance violations are quasi criminal a clear and convincing evidence test is required at trial (but not necessarily in a pretrial event, see blanche v muk choi lau 2026) under due course of law, article 1 section 12.
blanche v muk choi lau 2026.
It can also be argued that if the state constitution had been silent on this point, the 14th amendment comes into play.
Primarily this would be a due process claim, although it also a violation of equal protection and the p or i clause.
motion for appointment of counsel or ala gaurdian at litem for Chico.
suggest best interest of the dog.
defendant is elderly, has concerns about his own mental health and competence. I am functionally illiterate and may not be able to zealously advocate for Chico. AI may introdiuce nonobvious false claims.
d moves that the court appoint counsel, at d';s expense, or appoint something similar to a gaurdian at litem with the best interest of the dog as its guidepost.
I recognize of course that the dog lacks standing and is considered chattel. nor am i trying to mock the court. Here D's interests and the dog's interest are adverse. It would be easy enough to resolve the case by euthanizing Chico. He is at this point, if plaintiff's allegations are true, which they are not, an uninsurable liability.
I can get another dog for $20.
Chico deserves better.
I do not claim to be Chico's owner. I am here as a temporary guardian. The court may decide Chico's ownership if it chooses.
The dog may belong to Dawn Young, or Guy in woods. Tupac, real name unknown richared coombs? claims he has not been paid for the dog. perhaps that makes tupac thew owner. He can be found usually in care of Patricia Beecher and recently gave an address in 3000 block of Indiana Ave.
In the event that the court denies the motion to dismiss, the motion for s change of venue or recusal,
oh, motion for findings of fact and law. in the event that any of my motions are denied, i request fidnings of fatc anbd law, so a reviewing court has a full record.
answer, affirmative defenses, counterclaims, (municipal liability monell) crossclaims/
mandatory counterclaims. permissive counterclaims.
discovery
motions to file monday
suggestion for status conference
notice regarding recusal
This notice is to inform the court that defendant happens to be the gop nominee for county clerk. I am not moving for recusal, but I am aware some judges have a preference for recusing and end up moving such cases out of county, to the court of an elected judge prepared for a jury trial.
motion for jury trial
motion setting standard of review/
motion for appointment of counsel or ala gaurdian at litem for chico.
suggest best interest of the dog.
answer, affirmative defenses, counterclaims, (municiapl liab monell) crossclaims/
mandatory counterclaims. permissive counterclaims.