Official Complaint for Patent Infringement in Civil Action No. 4:12-cv-04055-KES: Adrian et. al. v. Manna Ministry Center et. al. Filed in U.S. District Court for the District of South Dakota, the Hon. Karen E. Schreier presiding. See http://news.priorsmart.com/-l5MA for more info.
Official Complaint for Patent Infringement in Civil Action No. 4:12-cv-04055-KES: Adrian et. al. v. Manna Ministry Center et. al. Filed in U.S. District Court for the District of South Dakota, the Hon. Karen E. Schreier presiding. See http://news.priorsmart.com/-l5MA for more info.
Official Complaint for Patent Infringement in Civil Action No. 4:12-cv-04055-KES: Adrian et. al. v. Manna Ministry Center et. al. Filed in U.S. District Court for the District of South Dakota, the Hon. Karen E. Schreier presiding. See http://news.priorsmart.com/-l5MA for more info.
F7l.En Jerome Adrian; Sonj a Adrian ) ) Plaintiff, ) ) v. ) ) Manna Ministry Center (Fraudulent); ) Hope Community Church; ) New Haven; All Occupants; ) Cadwell, Sanford, Deibert & ) Garry LLP; 50 John & Jane Does; ) Lincoln County (Sheriff, Register of ) Deeds, Clerk of court) ) KEVIN MYERS AND ESTHER, ) MYERS, ) ) Defendants. ) NO 1<1 - NAR 3 02012 Removal of state Civ. 12-
NOTICE OF REMOVAL AND JOIN WITH WITH STATE CIV.12-141 IN Federal Case 12-4052 Jerome Adrian and Sonja Adrian remove the above captioned action to this Court under 28 U.S.C. 1441(b) and gives notice that it is removing this action to this Court as required by 28 U.S.C. 1446(a). Jerome Adrian and Sonja Adrian further seek by this removal leave to join with removed state case 12-141, because this case involves the same matter and title to the land and property with the same Land Patent Issue, and involves the same Manna Ministry Center, with other parties who have claimed an interest or right to the land and property and unlawfully dispossessing. Adrians seek full permission of Myers and the Court or, if required a separate case, but with full jointer as to the issues and matters of law. On or about March 16,2012 a SUMMONS and COMPLAINT is filed in Lincoln County and served on the named Defendants to quit trespass on certain land and property described as: Tract 1 of Adrian's Addition in the NE 14 of Section 33, Township 100 North, Range 50 West of the 5 th P.M., Lincoln County, South Dakota. Now Defendants have continued total avoidance to answer and evading duty to prove their rights and interests in the property described. They seek to manipulate the court to also avoid and evade matters of Title to the land and property and the rights to possession as a result thereof. This state court has persisted in avoiding and evading basic federal law relating to land and rights held under patent as lawful assignee. Pursuant to 28 U.S.C. 1446(b), a defendant must file a notice of removal within thirty (30) days after receipt of a copy ofthe initial pleading. In this case, Plaintiffs filed notice ofa case on or about March 16,2012. All Defendants, except "occupant", are served summons and acknowledge the Summons and Complaint, but refuse to prove rights to the land and property described, or to lawful posssession. The action filed in state court is removable pursuant to 28 U.S.C. 1441(b), which states, "Any civil action of which the district courts have original jurisdiction founded on a claim or right arising under the Constitution, treaties or laws ofthe United States". As required by 28 U.S.C. 1446(a), Jerome Adrian and Sonja Adrian have attached copies of all documents delivered to the defendants and responsive documents from the Defendants, attempting evasion and avoidance of due process of law by manipulating state court, and the proof of service. Kevin and Esther Myers have given written notice of removal to the United States District Court for South Dakota, on the 23rdday of March 2012 in file Civ 12-141, holding Federal Case No. 12-4052, and have agreed to jointer. This NOTICE OF REMOVAL is sent to additional parties named in INFORMATION in defense of Complaint, New Life Center, New Haven, or Hope Community church, and the Second Judicial Circuit, Lincoln County, Canton, South Dakota pursuant to 1446( d). WHEREFORE, the civil action now pending as Civil Number 12-191 in the Second Judicial Circuit in Lincoln County, South Dakota is hereby removed to the United States District Court for the District of South Dakota. Adrians requests that this action be entered upon the docket of this Court in accordance with Fed. R. Civ. P. 81(c) and showing joinder as to cause. Trial by Jury was demanded by Plaintiffs, who are now removing, but the state court has received a MOTION TO DISMISS, thereby refusing to provide Trial by Jury on the merits. Judge Larry Long publicly admits to "non-oath". The Trial on the issue of Land Patent and Contract rights acquired as Assignee, as requested by Plaintiffs before a jury of the people, is prejudicially evaded. This Jury is also to determine whether there was fraud in Manna Ministry Center Claim to a "right to possession", the sole judgment adversely made by Judge Larry Long in state Number 12-141, when Manna Ministry Center had no Title, it had abandoned the property to New Haven on the public record, attempted excuses as a defense, and claimed past Title and right to possession by the use of a name change only. Respectfully Submitted, {terome Adrian 27219 473 rd Avenue Sioux Falls, South Dakota 57108 CERTIFICATE OF CONSENT TO JOINDER This is to state for the record that the undersigned, Kevin and Esther Myers, fully give consent and agree to the joining of cases, removed to determine the federal issue of Land Patent rights under Federal law and the due process clause. Dated this 26th day of March 2012. CERTIFICATE OF SERVICE This is to certify that a true and correct copy of this NOTICE OF REMOVAL AND JOIN WITH WITH STATE CIV. 12-141 IN Federal Case 12-4052 is sent to: CADWELL SANFORD DEIBERT & GARRY LLP 200 E. 10 th Street, Suite 200 Sioux Falls, South Dakota 57101-2498 Clerk of Court Lincoln County Courthouse Canton, South Dakota 57013 Manna Ministry Center (Fraudulent) Hope Community Church Lon Aaseltine, Registered Agent Mike Gaudet, Registered Agen 27213 473 rd Avenue 27009 S Western Ave Sioux Falls, SD 57108-8129 Sioux Falls, SD 57105 Cc: to President Bernard Schock New Haven Lincoln County Marjorie A Faehnrich 104 N. Main 225 E. 11th St. Suite 206 Canton, South Dakota 57013 Sioux Falls, SD 57104 on !his dO day of March 2012. d . ~ L ~