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EMBEZZLEMENT OF STATE TAX MONEY TO PROTECT CRIMINAL STATE EMPLOYEES AND PROTECT THE SINALOA CARTEL

STATE OF NEW MEXICO

BERNALILLO COUNTY

SECOND JUDICIAL DISTRICT COURT

CV-2023-07042

Plaintiff,

V.


OF NMSA RULE 11, RULE 16-103, 16-401, 16-804 MANDATED DISBARMENT OF ATTORNEY DANIEL MACKEY; REQUEST ADDITIONAL SANCTIONS WITHOUT BOUNDARIES AGAINST INDIVIDUAL CITIZEN JUSTIN GRAY, ATTORNEY DANIEL MACKEY FOR EXTREME VIOLATIONS OF FRAUD DESIGNED EXPLICITLY TO AFFECT THE DEMISE OF THE US CONSTITUTION ARTICLE III IN TREASON COLLUSION WITH THE INVADING MEXICAN NATIONAL SINALOA CARTEL AGAINST AMERICA TO SUBVERT THE CONSTITUTION OF THE UNITED STATES OF AMERICA; AND JUDICIAL NOTICE OF PLAINTIFF’S SUSTAINING THE FORMER MOTION FOR DEFAULT JUDGMENT AGAINST CITIZEN JUSTIN GRAY, BENAVIDEZ RANCH, AND CITIZEN “JOHN DOE”

COMES NOW the Plaintiff, David Derringer, representing himself Pro-Se with his Response in Opposition to private citizen Justin Gray’s fraud on the court and collusion in embezzlement of New Mexico tax monied to illegally conspire with NM State attorney Daniel Mackey, wherein both do fraud and multiple criminal acts against this Court, “in” in Court, and criminal acts under NMSA Article 30 demanding instant disbarment of attorney Daniel Mackey [2] and criminal prosecution of both Mackey and his illegal client Justin Gray for multiple criminal acts including conspiracy, whereas this court, not being able to file charges or prosecute is MANDATED to notify the New Mexico Attorney General as the “authorities” for such action. .Las Luminarias of the New Mexico Council of the Blind v. Isengard 587 p.2d 444, 92 NM 297 “Existence of civil conspiracy must be pled either by direct allegations or by allegations of circumstances from which a conclusion may be reasonably inferred.”. additionally, this Court is again MANDATED to take action for punishment already the Plaintiff noticing this Court “with knowledge” for extreme sanctions formerly requested, and additional punishment sanctions again separately and distinctly requested again of this Court that cannot be ignored defying all justice mandated under rule of law. What is exceedingly clear here, is that citizen Justin Gray met with a tax-paid New Mexico state attorney and both conjured up a criminal plan to distort the heading of the Derringer law suit, deleting specifically and deliberately the heading inclusive {“private New Mexico citizen Justin Gray (as an individual NM citizen precluded attorney representation by use of NM tax dollar fee payment) “} in a malicious criminal act under NMSA 30-26-1 so as to dupe and deceive this court that Justin Gray could be represented by a New Mexico tax-paid state attorney Daniel Mackey and collude with each other so as to embezzle state tax dollars illegally whereas no state attorney can represent a select private party citizen of New Mexico. U.S. v. Pedreza 27 F.3d 1515 cert denied 115 Supreme Court 347, 513 U.S. 941, 130 L.Ed.2d 303 cert denied “Elements of conspiracy are agreement with another person to violate law, knowledge of essential objectives of conspiracy, knowing and voluntary involvement, and interdependence among alleged co-conspirators.” Plaintiff has already notified this Court that distortion and tampering with public records and court records is a felony crime under NMSA 30-26-1, and NMSA 30-16-8. For the second time now in a row private citizen Justin Gray was worked in conspiracy criminal acts with attorney Daniel Mackey, in distortion of the legal heading of the Plaintiff Derringer suit specifically stating the suit against citizen Justin Gray is not against any New Mexico State employee in any state capacity, but against a private New Mexico citizen. Private citizen Justin Gray’s actions are malicious prosecution and extreme FRAUD ON THE COURT. The intent here is to directly bribe or coerce a judge to allow a private select citizen to collude with a state attorney so as to force the New Mexico taxpayer to pay for Justin Gray’s private attorney fees. This is directed AT THE COURT, as much as at the legal Plaintiff, meant to attack and distort the judicial process and rig and skew the case for improper decisions by the judge. In Bulloch v. United States, 763 F.2d 1115, 1121 (10th Cir. 1985), the court stated "Fraud upon the court is fraud which is directed to the judicial machinery itself and is not fraud between the parties or fraudulent documents, false statements or perjury. ... It is where the court or a member is corrupted or influenced or influence is attempted or where the judge has not performed his judicial function --- thus where the impartial functions of the court have been directly corrupted." Hence the fraudulent pleading filed on October 31, 2023 is entirely FRAUD ON THE COURT and cannot be considered in any of the contained writings. It is also clear and well-settled law that any attempt to commit "fraud upon the court" vitiates the entire proceeding. The People of the State of Illinois v. Fred E. Sterling, 357 Ill. 354; 192 N.E. 229 (1934) ("The maxim that fraud vitiates every transaction into which it enters applies to judgments as well as to contracts and other transactions."); Allen F. Moore v. Stanley F. Sievers, 336 Ill. 316; 168 N.E. 259 (1929) ("The maxim that fraud vitiates every transaction into which it enters ..."); In re Village of Willowbrook, 37 Ill.App.2d 393 (1962) ("It is axiomatic that fraud vitiates everything."); Dunham v. Dunham, 57 Ill.App. 475 (1894), affirmed 162 Ill. 589 (1896); Skelly Oil Co. v. Universal Oil Products Co., 338 Ill.App. 79, 86 N.E.2d 875, 883-4 (1949); Thomas Stasel v. The American Home Security Corporation, 362 Ill. 350; 199 N.E. 798 (1935).

Hence, there is no legal representation of Justin Gray by criminal acts of attorney Daniel Mackey and Mackey must be disbarred. Woodson v. Phillips Petroleum Co., 102 N.M. 333, 695 P.2d 483 (1985) “Lawyers are officers of the court and are always under obligation to be truthful to the court.” In re Nelson 79 N.M. 779, 450 P.2d 188 (1969) “Membership in the bar requires more than mere absence of intention to do wrong; otherwise a high standard of conduct could not be maintained.” ; In re C’De Baca, 109 N.M. 151, 782 P.2d 1348 (1989) “Attorney engaging in conduct involving dishonesty or misrepresentation,.. engaged in conduct prejudicial to the administration of justice, and engaged in conduct adversely reflecting upon his fitness to practice law.” ; In re Arrieta, 104 N.M. 389, 722 P.2d 640 (1986) “Attorney’s actions warranted..suspension since he made misrepresentations to a court”. In re Rickard, 93 N.M. 35, 596 P.2d 248 (1979) “Unprofessional conduct involving dishonesty and fraud warrants disbarment.”; In re Stewart, 104 N.M. 337, 721 P.2d 405 (1986) “Protection of public is primary concern. The court’s primary concern...is to assure that the public is protected from dishonest attorneys, whatever the explanation for the dishonesty.” ; Gengler v. Phelps, 89 N.M. 793, 558 P.2d 62 (Ct. App. 1976) “Rule 16-804 mandates “fair play” of opposing counsel in the administration of justice; lawyers should not attempt to take advantage of technical errors under the rules of civil procedure, as neither the trial court nor the appellate court will condone this practice.”; In re Ayala, 102 N.M. 214, 693 p.2d 580 (1984) “Attorney disbarred for having engaged in ..misconduct, including subornation of false statements,..dishonesty, and intentional misrepresentations..in the form of false statements”.; In re Gabriel, 110 N.M. 691, 799 P.2d 127 (1990) “Probation and indefinite suspension warranted.”; In re Quintana, 104 N.M. 511, 724, P.2d 220 (1986) “Indefinite suspension warranted- Sixteen violations of nine rules governing professional responsibility, involving misrepresentation, neglect, and other conduct prejudicial to the administration of justice resulted in defendant’s being suspended indefinitely from the practice of law.”; In re Gambell, 115 N.M. 737, 858 P.2d 404 (1993) “Disbarment for manufacturing evidence- When an attorney, who is an officer of the court, and whose duty is it to protect the integrity of the adversarial system, intentionally lies and manufactures documents designed to achieve an advantage in litigation, he demonstrates a complete lack of fitness to practice law.”

Accordingly, private citizen Justin Gray was not sued in this matter as any employee of the State of New Mexico, so with proper service applied by simply finding him at a place of employment has no bearing on his particular employment, whereas the tort claims of this private law suit against citizen Justin Gray involve his criminal and tort private acts having no bearing with his employer. Justin Gray citizen is attempting to bribe and coerce a Judge to grant himself some sort of special protection and is in fact asking this Judge to “rig the case” to indemnify and hold harmless a criminal private citizen that broke all laws by his personal acts to do extreme and malicious torts against the Plaintiff, and in point of fact did these torts in direct collusion and conspiracy with the other Defendants in this suit, all working “in concert”. Now, citizen Justin Gray ran to seek an unethical attorney to engage with him for protection at taxpayer expense, which is criminal embezzlement of tax money, yet another crime of citizen Justin Gray, now also a crime of attorney Daniel Mackey. State v. Padilla 879 P.2d 1208, 118 N.M. 189 Cert. Denied 877 P.2d 1105, 117 N.M. 802 “Agreement is gist of crime of conspiracy; overt act is not required, and crime is complete when felonious agreement is reached.” This is extreme FRAUD ON THE COURT that should insult and enrage the judge for proper and extreme punishment. Professor Moore writes that Fraud on the court is limited to fraud that does, or at least attempts to, "defile the court itself," or that is perpetrated by officers of the court "so that the judicial machinery cannot perform in the usual manner its impartial task of adjudicating cases." Moore's Federal Practice 3d ¶ 60.21[4][a] (3d ed. 2003). Thus, a "fraud on the court" is a fraud designed not simply to cheat an opposing litigant, but to "corrupt the judicial process" or "subvert the integrity of the court." Oxxford Clothes XX, Inc. v. Expeditors Int'l, Inc., 127 F.3d 574, 578 (7th Cir. 1997); Pumphrey v. K.W. Thompson Tool Co., 62 F.3d 1128, 1131 (9th Cir. 1995) (citation omitted); Transaero, Inc. v. La Fuerza Area Boliviana, 24 F.3d 457, 460 (2d Cir. 1994). It is marked by an "unconscionable plan or scheme which is designed to improperly influence the court in its decisions," Dixon v. Commissioner, No. 00-70858, 2003 U.S. App. LEXIS 4831, at *11-12 (9th Cir. Mar. 18, 2003), amending 316 F.3d 1041 (9th Cir. 2003), or by "egregious misconduct directed to the court itself." Greiner v. City of Champlin, 152 F.3d 787, 789 (8th Cir. 1998) (citation omitted).

Hence, an immediate Order of Default against private citizen Justin Gray is mandate to be filed of record in this case. When a defendant fails to reply to a lawsuit or otherwise take action in the case, a default judgment is issued in favor of the plaintiff. A default judgment is binding, and the defaulting defendant may not litigate his case or present any evidence. A civil action default judgment will grant the amount of relief sought in a plaintiff's complaint.

Defendants’ ILLEGAL, FRAUD, AND MISREPRESENTATION DEFENDANT’S SPECIAL APPREARANCE AND MOTION TO QUASH FOR IMPROPER SERVICE is entirely illegal as this law suit has nothing to do with the New Mexico Livestock Board or any and all other or former employment that Justin Gray might have had. and notice to the court of criminal acts distorting the court records in felonies state and federal. Due to fraud, all issues of 1-5 are mute. It is no matter what Justin Gray does for a living as the New Mexico State Statutes criminal Code Article 30 apply to all New Mexican citizens whether or not their job or profession is irrelevant and NO ONE IS ABOVE THE LEGISLATED CRIMINAL LAWS, nor is anyone above accountability to the United States and New Mexico Constitution. Hence, corruption of court records, stealing horses, in collusion with the invading Mexican National Sinaloa Cartel are criminal acts without any immunity for any reason whether alleged governmental employees or any other station in life. A government authority, even a Judge can claim no immunity when doing criminal acts on the job or moonlighting in other hours. Even any law enforcement officer in New Mexico has no immunity for performing criminal act even when at work. New Mexico Governor Michelle Lujan Grisham signed the New Mexico Civil Rights Act — also known as House Bill 4 — advancing fair and equal treatment under the law. The legislation effectively bans qualified immunity — a judicial doctrine that shields state actors, including law enforcement officials, from liability, even when they knowingly break the law. New Mexico is now the second state to ban qualified immunity. Citizen Justin Gray simply teamed up with Defendant Benjamin Benavidez Jr. and “John Doe” who have stolen now over 285 + Derringer horses of lifetime value or $28,500,000.00 ($28.5 MILLION DOLLARS), by simply leaving the dilapidated Pajarito fence line down until Derringer horses wander in, and then close the one of two strands of barbed wire to trap and contain them and suitably then herd them into permanent pens without food or water in animal abuse and from the permanent pens then making it easier to load them in horse trailers for larceny to the convicted rustler horse “fence” of Dennis Chavez in Los Lunas, New Mexico, who in turn give kickbacks to Benavidez and Justin Gray, as Dennis Chavez illegally sends the horses to the country of Mexico to be butchered for meat. This is RICO racketeering that Justin Gray is explicitly involved. This Judge can easily take Judicial notice of D-202-CV-2014-07755 wherein Derringer v. Benavidez et al, Derringer sued Benjamin Benavidez Jr. specifically for stealing formerly 2 Derringer horses, and in Benavidez Answer on January 15, 2014 Benavidez confessed in public court record to stealing Derringer horses, using his own truck and trailer to illegally transport the stolen livestock to Valencia County to felon horse rustler Dennis Chavez to sell the stolen property, and at that time criminal co-conspirator Randall Riley forced David Derringer to pay ransom/extortion of $60.00 to felon Dennis Chavez to get back Derringer’s stolen horses. So what is happening here if Justin Gray is assisting the Sinaloa Cartel Benavidez in RICO horse rustling where as a 1,200# horse sold for meat at $18.00 per pound gaining profit of $21,600.00. Benavidez and Justin Gray teamed up to simply claim that the Derringer horses “trespassed” so we’ll just claim a right to take them under NMSA 77-14-3(A) but the retarded Justin Gray and Benavidez didn’t read the statute PROHIBITING claiming any trespass since the Pajarito fence line is not compliant with NMSA 77-16-1. NMSA 77-14-3(A). Trespass on lands. A. It is unlawful for a person or his agents or employees having charge of livestock to permit or allow the livestock to go upon the lands of others in this state for the purpose of grazing or watering upon any waters upon the lands without the permission of the owner or legal claimant or his agent. The provisions of this section shall not be construed to affect the obligation of a property owner to meet the requirements of Section 77-16-1 NMSA 1978 for fencing against such trespasses.

Since Justin Gray was properly served under NMRA Rule 1-004(F)(3) and for any private law suit the Attorney General of NM does not have to be served, Justin Gray did not answer the Complaint as Pro-Se or file any dispositive motion, or hire any private attorney to represent himself, not did he motion the court for any extension of time, nor did he request of the Plaintiff any extension of time and simply DEFAULTED. Justin Gray then after an extensive length of time went to a corrupt state attorney Daniel Mackey and developed a fraud on the court in attempts to save Justin Gray from Default, and the criminal acts in collusion and conspiracy defined above started. In re Quintana, 104 N.M. 511, 724, P.2d 220 (1986) “Indefinite suspension warranted- Sixteen violations of nine rules governing professional responsibility, involving misrepresentation, neglect, and other conduct prejudicial to the administration of justice resulted in defendant’s being suspended indefinitely from the practice of law.” This court has a duty to act in punishment and disbarment to protect the integrity of the judicial system. Tyus v. Martinez, 106 Supreme Court 1787, 475 US 1138, 90 L.Ed.2d 333 on remand 800 F.2d 230 “A judge is not only entitled, but also has a duty to take all lawful measures reasonably necessary to prevent the occurrence of a crime in his courtroom.”Code of Judicial Conduct Canon 3 (D)(2). In re C’De Baca,109 N.M. 151, 782 P.2d 1348 (1989) “Attorney engaging in conduct involving dishonesty or mis-representation,.. engaged in conduct prejudicial to the administration of justice, and engaged in conduct adversely reflecting upon his fitness to practice law.” ; In re Ayala, 102 N.M. 214, 693 p.2d 580 (1984) “Attorney disbarred for having engaged in ..misconduct, including subornation of false statements, dishonesty, and intentional misrepresentations, in the form of false statements”. There is a showing of egregious misconduct directed to the court itself. Greiner v. City of Champlin, 152 F.3d 787, 789 (8th Cir. 1998) (citation omitted). "Proof of the scheme, and of its complete success up to date, is conclusive." Hazel-Atlas, 322 U.S. at 246.; Jemez Properties Inc. v. Lucero, 94 N.M. 181, 608 P.2d 157 (Ct. App.1979) cert denied 94 N.M. 628, 614 P.2d 545 (1980) “Tampering with evidence constitutes exceptional circumstances. Tampering with physical evidence in the case and with public records in the county clerk’s office went beyond the common fraud contemplated by Subdivision (b)(3) of this rule [Rule 1-060], and constituted exceptional circumstances to allow the reopening of judgement more than a year after its entry, under Subdivision (b)(6).”

REQUEST FOR SEVERE SANCTIONS AGAINST INDIVIDUAL CITIZEN JUSTIN GRAY, ATTORNEY DANIEL MACKEY FOR EXTREME VIOLATIONS IN FRAUD OF NMSA RULE 11 IN THIS INSTANT PLEADING TO BE ADDITIONAL AND SEPARATE FROM PREVIOUS REQUESTS

This instant pleading by Defendant individual citizen Justin Gray is fraud and collusion with a state paid attorney in a conspiracy to defile and deceive the court to protect Justin Gray’s moonlighting horse rustling with the Sinaloa Cartel invading the United States. The pleading was not only for improper purposes, but to dupe the court of misinformation, fraud of representation, attempts to dismiss a legal suit filed and served legally by lying to a judge and trying to influence a legal procedure when both attorney and alleged client are both doing criminal acts. New York State National Org. for Women v. Terry, 732 F Supp. 388 “SDNY 1990 Attorneys do not possess immunity from sanctions for their conduct in judicial proceedings so as to preclude imposition of Rule 11 sanctions pursuant to rules enabling act. Fed. Rules of Civil Procedure 11, 28 USCA, 28 USCA 2072." ; “Fraud by Client” “ Paragraph B of 16-401 (Truthfulness in statements to others) recognizes that substantive law may require a lawyer to disclose certain information to avoid being deemed to have assisted the clients’ crime or fraud.”NMRA 0-11 provides: The signature of (a)... party constitutes a certificate by the signer that the signer has read the pleading, motion or other paper: that to the best of the signer’s knowledge, information and belief there is good ground to support it; and that it is not interposed for delay....For a willful violation of this rule (a)...party may be subjected to appropriate disciplinary or other action. In adopting an abuse of discretion standard for the review of an award of sanctions, the Supreme Court stated: “A court may exercise its discretion and impose sanctions for a willful violation of the rule when it finds, for example, that a pleading or other paper signed by an attorney is not well grounded in fact, is not warranted by existing law or a reasonable argument for its extension, or is interposed for an improper purpose.” The primary goal of Rule 11 is to deter baseless filings in district court...Although the rule should be read in light of concerns that it will spawn satellite litigation and chill vigorous advocacy, an interpretation must give effect to the rules’s central purpose of deterrence. Id.; see also White v. General Motors Corp. 908 P.2d 675, 683 (10th Cir. 1990) (sanctions are intended to deter future litigation abuse, punish present litigations abuse, compensate victims of litigation abuse, and streamline court dockets and facilitate case management); Invest Fin. Group. Inc. v. Chem-Nuclear Sys., Inc., 815 P.2d 391, 404 (6th Cir.), cert. denied, 484 U.S. 927, 108 S. Ct. 291, 98 L.Ed.2d 251 (1987). This fraud is a direct violation of Rule 11. This is a "fraud on the court" is a fraud designed not simply to cheat an opposing litigant, but to "corrupt the judicial process" or "subvert the integrity of the court." Oxxford Clothes XX, Inc. v. Expeditors Int'l, Inc., 127 F.3d 574, 578 (7th Cir. 1997); Plaintiff requests for sanctions against each of individual Justin Gray and attorney Daniel Mackey separately in the amount to be awarded Plaintiff David Derringer of $100,000.00.

ADDITIONAL REQUESTS FOR SANCTIONS WITHOUT BOUNDARIES

This pleading in fraud presented by the Defendant Justin Gray in deliberate fraud on the court in cahoots with attorney Daniel Mackey goes well beyond sanctions of NMRA Rule 11 by attempting to defeat the very integrity of the judiciary itself asking a court to deny due process, deny equal protection and defeat the intent of the founders of Article III of the Constitution. US v. Kozminski, US Mich 1988, 108 S. Ct. 2751, 487 US 931, 101 L.Ed.2d 788, on remand 852 F.2d 1288 “Statute prohibiting conspiracy to interfere with rights secured by Constitution or laws of the United States created no substantive rights, but prohibits interference with rights established by Constitution or laws and by decisions interpreting them.” These matters involve not only false fraud on the court pleadings, but an attempt to stop the Plaintiff for any redress of stealing 17 horses included with the other 285 + horses worth themselves $28,500,000.00 and extreme other damages. (the 13(17) horses stolen specifically by Justin Gray have a value of $1,700,000.00 or if each horse is not returned Derringer is owed $100,000.00 per horse) [3] Defendant Justin Gray and attorney Mackey seek to weaponize the judicial system for improper purposes. Fraud on the court should embrace only that species of fraud which does or attempts to, subvert the integrity of the court itself, or is a fraud perpetrated by officers of the court. Kerwit Med. Prods., Inc. v. N. & H. Instruments, Inc., 616 F.2d 833, 837 (11th Cir. 1980). This matter supersedes the instant attack on the Plaintiff, and is an attack upon the integrity of the US Constitution Article III as its intent is to weaponize the courts to intimidate, retaliate and force oppression upon adversaries. The criminal Defendants actions are a fraud designed not simply to cheat an opposing litigant, but to "corrupt the judicial process" or "subvert the integrity of the court." Oxford Clothes XX, Inc. v. Expeditors Int'l, Inc., 127 F.3d 574, 578 (7th Cir. 1997). Plaintiff Derringer requests of the Court to punish Defendant Justin Gray and attorney Daniel Mackey each separately in abuse of process, and malicious prosecution to knowingly producing pleadings intended to delay justice and to deny redress and justice. Plaintiff Derringer requests permission to punish: sanctions without boundaries Harrison v. Bd. of Regents of the Univ. of New Mexico, 2013-NMCA-105, ¶ 2, 311 P.3d 1236, for this court to sanction Defendant Justin Gray and attorney Daniel Mackey each separately for an amount of $100,000.00 payable to Plaintiff David Derringer wherein this case is involving both false pleadings and oppression of Constitution and improper purposes to defeat justice on the most basic level. In NM Court of Appeals review of the “Harrison” case, the Court of Appeals upheld the sanctions. The main rationale for doing so was “ . the need to prevent abusive litigation practice and preserve the integrity of the judicial process.”

SUSTAINING THE MOTION FOR DEFAULT JUDGEMENT AGAINST DEFENDANT JUSTIN GRAY

Justin Gray was properly served under NMRA Rule 1-004(F)(3) and for any private law suit the Attorney General of NM does not have to be served, Justin Gray did not answer the Complaint as Pro-Se or file any dispositive motion, or hire any private attorney to represent himself, nor did he motion the court for any extension of time, nor did he request of the Plaintiff any extension of time and simply DEFAULTED. . Schmider v. Sapir, 82 NM 355, 482 P.2d 58 (1971); Gallegos v. Franklin, 89 NM 118, 547, Pl2d 1160 (Ct. App.) cert denied 89 NM 206, 549 P.2d 284 (1976); Kutz v. Independent Publishins Co., 101 NM 587, 686 Pl2d 277 (Ct. App. 1984). Wherefore, an instant Order then immediately filed with the court for Default is mandated wherein the FACTS are the well pleaded allegations of the Complaint, and ruled by existing statutory law and case laws in support as the sustaining law of the case wherein all counts and in all amounts requested and pleaded as well as all requested sanctions are under rule of law, and court costs, and other relief and deemed proper punishment and other remedy is proper for a Default Judgment against Justin Gray with entry of default and default judgment may be simultaneous, with Order for instant return of the Derringer horses IDENTIFIED AS #1 Bay stallion. #2 Buckskin mare. #3 Buckskin filly. #4 Sorrel mare. #5 Sorrel colt. #6 Black filly. #7 Bay colt. #8 Sorrel colt. #9 Sorrel colt. #10 Sorrel mare. #11 Sorrel colt. #12 Bay mare. #13 Bay filly. Rogers v. Lyle Adjustment Co., 70 NM 209, 372 P.2d 797 (1962).

Respectfully submitted by __________________________________________________

David Derringer, Pro-Se, Box 7431, Albuquerque, New Mexico 87194

I hereby certify that I mailed a copy of this Pleading to the 2nd Dist. Ct. on this date. 400 Lomas NW Albuquerque, New Mexico 87102

I further certify that I mailed a copy of this Response to John D’Amato PO Box 7888 Albuquerque New Mexico 87194 and only out of courtesy mailed a copy to Defaulted parties to Daniel Mackey8206 Louisiana Blvd NE Ste A Albuquerque, New Mexico 87113-1738.

[1] Tampering with public records consists of: A. knowingly altering any public record without lawful authority; B. any public officer or public employee knowingly filing or recording any written instrument, judicial order, judgment or decree in a form other than as the original thereof in fact appeared; C. any public officer or public employee knowingly falsifying or falsely making any record or file, authorized or required by law to be kept; D. any public officer or public employee knowingly issuing or causing to be issued, any false or untrue certified copy of a public record; or E. knowingly destroying, concealing, mutilating or removing without lawful authority any public record or public document belonging to or received or kept by any public authority for information, record or pursuant to law. Whoever commits tampering with public records is guilty of a fourth degree felony [2] Code of Judicial Conduct Canon 3 (D)(2). Disciplinary responsibilities: “A judge who receives information indicating a substantial likelihood that a lawyer has committed a violation of the Rules of Professional Conduct should take appropriate action. A judge having knowledge [3] It is a general rule that an owner of chattel property is competent to testify as to the value of his property. This rule is applicable in both civil and criminal trials. State v. Zarafonetis, 1970-NMCA-064, 81 N.M. 674, 472 P.

 
 
 

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