-----Original
Message-----
From: Charles Edward Lincoln III [mailto:xxxxxx@gmail.com]
Sent: Friday, August 01, 2014 1:30 AM
To: Alan & Amy Martin; Alan Martin
Subject: Courtesy copy of Motions to be filed in Law Division---Special Civil Part, Mercer County
Dear Mr. Alan J. Martin:From: Charles Edward Lincoln III [mailto:xxxxxx@gmail.com]
Sent: Friday, August 01, 2014 1:30 AM
To: Alan & Amy Martin; Alan Martin
Subject: Courtesy copy of Motions to be filed in Law Division---Special Civil Part, Mercer County
I am asking that you agree voluntarily to dismiss your complaint against me, or else to amend it and refile it in a court of general jurisdiction, so that I may counterclaim against you appropriately.
I attach the documents I have prepared for filing. It will save us both time and money if you will agree to a voluntary dismissal of your complaint against me filed in the Law Division of the Special Civil Part of the New Jersey Superior Court. If you cannot or will not agree to my motions, I will file these motions on Monday, prior to August 8, in addition to moving for a continuance of the hearing. I was entitled to 35 days after the date of service on the Complaint, by New Jersey Law, and 35 days will not have elapsed from July 16, 2014, on August 8, 2014, so the date was improper to begin with.
You appear to be suing for rescission of our February agreement for me to serve as your agent with Power of Attorney to negotiate with Wells Fargo, and to assign your rights to your home so that I can try to preserve them. Your complaint shows a woeful misunderstanding of our agreement, as well as the fact that YOU are the party in breach.
You have also joined and actively participated in a conspiracy against me, which makes me think of a famous New Orleans book you should read called, "A Confederacy of Dunces" (written by John Kennedy Toole, found, edited and posthumously published by Walker Percy, really it's an American Classic---if you haven't already read it). But seriously, you, Michael Mastoris, "Bill R. Johnson," and William Todd Overcash and his minions do make a most amusing bunch of bungling burglars, fraudsters, tricksters, con-artists, and defamers, if you weren't violating a wide variety of laws and injuring me without justification in the process.
Please make no mistake, I do intend to counterclaim against you as outlined in the three documents which I herein attach:
(1) Answer
(2) Motion to Dismiss (New Jersey Superior Form)
(3) Verified Motion to Dismiss (Free form Motion).
I have not yet prepared a Motion for Continuance on the grounds stated, in part because I expect your agreement.
If we proceed with this case, and you force me to file a New Lawsuit or Counterclaim, I will be counterclaiming against you or suing you for $250,000.00 in damages plus costs of suit.
I have taken a new job, but for the time being the 287 South Robertson Boulevard address is still the best by which to reach me. I have an agent with durable power of attorney in New Jersey and I think she is a necessary party to this lawsuit, since it involves events taking place since she became my agent with power of attorney, including the burglary of xxx xxxxxx xxxxxx and the attempted assault and battery planned at the Trenton-Princeton airport between you, Mastoris, and Overcash.
Charles Edward Lincoln, III
"Ich bin der Geist der stets verneint, und das mit recht,
denn alles was entsteht, Ist werth daß es zu Grunde geht."
Deo Vindice/Tierra Limpia
http://charleslincoln3.wordpress.com