SUPREME COURT OF OHIO ADMINISTRATIVE DIVISION ADMINISTRATIVE DIRECTOR OF THE COURT STEVEN C. HOLLON Harley E. Rowe., Case No. Plaintiff, -vs- JAVITCH, BLOCK & RATHBONE LLC et al, Defendants. MOTION IN OPPOSITION TO MOTION TO DISMISS RESPONDENTS IN STANTER Pro per Harley E. Rowe 43099 State Route 303 Lagrange, Oh 44050 Phone 440-452-4472 i ED MAR 2 9 2012 GLtRlt Ut GO11RT SUPREME COURT OF ONIO
MEMORANDUM IN SUPPORT MOTION IN OPPOSITION COMES NOW, Petitioner Harley E. Rowe Demanding my rights at all times and refusing no rights at any time especially the right to have access to the courts to redress grievances, and For my Complaint, Petitioner is not an attorney and is not well versed in law, not having access to West-law, nor to nexus Lexis. In order to immediately find case-law having expended an elaborate amount of time within the law library. Having common sense and using my commonsense as I would request this Hon. Court to do the same. COMMONSENSE REVIEW Respondent's counsel is an attorney that works for respondents law firm has gone through a great length by placing case-law as to why this Hon. Court should dismiss this action, Instead of just answering the complaint. Petitioner has the right to amend any complaint that is not proper, not being an attorney. I have put together a very simple complaint. I stated, several facts, which I will now do my best. To reiterate the facts simply and to the point. I have attached within the complaint, a certified copy from the Secretary of State
showing that Citibank South Dakota, was not registered as a natural entity within the state of Ohio. Due to that they did not have standing to bring an action within the state courts is very simple and direct as natural Entities. We have a right to have access to the courts Being sovereign citizens Citibank South Dakota is not a natural entity and must register with the Secretary of State of Ohio. In order to have the same rights as natural entities, which they did not do. The respondent had a duty holding a Bar card, and being a member of an association that has registered with the Secretary of State to ensure that any one that they have acted on behalf of or represented as a third-party debt collector had standing to file an action within any State Court of Ohio. By not doing so they have damaged me. I have requested on several occasions for them to cease the damage, which they have made a rational decision not to do. The respondents have been given proper notice, that I had honored all obligations administratively and privately. They refused to look into it and they made a rational decision to damage me. Petitioner has attached a US Supreme Court case, to my complaint which shows that Congress did not intend National Associations to misuse their authority They did intend for them to follow all laws, including all State laws such as registering with the Secretary of State to have standing to file an action in the Ohio courts. I believe that National Associations have intentionally not registered with the Secretary of State in order to defraud the state and the people of the State of moneys that are due to the State. Under collecting of debt "INCOME TAX" by not registering with the Secretary of State. They only had to file Federal income tax and not State income tax 3
attorneys cannot participate in fraud. Neither can state courts. Respondents have brought up evidence rule 201 please see the attached certificate from the Secretary of State as evidence, and also the United States Supreme Court's decision that has been attached to the original complaint also attached hereto and incorporated herein. Affidavit of Harley Rowe as evidence. Respondents brought up, an action in mandamus must be brought in the name of the state. I am a natural born entity of the territory of Ohio in which I have brought this complaint on behalf of myself and had mentioned the damage caused to the State. I have paid money to bring this action. The court has accepted my payment, and I have God-given rights, and if I have in any way filed an improper complaint. I would have a right to amend it under the law, and I would request that this Hon. Court allow me any rights to amend or repair my complaint. Respondents have brought up that relator is solely seeking damage against private parties, which is false, all parties are licensed in the State of Ohio and are corporate entities, not private individuals. Respondents allege that petitioner had adequate remedy. In regards to Civil Cases.ln the Elyria Municipal Court. This complaint has nothing to do with the case other than that respondents have used their sovereign authority to file. Frivolous actions with out standing having a duty and a responsibility not to do so thy have know caused damage.
CONCLUSION For the forgoing reasons, petitioner request this Honorable Court deny Respondents motion to dismiss All rights reserved Iy SUbmitted, Rowe 4309!rState Route 303 Lagrange, Oh 44050 Phone 440-452-4472 Certificate of service A true copy of the foregoing was sent the eye a ordinary US mail, postage prepaid to Michael D. Slodov, attorney for defendants Javitch Block & Rathbone, LLC 1100 superior MM period, 19th floor Cleveland, OH 44114. All rights reserved ectfl* Su^i itted, Har ey K. F36 We 43099 State Route 303 Lagrange, Oh 44050 Phone 440-452-4472 5
AFFIDAVIT OF Harley E. Rowe State of Ohio Lorain County ) )ss: I, Harley E. Rowe hereinafter Affiant, having first been duly sworn according to law, having first handknowledge of the facts herein, and being competent to testify, do affirm that the facts herein are stated by your affiant and are true, correct, complete and not misleading. 1. Your affiant went to the Secretary of State of Ohio and has first-hand knowledge that Citibank N.A. Has not properly registered within the State of Ohio. 2. Your affiant has Under and discharge all obligations to Citibank N.A. Privately and Administratively. 3. Your affiant has honored and discharged all obligations to Sears MasterCard and Choice of MasterCard as required under the UCC laws. 4. Your affiant, As attached the US Supreme Court case to the original complaint and has an understanding that all National Associations have to Follow all Federal and State laws. Affidavit of Harley E Rowe- Page 1 of 2
Further affiant saith naught. Before me a Notary Public, appeared Harley E. Rowe, who making himself known to me did affirm and subscribe hereto on this ^;n day of C^ 2012. Notary Public, My commission expires, F *p\al ^.' y,% ONDAREINKE Notary Public, State of Ohio My Commission Expires :J'.g February 25, 2013 ' O'rypEnOfUn"a Affidavit of Harley E Rowe- Page 2 of 2
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