February 19, 2018
THE MATTER: The
law in this case involves issues that affect thousands of potential
Family Court litigants each year who are involved in Paternity, Custody
and other Family Court related matters that cross state lines. These
cases occur due to individuals easily moving from state to state and
children raised by various family members across state lines. Questions
of paternity may be raised in one state, followed by subsequent
paternity actions in other states, as the child moves between relatives.
History: The
instant paternity action caused the court to find out both subject
matter and personnel jurisdiction were lacking where the Trial Court and
Appellate Division ignored key evidence of fraud and attorney collusion
used to hide and/or shield defendant
These issues are of
general public importance, by raising questions such as if the Appellate
division erred, and, by creating new rules with regards to the issues
of collateral estoppel and res judicata, namely, reliance on a vacated
judgment in a neighboring State Action as preclusive of issues of
paternity, the Appellate Division conflicted with substantial precedent.
By granting Full Faith
and Credit to a vacated judgment of a different jurisdiction, the
Appellate Division ignored precedent in both New Jersey and
Pennsylvania, the alternate forum. Such a decision will have substantial
implications for countless, future litigants in paternity, custody and
other family related matters, as more and more family court litigants
are forced to institute and defend actions in different jurisdictions.
THE SECOND PART: The error of law has occurred in allowing a Pennsylvania (PA) vacated order/judgment to
have legal standings in New Jersey(NJ) with merit, when the order no
longer exist in its home state. And, error of law also occurred when
the defendant who has contacts with state and owns New Jersey properties
did not abide by the laws of the State in avoiding jurisdiction. These
errors of law simply underscore the damage that will be done to New Jersey jurisprudence, if the court of appeals’ opinion is not corrected. And this Court’s intervention is required to correct the matter.
The error of law cause
by Appellant Division by allowing the actions of trial court presents
Federal Constitutional questions, if not corrected by this Court. Necessary
claims and rebuttals regarding personal and subject jurisdiction to all
courts. The hearing was based on Subject and Personal Jurisdiction but
the Judge only ruled on Subject Jurisdiction.
For more read below
https://drive.google.com/file/d/15fkg_NX5Feow4iHQjNw5Ob_jmQbp8pw8/view?usp=sharing
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