Thursday, April 25, 2013

appeal of 1st Amendment rights deprivations



STATE OF NEW MEXICO
COUNTY OF BERNALILLO
SECOND JUDICIAL DISTRICT COURT


BARRIE DERRINGER,                                                                       No. DV-12-0234
Petitioner,

v.

DAVID DERRINGER,
Respondent,

MEMORANDUM IN SUPPORT OF APPEAL AND OBJECTIONS TO COMMISSION/HEARING OFFICER COSGROVE/AGUILAR’S ILLEGAL AND UNCONSTITUTIONAL APRIL 15, 2013 RECOMMENDATIONS

            COMES NOW the Respondent David Derringer with his Memorandum in Support for Objections to Commission/Hearing Officer Recommendations of April 15, 2013 that must be dismissed entirely, including striking any Order for jail sentencing or any reference to criminal conduct without any criminal hearing, under the following: No summons was ever legally served (R.P. 2-17-2012 unable to serve.)
            On March 19, 2013 hearing was held illegally and without jurisdiction both due to the underlying lack of legal service of summons of this original case making it both in “fundamental error” and without jurisdiction and the matter that the jurisdiction of this DV-12-234 is in the New Mexico Court of Appeals under No. 32,326.
            The hearing was a “civil matter” of false claims of a violation of the order of protection due to Respondent placing legal court public record pleadings and his own “opinion” and headings on the Internet in blogs, that are not connected to any person or entity or any email or web site. Thus, under the 1st Amendment of freedom of speech, freedom or press, freedom of expression, and artistic license of expression, David Derringer has every right to make his own blogs on the Internet Google and to place this “information” for the world to see, including rhetorical questions of concern and confusion as to what happened in the Derringer marriage and a right to photographs of the Derringer’s in their wedding of 2010. Reno v. Am. Civil Liberties Union, 521 U.S. 844, 852, 117 S.Ct. 2329, 138 L.Ed.2d 874 (1997); U.S. v. Tucker, 305    F.3d 1193, C.A.10 (Utah), September 16, 2002 (NO. 01-4150); freedom of opinions and discussions about the Derringer situation as freedom of “expression”.  Elane Photography, LLC v. Willock 284 P.3d 428 this could not impeded the freedom of speech or compel unwanted expression; and did not violate the free exercise clause protections of First Amendment. First Amendment's freedom of expression applies not only to the written or spoken word, but also to expressive conduct and artistic expression. The Respondent was witness and the court record shows that Petitioner Barrie Derringer was asked and agreed that the Internet blogs were not direct contact with her and thus did not violate the no-contact provisions of the Order of Protection. In cross examination, Barrie Crowe aka Barrie Derringer again reiterated that the Internet blogs were not a direct communication to her, as they could not be since they were not sent to her email, were not tied to any web site and she had no obligation or need to access the blog site on which the court public records were posted. The Commissioner has no jurisdiction whatsoever to stop Internet postings by David Derringer of public record, opinions, marriage wedding photographs or commentary of artistic and freedom of expression of David Derringer’s thoughts, concerns, worries, and confusion about the Derringer marriage or the reality or deception of the last three years with wife Barrie Derringer. Brown v. Entertainment Merchants Ass'n 131 S.Ct. 2729, U.S.,2011; U.S. v. Alvarez 132 S.Ct. 2537 U.S.,2012.June 28, 2012 As a general matter, the First Amendment means that government has no power to restrict expression because of its message, its ideas, its subject matter, or its content, and as a result, the Constitution demands that content-based restrictions on speech be presumed invalid and that the Government bear the burden of showing their constitutionality. (Per opinion of Justice Kennedy, with three Justices concurring and two Justices concurring in the judgment.)
            Accordingly, the Commissioner cannot punish, persecute, sentence with criminal charges or act to stop, inhibit or prevent David Derringer from putting any blog on Google with a content of his own opinions, his own writings, public record court pleadings, captions to those pleadings, or dialog of thoughts, artistic interpretation or other means of personal blogs, that are meant not only to expose the public corruption underlying this family court system, but also the lies, untruths, slander and defamation of character that Barrie Derringer aka Barrie Crowe aka Barrie Beverley has spread to friends, employers, family and others of acts that David Derringer did not do, and that seek to fraudulently sustain the irrational and erratic actions of a wife that betrayed her husband and animals and seeks continually to ruin the life of David Derringer without cause. Woodhull v. Meinel, 145 N.M. 533, 202 P.3d 126, 2009 -NMCA- 015, N.M.App., October 24, 2008 (NO. 27,959) information service, system, or access software provider that provides or enables computer access by multiple users to a computer server, including specifically a service or system that provides access to the Internet provides all the world access to information and is well beyond the jurisdiction of the Commissioner in DV-12-234. The information is available for anyone and is not direct contact or use of writing to the Petitioner and does not violate the no contact order to which anyone may freely post information or commentary. Since David Derringer is a party to the litigation, and since the litigation specifically is titled Barrie Lee Derringer Petitioner v. David Brian Derringer Respondent, and in suit David Derringer v. Barrie Crowe aka Barrie Derringer aka Barrie Beverley Defendants, the title of the blogs are appropriately named with Barrie’s various names as in the court documents and this court has no jurisdiction to stop or order a change to the blog names any more than it has jurisdiction to change the name of the legal case and pleadings filed. Claiming that David Derringer tailored his title or speech as a criminal act was illegal and without the jurisdiction of this Commissioner or any court. Ashcroft v. American Civil Liberties Union, 542 U.S. 656, 124 S.Ct. 2783, 159 L.Ed.2d 690, 72 USLW 4649, 32 Media L. Rep. 1865, 04 Cal. Daily Op. Serv. 5781, 2004 Daily Journal D.A.R. 7896, 32 Communications Reg. (P&F) 1089, 17 Fla. L. Weekly Fed. S 507, U.S., June 29, 2004 (NO. 03-218) regulating speech or content by criminalizing certain Internet speech, was unconstitutional because it was not narrowly tailored to serve a compelling governmental interest. Web speakers and others as well as the Constitution 1st Amendment is concerned with protecting the freedom of speech.
            In this matter, there is simply a situation that Barrie Derringer found by accident or by someone other than David Derringer a reference to her name of public record, that was listed in court documents on the Internet not tied in any way to Barrie Derringer by email, web site or other, and was at no time sent to Barrie Derringer. After finding the legal “expressions” opinions and feelings of David Derringer on his own blog with attending public records of court pleadings that exposed Barrie Derringer’s lies about the abandonment of the Derringer marriage and her abandonment of her vows and loyalty to David Derringer, Barrie Derringer sought in fraud and perjury to attack David Derringer illegally in malicious prosecution with re-opening the order of protection, claiming violation in a retaliatory act of viciousness. Barrie Derringer cannot sue, claim damages, claim violations or any other tort act due to the legal use of David Derringer’s 1st Amendment rights. Snyder v. Phelps, 131 S.Ct. 1207, 179 L.Ed.2d 172, 79 USLW 4135, 39 Media L. Rep. 1353, 11 Cal. Daily Op. Serv. 2774, 2011 Daily Journal D.A.R. 3307, 22 Fla. L. Weekly Fed. S 836, U.S., March 02, 2011 (NO. 09-751) ...Freedom of Speech, Expression, and Press in general, and particular issues and applications cannot be used to deprive 1st Amendment rights under Constitution. The Free Speech Clause of the First Amendment can serve as a defense in state tort suits, including suits for intentional infliction of emotional distress. Matters of “public concern” which in this matter includes the fact admitted to under oath by Barrie Crowe aka Barrie Derringer aka Barrie Beverley that she is infected and will spread the STD Sexually Transmitted Disease Herpes that is a part of the tort suit David Derringer v. Barrie Crowe of public record and as public record can be on the blogs of the Internet as “information” and as matters of public concern. Speech on matters of public concern is at the heart of the First Amendment's protection.
      In DV-12-234, Barrie Derringer seeks to mis-use the court system in malicious prosecution to silence David Derringer’s feeling, opinions and public record to stem and stop any members of the public, Barrie’s friends, Barrie’s parents, Barrie’s employers, future dates or others of acquaintance from knowing what Barrie did to her marriage, discharge of her marriage vows, abandoning her husband and animals, particularly after a disaster, with leaving a good marriage without cause. It is notably “disturbing” that the world can hear the truth and the other side of the picture of Barrie’s filing for a no-contact order, a dissolution of marriage and other outrageous acts against a husband that only loved and protected this woman with a loyalty still standing. Both Barrie and the Courts cannot stop the 1st Amendment rights to David Derringer’s opinion of this matter. Sorrell v. IMS Health Inc., 131 S.Ct. 2653, 180 L.Ed.2d 544, 79 USLW 4591, 11 Cal. Daily Op. Serv. 7745, 2011 Daily Journal D.A.R. 9263, 22 Fla. L. Weekly Fed. S 1246, 67 A.L.R.6th 755, U.S., June 23, 2011 (NO. 10-779) ..Freedom of Speech, Expression, and Press is so important in the Constitution that the State finds expression too persuasive and does not permit it to quiet the speech or to burden its messengers.The State may not burden the speech of others in order to tilt public debate in a preferred direction. As law and general rule is that the speaker and the audience, not the government, assess the value of information presented in..Internet blogs, outside of the jurisdiction of the courts.
            This court and the Commissioner, as well as Barrie Derringer have no ability to muzzle or control the writings or opinions of David Derringer under rights of the 1st Amendment, no matter how exposing those opinions are to the Petitioner’s statements formerly to others. Bartnicki v. Vopper, 532
U.S. 514, 121 S.Ct. 1753, 167 L.R.R.M. (BNA) 2199, 149 L.Ed.2d 787, 69 USLW 4323, 143 Lab.Cas. P 59,221, 29 Media L. Rep. 1737, 01 Cal. Daily Op. Serv. 4037, 2001 Daily Journal D.A.R. 4961, 14 Fla. L. Weekly Fed. S 254, 2001 DJCAR 2488, U.S.Pa., May 21, 2001 (NO. 99-1728, 99-1687) Freedom of speech, is different from freedom of conduct. As David Derringer expresses his views, opinions, dreams, expressions and viewpoints, law dictates that no one can control, stop or limit such freedoms under the 1st Amendment. Freedom of Speech, Expression, and Press in general mandate content-neutral regulations or restrictions preventing injunctions or court limitations on speech, Internet blogs and freedom of “expressions”. In determining whether regulation of speech is content-based or content-neutral, court looks to purpose behind regulation; typically, government regulation of expressive activity is content-neutral so long as it is justified without reference to content of regulated speech. As David Derringer is the husband that is aggrieved and violated by the abandonment and abuse of a wife without any cause and with emotional disorders that the husband sought at all times to remedy or assist to a balance, the husband Respondent of the unreasonable acts by Barrie Derringer has a right to expound on his feelings, opinions and his seeking to help a wife he believes is in trouble. There is certainly no crime of a husband loving a wife and seeking to keep a marriage intact and gain counseling for a woman believed to be under emotional PTSD and a bi-polar condition or drugs that render herself incapable for “self-rescue”. State ex rel Stratton v. Sinks, 106 N.M. 213, 220, 741 P.2d 435, 442 (Ct. App. 1987) “substantial evidence is such relevant evidence that a reasonable mind would find adequate to support a conclusion.” In blogs, just as in the press, if David Derringer lawfully obtains information by his own knowledge or through discovery or other that is the truth or believed to be the truth in good faith, and seeks to use that information to expose the truth and stem lies and corruption that includes truthful information about a matter of public significance, state officials may not constitutionally punish publication of such information. Post-traumatic stress disorder admissible. — Post-traumatic stress disorder (PTSD) is both valid and probative and, because it is not unduly prejudicial, it is admissible for establishing whether an alleged victim exhibits symptoms of PTSD that are consistent with emotional disasters. State v. Alberico, 116 N.M. 156, 861 P.2d 192 (1993).   
            In this matter, the jurisdiction is lacking entirely in DV-12-234 to have any in personam control or personal jurisdiction over David Derringer due to the fundamental problem of lacking legal service of summons in the initiative of the action, as well as having no jurisdiction of the subject matter of control over the blogs on the Internet under the rights under the 1st Amendment. Utah Licensed Beverage Ass'n v. Leavitt, 256 F.3d 1061, 29 Media L. Rep. 2193, 2001 DJCAR 3813, C.A.10 (Utah), July 24, 2001 (NO. 00-4058) Freedom of Speech. Finally, we come to the fourth element, whether an injunction would be adverse to the public interest. In A.C.L.U. v. Johnson, we held that an injunction that would block an unconstitutional New Mexico regulation of the Internet would not be “adverse to the public interest[,] as it will protect the free expression of the millions of Internet users both within and outside of the State of New Mexico.” Johnson, 194 F.3d at 1163. Because we have held that Utah's challenged statutes also unconstitutionally limit free speech, we conclude that enjoining their enforcement is an appropriate remedy not adverse to the public interest. See also Elam Constr., Inc. v. Regional Transp. Dist., 129 F.3d 1343, 1347 (10th Cir.1997) (stating, in the context of a request for injunctive relief, that “[t]he public interest . These case laws legally support that the Commissioner cannot stop, punish, cause directive, Order changes, or control or limit David Derringer’s blogs on the Internet and that the Order of April 15, 2013 is both illegal and “cruel and unusual punishment in violation of the 13th Amendment and has to be entirely withdrawn with also making sure that the “sentencing” punishment for retaliation is not placed on any public record against David Derringer regarding “criminal charges”. Mink v. Knox, 613 F.3d 995, 38 Media L. Rep. 1961, C.A.10 (Colo.), July 19, 2010 (NO. 08-1250) ...Freedom of Speech, Expression, and Press. The 1st Amendment free speech is protection from defamation claims extends to parody, fantasy, rhetorical hyperbole, and imaginative expressions, that cannot reasonably be interpreted as stating actual facts about an individual. Even though this court claims that David Derringer asked rehetorical questions regarding his wife and marriage, that does no constitute any violation of a no-contact order, nor can it be controlled, stopped or muzzled to deny the Respondent freedom or speech, freedom or press or freedom of emotional, artistic, or other expression. This court has no ability to convict without standard of evidence or based on conjecture and without Miranda rights or attorney, the Respondent to face and be assessed “criminal sentence” for a crime that did not occur in abuse of discretion and humiliation of cruel and unusual punishment, persecution and bias of the Commissioner and such Order is mandated to be withdrawn with restitution for its formation. David Derringer has no criminal liability. Civil and criminal libel cases are subject to the same First Amendment free speech limitations. Mink v. Knox, 613 F.3d 995, 38 Media L. Rep. 1961, C.A.10 (Colo.), July 19, 2010 (NO. 08-1250).
            This court and particularly the Commissioner has no jurisdiction over the world wide Internet mandating the Order of April 15, 2013 be quashed and dismissed in its entirety. Quik Payday, Inc. v. Stork, 549 F.3d 1302, C.A.10 (Kan.), December 12, 2008 (NO. 07-3289) blogs on Google and...posting the information. See id. at 1157. If such a posting were subject to New Mexico law, it would be equally subject to the laws of every jurisdiction in which the Internet operated. See id. at 1159 ( “[V]irtually all communication on the Internet would meet the statutory definition of ‘knowingly’ and potentially be subject to liability under [the statute]. ” ) Such a regulatory regime could obviously cripple that medium of communication. There is no such regulation of one-to-one commercial exchanges via the Internet. David Derringer’s blogs and Internet postings do not give this Commissioner in personam jurisdiction over either David Derringer or his writings. Sublett v. Wallin, 136 N.M. 102, 94 P.3d 845, 2004 -NMCA- 089, N.M.App., May 24, 2004 (NO. 24101)  A Post website is not sufficient to confer jurisdiction. See Jason H. Eaton, Annotation, Effect of Use, or Alleged Use, of Internet on Personal Jurisdiction in, or Venue of, Federal Court Case, 155 A.L.R. Fed 535, § 4[b] (1999) (listing the many cases that do not find personal jurisdiction where informational websites are involved); see generally Richard E. Kaye, Annotation, Internet Web Site Activities of Nonresident Person or Corporation as Conferring Personal Jurisdiction Under Long–Arm Statutes and Due Process Clause, 81 A.L.R.5th 41 (2000) . {30} The Pillar To Post website appears to be primarily passive. We note at the outset that the only evidence in the record pertaining to the Pillar To Post website is a two-page printout of the page containing information on Wallin and Plaintiff's affidavit detailing her experience with the website. The long arm statute of New Mexico does not confer jurisdiction against David Derringer for any blogs of public record or opinions of David Derringer regarding his marriage or of his opinions of wife Barrie Derringer. Barrie Derringer aka Barrie Crowe cannot exert her control, manipulation and oppression over David Derringer via the Internet.
LEGAL AND CONSTITIONAL VIOLATIONS OF THE MINUTE ORDER MANDATING ITS WITHDRAWAL WITH RESTITUTION AFFORDED THE RESPONDENT FROM BARRIE CROWE AKA BARRIE DERRINGER, ATTORNEY ALAIN JACKSON, COMMISSIONER COSGROVE/AGUILAR, AND THE STATE OF NEW MEXICO
            David Derringer Respondent has been egregiously violated by abuse of process, malicious  prosecution and outrageous Constitutional deprivations that encompass “conspiracy against rights” and “deprivation of rights under color of law” by the Court outside of jurisdiction and judicial capacity and the violent wrath of Barrie Derringer and her unscrupulous attorney Alain Jackson. In the hearing of March 19, 2013 no statements or mention was made that the Commissioner was intending to persecute the Respondent by arbitrarily changing the civil venue of the order of protection to attempt to force a criminal record against the Respondent with in fact no criminal violations have occurred. In this instance, there was no notification to David Derringer of his Miranda rights, there was no ability to gain an attorney for criminal defense and the Commissioner and the Petitioner met in conspiracy to persecute the Respondent in any way possible. Before the hearing, the Respondent had already motioned the Commissioner to recuse for cause, and had motioned the Commissioner to comply with legal Rules of evidence and standards of proof and the Respondent had been denied all relief, with the court stating before the hearing that the court would not be subject to any law, any standard of proof and would not comply with any standard of evidence; obviously a biased and prejudiced court that would stop at nothing to “convict and sentence” the Respondent for criminal act that had not occurred. The Motion and this Memorandum make it clear that there is no possibility of the Order of April 15, 2013 without any jurisdiction of either subject matter or personam jurisdiction over David Derringer and that all actions of the Commissioner were illegal, and well outside of all law.
No. 1.  The Respondent had made all allegations to sustain recusal for cause in written pleading that was reiterated in verbal motion before the court in hearing of March 19, 2013 mandating the Commissioner to recuse; of which she refused in violation of NMRA 1-088.1. It was found in “common knowledge” as the Respondent attempted to gain a “civil attorney” to go up against the Commissioner that all attorneys knew they would lose simply because it was common knowledge that there was both a bias against men in this court as well as a bias against pro-se parties. Since at all times the Commissioner has violated Constitution, violated due process and equal protection and continued with a case that was without any legal service of summons, the recusal was mandated. Huff v. Standard Life Ins. Co., SD Fla. 1986 “Strict construction of statute disqualifying trial judge for bias or prejudice is  grounded upon sound principle that there is possibility of substantial abuse since harsh remedy of cessation of trial proceedings is mandated if allegations purport to state cause for bias. 28 USC 455"; In re A.tl Robins Co. Inc., 97 BR 525 ED.Va 1995 “Bias” is condition of mind, which sways judgement and renders judge unable to exercise his functions impartially in particular case.”
No. 2.              In the MAV Motion the Petitioner did fraud to the court, just as is proven by her own impeachment of the primary Petition for Order of Protection, and this court knows by Oath and Canon that the Commissioner cannot violate provisions of the Constitution, and all case laws presented prove that the court has no in personam jurisdiction over David Derringer and Internet postings, and has no jurisdiction over David Derringer due to never having been served any initial summons. The Order of Protection of February 21, 2012 is void under Constitutional law and lack of due process, and the Petitioner’s Motion of December 11, 2012 was brought in retaliation, retribution and revenge of the tort law suit prior of November 26, 2012 of David Derringer v. Barrie Crowe and Alain Jackson et al. CV-12-10816. The act of Petitioner thus was criminal fraud and malicious prosecution to reopen DV-12-234. Both the “motive” and “purposes” of CV-2010-03825 were “improper ones”. Richter v. Neilson, 11 Cal. App.2d 503, 54 P.2d 54 Cal. App. 1 Dist. 1936. The malicious prosecution here lies in the want of probable cause to bring the action. Clearly, before filing the Petition, the Petitioner and her attorney should have learned the law regarding 1st Amendment rights in the United States of America where we have a “Constitution”. In abuse of process a perversion of court processes is used to accomplish some end which the process was never intended to accomplish, or which compels the party against whom it has been used to do some collateral thing which he could not do legally and regularly be compelled to do, or to keep the party against whom it has been used to stop doing some collateral thing in which he has rights to do. Geier v. Jordan DC Mun. App. 107 A.2d 440.
No. 3 (mismarked on the Order as also No. 2) The Respondent has placed legal court pleadings of public record and at the most, personal thoughts, opinions and freedoms of expressions on the Internet Google under blogs that are not tied to any emails, web sites and stand alone for the world to see the lies and corruption of the courts and the fraud underlying the Petitioner’s actions to ruin the life of the Respondent by falsely accusations for a bogus Order of Protection that was never legally served in summons. All actions in this matter are not within the jurisdiction of this court or the Commissioner. U.S. v. Tucker, 305    F.3d 1193, C.A.10 (Utah), September 16, 2002 (NO. 01-4150)...“is analogous to a bulletin board” for information. It allows computer users “to search for and retrieve information.” These blogs did expose however also the courts in fraud, as well as exposing the public corruption of the State of New Mexico family court system of the “known hatred” of men by Commissioner  and Judge Hadfield, and the severe “sedition and treason” of deprivation of Constitutional rights without due process by the bias of the judiciary, including violations of Canon, Code of Judicial Conduct, Oath and ignoring all laws that violated the Order of Protection. freedom of opinions and discussions about the Derringer situation as freedom of “expression”.  Elane Photography, LLC v. Willock 284 P.3d 428 this could not impeded the freedom of speech or compel unwanted expression; and did not violate the free exercise clause protections of First Amendment. First Amendment's freedom of expression applies not only to the written or spoken word, but also to expressive conduct and artistic expression. The Commissioner has both no “jurisdiction” or legal ability to deny David Derringer “free speech”, or control or limit what David Derringer chooses to say about his personal life, opinions of his marriage, or certainly cannot stop David Derringer from posting “legal public documents of court pleadings”. Brown v. Entertainment Merchants Ass'n 131 S.Ct. 2729, U.S.,2011 On First Amendment challenge to California law that restricted speech based on its content, California failed to satisfy burden of showing either that the law was justified or by compelling government interest.
No. 4 (mismarked on the Order as No. 3) All of the postings on the Internet are exact copies of legally filed court pleadings and court papers, legal complaints against the Commissioner, attorney Alain Jackson and show the corruption of the court by “public record”. The Court in hearing sustained that the actual pleadings posted were identical to the filed and stamped court record in DV-12-234, DM-12-610, CV-12-1307 and CV-12-10816 in the Second Judicial District Court of Bernalillo County. All court actions involve the Petitioner Barrie Derringer, her employer NAI Maestas and Ward and owners and employees thus, and the parents of Barrie Derringer; Geraldine and Warren Crowe, and the attorney Alain Jackson and are a legal suit by David Derringer under US Code Title 42 Section 1981(a). Village of Ruidoso v. Warner, 274 P.3d 791, 2012 -NMCA- 035, N.M.App., February 15, 2012 (NO. 30,591) It is illegal even when claims of facially valid if it deprived the challenger of a protected right of Freedom of Speech, Expression, and Press and cannot hold with interfering with First Amendment freedoms.
No. 5 (mismarked on the Order as No. 4) The acts of the court are a direct and unconscionable violation by the court of all Rules of evidence as the exhibits of No 1-10 were incomplete and not admissible in a court of law. Each “exhibit” marked as 1-10 was only a top page of what was at least 20 pages of document missing in each exhibit. Objection was made in the hearing by the Respondent, that was “sustained” by the Commissioner that such exhibits could not be introduced as evidence for any purpose. In the hearing,  recess was extensive wherein the Commissioner allowed the Petitioner and her attorney Alain Jackson to gain the other pages of each exhibit of which they failed to produce. At all times the Respondent objected that exhibits 1-10 did not meet any standard of evidence and had to be discarded and not considered by the court as “inadmissible”. Without legal merit, the Commissioner after hearing now uses this inadmissible exhibits to attack and  condemn the Respondent well outside of any judicial power. However. All names of Barrie Derringer are permitted to be on any blog as they are defined in David Derringer v. Barrie Crowe aka Barrie Derringer aka Barrie Beverley et al in CV-12-10816 of court record as Title to the law suit, making no legal problem with posting the title to what is of record with the Second Judicial District Court in CV-12-10816. The Commissioner has no jurisdiction anyway of the Internet and has no jurisdiction to use, peruse or validate exhibits 1-10 that are incomplete and inadmissible under the rules of evidence. Improper admission of exhibits afforded no ground for reversal under former law unless it appeared that the court considered them in deciding the case, particularly where there was testimony free from objection to support the court's findings. Gish v. Hart, 75 N.M. 765, 411 P.2d 349 (1966).  Where the improper evidence has been used for impeachment purposes, not only does the error permit the jury to consider the substantive effect of the evidence itself; it also discredits the testimony of the witness, including, of course, the defendant if he or she has testified. Clark v. State, 112 N.M. 485, 816 P.2d 1107 (1991).  In this matter, the court sustained the inadmissible evidence, and then in “fraud” against the Respondent illegally used that inadmissible evidence in the Order. State v. King, 90 N.M. 377, 563 P.2d 1170 (Ct. App. 1977), overruled on other grounds State v. Reynolds, 98 N.M. 527, 650 P.2d 811 (1982).   
No. 6 (mismarked as No. 5 in the Order) Exhibit 7, as all exhibits 1-10 were incomplete and inadmissible as any evidence, and the Respondent properly objected to this, and then in fraud, the Commissioner used the inadmissible evidence against the Respondent in the Order. To preserve error on appeal, there must be a proper objection. Poorbaugh v. Mullen, 99 N.M. 11, 653 P.2d 511 (Ct. App. 1982). All case laws sustain that the Commissioner has no jurisdiction over David Derringer in personam due to a lack of legal service of summons as well as has no jurisdiction over the Internet. Under Constitutional provisions of freedom of speech, freedom or press, and freedom of expression including freedom or artistic expression, there is no legal problem with the husband of Barrie Derringer exercising his rights to post a photograph of his wife at the time they were married with his opinion or confusions of the divorce actions and other legal expressions of thought as a matte of law. Canon 3 (B)(2): A judge shall be faithful to the law and maintain professional competence in it.
No. 7 (mismarked on the Order as No. 6) In the illegal and unconstitutional Order of Protection of which was never served summons legally upon David Derringer states without jurisdiction that the Respondent may not abuse Petitioner. Specifically it states that the Respondent may not harass Petitioner. Smith v. Doe, 538 U.S. 84, 123 S.Ct. 1140, 155 L.Ed.2d 164, 71 USLW 4125, 71 USLW 4182, 03 Cal. Daily Op. Serv. 1974, 2003 Daily Journal D.A.R. 2474, 16 Fla. L. Weekly Fed. S 142, U.S., March 05, 2003 These facts do not render Internet notification punitive. Placing legal court public record on the Internet and placing legal opinions and concerns does in no way either abuse or harass the Petitioner, as the actions of David Derringer have been sustained in case laws to be expressions of the rights under the 1st Amendment as well as rights to paraphrase names, sequences and torts already complained of in court record, to include, but not limited to the statements under Oath of Barrie Derringer in both DV-12-234 and DM-12-610 of “lying”, “domestic violence against husband David Derringer”, “having the STD venereal disease of Herpes”, and being “suicidal”; such statements thus not being slander or abuse but of court record. There was no abuse or harassment of Barrie Derringer on any Internet sites that are not under the jurisdiction of this court or the Commissioner. Brown v. Entertainment Merchants Ass'n 131 S.Ct. 2729, U.S.,2011 On First Amendment challenge to California law that restricted speech based on its content, California failed to satisfy burden of showing either that the law was justified or by compelling government interest.
No. 8 (mismarked on the Order as No. 7) Although NMSA Section 30-3A-2 defines a section of statements, of which do not apply in this matter as David Derringer has a right to post legal pleadings and truths and court actions of torts in detail as in the pleadings regardless if those court actions of tort claims annoy, alarm, terrorize, or cause emotional distress. The Rules of Civil Procedure clearly state in NMRA Rule 1-090 that the “truth” must be told to the courts, despite how “ugly” that truth is to Petitioner Barrie Derringer or the corruption of the Commissioner being exposed in court record. Canon: “Our legal system is based on the principle that an independent, fair, and competent judiciary will interpret and apply the laws that govern us. The role of the judiciary is central to American concepts of justice and the rule of law. Intrinsic to all sections of this Code are the precepts that judges, individually and collectively, must respect and honor the judicial office as a public trust and strive to enhance and maintain confidence in our legal system. The judge is an arbiter of facts and law for the resolution of disputes and a highly visible symbol of government under the rule of law.” Although maligned continuously by the corrupt section of the judicial system, the Respondent states the facts as truth that is distasteful to some, in “good faith” for justice to be served, which rarely occurs. McKay v. Farmers & Stockmans Bank, 92 NM 181, 585 P.2d325 (Ct. App.) Cert denied 92 N.M. 79, 582 P.2d 1292 (1978) “Good faith is usually a question of fact.” Clearly, if the Petitioner had not done torts that caused a legal suit from the Respondent including infliction of a STD venereal disease of Herpes, criminal conversion, assault and battery and other egregious torts, the suit would not be of public record and there is no violation by David Derringer of any criminal statutes including but not limited to NMSA 30-3A-2 or other and this court does not have in personam jurisdiction over David Derringer without proper service of summons and has no jurisdiction over the Internet or postings thereon, whether or not such posting contain photographs, opinions, conclusions or public records. For any claim of criminal violation of “harassment”, David Derringer was to be afforded an attorney to defend criminally, his Miranda rights read before commencement of any criminal proceeding, and this was denied to David Derringer, making the Order of April 15, 2013 “jurisdictionally defective” and in “fundamental error” of due process and equal protection.
No. 9 (mismarked on the Order as No. 8) The court is legally incorrect, as under all case laws presented to this court the Respondent did not harass the Petitioner at any time, whether on the Internet and did no communication with the Petitioner at any time, and this court has no in personam jurisdiction over David Derringer without proper service of summons and has no jurisdiction over the Internet or postings thereon, whether or not such posting contain photographs, opinions, conclusions or public records. Reno v. Am. Civil Liberties Union, 521 U.S. 844, 852, 117 S.Ct. 2329, 138 L.Ed.2d 874 (1997) The information is stored in the form of blogs on Web “pages.” “Web pages frequently contain information..”. The blogs are not tied to anyone’s web page or email nor were they sent to any persons making them not in violation of the “no-contact” order as testified by Barrie herself both in testimony of witness and under cross examination that Barrie Petitioner did not consider the Internet blogs to be a way to contact her directly. Since the Petitioner’s name is entitled in the public record as “DV-12-234 and DM-12-610” Barrie Lee Derringer Petitioner v. David Brian Derringer Respondent there is legal application for the title of the blog to be so addresses as in public record of the Second Judicial District Court as well as all names of the Petitioner addressed in public record of CV-12-10816 as David Derringer v. Barrie Crowe aka Barrie Derringer aka Barrie Beverley et al. Since public records sustain all of the names of Barrie Derringer as the Petitioner in this matter and the Internet posting all contain public court pleadings of such cases, these is no “harassment” of using the legal names of the Petitioner and Defendant to such cases. The wedding photographs of Barrie Derringer and David Derringer are not in any way offensive or pornographic and are within the guidelines of “expression and opinions and artistic expression” of the blogs of David Derringer under all case laws that this court has to follow involving the right of David Derringer under the 1st Amendment. Schwartz v. New Mexico Medical Bd., P.3d, 2012 WL 4434739, N.M.App., August 14, 2012 (NO. 31,303).
No. 10 (mismarked as No. 9 in the Order) Under law and former case law that this court has to follow under Oath and Canon, this court cannot order David Derringer to remove any text, photographs or other “1st Amendment expressions” in any blogs on the Internet as the Court and this Commissioner have no jurisdiction for such an order. Smith v. Doe, 538 U.S. 84, 123 S.Ct. 1140, 155 L.Ed.2d 164, 71 USLW 4125, 71 USLW 4182, 03 Cal. Daily Op. Serv. 1974, 2003 Daily Journal D.A.R. 2474, 16 Fla. L. Weekly Fed. S 142, U.S., March 05, 2003. This court cannot impose sanctions or criminal sentencing for actions supported by Constitution and case laws that this court has to abide, nor can this court sanction, persecute or condemn or cause cruel and unusual punishment against David Derringer for exercising his rights under Constitution. US v. McDermott, CA2 (N.Y.) 1990, 918 F.2d 319 cert. denied 111 S. Ct. 1681, 500 US 904, 114 L.Ed.2d 76 “Statute prohibiting conspiracy to injure, oppress, threaten or intimidate any inhabitant of a state in free exercise or enjoyment of a right or privilege secured under Constitution or laws of United States applied to alleged Fourteenth Amendment violations.”; 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.”; Title 18 Section 241-Conspiracy against rights  Title 18 Section 241 provides:  “If two or more persons conspire to injure, oppress, threaten, or intimidate any person in any State, Territory, Commonwealth, Possession, or District in the free exercise or enjoyment of any right or privilege secured to him by the Constitution or laws of the United States, or because of his having so exercised same”.; Title 18 Section 242-Deprivation of rights under color of law Title 18 Section 242 provides:   Whoever, under color of law, statute, ordinance, regulation, or custom willfully subjects any person in any State, Territory, Commonwealth, Possession, or District to the deprivation of any rights, privileges, or immunities secured or protected by the Constitution or laws of the United States, or to different punishments, pains, or penalties, ..than are prescribed for the punishment of citizens, shall be fined under this title or imprisoned..” This court has no in personam jurisdiction over David Derringer without proper service of summons and has no jurisdiction over the Internet or postings thereon, whether or not such posting contain photographs, opinions, conclusions or public records.
No. 11 (mismarked as No. 10 on the Order) Under law and former case law that this court has to follow under Oath and Canon, this court cannot order David Derringer to remove any text, photographs or other “1st Amendment expressions” in any blogs on the Internet. Ashcroft v. American Civil Liberties Union, 542 U.S. 656, 124 S.Ct. 2783, 159 L.Ed.2d 690, 72 USLW 4649, 32 Media L. Rep. 1865, 04 Cal. Daily Op. Serv. 5781, 2004 Daily Journal D.A.R. 7896, 32 Communications Reg. (P&F) 1089, 17 Fla. L. Weekly Fed. S 507, U.S., June 29, 2004 (NO. 03-218) criminalizing certain Internet speech, was unconstitutional as the Court and this Commissioner have no jurisdiction for such an order, nor can this court sanction, persecute or condemn or cause cruel and unusual punishment against David Derringer for exercising his rights under Constitution. US v. McDermott, CA2 (N.Y.) 1990, 918 F.2d 319 cert. denied 111 S. Ct. 1681, 500 US 904, 114 L.Ed.2d 76 “Statute prohibiting conspiracy to injure, oppress, threaten or intimidate any inhabitant of a state in free exercise or enjoyment of a right or privilege secured under Constitution or laws of United States applied to alleged Fourteenth Amendment violations.”; 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.”; Title 18 Section 241-Conspiracy against rights  Title 18 Section 241 provides:  “If two or more persons conspire to injure, oppress, threaten, or intimidate any person in any State, Territory, Commonwealth, Possession, or District in the free exercise or enjoyment of any right or privilege secured to him by the Constitution or laws of the United States, or because of his having so exercised same”.; Title 18 Section 242-Deprivation of rights under color of law Title 18 Section 242 provides:   Whoever, under color of law, statute, ordinance, regulation, or custom willfully subjects any person in any State, Territory, Commonwealth, Possession, or District to the deprivation of any rights, privileges, or immunities secured or protected by the Constitution or laws of the United States, or to different punishments, pains, or penalties, ..than are prescribed for the punishment of citizens, shall be fined under this title or imprisoned..” This court has no in personam jurisdiction over David Derringer without proper service of summons and has no jurisdiction over the Internet or postings thereon, whether or not such posting contain photographs, opinions, conclusions or public records. This court has no legal jurisdiction to order David Derringer to remove any photographs from the Internet by May 15, 2013 or any other time and no jurisdiction, authority, or juridical ability to sanction the Respondent for exercising his 1st Amendment right with a photograph of a marriage of the parties well before any court action took place that is not offensive in any manner.
No. 12 (mismarked on the Order as No. 11) The court misuses “exhibit 4” that is inadmissible under the rules of evidence as “incomplete” and without jurisdiction. Regardless, both exhibits 4 and 11 are Internet postings of legal public records of court pleadings with the names of proper parties of those pleadings which include public record as “DV-12-234 and DM-12-610” Barrie Lee Derringer Petitioner v. David Brian Derringer Respondent there is legal application for the title of the blog to be so addresses as in public record of the Second Judicial District Court as well as all names of the Petitioner addressed in public record of CV-12-10816 as David Derringer v. Barrie Crowe aka Barrie Derringer aka Barrie Beverley et al. Since public records sustain all of the names of Barrie Derringer as the Petitioner in this matter and the Internet posting all contain public court pleadings of such cases, these is no “harassment” of using the legal names of the Petitioner and Defendant to such cases. Presumptions did not dictate a result in a civil trial under this rule. Algermissen v. Sutin, 2003-NMSC-001, 133 N.M. 50, 61 P.3d 176. The wedding photographs of Barrie Derringer and David Derringer are not in any way offensive or pornographic and are within the guidelines of “expression and opinions and artistic expression” of the blogs of David Derringer under all case laws that this court has to follow involving the right of David Derringer under the 1st Amendment. Under law and former case law that this court has to follow under Oath and Canon, this court cannot order David Derringer to remove any text, photographs or other “1st Amendment expressions” in any blogs on the Internet as the Court and this Commissioner have no jurisdiction for such an order, nor can this court sanction, persecute or condemn or cause cruel and unusual punishment against David Derringer for exercising his rights under Constitution. US v. McDermott, CA2 (N.Y.) 1990, 918 F.2d 319 cert. denied 111 S. Ct. 1681, 500 US 904, 114 L.Ed.2d 76 “Statute prohibiting conspiracy to injure, oppress, threaten or intimidate any inhabitant of a state in free exercise or enjoyment of a right or privilege secured under Constitution or laws of United States applied to alleged Fourteenth Amendment violations.”; 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.”; Title 18 Section 241-Conspiracy against rights  Title 18 Section 241 provides:  “If two or more persons conspire to injure, oppress, threaten, or intimidate any person in any State, Territory, Commonwealth, Possession, or District in the free exercise or enjoyment of any right or privilege secured to him by the Constitution or laws of the United States, or because of his having so exercised same”.; Title 18 Section 242-Deprivation of rights under color of law Title 18 Section 242 provides:   Whoever, under color of law, statute, ordinance, regulation, or custom willfully subjects any person in any State, Territory, Commonwealth, Possession, or District to the deprivation of any rights, privileges, or immunities secured or protected by the Constitution or laws of the United States, or to different punishments, pains, or penalties, ..than are prescribed for the punishment of citizens, shall be fined under this title or imprisoned..” This court has no in personam jurisdiction over David Derringer without proper service of summons and has no jurisdiction over the Internet or postings thereon, whether or not such posting contain photographs, opinions, conclusions or public records. This court has no legal jurisdiction to order David Derringer to remove any photographs from the Internet by May 15, 2013 or any other time and no jurisdiction, authority, or juridical ability to sanction the Respondent for exercising his 1st Amendment right with a photograph of a marriage of the parties well before any court action took place that is not offensive in any manner.
No. 13 (mismarked as No. 12 of the Order) The Respondent has not abused the Petitioner in any way by having public records on the Internet outside of the jurisdiction of this court and is protected from criminal violation and torts by the 1st Amendment of the Constitution wherein this court has no jurisdiction and cannot inflict punishment against David Derringer for any action on the Internet which indeed are not offensive, of public record and all fall under 1st Amendment rights. Internet postings of legal public records of court pleadings with the names of proper parties of those pleadings which include public record as “DV-12-234 and DM-12-610” Barrie Lee Derringer Petitioner v. David Brian Derringer Respondent there is legal application for the title of the blog to be so addresses as in public record of the Second Judicial District Court as well as all names of the Petitioner addressed in public record of CV-12-10816 as David Derringer v. Barrie Crowe aka Barrie Derringer aka Barrie Beverley et al. Since public records sustain all of the names of Barrie Derringer as the Petitioner in this matter and the Internet posting all contain public court pleadings of such cases, these is no “harassment” of using the legal names of the Petitioner and Defendant to such cases. An inference may continue to operate in an evidentiary sense even after introduction of evidence tending to establish the contrary, and may sufficiently influence the trier of facts to conclude that the presumed fact does exist. Sanchez v. Quintana, 97 N.M. 508, 641 P.2d 539 (Ct. App. 1982); Montoya v. Torres, 113 N.M. 105, 823 P.2d 905 (1991). The wedding photographs of Barrie Derringer and David Derringer are not in any way offensive or pornographic and are within the guidelines of “expression and opinions and artistic expression” of the blogs of David Derringer under all case laws that this court has to follow involving the right of David Derringer under the 1st Amendment. Under law and former case law that this court has to follow under Oath and Canon, this court cannot order David Derringer to remove any text, photographs or other “1st Amendment expressions” in any blogs on the Internet as the Court and this Commissioner have no jurisdiction for such an order, nor can this court sanction, persecute or condemn or cause cruel and unusual punishment against David Derringer for exercising his rights under Constitution. US v. McDermott, CA2 (N.Y.) 1990, 918 F.2d 319 cert. denied 111 S. Ct. 1681, 500 US 904, 114 L.Ed.2d 76 “Statute prohibiting conspiracy to injure, oppress, threaten or intimidate any inhabitant of a state in free exercise or enjoyment of a right or privilege secured under Constitution or laws of United States applied to alleged Fourteenth Amendment violations.”; 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.”; Title 18 Section 241-Conspiracy against rights  Title 18 Section 241 provides:  “If two or more persons conspire to injure, oppress, threaten, or intimidate any person in any State, Territory, Commonwealth, Possession, or District in the free exercise or enjoyment of any right or privilege secured to him by the Constitution or laws of the United States, or because of his having so exercised same”.; Title 18 Section 242-Deprivation of rights under color of law Title 18 Section 242 provides:   Whoever, under color of law, statute, ordinance, regulation, or custom willfully subjects any person in any State, Territory, Commonwealth, Possession, or District to the deprivation of any rights, privileges, or immunities secured or protected by the Constitution or laws of the United States, or to different punishments, pains, or penalties, ..than are prescribed for the punishment of citizens, shall be fined under this title or imprisoned..” This court has no in personam jurisdiction over David Derringer without proper service of summons and has no jurisdiction over the Internet or postings thereon, whether or not such posting contain photographs, opinions, conclusions or public records. This court has no legal jurisdiction to order David Derringer to remove any photographs from the Internet by May 15, 2013 or any other time and no jurisdiction, authority, or juridical ability to sanction the Respondent for exercising his 1st Amendment right with a photograph of a marriage of the parties well before any court action took place that is not offensive in any manner.
No. 14 (improperly numbered No. 13 on the Order) The court misuses “exhibit 4” that is inadmissible under the rules of evidence as “incomplete” and without jurisdiction. Although objection was not as specific as it might have been, as it sufficiently informed the court that objection was being made to proof of content of a document in violation of the best evidence rule, it was sufficient to preserve that objection for review. Frost v. Markham, 86 N.M. 261, 522 P.2d 808 (1974). Regardless, both exhibits 4 and 11 are Internet postings of legal public records of court pleadings with the names of proper parties of those pleadings which include public record as “DV-12-234 and DM-12-610” Barrie Lee Derringer Petitioner v. David Brian Derringer Respondent there is legal application for the title of the blog to be so addresses as in public record of the Second Judicial District Court as well as all names of the Petitioner addressed in public record of CV-12-10816 as David Derringer v. Barrie Crowe aka Barrie Derringer aka Barrie Beverley et al. Since public records sustain all of the names of Barrie Derringer as the Petitioner in this matter and the Internet posting all contain public court pleadings of such cases, these is no “harassment” of using the legal names of the Petitioner and Defendant to such cases. The wedding photographs of Barrie Derringer and David Derringer are not in any way offensive or pornographic and are within the guidelines of “expression and opinions and artistic expression” of the blogs of David Derringer under all case laws that this court has to follow involving the right of David Derringer under the 1st Amendment. Under law and former case law that this court has to follow under Oath and Canon, this court cannot order David Derringer to remove any text, photographs or other “1st Amendment expressions” in any blogs on the Internet as the Court and this Commissioner have no jurisdiction for such an order, nor can this court sanction, persecute or condemn or cause cruel and unusual punishment against David Derringer for exercising his rights under Constitution. US v. McDermott, CA2 (N.Y.) 1990, 918 F.2d 319 cert. denied 111 S. Ct. 1681, 500 US 904, 114 L.Ed.2d 76 “Statute prohibiting conspiracy to injure, oppress, threaten or intimidate any inhabitant of a state in free exercise or enjoyment of a right or privilege secured under Constitution or laws of United States applied to alleged Fourteenth Amendment violations.”; 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.”; Title 18 Section 241-Conspiracy against rights  Title 18 Section 241 provides:  “If two or more persons conspire to injure, oppress, threaten, or intimidate any person in any State, Territory, Commonwealth, Possession, or District in the free exercise or enjoyment of any right or privilege secured to him by the Constitution or laws of the United States, or because of his having so exercised same”.; Title 18 Section 242-Deprivation of rights under color of law Title 18 Section 242 provides:   Whoever, under color of law, statute, ordinance, regulation, or custom willfully subjects any person in any State, Territory, Commonwealth, Possession, or District to the deprivation of any rights, privileges, or immunities secured or protected by the Constitution or laws of the United States, or to different punishments, pains, or penalties, ..than are prescribed for the punishment of citizens, shall be fined under this title or imprisoned..” This court has no in personam jurisdiction over David Derringer without proper service of summons and has no jurisdiction over the Internet or postings thereon, whether or not such posting contain photographs, opinions, conclusions or public records. This court has no legal jurisdiction to order David Derringer to remove any photographs from the Internet by May 15, 2013 or any other time and no jurisdiction, authority, or juridical ability to sanction the Respondent for exercising his 1st Amendment right with a photograph of a marriage of the parties well before any court action took place that is not offensive in any manner. Smith v. Doe, 538 U.S. 84, 123 S.Ct. 1140, 155 L.Ed.2d 164, 71 USLW 4125, 71 USLW 4182, 03 Cal. Daily Op. Serv. 1974, 2003 Daily Journal D.A.R. 2474, 16 Fla. L. Weekly Fed. S 142, U.S., March 05, 2003 Blog posts of information on the Internet does not alter our conclusion. It must be acknowledged that notice of a criminal conviction subjects the offender to public shame, the humiliation increasing in proportion to the extent of the publicity. And the geographic reach of the Internet is greater than anything which could have been designed in colonial times. These facts do not render Internet notification punitive. The purpose and the principal effect of notification are to inform the public for its own safety, not to humiliate the offender. Widespread public access is necessary for the efficacy of the scheme, and the attendant humiliation is but a collateral consequence of a valid regulation. U.S. Supreme Court Brief  “In addition, citizen amici explain that a decision to the contrary will endanger the free and open character of the Internet, thus implicating First Amendment principles.. 2001  United States Supreme Court Amicus Brief.  ...It is hard to see how the public interest will be better served by having no public Internet access than substantially increased, free Internet access.”
No. 15 (mismarked as No. 14 on the Order) In no Internet blogs is there any direct communication with the Petitioner and the Respondent under the 1st Amendment has a right to his opinion, his conjecture of what happened and is able to use rhetorical questions or ideas to attempt to ease his confusion of the incidents without punitive redress as “freedom of expression” In the testimony of Barrie under Oath and under cross examination, she repeatedly expressed her opinion that David Derringer had not contacted her in any manner and as the Internet postings are not connected to any email or web site and were never sent to the Petitioner there was “no contact” between the Respondent and Petitioner. State v. Martinez, P.3d, 2013 WL 597038, N.M.App., January 31, 2013 (NO. 32,271) OPINION SUTIN , Judge...for review does not preclude the appellate court from considering questions, in its discretion, involving fundamental error or the fundamental rights of a party). “Information” no matter how damaging, exposing, or distasteful, is allowed to be put on the Internet, including “public records of court pleadings” and the Commissioner cannot regulate or control the Respondent in any manner regarding the Internet. This court has no in personam jurisdiction over David Derringer without proper service of summons and has no jurisdiction over the Internet or postings thereon, whether or not such posting contain photographs, opinions, conclusions or public records. This court has no legal jurisdiction to order David Derringer to remove any photographs from the Internet by May 15, 2013 or any other time and no jurisdiction, authority, or juridical ability to sanction the Respondent for exercising his 1st Amendment right with a photograph of a marriage of the parties well before any court action took place that is not offensive in any manner. This court believes in error that it can control the Internet and all that post upon it under freedom of speech. This Court has no jurisdiction of the Internet or upon those that post upon it with personal blogs. Allen v. McClellan,77 N.M. 801, 427 P.2d 677 (1967) “No court can make a decree which will bind anyone but a party; it cannot lawfully enjoin the world at large, no matter how broadly it words its decree. If it assumes to do so, the decree is pro tanto brutum fulmen.”
No. 16 (mismarked as No. 15 in the Order) Testimony is sustained in every question to the Petitioner as to the Internet postings being communication to the Petitioner. Despite the testimony of the Petitioner, Barrie Derringer and this court seek to stop 1st Amendment rights illegally against David Derringer to muzzle him. City of Albuquerque v. Pangaea Cinema LLC, 284 P.3d 1090, 2012 -NMCA- 075, N.M.App., May 29, 2012 (NO. 30,380) the courts are without jurisdiction to form a personal opinion and use subjective bias, with the attendant dangers of arbitrary and discriminatory application against Constitutional Law Freedom of Speech, Expression, and Press or to inhibit matters of. ...flow of ideas and opinions or on matters of public interest and concern. This is a violation of Freedom of Speech, Expression, and Press and in General viewpoint or idea discrimination. Since all postings are freedom of speech not under the jurisdiction of this court and such postings are not connected in any way and have never been sent in any way to the Petitioner, there is no violation of a no-contact order and there was no communication between David Derringer and the Petitioner.
No. 17 (mismarked as No. 16 of Order) Testimony is sustained in every question to the Petitioner as to the Internet postings being communication to the Petitioner. Despite the testimony of the Petitioner, Barrie Derringer and this court seek to stop 1st Amendment rights illegally against David Derringer to muzzle him. City of Albuquerque v. Pangaea Cinema LLC, 284 P.3d 1090, 2012 -NMCA- 075, N.M.App., May 29, 2012 (NO. 30,380) the courts are without jurisdiction to form a personal opinion and use subjective bias, with the attendant dangers of arbitrary and discriminatory application against Constitutional Law Freedom of Speech, Expression, and Press or to inhibit matters of. ...flow of ideas and opinions or on matters of public interest and concern. This is a violation of Freedom of Speech, Expression, and Press and in General viewpoint or idea discrimination. Since all postings are freedom of speech not under the jurisdiction of this court and such postings are not connected in any way and have never been sent in any way to the Petitioner, there is no violation of a no-contact order and there was no communication between David Derringer and the Petitioner. This court has no in personam jurisdiction over David Derringer without proper service of summons and has no jurisdiction over the Internet or postings thereon, whether or not such posting contain photographs, opinions, conclusions or public records. This court has no legal jurisdiction to order David Derringer to remove any photographs from the Internet by May 15, 2013 or any other time and no jurisdiction, authority, or juridical ability to sanction the Respondent for exercising his 1st Amendment right with a photograph of a marriage of the parties well before any court action took place that is not offensive in any manner. The court simply exercises its corruption outside of law to have its own personal opinion in the ruling on the matter, unavailable under the jurisdiction controlled in Canon by “law”. Baker v. Horn, 201 Supp.2d 592 “Fact cannot become of record solely by virtue of its inclusion in trial court’s opinion.”
No. 18 (mismarked as No. 17 in the Order) Order of Protection thus is “federally illegal” against David Derringer both under Constitutional law and lack of summons service, and thus so is the illegal Order of April 15, 2013 denying 1st Amendment rights and attempting to sentence David Derringer to criminal accusations without Miranda rights or legal right to an attorney. Clearly, David Derringer did no at any time waive his rights to an attorney or Miranda notification by verbal or written waiver and the Commissioner’s idea to persecute David Derringer without such Miranda rights had to stop instantly at the onset of the hearing of March 19, 2013 well prior to the Commissioner’s later Order of her own deprivations of April 15, 2013. State v. King,  P.3d, 2013 WL 1502195, N.M., April 15, 2013 (NO. 33,395) The actions of the Commissioner holding an illegal hearing of March 19, 2-13 without jurisdiction as a “civil” matter, and then after the hearing turning the action into a “criminal” action against David Derringer illegally without Miranda rights or attorney, and without any actions by David Derringer to waive any rights, mandate that the matter is jurisdictionally defective and David Derringer would have remained silent in the entire process if he knew that the underlying corruption of the Commissioner was to attack David Derringer criminally when well outside of her jurisdiction to do so. This court has no in personam jurisdiction over David Derringer without proper service of summons and has no jurisdiction over the Internet or postings thereon, whether or not such posting contain photographs, opinions, conclusions or public records. This court has no legal jurisdiction to order David Derringer to remove any photographs from the Internet by May 15, 2013 or any other time and no jurisdiction, authority, or juridical ability to sanction the Respondent for exercising his 1st Amendment right with a photograph of a marriage of the parties well before any court action took place that is not offensive in any manner. This court cannot legally “sentence” David Derringer to jail without a criminal trial with prior Miranda rights being noticed and without David Derringer having a criminal attorney and without any jurisdiction to do so. It is immaterial that the “sentence”  is suspended as this court has no ability to cause a criminal record or a record in this court of jail time assessed without any crime being committed. Clearly, under law there was no “contempt of this court,” but an attempt by this court to falsely accuse and sentence David Derringer without jurisdiction in a “conspiracy of bias with the Petitioner” The Respondent has not abused the Petitioner in any way by having public records on the Internet outside of the jurisdiction of this court and is protected from criminal violation and torts by the 1st Amendment of the Constitution wherein this court has no jurisdiction and cannot inflict punishment against David Derringer for any action on the Internet which indeed are not offensive, of public record and all fall under 1st Amendment rights. Internet postings of legal public records of court pleadings with the names of proper parties of those pleadings which include public record as “DV-12-234 and DM-12-610” Barrie Lee Derringer Petitioner v. David Brian Derringer Respondent there is legal application for the title of the blog to be so addresses as in public record of the Second Judicial District Court as well as all names of the Petitioner addressed in public record of CV-12-10816 as David Derringer v. Barrie Crowe aka Barrie Derringer aka Barrie Beverley et al. Since public records sustain all of the names of Barrie Derringer as the Petitioner in this matter and the Internet posting all contain public court pleadings of such cases, these is no “harassment” of using the legal names of the Petitioner and Defendant to such cases. The wedding photographs of Barrie Derringer and David Derringer are not in any way offensive or pornographic and are within the guidelines of “expression and opinions and artistic expression” of the blogs of David Derringer under all case laws that this court has to follow involving the right of David Derringer under the 1st Amendment. Under law and former case law that this court has to follow under Oath and Canon, this court cannot order David Derringer to remove any text, photographs or other “1st Amendment expressions” in any blogs on the Internet as the Court and this Commissioner have no jurisdiction for such an order, nor can this court sanction, persecute or condemn or cause cruel and unusual punishment against David Derringer for exercising his rights under Constitution. US v. McDermott, CA2 (N.Y.) 1990, 918 F.2d 319 cert. denied 111 S. Ct. 1681, 500 US 904, 114 L.Ed.2d 76 “Statute prohibiting conspiracy to injure, oppress, threaten or intimidate any inhabitant of a state in free exercise or enjoyment of a right or privilege secured under Constitution or laws of United States applied to alleged Fourteenth Amendment violations.”; 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.”; Title 18 Section 241-Conspiracy against rights  Title 18 Section 241 provides:  “If two or more persons conspire to injure, oppress, threaten, or intimidate any person in any State, Territory, Commonwealth, Possession, or District in the free exercise or enjoyment of any right or privilege secured to him by the Constitution or laws of the United States, or because of his having so exercised same”.; Title 18 Section 242-Deprivation of rights under color of law Title 18 Section 242 provides:   Whoever, under color of law, statute, ordinance, regulation, or custom willfully subjects any person in any State, Territory, Commonwealth, Possession, or District to the deprivation of any rights, privileges, or immunities secured or protected by the Constitution or laws of the United States, or to different punishments, pains, or penalties, ..than are prescribed for the punishment of citizens, shall be fined under this title or imprisoned..” This court has no in personam jurisdiction over David Derringer without proper service of summons and has no jurisdiction over the Internet or postings thereon, whether or not such posting contain photographs, opinions, conclusions or public records. This court has no legal jurisdiction to order David Derringer to remove any photographs from the Internet by May 15, 2013 or any other time and no jurisdiction, authority, or juridical ability to sanction the Respondent for exercising his 1st Amendment right with a photograph of a marriage of the parties well before any court action took place that is not offensive in any manner. The Order of April 15, 2013 must be rescinded as a matter of law with no record of David Derringer being “sentenced to jail” for doing no crimes.
No. 19 (mis-numbered in the Order as No. 18) Testimony is sustained in every question to the Petitioner as to the Internet postings being communication to the Petitioner. Despite the testimony of the Petitioner, Barrie Derringer and this court seek to stop 1st Amendment rights illegally against David Derringer to muzzle him. City of Albuquerque v. Pangaea Cinema LLC, 284 P.3d 1090, 2012 -NMCA- 075, N.M.App., May 29, 2012 (NO. 30,380) the courts are without jurisdiction to form a personal opinion and use subjective bias, with the attendant dangers of arbitrary and discriminatory application against Constitutional Law Freedom of Speech, Expression, and Press or to inhibit matters of. ...flow of ideas and opinions or on matters of public interest and concern. This is a violation of Freedom of Speech, Expression, and Press and in General viewpoint or idea discrimination. Since all postings are freedom of speech not under the jurisdiction of this court and such postings are not connected in any way and have never been sent in any way to the Petitioner, there is no violation of a no-contact order and there was no communication between David Derringer and the Petitioner. This court has no in personam jurisdiction over David Derringer without proper service of summons and has no jurisdiction over the Internet or postings thereon, whether or not such posting contain photographs, opinions, conclusions or public records. This court has no legal jurisdiction to order David Derringer to remove any photographs from the Internet by May 15, 2013 or any other time and no jurisdiction, authority, or juridical ability to sanction the Respondent for exercising his 1st Amendment right with a photograph of a marriage of the parties well before any court action took place that is not offensive in any manner. The court simply exercises its corruption outside of law to have its own personal opinion in the ruling on the matter, unavailable under the jurisdiction controlled in Canon by “law”. Baker v. Horn, 201 Supp.2d 592 “Fact cannot become of record solely by virtue of its inclusion in trial court’s opinion.” Utah Licensed Beverage Ass'n v. Leavitt, 256 F.3d 1061, 29 Media L. Rep. 2193, 2001 DJCAR 3813, C.A.10 (Utah), July 24, 2001 (NO. 00-4058) Finally, we come to the fourth element, whether an injunction would be adverse to the public interest. In A.C.L.U. v. Johnson, we held that an injunction that would block an unconstitutional New Mexico regulation of the Internet would not be “adverse to the public interest[,] as it will protect the free expression of the millions of Internet users both within and outside of the State of New Mexico.” Johnson, 194 F.3d at 1163. Because we have held that Utah's challenged statutes also unconstitutionally limit free speech, we conclude that enjoining their enforcement is an appropriate remedy not adverse to the public interest. See also Elam Constr., Inc. v. Regional Transp. Dist., 129 F.3d 1343, 1347 (10th Cir.1997) (stating, in the context of a request for injunctive relief, that “[t]he public interest . favors plaintiffs' assertion of..facts and Information.
No. 20 (mismarked in Order as No. 19) The corruptive element of this court chooses time after time to disregard Constitutional law, case law and statutory law. The record is clear that the Respondent constantly uses many authorities and in fact “saturates” the court record with “law” that this judge has to obey, yet disregards. In the court record it is seen that the Petitioner and her attorney rarely if ever answer any pleadings or motions of the Respondent and at no time whatsoever, have the Petitioner or her attorney sustained any motion, response or court litigation with any authority whatsoever, whether that be construed to be Constitution, case law or statutes. In matter of fact, the Commissioner as most courts in New Mexico disregard the Pro-Se person despite the law to be enforced, and in this matter, the Commissioner chooses to malign, threaten, and discharge duties under Canon and Oath to violate law, based upon only the “word” of the opposition attorney without any law for support. Then, the Commissioner admonishes this Respondent while ignoring all of the law presented each time to simply find some other case wherein the corruption is being covered as this instant case to reach outside of court record to make a decision in this matter; all of these methods being “illegal”. Matter of Charge of Judicial Misconduct or Disability, 39 F.3d 374, 309, US App. DC 97 “Judge in adversarial judicial proceeding...who reaches outside of record to decide case defiles process.” This Commissioner violates Constitution, disregards lack of summons service, disregards rules of evidence, does fraud to the Respondent with inadmissible evidence, and then talk to the Respondent about “the nature of his pleadings” all which the Respondent supports entirely with “LAW”. Simmons v. Conger, 86 F.3d 1080 “To be entitled to relief from allegedly unconstitutional actions of a judge acting pursuant to a state statute, plaintiff must allege either that statute is unconstitutional or that a particular judge’s actions pursuant to that statute violated limits placed upon him by Constitution.”
No. 21 (mismarked in Order as No. 20) The record is clear that the Respondent constantly uses many authorities and in fact “saturates” the court record with “law” that this judge has to obey, yet disregards. In the court record it is seen that the Petitioner and her attorney rarely if ever answer any pleadings or motions of the Respondent and at no time whatsoever, have the Petitioner or her attorney sustained any motion, response or court litigation with any authority whatsoever, whether that be construed to be Constitution, case law or statutes. In matter of fact, the Commissioner as most courts in New Mexico disregard the Pro-Se person despite the law to be enforced, and in this matter, the Commissioner chooses to malign, threaten, and discharge duties under Canon and Oath to violate law, based upon only the “word” of the opposition attorney without any law for support. The corruption of this court is extreme, but with the exposure of this corruption and rulings well outside of Constitution and law, the common defense of such exposure is to attack the “whistleblower” of whom David Derringer is protected under Federal Law the Whistleblowing Act of 1989. The truth of corruption in this matter is “ugly” and under NMRA Rule 1-090, it will still be exposed under law. If the Respondent was totally unfounded in his legal contentions, there would not be the vast amount of case law in support of the Respondent that this court ignores each hearing, pleading and Order. The Respondent is not a “vexatious litigant” but a conscientious litigant that properly does his legal research, states authorities and exposes the court not following the stare decisis of “law”. Hill v. Silsbee Independent Scholl dist., 933 F. Supp. 616 ED Tex. 1996 “Qualified Immunity does not shield public official whose conduct violates clearly established constitutional rights at the time of the incident, if reasonable person would have known that such conduct was unconstitutional.” Then, the Commissioner admonishes this Respondent while ignoring all of the law presented each time to simply find some other case wherein the corruption is being covered as this instant case to reach outside of court record to make a decision in this matter; all of these methods being “illegal”.  Wojcik v. Town of North Smithfield, 87 F. Supp. 508 affirmed 76 F.3d 1 “Law or Constitutional right is “clearly established” such that public official who violated it is not entitled to qualified immunity if its contours are sufficiently clear that reasonable person would understand its terms and be able to measure his or her conduct against it.” US v. Barker, CADC 1976, 546 F.2d 940, 178 US App DC 174 “ Mistake of law will not generally excuse commission of the offense; thus, defendant’s error as to his authority to engage in particular activity, if based upon mistaken view of legal requirements or ignorance thereof, is mistake of law, and fact that he relied upon erroneous advice of another is not, typically , an exculpatory circumstance; he will still be deemed to have acted with culpable state of mind.” “It is dangerous to be right in matters on which the established authorities are wrong.” -Voltaire [Francois Marie Arouet] (1694-1778).
No. 22 (mismarked in Order as No. 21) The Respondent files all pleadings in accordance with the Rules of Civil Procedure, and it is those very Rules, such as the Rules of Evidence NMRA Rule 11-103 that this court violated to sustain the illegal Order of April 15, 2013 and ignores the fundamental error that a summons was never served, defeating due process and equal protection, then attack the Respondent that it believes that the Commissioner can then persecute the Respondent to cover up the corruption of this court or to single out the Respondent that voices his Constitutional rights to stop litigation that the corruptive element does not want exposed. US v. Guest, US Ga. 1966, 86 S.Ct. 1170, 383 US 745, 16 L.Ed.2d 239 “This section (Title 18 Section 241) pertaining to conspiracy against rights of citizens encompasses due process and equal protection clauses of USCA Constitution Amendment 14 and is not unconstitutionally vague.” US v. Anderson, 798 F.2d 919 CA7 (Ind.) 1986 “Word should in Canon..of Judicial Conduct which states that judge “should” accord to every interested person a full right to be heard, imposes mandatory standard of conduct upon judges and requires presence of both prosecuting attorneys and defendant at any proceeding which bears on outcome of pending..case.” Code of Judicial Conduct Canon 3, Subd. A(4) and C(1)(a)  This court is bound by the “supremacy clause” that defeats the Order of April 15, 2013 due to violations of Constitution and case laws. This court uses intimidation, threats of incarceration as coercion and extortion in order to enforce an order of protection that in Constitutionally defective, and chooses to attack the Respondent that divulges the law that must be followed defeating the irrational decisions of this court. This court cannot punish exercise of Derringer’s Constitutional rights and statutory rights “to sue” under Title 42 Section 1981(a) and prohibits the exercise of “sanctions” or specialized “control” oppression and tyranny to stop the legal use and filings within the US judicial system by a US citizen for use of vindictive persecution of the Plaintiff. On June 6, 2005, the United States Supreme Court ruled that.. The Supremacy Clause unambiguously provides that if there is any conflict between federal and state law, federal law shall prevail...” in Gonzales v. Raich, No. 03-1454 SEE United States v. Colorado Supreme Court, No. 98-1081, 10th USCA, where the court upheld that “ the [rule] violated the Supremacy Clause by attempting to regulate an area of federal law controlled. Dismissing the need to characterize the rule as either procedural or ethical, the court stated, ‘for purposes of determining whether [the rule] violates the Supremacy Clause, it matters not at all what the Board or Baylson choose to call it. What matters is whether the substance of [the rule] actually conflicts or is incompatible with federal law.’ The [rule] “does not suddenly become consistent with Fed. R. Civ. P. 17 as a state rule of professional conduct” “The Court held that the rule’s judicial approval requirement violated the Supremacy Clause because it was incompatible with the federal rules of criminal procedure”. In the same manner, for this court to threaten to make David Derringer apply or gain “approval” before filing is a violation of the Supremacy Clause to be liable under US Code Title 42 Sections 1981, 1982, 1983, 1985 and 1986. Therefore the threats and extortion fall under the Federal criminal code of Title 18 Section 1503 “obstruction of justice” and such a Commissioner working outside of jurisdiction is liable to persecute the Respondent for exercising his Constitutional and statutory rights to protect his rights under Constitution and meant for “cruel and unusual punishment” and “oppression” and “tyranny” against the Respondent where it destroys and is meant to kill the Plaintiff by attrition of deprivation of income and necessities for life itself. See also the parameters set forth in mis-use of a rule in Stoneking v. Bank of America, 132 NM 79, 43 P. 3d 1089. “Under Article VI of the Constitution, the laws of the United States “shall be the supreme law of the land..any thing in the Constitution or laws of any State to the contrary notwithstanding”. US Constitution Article VI Cl.2 “The Supremacy Clause prohibits the application of state laws which conflict with federal laws.” Home Mortgage Bank v. Ryan, 986 F.2d 372, 375 (10th Cir. 1993).”  US v. Guest, US Ga. 1966, 86 S.Ct. 1170, 383 US 745, 16 L.Ed.2d 239 “This section (Title 18 Section 241) pertaining to conspiracy against rights of citizens encompasses due process and equal protection clauses of USCA Constitution Amendment 14 and is not unconstitutionally vague.” US v. Ehrlichman, CADC 1976, 546 F.2d 910, 178 US App.DC 144, cert denied 97 S. Ct. 1155, 429 US 1120, 51 Led.2d 570 “Title 18 Section 241- offender must act with specific intent to interfere with rights in question.”; US v. McDermott, CA2 (N.Y.) 1990, 918 F.2d 319 cert. denied 111 S. Ct. 1681, 500 US 904, 114 L.Ed.2d 76 “Statute prohibiting conspiracy to injure, oppress, threaten or intimidate any inhabitant of a state in free exercise or enjoyment of a right or privilege secured under Constitution or laws of United States applied to alleged Fourteenth Amendment violations.”.
No. 23 (mismarked in Order as No. 22) US v. Ellis WDSC 1942, 43 F.Supp. 321 “The provision of Title 18 Section 241 covering offense of conspiracy to injure citizens in exercise of civil rights was applicable to instances of conspiracy on part of both private individuals and public officials.” “Where the state is not in compliance with the federal regulations because of judicial constructions that circumvent or undermine the legislative intentions of the act, a new question arises as to the legitimacy of the state’s participation in the federal program. Because federal regulations and laws cannot infringe upon the Constitutional rights of United States Citizens, it can be presumed that those rights are protected under the federal mandates. If the state is going to make rules or practice procedures, which deny those rights, then the state actions become void, and this issue prevails over any other under consideration. And where the Constitution of the state or the state statutory laws are subverted through similar means, the people have no duty to perform unless under threat or coercion by further illegitimate means in order to protect their very lives.”  “A judgment is void only if the court rendering it lacked jurisdiction or the subject matter, or of the parties, or acted in a manner inconsistent with due process of law.” Classen v. Classen, 119 NM 582, 585 (App 1995) 893 P.2d 478 see also Nesbit v. City of Albuquerque, 91 NM 455, 459 (1977) 575 P.2d 1340 “The district courts found as a matter of law that the failure to give notice required by statute rendered all subsequent acts void..by failing to follow statutory procedures, due process of law was violated and no subsequent act could correct the defect.” With no summons legally served, Constitutional rights denied, fraud of the Commissioner not following the Rules of evidence and using inadmissible evidence against the Respondent for “criminal sentencing” without Miranda rights read, and without an attorney to represent the Respondent renders this Commissioner unfit to serve upon the bench in sedition and treason against the United States. “US Constitution 14th Amendment Section 3-No person shall be an...elector..or hold any office, under the United States, or under any State, who, having previously taken an oath,... as a judicial officer of any State, to support the Constitution of the United States, shall have engaged in insurrection or rebellion against the same, or given aid or comfort to the enemies thereof.”  Cartello v. US CCA8 (Mo) 1937, 93 F.2d 412 “A conspiracy is the gist of the offense of conspiring to injure citizens in exercise of right secured by federal constitution or laws.”
REQUEST FOR RELIEF
The order of protection has been always jurisdictionally defective and in fundamental error and must be dismissed in its entirety. The Order of April 15, 2013 was brought in fraud by the Commissioner in bias and prejudice against the Respondent using inadmissible evidence to persecute and attempt to create a criminal record against the Respondent when no violations have occurred, by use of “public corruption” in the extreme. The entire order of protection must be dismissed with prejudice with restitution in extreme monetary amounts for David Derringer for 1 ½ years of Constitutional deprivations, and the Order of April 15, 2013 must be dismissed with restitution for taking and interfering with David Derringer’s 1st Amendment rights. Barker v. Barker, 94 NM 162, 608 p.2d 138 (1980) “In simple English, the language of the “other reasons” clause, ...vests power in court adequate to enable them to vacate judgment whenever such action is appropriate to accomplish justice.”;When an alleged constitutional rights is involved, most courts hold that no further showing of irreparable injury is necessary” (citing 11A Charles Alan Wright, Arthur R. Miller and Mary Kay Kane, Federal Practice and Procedure 2948.1 (2d.ed 1995) see also Suster v. Marshall, 149 F.3d 523, 533 (1998). “...the loss of Amendment freedoms, for even minimal periods of time constitutes irreparable injury”.
And other relief that the court deems just and proper.
Respectfully submitted by: _______________________________
David Derringer, Box 1205, Albuquerque, New Mexico 87103
CERTIFICATE OF SERVICE                        April 24, 2013
Petitioner’s attorney of record
Alain Jackson
423 6th St. NW
Albuquerque, New Mexico 87102
505-620-6688

On April 24, 2013 I hereby certify that I hand delivered a  copy of this pleading to:
The Second Judicial District Court
400, Lomas NW
Albuquerque, New Mexico 87102


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