pampamk

In need of some direction, served, answered, received interrogatories

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@pampamk

 

You might be referring to issues on appeal.  One issue would be the statute.  Another issue would be the sufficiency of the evidence.

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Everything you objected to is what you are appealing. You want the appellate court to review every objection you made, state their opinion and reverse the judges ruling.

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So would you say something like: Appellant is appealing the judgement from judge xxxx. Including the misinterpretation of K.S.A. 60-518, and the overruling of appellant's objection to the evidence provided by appellee as proof of standing/capacity to sue. Appellant also appeals her position of Res Judicata applies which was presented but not addressed in the final judgement. 

 

The judge made no mention of my argument of Res Judicata in his ruling, whether it applies or not, I should throw it in there, correct?

 

How about the judge completely ignoring them filing in the wrong venue,  he writes in the judgement plaintiff eventually discovered defendant does in fact live in county A. Which is untrue, and I pointed that out. I'm not attacking wrong venue, I am showing they did not perform due diligence in discovering my whereabouts and their claim of sheriff error should be a moot point.  Should I say something to the effect: appellant also appeals the judgement stating she lives in county A which is in error as she stated during trial. The reason I feel I should bring this up is I know the opposing side will in their answer, and I want to have already pointed out the error. 

 

Thanks all, more questions to come....

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So I finally realized I am sweating the small stuff, so to speak. The rule says...(designate the judgement or part of the judgement or other appealable order) you are appealing. In my notice of appeal I just need to write I am appealing the judgement against me... duh...

 

I have been reading and reading, I made myself an outline, timeline, of every step so that I know exactly what to to do when.  I still have many questions, and look forward to the help each of you give me. You have helped me so much, I would be dead in the water already if it weren't for y'all. I am wavering back and forth on requesting the transcript, mainly because my appeal is based on standing and interpretation of statute and the Court of Appeals has stated in every case I have read that their review is unlimited, that there not need be an objection for them to review...  I am going to find out if/how I can listen to the recording and then make my final decision...

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I am working on my docketing statement and have a few questions. I don't know the best way to do this: copy and paste or attach file.... I guess I will try copy and paste.... 

 

IN THE ___ SUPREME COURT ___ COURT OF APPEALS OF THE STATE OF KANSAS
Case Caption: County Appealed From:
District Court Case No(s).: Do I put both case numbers here? Magistrate and District?
Proceeding Under Chapter:
Party Filing Appeal: My name here Defendant-Appellant
Party/Parties who will Appear as Appellees: PRA
DOCKETING STATEMENT - CIVIL
1. Civil Classification: From the list of civil topic sub-types listed below, choose the one
which best describes primary issue in this appeal. Statutory Interpretation
2. Proceedings in the District Court:
a. Trial Judge from whose decision this appeal is taken:
b. List any other judge who has signed orders or conducted hearings in this matter:
c. Was this case disposed of in the district court by:
___ Jury Trial Summary Judgment
___ Bench Trial

___ Dismissal
d. Length of trial, measured in days (if applicable):

e. State the name of each court reporter and/or transcriptionist who has reported or
transcribed any or all of the record for the case on appeal. (This is not a substitute
for a request for transcript served on the individual reporter or transcriptionist
pursuant to Rule 3.03.)
f. State the legal name of all entities who are NOT listed in the case caption
(including corporations, associations, parent, subsidiary, or affiliate business
entities) who are parties or who have a direct involvement in the case on appeal:

g. State the name, address, and telephone number of every attorney who has
represented a party in district court if that attorney’s name does NOT appear on
the certificate of service attached to this docketing statement. Clearly identify each
party represented.  The court sent the judges ruling to the attorney who first filed this case but has never done anything else. Another attorney has been the only one to appear at any proceedings, so I followed the court and sent my notice of appeal to the same attorney. So here I would put the attorney who has appeared?
3. Jurisdiction:
a. Date journal entry or judgment form filed:
b. Is this order appealed from a final order, i.e., does it dispose of the action as to all
claims by all parties?

c. If the order is not a final disposition as to all claims by all parties, did the district
court direct the entry of judgment in accordance with K.S.A. 60-254(B)?
Yes No
If applicable, date K.S.A. 60-254(B) certificate filed:
d. Date any post-trial motion filed:
e. Date disposition of any post-trial motion filed:
f. Date notice of appeal filed in district court:

g. Other relevant dates necessary to establish this court’s jurisdiction to hear the
appeal, i.e., decisions of administrative agencies or municipal courts and appeals thereform:
date of file stamp - District Mag Judge (his name here) Journal Entry of Judgment filed

date  - Defendant-Appellant filed Notice of Appeal
h. Statutory authority for appeal: K.S.A. 61-3109
i. Are there any proceedings in any other court or administrative agency, state or
federal, which might impact this case or this court having jurisdiction?
No (but to be honest, I don't know, I have looked, doesn't mean it's not there)
If “yes,” identify the court or agency where the related proceeding is pending. List
the case captions and the case or docket numbers.
4. Constitutional Challenges to Statutes or Ordinances:
Was any statute or ordinance found to be unconstitutional by the trial court?

If “yes,” what statute or ordinance?

5. Related Cases/Prior Appeals:
a. Is there any case now pending or about to be filed in the Kansas Appellate Courts
which: (again, NO, but not 100% positive)
(1) Arises from substantially the same case or controversy as this appeal?
Yes No If “yes,” give the case caption and docket number:
(2) Involves an issue that is substantially the same, similar or related to an
issue on this appeal?
Yes No If “yes,” give the case caption and docket number:
b. Has there been any prior appeal involving this case or controversy? I'm assuming it means in the appellate court? or does it mean my appeal from the magistrate court?
Yes No If “yes,” give the case caption and docket number:

6. Brief statement (less than one page), without argument, of the material facts. This is not intended
to be a substitute for the factual statement which will appear in the brief.

1. This is a collection case for alleged bad debt.
2. It is uncontroverted The Statute of Limitations ran July XX, 2013.
3. Defendant lives in C County.
4. Plaintiff filed its petition in A County on April XX, 2012.
5. Summons was returned with no service stating B County address on May XX, 2012.
6. A Notice of Dismissal was sent by the Court July XX, 2012.
7. August XX, XXXX an Order of Dismissal was filed.
8. Plaintiff filed its petititon in B County.
9. Numerous unsuccessful attempts of service ensued.
10. Plaintiff filed a Motion to Reinstate in A County on August XX, 2013.
11. An Order Reinstating the case in A County was filed August XX, 2013.

12. A Notice of Dismissal was sent by the B County Court October XX, 2013.
13. Defendant was served November XX, 2013 by an Alias Summons through C County Sheriff.

14. An Order of Dismissal was filed by B County Court December X, 2013.
15. Defendant filed a Motion of Dismissal based on the Statute of Limitations on January XX, 2014.
16. Judge (his name here) denied Defendant's Motion to Dismiss and Plaintiff's Motion for Summary Judgment on February XX, 2014, and a trial date was set.
17. The case was tried by Judge (his name here)on April XX, 2014.
18.  A Journal Entry of Judgment was filed May XX, 2014, granting judgment against Defendant.
19. Defendant filed a Notice of Appeal to the District Court May XX, 2014.
20. The case was tried by Judge (his name here) on September X, 2014.
21. A Journal Entry of Judgment was filed October XX, 2014 granting judgment against Defendant.
22. Defendant filed a Notice of Appeal to the Kansas Court of Appeals on November XX, 2014. 

7. Concise statement of the issues proposed to be raised. You will not be bound by this statement
but should include issues now contemplated. Avoid general statements such as “the judgment is
not supported by the law.”

1. The judgment against Defendant is based on misinterpretation of K.S.A. 60-518.

2. The Statute of Limitations had run before the action was commenced.

3. Plaintiff's evidence is not sufficient to prove Standing/Capacity to Sue.


CIVIL TOPIC SUB-TYPES: Select the one sub-type which best describes this appeal.
See Question 1, page 1.
Administrative—KS Corporation Commission
Administrative—Licensing
Administrative—Public Utility Rate Case
Administrative—Taxation
Administrative—Workers Compensation
Administrative—Other
Certified Question
Children—Adoption
Children—CINC
Children—Termination of Parental Rights
Conservators/Conservatorships
Constitutional Law
Contracts
Creditors and Debtors - I debated on this one or the Statutory Interpretation below
Damages—Personal Injury
Damages—Property
Damages—Punitive
Divorce
Election Contest
Eminent Domain
Employment
Governmental Immunity
Habeas—appeal from district court
Insurance
Jurisdiction
Juvenile Offenders Code
K.S.A. 60-1507
Libel and Slander
Mandamus—appeal from district court
Negligence
Oil and Gas
Personal Property
Probate
Procedure
Quo Warranto—appeal from district court
Real Property
Statutory Interpretation or Construction Should I include Construction or leave it off?
Teacher Employment/Due Process
Torts (specify sub-type)
Wrongful Death
Zoning
Other (please specify):
 

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I am still debating on requesting a transcript or not. My main focus, statutory interpretation and standing, are questions of law over which an appellate court has plenary review. Everything needed for them to make a decision will be in the record. I don't think the transcript itself will add anything, as I can add my arguments in my brief. What do you think?

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I think as a pro-se litigant and appellant if you want to convince the court that you effectively argued your case and the trial judge erred you need to include the transcript that shows that.

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As I have read and read and read tonight, I realize I should go ahead and request the transcript. According to the rules, I can(should) stipulate portions not needed... So does that mean in my request for the transcript I can state I want where I specifically stated I live in x county, I want where I objected to plaintiff's evidence as proof of debt, etc.  I guess I need to make a trip to the court house and see if I can listen to the recording so that I will know exactly what parts I do and do not want....

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@BV80 @Anon Amos @shellieh98 and all others who have so graciously helped me... I would appreciate your input on this.

I am working on my docketing statement and have a few questions. I don't know the best way to do this: copy and paste or attach file.... I guess I will try copy and paste.... 

 

IN THE ___ SUPREME COURT ___ COURT OF APPEALS OF THE STATE OF KANSAS
Case Caption: County Appealed From:
District Court Case No(s).: Do I put both case numbers here? Magistrate and District?
Proceeding Under Chapter:
Party Filing Appeal: My name here Defendant-Appellant
Party/Parties who will Appear as Appellees: PRA
DOCKETING STATEMENT - CIVIL
1. Civil Classification: From the list of civil topic sub-types listed below, choose the one
which best describes primary issue in this appeal. Statutory Interpretation
2. Proceedings in the District Court:
a. Trial Judge from whose decision this appeal is taken:
b. List any other judge who has signed orders or conducted hearings in this matter:
c. Was this case disposed of in the district court by:
___ Jury Trial Summary Judgment
___ Bench Trial

___ Dismissal
d. Length of trial, measured in days (if applicable):

e. State the name of each court reporter and/or transcriptionist who has reported or
transcribed any or all of the record for the case on appeal. (This is not a substitute
for a request for transcript served on the individual reporter or transcriptionist
pursuant to Rule 3.03.)
f. State the legal name of all entities who are NOT listed in the case caption
(including corporations, associations, parent, subsidiary, or affiliate business
entities) who are parties or who have a direct involvement in the case on appeal:

g. State the name, address, and telephone number of every attorney who has
represented a party in district court if that attorney’s name does NOT appear on
the certificate of service attached to this docketing statement. Clearly identify each
party represented.  The court sent the judges ruling to the attorney who first filed this case but has never done anything else. Another attorney has been the only one to appear at any proceedings, so I followed the court and sent my notice of appeal to the same attorney. So here I would put the attorney who has appeared?
3. Jurisdiction:
a. Date journal entry or judgment form filed:
b. Is this order appealed from a final order, i.e., does it dispose of the action as to all
claims by all parties?

c. If the order is not a final disposition as to all claims by all parties, did the district
court direct the entry of judgment in accordance with K.S.A. 60-254( B)?
Yes No
If applicable, date K.S.A. 60-254( B) certificate filed:
d. Date any post-trial motion filed:
e. Date disposition of any post-trial motion filed:
f. Date notice of appeal filed in district court:

g. Other relevant dates necessary to establish this court’s jurisdiction to hear the
appeal, i.e., decisions of administrative agencies or municipal courts and appeals thereform:
date of file stamp - District Mag Judge (his name here) Journal Entry of Judgment filed

date  - Defendant-Appellant filed Notice of Appeal
h. Statutory authority for appeal: K.S.A. 61-3109
i. Are there any proceedings in any other court or administrative agency, state or
federal, which might impact this case or this court having jurisdiction?
No (but to be honest, I don't know, I have looked, doesn't mean it's not there)
If “yes,” identify the court or agency where the related proceeding is pending. List
the case captions and the case or docket numbers.
4. Constitutional Challenges to Statutes or Ordinances:
Was any statute or ordinance found to be unconstitutional by the trial court?

If “yes,” what statute or ordinance?

5. Related Cases/Prior Appeals:
a. Is there any case now pending or about to be filed in the Kansas Appellate Courts
which: (again, NO, but not 100% positive)
(1) Arises from substantially the same case or controversy as this appeal?
Yes No If “yes,” give the case caption and docket number:
(2) Involves an issue that is substantially the same, similar or related to an
issue on this appeal?
Yes No If “yes,” give the case caption and docket number:
b. Has there been any prior appeal involving this case or controversy? I'm assuming it means in the appellate court? or does it mean my appeal from the magistrate court?
Yes No If “yes,” give the case caption and docket number:

6. Brief statement (less than one page), without argument, of the material facts. This is not intended
to be a substitute for the factual statement which will appear in the brief.

1. This is a collection case for alleged bad debt.
2. It is uncontroverted The Statute of Limitations ran July XX, 2013.
3. Defendant lives in C County.
4. Plaintiff filed its petition in A County on April XX, 2012.
5. Summons was returned with no service stating B County address on May XX, 2012.
6. A Notice of Dismissal was sent by the Court July XX, 2012.
7. August XX, XXXX an Order of Dismissal was filed.
8. Plaintiff filed its petititon in B County.
9. Numerous unsuccessful attempts of service ensued.
10. Plaintiff filed a Motion to Reinstate in A County on August XX, 2013.
11. An Order Reinstating the case in A County was filed August XX, 2013.

12. A Notice of Dismissal was sent by the B County Court October XX, 2013.
13. Defendant was served November XX, 2013 by an Alias Summons through C County Sheriff.

14. An Order of Dismissal was filed by B County Court December X, 2013.
15. Defendant filed a Motion of Dismissal based on the Statute of Limitations on January XX, 2014.
16. Judge (his name here) denied Defendant's Motion to Dismiss and Plaintiff's Motion for Summary Judgment on February XX, 2014, and a trial date was set.
17. The case was tried by Judge (his name here)on April XX, 2014.
18.  A Journal Entry of Judgment was filed May XX, 2014, granting judgment against Defendant.
19. Defendant filed a Notice of Appeal to the District Court May XX, 2014.
20. The case was tried by Judge (his name here) on September X, 2014.
21. A Journal Entry of Judgment was filed October XX, 2014 granting judgment against Defendant.
22. Defendant filed a Notice of Appeal to the Kansas Court of Appeals on November XX, 2014. 

7. Concise statement of the issues proposed to be raised. You will not be bound by this statement
but should include issues now contemplated. Avoid general statements such as “the judgment is
not supported by the law.”

1. The judgment against Defendant is based on misinterpretation of K.S.A. 60-518.

2. The Statute of Limitations had run before the action was commenced.

3. Plaintiff's evidence is not sufficient to prove Standing/Capacity to Sue.


CIVIL TOPIC SUB-TYPES: Select the one sub-type which best describes this appeal.
See Question 1, page 1.
Administrative—KS Corporation Commission
Administrative—Licensing
Administrative—Public Utility Rate Case
Administrative—Taxation
Administrative—Workers Compensation
Administrative—Other
Certified Question
Children—Adoption
Children—CINC
Children—Termination of Parental Rights
Conservators/Conservatorships
Constitutional Law
Contracts
Creditors and Debtors - I debated on this one or the Statutory Interpretation below
Damages—Personal Injury
Damages—Property
Damages—Punitive
Divorce
Election Contest
Eminent Domain
Employment
Governmental Immunity
Habeas—appeal from district court
Insurance
Jurisdiction
Juvenile Offenders Code
K.S.A. 60-1507
Libel and Slander
Mandamus—appeal from district court
Negligence
Oil and Gas
Personal Property
Probate
Procedure
Quo Warranto—appeal from district court
Real Property
Statutory Interpretation or Construction Should I include Construction or leave it off?
Teacher Employment/Due Process
Torts (specify sub-type)
Wrongful Death
Zoning
Other (please specify):
 

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@pampamk

 

In regard to the court specific details, I'm just not sure.   It's possible that the clerk of court could help you.

 

Statutory interpretation or construction.  From what I understand, construction is what the statute means.  Is the meaning clear or unclear?  Is it written in such a way that it could have more than one meaning?  Here's the KS statute for statutory construction.

 

http://kslegislature.org/li/b2013_14/statute/077_000_0000_chapter/077_002_0000_article/077_002_0001_section/077_002_0001_k/

 

In regard to  #7 and the issues proposed to be raised, should one of the issues be whether the actions filed on  _____ and ______ (filing #1 and #2) had commenced in accordance with K.S.A. 60-203(a).  (You did raise that statute at trial, correct?)

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@BV80

@pampamk

 

In regard to the court specific details, I'm just not sure.   It's possible that the clerk of court could help you. Yes, I have started a list of questions, I will add that to it.

 

Statutory interpretation or construction.  From what I understand, construction is what the statute means.  Is the meaning clear or unclear?  Is it written in such a way that it could have more than one meaning?  Here's the KS statute for statutory construction.  I see what you are saying and why they are together, I will amend and include it as it is shown.

 

http://kslegislature.org/li/b2013_14/statute/077_000_0000_chapter/077_002_0000_article/077_002_0001_section/077_002_0001_k/

 

In regard to  #7 and the issues proposed to be raised, should one of the issues be whether the actions filed on  _____ and ______ (filing #1 and #2) had commenced in accordance with K.S.A. 60-203(a).  (You did raise that statute at trial, correct?)  Ah, you are thinking I should be more specific... yes, I raised the statute and the judge raised it in his ruling.

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As I won my appeal , and failed to win in my second trial (sigh) and am appealing for what I hope is the final time., I would maybe at this point in where you are,  pay a small fee to have a consult with a consumer atty in your area.  In my area , for example, the atty  would have represented me at court for 650.00   , because I did all the preliminary work.

 

After , I lost again (sigh) it was 750.00 for him to write my appellant memo, because I was too burnt out to do it again.  but for a consult on what to do was free,  and even if it was 100,00 , and you win , you recoup expenses.  JDB's continue to fight when you have no atty , because there are no expenses for them to pay.

 

And in retaining an atty, they know how to get your costs back!!!!!   Just my thoughts   Pam

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I should have gone further and said the judge actually stated in his ruling the action was not commenced until the date I was served in Nov. He cited both K.S.A. 60-203(a)(1) and K.S.A. 61-2704(a). This will be easier... this is his ruling.... Here Defendant was served Nov. xx 2013, which under K.S.A. 60-206(a)(1)© is 92 days, not the 90 days argued by the Plaintiff after the Aug. xx, 2013, Order of Reinstatement. Nov. xx was a xxxday, not a Saturday, Sunday, or legal Holiday. Plaintiff also did not seek leave from the court to extend service an additional 30 days as provided in K.S.A. 60-203(a)(1). K.S.A. 60-203(a)(1) also does not save Plaintiff's claim. Here service does not relate back to the July xx, 2013,(pretty sure he got his dates mixed up, it should be Aug,) or April 30, 2012, when plaintiff filed the petition. Plaintiff's claim commenced on the date of service, Nov. xx 2013, which is after the July xx(he also got this date wrong, right month, wrong day), 2013 deadline. 

 

    But the analysis does not end without another look at KSA 60-518 which provides that plaintiff "may commence a new action within 6 months after such failure." Here the failure occurs on July xx, 2013. The case is commenced on November xx 2013. Nov xx 2013 is within the 6 months of July xx 2013. So KSA 60-518 saves the plaintiff's claim.

 

That is the main part of his ruling.

 

I have issues with some of his background he stated before ruling.  Such as his saying plaintiff dismissed first action because service stated I lived in another county, but then plaintiff found out I actually live in the county of the first action, which is entirely untrue, and I pointed it out several times.  There is more, and I will post later....

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As I won my appeal , and failed to win in my second trial (sigh) and am appealing for what I hope is the final time., I would maybe at this point in where you are,  pay a small fee to have a consult with a consumer atty in your area.  In my area , for example, the atty  would have represented me at court for 650.00   , because I did all the preliminary work.

 

After , I lost again (sigh) it was 750.00 for him to write my appellant memo, because I was too burnt out to do it again.  but for a consult on what to do was free,  and even if it was 100,00 , and you win , you recoup expenses.  JDB's continue to fight when you have no atty , because there are no expenses for them to pay.

 

And in retaining an atty, they know how to get your costs back!!!!!   Just my thoughts   Pam

@hot in az

 

I hear ya! Believe you me I have considered getting one, actually, I called one, he never called me back, I emailed another, they never got back. I guessed they felt it too litigated, however, they do not know the specifics. I am still tossing around calling one, and I guess I should just do.............there are none in my area, I would have to make a day trip to consult with one, but that is okay, I don't mind, it would be well worth it, I just need to do it I know.  Thanks for the input!!!

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Just a thought,

Have you contacted NACA for attorney referrals?

Maybe a preamble to your voicemail, "I am calling as a potential client, referred by NACA.", will garner a better call-back response?

Just a thought.

You're impressing me with all your consumer-chaired legal battles!

Keep on keeping on, please. You are inspiring!

Warmly,

@hot in az

 

I hear ya! Believe you me I have considered getting one, actually, I called one, he never called me back, I emailed another, they never got back. I guessed they felt it too litigated, however, they do not know the specifics. I am still tossing around calling one, and I guess I should just do.............there are none in my area, I would have to make a day trip to consult with one, but that is okay, I don't mind, it would be well worth it, I just need to do it I know.  Thanks for the input!!!

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@pampamk

 

But the analysis does not end without another look at KSA 60-518 which provides that plaintiff "may commence a new action within 6 months after such failure." Here the failure occurs on July xx, 2013. The case is commenced on November xx 2013. Nov xx 2013 is within the 6 months of July xx 2013. So KSA 60-518 saves the plaintiff's claim.

 

 

How did the judge come up with July xx, 2013 as the date of failure?

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@BV80

@pampamk

 

 

How did the judge come up with July xx, 2013 as the date of failure?  He is referring to the SOL. Which is why I am appealing on misinterpretation of statute... with all of my research I can say I know that statute inside out and he definitely misinterpreted! One would think he would know by now I am not as stupid as I look or represent myself, and I will appeal. I can only assume he actually believes me being Pro SE I will not continue the fight...

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@HelpingGreg

 

Just a thought,

Have you contacted NACA for attorney referrals?
Maybe a preamble to your voicemail, "I am calling as a potential client, referred by NACA.", will garner a better call-back response?

Just a thought.  Good idea, I think I will do that... Thank you!

You're impressing me with all your consumer-chaired legal battles!

Keep on keeping on, please. You are inspiring!  You have no idea how good this made me feel. I thank you from the bottom of my heart! Not even a handful of people know I am doing this, so encouragement is sparse. Honestly, the only encouragement I have received is from this forum! 

Warmly,

 

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@pampamk

 

That's unbelievable.  I can't believe the judge doesn't understand that the "failure" referred to in the statute is the dismissal of the complaint. 

 

Under the Kansas saving statute, a plaintiff who timely files a legal action that is dismissed otherwise than on the merits after any applicable statute of limitation has run may file a second legal action within 6 months of the dismissal of the first action without being barred by the statute of limitation. Seaboard Corporation v. Marsh Inc., 295 Kan. 384, 392, 284 P.3d 314 (2012).

 

He also doesn't seem to understand the meaning of the word "commenced".  Geez!

 

But, that's why I'm thinking that in your facts of the case, you might want to make sure that it's clear that you were never served after the first 2 actions were filed.  For instance:

 

7. August XX, XXXX an Order of Dismissal was filed.

 

8.  The action filed on April XX, 2012 and dismissed on August XX, XXXX was never commenced in accordance with K.S.A. 60-203(a).  (Something like that).  Then do the same for the action filed in county B.

 

By pointing out that the first 2 actions never commenced, that would lead to the statement of issues raised:  Whether or not either those actions ever commenced in order for the plaintiff to utilize 60-518.

 

 

Therefore, neither case ever commenced.   That would lead to the issue

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Well, debts are usually private affairs, so, I can totally see how the block isn't hosting a potluck, the church isn't holding a rummage sale, and the cashiers across town aren't setting out jars with my photo and "PLEASE HELP PAY OFF HIS DEBT" taped around them. LOL!

Actually, now that I paused to think on it a sec., we are all here way better off than those "lucky folks getting helped", most of them being burned out of their homes, drowning under massive medical debts to keep their loved one (s) alive through horrendous circumstances, etc

So there's that to adjust my perspective on the PDQ. "-)

This site being so beneficial to all of us, and at such affordable rates, (FREE!), I think generates a population here of members who are pleasantly surprised to find no-strings-attached hands-up really do exist, put in their "sweat equity" piecing their defense as guided by successful peers here, etc, and, ultimately return, paying it forward, as the saying goes.

I think that is the "recipe" for this site's success. Oh! Have you read some of the success stories, yet? How about some of the stunning threads from winners, e.g., 1111girl AMSTMedic HomelessInCa String there are many more!

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Hang on to your hats, here we go....... My appeal will be docketed with the court of appeals tomorrow!! Woo hoo!!! I have been doing lots of research on brief writing, and plan on posting on here each step of the way to get your input, advice, expertise, knowledge. Thank you in advance for everything!!!

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Thank you, in advance, for enriching your thread with these upcoming steps toward what I, for one, anticipate as your ever-nearer VICTORY!

Many members are reading your progress, learning from your peer-to-peer contributions to the site, via your thread's uploads, and, becoming better litigants with increased optimism for having visited your thread!

Wa-HOO!

You're so hot, Kansas must NEED the snow just to keep the climate aligned in your presence! LOL!

Keep on keeping on! You are an inspirational motivation! YES!

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Sometimes, as I do my research, I end up on very interesting pages. I found this to be very interesting. This may not be news to any one other than me... Capital One Financial Corp received a $3.6 billion investment and paid it back, plus $254 million. The company’s three-year profit was $1.3 billion. It paid no income tax in 2010, according to the study. This really burns me... They received the bailout the same year my struggles began, they paid no income tax the same year this mess I am fighting now began. hmmmm wonder if there is a way to incorporate this in my brief.... think think think

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@pampamk

 

Unfortunately, it would be completely irrelevant.

I know, but sure would like to throw it in there, especially if I knew which judges were going to be on my action and what their stance was on the bailouts... just daydreaming...

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