Kansas Commission on Judicial Qualificalions

301 S.W. Tenth Avenue

Topeka Ks 66612

Re: 15CV38P

THIS COMPLAINT IS AGAINST 11THDISTRICT JUDGES A.J. WACHTER AND KURT LOY
FOR USURPATION OF OFFICE UNDER K.S.A. 60-1201. K.S.A. 60-1202(1)(2)(4)(5),
K.S.A. 60-1205, K.S.A. 60-1206(a)(b), K.S.A. 60-1207 and for violations of RULES
RELATING TO JUDICIAL CONDUCT CODE OF JUDICIAL CONDUCT Rule 601A, and
Rule 5.4 of The Uniform Bonding Code.

I recently signed a grand jury petition that was going around to oust all 11th judicial district j4dges due to
conflicts of interest between them which was filed in case number 2015MR2P. During the pefition drive to
try to'get the signatures a radio ad was ran on 100.7 ESPN My Town Media which is owned by attorney Bill
Wachter. After just 2 days of running on the air Judge Lori Fleming took it upon herself to use her power
inappropriately as a judge and to usurp/intrude into a private business contract between Summary
Judgment Group and My Town Media. She wrote a private email on her regular job time-as a public
servant judge and she then had the nerve to profile the Summary Judgment Group and make slanderous,
demeaning nicknames by calling anyone who signed it including "myself' "posse cometaut" because of
my political views to simply sign a constitutional grand jury petition.
What Lori Fleming called anyone that signed the grand jury petition is really "posse comitatus", The fact
that Lori Fleming made typos in her slanderous insulting remarks or the fact that she can't simply spell the
word "posse comitatus" doesn't change the fact she insulted anyone who signed the petition and labeled us
in a political box now! Who is Kurt in the email? ls it Judge Kurt Loy was he in on this too?? I think since
the copy of the message sent to 100.7 ESPN was from the email address of <Ifleming @11thjd.org> is from
a public judicial courthouse emait address that the computer this was sent from needs to b~ taken during
the investigation and see how many other messages and emails were sent ex parte and about private
matters as well. I have included a copy of the picture going around the 11th judicial district which shows Lori
Fleming contacting 100.7 ESPN at 1:43 P.M. on February 19, 2015. Is this why the state has to have
furloughs is because our public servants are conducting private business on taxpayers time. The state
should now have a permanent furlough and decrease about 70% of these government job~ since the public
servants don't want to perform their public job duties. I will be signing a class-action lawsuit now against
Lori Fleming in her private capacity since she was not performing her public ministerial duties or job
descriptions by interfering in a radio ad and damaging the summary judgment group and not getting the
required voters due to her interference in a private business matter and constitutional grand jury petition.
Since the "GRAND JURY PETITON' was for the purpose to impeach the 11th district judges
I feel Lori Fleming violated Rule 4.1 since she is making speeches in her email to attorney
Bill Wachter about the possibility of losing her political job and she should not be calling
people "POSSE COMITATUS" "WHICH IS A RACIAL NAZI SLUR"which the court of

Crawford County has been known to do in the past according to attorney Mark Fern in my
public court case number 14CV14P where attorney Mark Fern filed a "MOTION TO STRIKE
THIRD-PARTY PETITION AGAINST DEFENDANTS FERN & ANGERMAYER LLC AND
STEPHEN B. ANGERMA YER AND FOR SANCTIONS" and he says on statement S page 2
comparing the Pro Se client to something called "Kansas Militia Members" and on statement
14 of page 6 says that the Pro Se clients tactics are what "THIS COURT" meaning
"CRAWFORD COUNTY" that this court commonly associates with the "KANSAS
MIUTIA"!!!! The statement of people representing

themselves being "MILITIA" by the 11th

judicial district court is just one of the bias and prejudices under Rule 2.3, and due process
violations that led to the "GRAND JURY PETITION" to impeach all 11thdistrict court judges.
Maybe attorney Mark Fern had spoken with Judge Lori Fleming since she was one of three
(3) district judge members of "the court" in the 11thjudicial district in Crawford County in
2014 when that statement was made public when it was filed.
I don't feel confident going in front ofJudge

A.I. Wachter

in case number ISCY38P since his

brother is the attorney that Lori Fleming was making "NAZI RACIAL SLURS" with and
calling me "posse comeataut".

All judges in the 11thdistrict have now showed proof of bias

and prejudice against Pro Se litigants and Judge Wachter is the chief judge which should
violate Rule 2.12 for not properly supervising his employees.

I also don't feel A.J. Wachter

should hear this case because Steve Stockard of Wilbert and Towner is an attorney in this
case and

A.I. Wachter

used to own Wilbert and Towner and Wilbert and Towner is the law

firm that is owned by My Town Media owner, attorney Bill Wachter who receives e-mails
from Lori Fleming which is unethical.

Please investigate this matter and assign a judge from

out of the 11thjudicial district to hear this case under Rule 2.11 (A) Disqualification.

Very truly yours,

f~ ~.
~

James Beckley Jr.

30 ~ w.

CC Attorney General's Office

State Insurance Commissioner

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7 to .3

MINTER & POLLAK

545 N. Woodlawn
Wichita, Kansas 67208
(316) 265-0797

DISTRICT COURT, CRAWFORD COUNTY, KANSAS

CIVIL DEPARTMENT
COMMUNITY NATIONAL BANK & TRUST,

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Plaintiff,

CASE NO. 15 CV 38-P

v.

JAMES A. BECKLEY, SR., deceased,

JAMES A BECKLEY, JR.,
MICHAEL ANDREW EDWARDS,
UNKNOWN SPOUSE OF MICHAEL ANDREW
EDWARDS, UNKNOWN TENANT(S),
JESUS PIEDRA-SEGOVIA A/KiA JESUS PIEDRA,
MARIA LOPEZ, JUAN LOPEZ,
KANSAS DEPARTMENT OF REVENUE,
BOARD OF COUNTY COMMISSIONERS FOR
CRAWFORD COUNTY et al.

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TITLE iNVOLVING
REAL ESTATE

OGo~y
FILE BY FAX

Defendants.

----------------------------------)
Pursuant to K.S.A. Chapter 60
(REAL ESTATE FORECLOSURE ACTION)
MOTION TO DISMISS COUNTERCLAIMS

AGAINST PLAINTIFF

COMES NOW, the Plaintiff, Community National Bank & Trust for its Motion to
dismiss the counterclaims asserted by the Defendant James A. Beckley, Jr. pursuant to
K.S.A. 60-212(b) and in support of said request states as follows:
1) Plaintiff is entitled to judgment on all counterclaims and defenses
In this matter the Defendant James Beckley, Jr. has asserted numerous
defenses and counterclaims which have no basis under Kansas law and should be
dismissed pursuant to K.S.A. 60-212(b)(1) for lack of subject-matter jurisdiction or 60212(b)(6) for failure to state a claim upon which relief can be granted. Given the nature

CERTIFICATE OF MAILING
The undersigned hereby certifies that on this 20th day of May, 2015 the original
above and foregoing Motion to Dismiss Counterclaims Against Plaintiff was deposited in
the United States Mail, postage prepaid and properly addressed to:
James A. Beckley, Jr.
302 W. McKay
Frontenac, KS 66763
Kip Sagehorn
Loy & Sagehorn, LLC
P.O. Box B
Pittsburg, KS 66762

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Steve Stockard
Wilbert & Towner, PA
506 N. Pine
Pittsburg, KS 66762

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Creath Pollak, #21681

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Case

201S.CV.000038,P

Judge'
Filing date:

Repository

Case subtype:
Under ad...
~sement:
Discovery conf.:

Comment:

Previous cass:
Next

hearing:

Pretrial conf.:
0710212015 09:00 AM, Needs Set Discovery

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Source:

Termination

date:

,00;0010000 ".

Re.instatement

Created by: KV on 041061201510:15 AM

'Plaintiff

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Trial eno:

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Termination typs:

Nature of judgment

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Trial start:

Filing stats sent:

DOIDO/Oo-OO

date:

Term. slats sent:

Updated by: KV on 04f06l2015

Attorney:

Natlcnat

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Plaintiff

Community

10:21 AM

Other part'.~~. ]Le.~e~

1

of 1

Status History

Bank & Trust

Pollak, Creath

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Send to Pros-ecUlor'

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Send notices:

f~1 Post-active:

, litigant Options

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Comment:

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Counter claimant:
Counter defendant:
claimant:
CfOSS defendant:

Cross

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Third party plaintiff:

Third party defendant:
lntsrvenor:

Amicus

Interplead or:
Non party:
Other party:
Amount claimed:

curiae:

Journal entri required:

~i
Journal -entry date:
Created by: KV on 0410612015 10:16 AM

M/OOfOUOD
Updated by: KV on 04i0612015

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INTHEDISTRICTCOURTOF CRAWFOfo tbfr~NSAS

Community

National Bank & Trust,

Plaintiff,

14 MAR14 P 2 :04

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Case No. 14 CV 14 P

James A. Beckley, Jr., and the unknown

heirs, executors, administrators,
devisees,
trustees, creditors and assigns of such of
the defendant as may be deceased and
the unknown spouses of the defendant;
the unknown officers, successors, trustees,)
creditors and assigns of such defendant
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as are existing, dissolved or dormant
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corporations; the unknown executors,
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administrators, devisees, trustees,
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creditors, successors and assigns of such )
defendant as are or were partners or in
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partnership; and the unknown guardians,
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conservators, and trustees of such of the
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defendant as are minors or are in
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anywise under legal disability; and the
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unknown heirs, executors, administrators,
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devisees, trustees, creditors, and assigns of)
any person alleged to be deceased.
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Defendants.
}

-------------------------------)
PURSUANT TO CHAPTER 60 OF
KANSAS STA lUTES ANNOTATED
MOTION TO STRIKE THIRD-PARTY PETITION AGAINST DEFENDANTS
FERN & ANGERMAYER LLC AND STEPHEN 8. ANGERMAYER
AND FOR SANCTIONS
Come now third-party defendants Fern ~ Angermayer, LLC and Stephen B.
Angermayer by and through their attorney Mark E. Fern and for their motion to strike
the third-party petition against them and for sanctions state:
1. Plaintiff, Community National Bank & Trust, a financial institution, organized

'k

existing, and doing business

against the defendant
foreclose

a security

James

answer to the plaintiff's

James A. Beckley,

B. Angermayer

complaint
allegations

against

all parties he

against

and his firm, the president

the attorney
of the bank,

deputy, Robert Peters, who served the defendant

with

and petition.
defendant

with various regulatory

also filed complaints

authorities.

counsel with the Kansas Office of Disciplinary

with the Comptroller
County Sheriff's

:j---

Jr., was properly served and filed a pro-se

in the suit. He made third-party

and the sheriff's

4. The third-party
defendants

note and to

petition.

for the plaintiff bank, Stephen

the summons

A. Beckley Jr. for defaulting on a promissory

Beckley filed a pro-se, third-party

believed were involved

Tony Stonerock,

by virtue of law, filed a petition in this action

interest.

2. The defendant,

3. Defendant

under and

of Currency,

against

He filed a complaint
Administrator,

and against the sheriff's

against

bank's

against the Bank President

deputy with the Crawford

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L-O(:

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,-7 \J+;J. weul)U

Department.

5. Third-party

all third-party

defendant

tactics, as set auf above

m irr-o-r-w-h-a-t
-th-is~co-u-rt-h-a-s
-

received in prior cases from Kansas Militia members.

--------------~

6. The statute on third-party practice states as follows:

Statute 60-214: Third-party practice.

(a) When defendant may bring in third

party. At any time after commencement of the action a defending party, as a
third-party plaintiff, may cause a summons and petition 10 be served upon a
person not a party to the action who is or may be liable to the third-party plaintiff
for all or part of the plaintiff's claim against the third-party plaintiff. The third-party
plaintiff need not obtain leave to make the service if the third-party plaintiff files
the third-party petition not later than 10 days after serving the original answer.
Otherwise the third-party plaintiff must obtain leave on motion upon notice to all
parties to the action. The person served with the summons and third-party
2

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14. The Third-party plaintiff has interposed the third-party claim for the purpose

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harassment and delay. His tactics are what this court commonly associates with the

Kansas Militia. Their pleadings are typically filed p;o-se with a convoluted reference to

..

'-----

Kansas statutes. Often the alleged facts are untrue, and the Militia's hallmark is an

----------

extreme anti-government ideology along with elaborate conspiracy theories.

15. In Wood v. Groh, 269 Kan. 420, 431,7 P.3d 1163 (2000) the court listed the

following factors to be considered by the court when awarding sanctions against a party
who violates KSA 60-211 :

(1) whether the improper conduct was willful or negligent;

(2) whether it was part of a pattern of activity or an isolated event;
(3) whether it infected the entire pleading or only one particular count or
defense;
(4) whether the person has engaged in similar conduct in other litigation;
(5) whether it was intended to injure;
(6) what effect it had on the litigation process in time orexpense:
(7) whether the responsible person is trained in the law;
(8) what amount, given the financial resources of the responsible person, is
needed to deter that person from repetition in the same case; and
(9) what amount is needed to deter similar activity by other litigants.
/d.
16. The movants request that the court find the Third-party plaintiff has filed his
third-party claim in violation of KSA 60-211, and awards them attorney's fees for filing
this response and attending any subsequent hearings in this matter.
WHEREFORE, Third-Party Defendants, by reason of the matters above set forth
above, are entitled to have the third-party claims against them dismissed with prejudice.
The movants are entitled to an award of attorney's fees for defending this action and for
any subsequent hearings, and for such other relief that the court deems proper.