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Motion to Transfer Venue

After I filed a detailed Motion for Sanctions and a Motion for Leave to Reply in the Court of Appeals, opposing counsel doubled down by responding in a hostile, condescending tone—continuing to misrepresent both the procedural record and the law. Their response to my Motion for Sanctions accused me of filing premature appeals for the purpose of delay, dismissed my valid objections as personal grievances, and even invited the Court to sanction me “sua sponte.” They falsely claimed I filed multiple amended complaints without permission and defended the trial court’s actions while twisting precedent to justify ignoring the automatic stay. Then, instead of simply opposing my Motion for Leave to Reply, they filed a separate Motion to Strike—arguing that my request was redundant, repetitive, and unnecessary, despite the clear misrepresentations in their previous filings that I had every right to respond to.

To make matters worse, on March 26, 2025, opposing counsel filed a Motion to Transfer the case to Superior Court under N.C. Gen. Stat. § 7A-258, based solely on the counterclaim they had improperly filed during the automatic stay. Not only was the counterclaim itself procedurally invalid, but using it to try to move the case to a higher court was yet another attempt to manipulate jurisdiction and sidestep accountability. Filing this transfer motion while jurisdiction was still with the Court of Appeals is a clear violation of N.C. Gen. Stat. § 1-294 and further demonstrates the ongoing abuse of process and disregard for proper procedure.

The Court of Appeals denied his Motion to Strike and my Motion for Leave.

Response to Sanctions

Motion to Strike

Motion to Transfer