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Response for Dismissal

I filed a detailed Response in Opposition to Defendants’ Motion for Sanctions in COA 25-521, calling it procedurally defective, legally unsupported, and clearly retaliatory. The filing laid out a broader pattern of misconduct involving both opposing counsel and the North Carolina Court of Appeals, including improper rejections of my filings, unsigned and possibly unauthorized judicial orders, and the misapplication of Rule 11(c) to circumvent my appellate rights. I argued that the sanctions threat wasn’t just reactionary—it was premeditated. Back in February, opposing counsel had already threatened this exact move after I called out their procedural manipulation and warned I would be documenting it. That warning proved prophetic when the motion was filed just days after I served them in my federal § 1983 civil rights lawsuit.

In my response, I also raised concerns about possible ex parte communication and coordination between Clerk Eugene Soar and Judge Eagles, especially around the timing of rejected filings and the appearance of orders that bore no judicial signature. I demanded that any ruling on the sanctions motion be issued by a named judge—not processed anonymously or administratively—and that Clerk Soar recuse himself entirely from any further involvement due to his conflict of interest as a named defendant. I reaffirmed my right to preserve the full Record on Appeal, including my Rule 9(d) supplement, and made clear that the appellate court’s pattern of procedural gamesmanship was now part of active federal litigation. The response wasn’t just about defeating sanctions—it was about exposing how institutional abuse is being weaponized against me for asserting my rights.


Response to Sanctions