MOTION TO QUASH AGAINST MARK BIBBS

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Happy, Nerdy Young Woman Making an "L" on Her Forehead

I am posting this article about a scumbag attorney Mark L. Bibbs. I have had several dealings with this individual and none of them have been, lets just say delightful. I have my own opinion of this moron. I will let you make up your own mind about what has transpired with communications with this so called officer of the court. Just remember this individual is supposed to be a professional attorney. This in my opinion is one of those attorney’s that just give a bad name to all other attorney’s.

 

STATE OF NORTH CAROLINA                      IN THE GENERAL COURT OF JUSTICE

COUNTY OF GUILFORD                                     SUPERIOR COURT DIVISION

16 CVS 7708

 

PREMIER JUDICIAL CONSULTANTS,LLC

AND CANNON SURETY, LLC.

V

CLYDE ROBERT BRAWLEY                   SUBPOENA OF RONALD PIERCE

MOTION TO QUASH

PROTECTIVE ORDER

 

I Ronald Pierce, Pro Se, and only a witness in this matter. Moves the court for a Motion to Quash and a Protection Order on the matter at hand for the following reasons.

1.)  In accordance with Rule 45 of the North Carolina Rules of Civil Procedure, Subsection (c) item (1). Also item (3) and (d). (Avoid undue burden or expense). This is the second Subpoena that I have been subject to as a Witness. Neither as a Defendant nor as a Plaintiff.

2.)  I own and operate a small construction company. I wasted a complete day on the first Deposition where I could not engage on or in my business to make monies.

3.)  I also wasted two complete days of my time due to production that was demanded of me and the bill supplied to the attorney of record with and for my production costs was supplied to the attorney of record and was outright refused to be paid by the attorney of record. There were over 2000 pages of records produced by me on the first request, I sent a bill for $902.25 to the attorney of record, then another two hundred pages were produced by me on the second request for documents and a bill of $125. was presented, and yet no payment of any kind was ever made or paid by the attorney of record, nor the Plaintiff, nor were monies received by me for either amount. With a total of $1,027.25 for production costs. All information was stored on my computer so only I could retrieve the production.

4.)  Since the first Subpoena and documents supplied by me, Mark Bibbs and the same Plaintiffs with whom Mark Bibbs represent on this matter. Have used this information to file suit against me. Through another attorney, G. Grady Richardson has filed a complaint that lists me Ronald Pierce as a Defendant, to include Clyde Robert Brawley of which this case is based, of which I am defending Pro Se. That case number is 17 CVS 3831. The attorney of record is trying to obtain any records that can through this case and share with the other attorney on this matter that I am a defendant on without going thru proper procedures in and through the court system.

5.)  I am bringing the court’s attention to the outrageous actions from the attorney of record and a so called Officer of the Court. On 6 June 2017 my sister Billie Jo Parsons passed in Cleveland Ohio, I notified Mark Bibbs that the scheduled second Deposition that was scheduled for me by the attorney of record on Thursday, 8 June 2017. I would not be able to attend the Deposition. I left North Carolina early Thursday morning and drove to Cleveland Ohio to get my sisters body from the coroner and prepare for the funeral. Later that day I received a call from my wife that Timothy Mathis came to my house to deliver another Subpoena for additional documentation, when my wife refused to accept delivery he throw the Subpoena at her feet, then left the property, I wrote an email to the attorney of record and demanded that Timothy Mathis was not to come to my property under any circumstances. If Mark Bibbs wanted to Subpoena me any further then the sheriff’s office can deliver them, the actions and demands from this attorney are and were outrageous in nature to begin with. A full list of this attorney’s demands is supplied with this Motion to Quash and this Protective Order.

6.)  I am asking this court for a hearing on these matters if the court deems it necessary. I am also asking the court for sanctions against Mark Bibbs. I will include a copy of the emails/communications from this attorney of record.

7.)  I am asking this court for a protection order for any further subpoenas and or depositions, in as much as these are just outright attempts to obtain information for another case that I am subject to.

8.)  This is a notification to this court of harassment, threatening, and intimidation of a witness “ME” by Mark Bibbs against and to me and my wife.

9.)  I will be filing a complaint to the NC Bar on this attorney’s actions and outrageous conduct.

10.)  I bring to the attention of this court NC BAR Rule 4.1. Truthfulness in Statements To Others, which states the following: In the course of representing a client a lawyer shall not knowingly make a false statement of material fact or law to a third person. Which is exactly what has happened here? I never made any such statements, nor even if I had of even thought of these remarks, I am not stupid enough to make them via text or email.

11.)  Next I bring to the courts attention to NC Bar Rule 3.3 Candor Toward The Tribunal. Which states the following: (a) A lawyer shall not knowingly: (1) make a false statement of material fact or law previously made to the tribunal by the lawyer. Since all of the actions on this case and the fact that I am only a witness in this matter the court needs to intercede.

12.)  Next you will find text messages that were supposed to have been sent by me. Vulgar, totally unprofessional, false statements, made by and sent by Mark Bibbs, I remind this court in this matter that this attorney is an officer of this court, sent to the attorney of Clyde Robert Brawley, Mr. Steve McCloskey, in this case to try and discredit me of some sort of way. Of which I expressly deny any involvement in these False text messages. These are made up False Statements from the attorney of record, of which can easily be disproved by a copy of my own phone records. Of which I will request a copy of immediately from my phone company.

13.)  At this point I am not only asking but demanding justice and respect from this court where this unethical, unprofessional attorney Mark Bibbs is concerned. He has lied, will continue to lie, intimidate, harass, and coerce until this court intervenes. This attorney gives all other attorney’s a very bad name.    Signed Ronald Pierce.

Next I will recreate the emails and texts here for everyone to see. These are very graphic. I openly state that I did not make these texts. They were made by Mark Bibbs and done so to try and discredit me in some way. You can use your own intelligence to figure out where they came from.

EMAILS

From: Steve McCloskey    Sent: Wednesday, June 7, 2017 5:22 PM      To:  Robert Brawley

Additional pleasantries……..

From:  Mark Bibbs   Sent Wednesday, June 7, 2017 4:32 PM  To: Steve McCloskey         CC: Dallas McClain <duhkingfish@yahoo.com>; Lyne Thompson <lyne.thompson@gmail.com>; Carl Valentine <valgunny@aol.com>; Betty Jordan <bjordanco@mindspring.com>      Subject: Ron Pierce texts

4:29 PM……fuck you I’m not telling you anything. Suck My. Dick…………In that case, I will expect to see you in the morning at 9:30…….okay but also give me my 2 grand…….why……You are not entitled to any money for any reason. You are a witness, and therefore not entitled to a fee……….okay I’ll tell you what I know……..

All communications are and were made up lies by Mark Bibbs at bibbslawgroup@gmail.com.

These false text were because I had my sister pass away in Cleveland Ohio on 6 June 2017. I sent this so called attorney a notification that my sister had passed and that I would not be available to attend his deposition of me on 8 June 2017. This was his reply verbatim…….

From:   Mark Bibbs   To:   Ron   CC;  Dallas McClain; Lyne Thompson; Carl Valentine; Betty Jordan; Steve McCluskey; Grady; Mary…..Subject:   Re: DEPOSITION

Mr. Pierce,  I am sorry to learn of the death of your sister in Ohio. Please forgive me if I require proof and verification of her death, and your kinship, from you before rescheduling your deposition.

Once I have verifiable proof of her death and your relationship to her, we can reschedule your deposition for another date very soon, perhaps as early as this coming Monday, June 12, at 9:00 AM at the same location. That depends on all parties availability along with the court reporter. Not yours.

In order for me to reschedule your deposition in this matter, I require from you: 1.  Her full legal name;  2.  Location of her death; city, County and State;  3.  Name of funeral home & contact information for the funeral home, including a telephone number and the name of the funeral director;  4.  A printed death announcement that shows the death;  5.  A printed biography showing that you are in fact related as brother and sister;  6.  Documentation of the date and time for any funeral or memorial service.

MY REPLY:

I don’t care what you require. You are a cold heartless Bastard. Fell free to make your Motion for Sanctions, I will be more than happy to see your sorry ass in Court. I’ll make you make a Motion in Court to reschedule since you are being a total ass. I’ll show everything to the judge. I also don’t care what you believe. Unlike you I don’t lie. I will also file suit against you for the last documentation that I provided. As you have found out that I can defend myself in court. As far as you bringing your ass to Charlotte a day before is your problem and not mine. I notified you of the death at *AM this morning. Please notify me by Sheriff when your Motion will be heard in Court. When I get back I will do my own Motion to Quash in accordance with Rule 45 of the Civil Procedure. You have been notified.  Ronald Pierce.

And here it is my Motion to Quash. Oh by the way everyone….my only answers for any more questions from Mark Bibbs will be I plead the 5th Amendment and have a nice day.

 

 

 

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