Exhibit 13

Exhibit 13.0

OBJECTION TO PLAINTIFF’S REPLY TO PLAINTIFF’S MOTION FOR JUDGMENT ON THE PLEADINGS

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OBJECTION TO PLAINTIFF’S REPLY TO PLAINTIFF’S MOTION FOR JUDGMENT ON THE PLEADINGS

COMES NOW Margaret Edwards, defendant, and hereby objects to the plaintiff’s reply to their motion for judgment on the pleadings. As grounds therefore and in support thereof, Edwards states:

1. The notarized Affidavit of Indebtedness & Debt & Non-Military & Contract, dated November 13, 2002, does not identify Affiant/Declarant with sufficient clarity and accuracy to hold the signer accountable for business transactions of a foreign corporation pursuant to NMSA 53-11-14 [Service of process on corporation. (1967)]. Further, DIRECT MERCHANTS CREDIT CARD BANK is not licensed to do business in the state of New Mexico.

2. The entire matter related to the alleged debt took place through the United States Postal service, which places jurisdiction in a federal court, not in state court.

3. The alleged application Account, No. 5480-0040-4318-2227, is shown in Section 1 to be unsecured, and further, said application is fraudulent because it does not provide full disclosure.

4. Edwards rebuts statement by Plaintiff’s attorney, Catherine Sanchez, that “there is no dispute as to any material fact,” since Edwards has rebutted Plaintiff’s allegations in previous pleadings, and further, Edwards sent letters, dated September 30, 2002, October 21, 2002, December 4, 2002, December 5, 2002, January 5, 2003, and January 6, 2003, to DIRECT MERCHANTS CREDIT CARD BANK and to METRIS COMPANIES LLP, by and through attorney Catherine Sanchez, which contained, in part, charges of fraudulent business practices, in violation of federal law. These letters required a response to rebut Edwards’ statements and charges, if respondents disagree. No rebuttal was ever made, ergo, Edwards’ charges stand as true and respondents agree, by acquiescence, with Edwards’ charges. Legitimate debt is valid; fraudulent debt is not legitimate.

5. Edwards formally challenges the jurisdiction of this Court to consider this matter.

WHEREFORE, Edwards objects to the reply submitted by Plaintiff METRIS COMPANIES, LLP (Auto Add for the foregoing reasons and formally challenges the Court’s jurisdiction in this matter.

I certify that a true and correct copy of the foregoing objection to plaintiff’s reply to motion for judgment on the pleadings was sent first class by U.S. Mail, postage prepaid, to Catherine Sanchez, Esq., Post Office Box 37290, Albuquerque, New Mexico 87176, this ____day of October, 2003.