Exhibit 20

Exhibit 20.0
Edwards replied to Metris’ Response to her Demand For Trial By Jury

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1. Plaintiff, by and through counsel, did not rebut, with particularity, any of the statements and charges made in Defendant’s Motion for Citizen’s Demand for Trial by Jury. Because of the oath required and taken by counsel, counsel could not deny that the National Constitution is the Supreme Law of the land and deny powers of both Constitutions. Edwards invokes NMRA 1-008 (D) on grounds Plaintiff, by and through counsel of record, admitted to the veracity of all averments in Edwards’ Motion, which required a response, because they were not denied or addressed. NMRA 1-008 (D) is quoted for the information of the Court: To wit:

Effect of failure to deny. Averments in a pleading to which a responsive pleading is required, other than those as to the amount of damages, are admitted when not denied in the responsive pleading. Averments in a pleading to which no responsive pleading is required or permitted, shall be taken as denied, or avoided.

Since Plaintiff is in agreement with Edwards’ Motion for Citizen’s Demand for Trial by Jury, and since her argument does not supersede the Constitutions or deny the powers of both Constitutions, the trial by jury must take place.

2. The Court is advised that the demand for jury trial -“as it has heretofore existed” - was authorized pursuant to Kearney Bill of Rights, Clause 5 in Pamphlet 3, and New Mexico Constitution, Article II, Section 12, and remains inviolate; New Mexico case law and court rules altering the integrity of the inviolate right - “as it has heretofore existed” - to the contrary, notwithstanding.

The right of trial by jury as it has heretofore existed shall be secured to all and remain inviolate. In all cases triable in courts inferior to the district court the jury may consist of six. The legislature may provide that verdicts in civil cases may be rendered by less than a unanimous vote of the jury.

Phrase “as it has heretofore existed” refers to the right to jury trial as it existed in the territory of New Mexico immediately preceding adoption of the Constitution. Bliss v. Greenwood, 63 N.M. 156, 315 P. 2d 223 (1957); Gutierrez v. Gover, 43 N.M. 146, 87P. 2d 437 (1939); Young v. Vail, 29 N.M. 324, 222 P.912 (1924); State v. Holloway, 19 N.M. 528, 146 P. 1066, 1915F L.R.A. 922 (1914).

It was the purpose of the Constitution framers to retain the right of trial by jury, as it theretofore existed in the territory of New Mexico, except in special proceedings, for which express provision was made in the same instrument. Seward v. Denver & R.G.R.R., 17 N.M. 557, 131 P. 980, 46 L.R.A. (n.s.) 242 (1913).

Procedure to be followed in securing right to jury. - The right to trial by jury as guaranteed by the Constitution is to be distinguished from the procedure to be followed in securing the right. Reasonable regulatory provisions, although different in form and substance from those in effect at the adoption of the Constitution, do not abridge, limit or modify the right which is to remain inviolate. Carlisle v. Continental Oil Co., 81 N.M. 484, 468 P. 2d 885 (Ct. App. 1970).

3. All New Mexico public officers, pursuant to the National and State Constitutions haven taken an oath to support and uphold said Constitutions and are required to honor that oath in the faithful performance of their duties and in compliance with their responsibilities to the public trust. As is clearly demonstrated, herein, the Constitution of the Republic of New Mexico guarantees the Right of jury trial and that Right remains inviolate, case law, court rules, procedures, statutes and other rules and regulations, to the contrary, not withstanding.

4. Any fee charged for jury is not authorized or permitted by the New Mexico Constitution and the National Constitution, and is, thus, invalid, without force or effect. (See Marbury v. Madison.) Those bodies and those entities which assume power not authorized by the Constitutions unlawfully usurp power not possessed and deny the powers of both Constitutions. (See Miller v. U.S.; New Mexico Constitution, Art. II, Sections 2,3, 4.) Any fee charged for jury is coercion of funds, the “buying and selling” of “justice”, extortion, unequal protection under the law, deprivation of Rights guaranteed in both Constitutions, denial of due process of law, disincentive by financial hardship and intimidation by the state .

5. Article II, Section One of the New Mexico Constitution states that the Constitution of the United States of America is the Supreme Law of the land. The National Constitution supersedes and is superior to all other domestic laws, rules, regulations and procedures, whatsoever. Neither Constitution authorizes or permits fees for jury. The federal court system does not require the posting of a fee when a litigant files a demand for trial by jury. That New Mexico does so, is a violation of equal protection under the law. ( National Constitution, 14^th Amendment, Sec. 1; New Mexico Constitution, Art. II, Sec. 18.)

6. Since neither Constitution authorizes fees, those laws, rules and regulations which do, are unconstitutional and unlawful, and those who enforce, or attempt to enforce, them engage in insurrection and rebellion against both Constitutions. (See National Constitution, 14th Amendment, Sections 3 and 4.)

“But whenever the judicial power is called into play, it is responsible to the fundamental law and no authority can intervene to force or authorize the judicial body to disregard it.” Yakus v. U.S. 321 U.S. 414, Pg. 468 (1944). The fundamental law of this Nation and this state is the National Constitution, which guarantees trial by jury without fees and time qualifications for demand. (See New> National Constitution, 7^th Amendment.) “All laws which are repugnant to the Constitution are null and void.” Marbury v. Madison 5 U.S. 137 at 174 and 176.

7. The Plaintiff, by and through counsel, pursuant to her oath and requirements thereof, brings a fraud upon the Court, and appears, based upon the foregoing, to be influencing the presiding judge, through pleadings and ex parte communication, to defy the Law, deny the powers of the Constitution and perjure his oath.

8. Further, neither Constitution limits time for demand for trial by jury. Edwards denies that she “waived” a trial by jury. Edwards hereby claims all her Rights, secured for her in both Constitutions. (See Miller v. U.S.) Edwards states that she did not submit a demand for trial by jury, earlier, because due to the frivolous charges brought by Plaintiff and the crimes admitted to by Plaintiff, by acquiescence with Edwards’ letters sent to Plaintiff and counsel, Edwards reasonably expected the charges to be dismissed. Unrebutted statements stand admitted and as truth. When Edwards was notified, without ever having been consulted about the possibility of a telephonic hearing, that such telephonic hearing had been scheduled, apparently, as a result of ex parte communication between Plaintiff, by and through counsel, and the Court, Edwards, based upon that unlawful action, then, elected to exercise her Constitutional Right to demand a trial by jury.

9. Still further, Edwards rebuts Plaintiff’s representation concerning pleadings. All filings with the Court, by either party, are pleadings.

10. The Court is also advised that District Judge, Carol Vigil, informed Citizen, Carole Anton, from the bench, during a trial held on December 29, 2003 in City of Santa Fe v. Anton, D-101-CV-200300523, First Judicial District, New Mexico, the following:

a. The Court Rules, binding the Court, put any unrepresentative litigant at a clear disadvantage; that the New Mexico Court of Appeals ruling on complaints of that nature forced district judges to hold litigants, without representation, to the court rule disadvantages and that she, Judge Vigil, would hold Anton to the disadvantages, in perjury of her oath, in violation of Anton’s Citizen Rights to due process and equal protection under the law, and in denial of the powers of both Constitutions.

b. The facts cited above are of record in the December 29, 2003 trial and those statements were heard and witnessed by numerous Citizens, some of whom had been held involuntarily in state courts, at all levels, to those conditions of servitude, denying the power of both the National and State Constitutions.

c. The most recent example can be found in the order of this Court, dated January 6, 2004, in a case entitled, State of New Mexico v. Plagge, 02-10-LR, which by litigation trickery, was a New Mexico Supreme Court petition for writ of prohibition, submitted by Plagge, challenging the legality of Court Rules holding her, as an unrepresented litigant, to conditions of involuntary servitude. This Court did not have jurisdiction to decide the legality of Supreme Court Rules imposed on the People of New Mexico as though they were chattel property owned by that Court. Nevertheless, by legal trickery, the person improperly assigned the supreme court petition, decided the matter in favor of the conditions of involuntary servitude.

d. Further, the person assigned the Plagge petition in this Court had several motions for leave to file with the supreme court as amicus curiae, one of which showed that public appropriations were being embezzled, with abandon, in San Juan County. The assigned judge in this Court denied the motion for leave to file and simultaneously aided and abetted the embezzlement of public appropriations by the said Order, dated January 6, 2004.

WHEREFORE, Defendant-in-Error, Edwards, files this Reply for the benefit of this Honorable Court in support of her Right to a jury trial and to avoid any litigation trickery being exercised because she is a litigant unrepresented by a licensed attorney.

I certify that a true and correct copy of the foregoing Reply to Plaintiff’s Response was sent first class by U.S. Mail, postage prepaid, to Catherine Sanchez, Esq., Post Office Box 37290, Albuquerque, New Mexico 87176-7290 on this ____ day of January, 2004.