FOURTH JUDICIAL
DISTRICT
COUNTY OF SAN
MIGUEL
STATE OF NEW
MEXICO
METRIS COMPANIES LLP
Plaintiff-in-Error,
v.
Case No. 2003-188-CV
MARGARET EDWARDS,
Defendant.
MOTION TO
DISMISS
COMES NOW Margaret
Edwards, (hereinafter “Edwards”), moving the Court to dismiss the case
captioned pursuant to NMRA 1-060B(3),and as grounds therefor and by memorandum
brief in support thereof to state:
1) The contract alleged to be between Edwards and Metris
Companies LLP, is not true.
2)
Edwards has never knowingly contracted at anytime with Metris Companies LLP.
3) Edwards
questions the veracity of the Complaint for Breach of Agreement and
Debt and Money Due on the basis of paragraphs 1 and 2 above.
4)
Edwards charges the proper jurisdiction for interstate commerce is
federal court.
5)
Edwards challenges the jurisdiction of the Court based upon paragraphs
1,2,3,
and
4 above.
Wherefore,
Defendant
demands the Court dismiss Plaintiff’s Complaint for lack of jurisdiction.
Respectfully submitted,
All Rights Reserved
_________________________
Margaret D. Edwards
C/o 739 Dalbey Drive
Las Vegas, New Mexico [87701]
(505) 425-0659
CERTIFICATE OF
SERVICE
I certify that a true and correct copy of the foregoing Motion and
Memorandum Brief were sent first class by U.S. Mail, postage prepaid, to
Catherine Sanchez, Esq., Post Office Box 37290, Albuquerque, New Mexico
87176-7290, this 19th day of June, 2003.
___________________________
Margaret D. Edwards