Section 6
– Exhibit 13 – filed October 24, 2003
Edwards filed this Objection to Plaintiff’s Reply pursuant to its Motion For Judgment
On The Pleadings and Edwards Response thereto.
It is imperative to always rebut
or deny untruthful charges made by one’s opponent in his/her pleadings.
Edwards always rebutted Metris’ charges made in its pleadings, and,
again, points out that Metris is not licensed to do business in New Mexico. Again, since DMB solicited Edwards by and through the U. S.
Postal Service, proper jurisdiction is federal district court, not state
district court. The alleged
application is fraudulent, since DMB failed to provide full disclosure, and the
“credit” is unsecured. If
unsecured, then any action taken to recover anything unsecured is fraudulent.
The Objection follows on the next page.