STATE OF NEW MEXICO
COUNTY OF CHAVES
FIFTH JUDICIAL DISTRICT COURT
CHASE XANDER
plaintiff,
vs. Case No. D-504-CV-202300223
AMERICAN MEDICAL RESPONSE AMBULANCE SERVICE, INC.
defendant,
EASTERN NEW MEXICO MEDICAL CENTER INC.
defendant,
REPLY TO DEFENDANT AMR’S ANSWER TO AMENDED COMPLAINT
Your Honor, I object because once again the defendants are lying to you. They are liars they do nothing but lie, I knew this would happen when I, after all these years decided to sue, I KNEW they would lie to your face. There NEVER was any ‘self defense’ for the employees of AMR they ALWAYS batter and abuse me making it next to impossible to get emergency help.
I will show during trial 10 years of abuse from them, me begging dispatch to make sure they send EMT’s that don’t batter and abuse me, them ALWAYS using excessive force like the sheriffs use to do putting MY LIFE in serious danger like they did when I had covid.
Or the time in the federal case where I burned my leg and it got infected I called an ambulance I got around 15 medical and law enforcement at my house blocked off my road for a mile. Just so they could play their practice raiding games on me, a CRIPPLED old lady who has NEVER owned a gun. They all thought I was too poor, too crazy and TOO ALONE to do anything about it.
Or the time ENMMC gave me 500 mg of ketomine one night, more than enough to kill a person, I spoke with their ‘in house legal representatives’ about this as well.
The defendants asked in interrogatories if I have ever been convicted of being untruthful, that is a full no and stop and unlike the defendants and their attorneys NEVER have I EVER lied in court I would be terrified to do so but it comes so easy for these attorneys.
The sheriffs knew enough to settle in the federal case. They KNEW the damages done to me by them AND both defendants. What they say are LIES and RIDICULOUS.
And just so you know your honor, the ambulance in discrimination and since the abuse has the sheriffs accompany them when they come to my house, and the sheriffs would love nothing more than to arrest me you yourself can attest to that. If I had ever lifted a single finger in my own self defense, they would quickly have arrested me for that. Also even when beaten almost to death over the 10 years of abuse and false detainment, I didn’t lift one finger to defend myself because I KNEW if I did I would be charged with it. You seen when this happened.
I know you know I know how to cite cases and handle the burden of this legal case, I made it all the way to appeals with case on innogames. I also know that I know how to make my pleadings more professional, and I will from this point on try and copy some of the legal style of pleadings, but also know I do not have to know or write legalese to represent myself, but I need you to know these things. And council seems to just tell you anything they want you to know- illegal (my hospital records and personal email) and deceptive. I don’t know how to do that except in my pleadings and every time I submit a pleading or reply in court I am under a vow of oath to tell the truth and nothing but the truth. Except the defendants and their attorneys seem completely able to tell the truth and it would seem they are completely willing to lie for each other, something I would have predicted out of the sheriffs, yet they were honest, and settled. And I am willing and ready to take a lie detector test although without the extreme excessive force negligence and illegal detention, I believe my case is still fairly solid.
WHEREFORE
I ask the court to treat the defendants AMR’s response as the lie it is. And to understand that my disability makes this EXTREMELY hard to deal with and relive over and over, I never wanted in your courtroom or any other. What I want is not to be damaged EVER AGAIN. But until every entity in this county figures out that I will sue if I am abused- it will end legally when they admit what they did and pay a FAIR amount for the damages they owe or a court tells me I can no longer seek restitution.
Respectfully submitted,
Chase Xander pro se
/s/ Chase Xander
ALL PLEADINGS
Re: ALL PLEADINGS
STATE OF NEW MEXICO
COUNTY OF CHAVES
FIFTH JUDICIAL DISTRICT COURT
CHASE XANDER
plaintiff,
vs. Case No. D-504-CV-202300223
AMERICAN MEDICAL RESPONSE AMBULANCE SERVICE, INC.
defendant,
EASTERN NEW MEXICO MEDICAL CENTER INC.
defendant,
MOTION FOR A COURT APPOINTED ATTORNEY
Your Honor, I am being harmed mentally over this case. It is easy for the defendants attorneys nothing happened to them, they are not emotionally involved in this case like I am. I have SEVERE mental disabilities and this case is making it so much worse. Each and every time I open this case to work on it, I am FLOODED with memories of what was done to me.
I am having what can easily be medically documented a very hard time responding in a civil manner with decorum because these attorneys not only know what their clients have done but they are lying about it in court.
Your Honor holds me to the same standards as an uninvolved attorney with no mental health issues. This is a violation and discrimination against me.
I am perfectly capable of handling this case cognitively it is easy, come to court with the truth and I will win. I have to believe that because every thing I was taught when I was growing up like the cops are the good guys has been demolished. I have to hold on to the belief that the court will be fair. Also I do trust you in your rulings to be fair, not kind but fair. But your orders for me to ‘behave normally’ are discriminatory. Sorry.
The best and easiest solution to this if for a court to appoint me an attorney if for nothing but consolation.
While New Mexico does not have any statues insuring a court appointed attorney for the indigent there are also no statues that deny it. In abuse cases courts have given counsel to the victims. I am a victim. I am abused and this case is making me very sick mentally.
Naranjo v. Thompson: In this case, Mario Naranjo, a prisoner at Reeves County Detention Center in Texas, sued prison management for constitutional violations. The court ruled that Naranjo merited assistance from an attorney due to exceptional circumstances. When no willing lawyer was found, the Fifth Circuit held that the court had the inherent power to compel counsel to accept an uncompensated appointment1.
Douglas v. California (1963): Although primarily related to criminal cases, this landmark decision established the right to counsel for indigent defendants. It laid the foundation for subsequent cases involving civil representation.
Smith v. Bennett (1961): This case reinforced the importance of providing counsel to indigent parties in civil matters. It contributed to the evolving jurisprudence on court-appointed attorneys.
WHEREFORE
I ask the court to appoint me an attorney if for nothing but consultation. This will save the court time and money because you won’t have to deal with my messy court pleadings. This should also be done because of my health concerns about continuing this case.
Both defendants oppose this motion.
Thank you for your time.
Respectfully submitted,
Chase Xander pro se
Judge Hudson will rule against this, he believes me to be a fully capable legal representative
COUNTY OF CHAVES
FIFTH JUDICIAL DISTRICT COURT
CHASE XANDER
plaintiff,
vs. Case No. D-504-CV-202300223
AMERICAN MEDICAL RESPONSE AMBULANCE SERVICE, INC.
defendant,
EASTERN NEW MEXICO MEDICAL CENTER INC.
defendant,
MOTION FOR A COURT APPOINTED ATTORNEY
Your Honor, I am being harmed mentally over this case. It is easy for the defendants attorneys nothing happened to them, they are not emotionally involved in this case like I am. I have SEVERE mental disabilities and this case is making it so much worse. Each and every time I open this case to work on it, I am FLOODED with memories of what was done to me.
I am having what can easily be medically documented a very hard time responding in a civil manner with decorum because these attorneys not only know what their clients have done but they are lying about it in court.
Your Honor holds me to the same standards as an uninvolved attorney with no mental health issues. This is a violation and discrimination against me.
I am perfectly capable of handling this case cognitively it is easy, come to court with the truth and I will win. I have to believe that because every thing I was taught when I was growing up like the cops are the good guys has been demolished. I have to hold on to the belief that the court will be fair. Also I do trust you in your rulings to be fair, not kind but fair. But your orders for me to ‘behave normally’ are discriminatory. Sorry.
The best and easiest solution to this if for a court to appoint me an attorney if for nothing but consolation.
While New Mexico does not have any statues insuring a court appointed attorney for the indigent there are also no statues that deny it. In abuse cases courts have given counsel to the victims. I am a victim. I am abused and this case is making me very sick mentally.
Naranjo v. Thompson: In this case, Mario Naranjo, a prisoner at Reeves County Detention Center in Texas, sued prison management for constitutional violations. The court ruled that Naranjo merited assistance from an attorney due to exceptional circumstances. When no willing lawyer was found, the Fifth Circuit held that the court had the inherent power to compel counsel to accept an uncompensated appointment1.
Douglas v. California (1963): Although primarily related to criminal cases, this landmark decision established the right to counsel for indigent defendants. It laid the foundation for subsequent cases involving civil representation.
Smith v. Bennett (1961): This case reinforced the importance of providing counsel to indigent parties in civil matters. It contributed to the evolving jurisprudence on court-appointed attorneys.
WHEREFORE
I ask the court to appoint me an attorney if for nothing but consultation. This will save the court time and money because you won’t have to deal with my messy court pleadings. This should also be done because of my health concerns about continuing this case.
Both defendants oppose this motion.
Thank you for your time.
Respectfully submitted,
Chase Xander pro se
Judge Hudson will rule against this, he believes me to be a fully capable legal representative
Re: ALL PLEADINGS
gonna sticky this cuz i will try to get you guys a lot more here. Things are coming on the horizons. These attorneys think they will win this case and get their clients off scott free. I think these attorneys are delusional.
Re: ALL PLEADINGS
STATE OF NEW MEXICO
COUNTY OF CHAVES
FIFTH JUDICIAL DISTRICT COURT
CHASE XANDER
plaintiff,
vs. Case No. D-504-CV-202300223
AMERICAN MEDICAL RESPONSE AMBULANCE SERVICE, INC.
defendant,
EASTERN NEW MEXICO MEDICAL CENTER INC.
defendant,
MOTION FOR REFERRAL TO MEDIATION
(form created by Bing AI)
COMES NOW the Plaintiff Chase Xander, by and through theirself as a Pro Se, and respectfully moves this Court for an Order referring this case to mediation, and states in support thereof as follows:
1. Introduction
This case involves a dispute between Plaintiff and Defendants regarding These latest incidents listed on the complaint and ten years of harassment and malpractice. This party believe that mediation offers a more efficient and cost-effective way to resolve this dispute compared to full litigation.
2. Benefits of Mediation
Mediation provides a neutral forum for the parties to discuss their positions and explore potential solutions. It can be a faster and less expensive way to reach a settlement compared to a full trial. Furthermore, a mediated agreement is often more likely to be satisfactory to both parties than a court-imposed judgment.
3. Suitability for Mediation
The nature of this dispute is well-suited for mediation. Because I could represent my case in a slightly less formal manner and cause me much less mental stress the kind of mental stress that puts one in the hospital.
4. Request for Referral
For the foregoing reasons, Plaintiff/Defendant respectfully requests that this Court issue an Order referring this case to mediation.
5. Selection of Mediator
This Party is willing to discuss and agree upon a qualified mediator. In the alternative, they request that the Court appoint a mediator from its approved list.
6. Conclusion
Mediation provides a valuable opportunity to resolve this dispute efficiently and amicably. Plaintiff urges this Court to grant this Motion and refer this case to mediation.
WHEREFORE, Plaintiff respectfully requests that this Court issue an Order:
Referring this case to mediation;
Directing the parties to participate in a mediation session with a qualified mediator; and
Granting such other relief as the Court deems just and equitable.
Dated: 03/20/2024
Respectfully submitted,
Chase Xander
/s / Chase Xander
COUNTY OF CHAVES
FIFTH JUDICIAL DISTRICT COURT
CHASE XANDER
plaintiff,
vs. Case No. D-504-CV-202300223
AMERICAN MEDICAL RESPONSE AMBULANCE SERVICE, INC.
defendant,
EASTERN NEW MEXICO MEDICAL CENTER INC.
defendant,
MOTION FOR REFERRAL TO MEDIATION
(form created by Bing AI)
COMES NOW the Plaintiff Chase Xander, by and through theirself as a Pro Se, and respectfully moves this Court for an Order referring this case to mediation, and states in support thereof as follows:
1. Introduction
This case involves a dispute between Plaintiff and Defendants regarding These latest incidents listed on the complaint and ten years of harassment and malpractice. This party believe that mediation offers a more efficient and cost-effective way to resolve this dispute compared to full litigation.
2. Benefits of Mediation
Mediation provides a neutral forum for the parties to discuss their positions and explore potential solutions. It can be a faster and less expensive way to reach a settlement compared to a full trial. Furthermore, a mediated agreement is often more likely to be satisfactory to both parties than a court-imposed judgment.
3. Suitability for Mediation
The nature of this dispute is well-suited for mediation. Because I could represent my case in a slightly less formal manner and cause me much less mental stress the kind of mental stress that puts one in the hospital.
4. Request for Referral
For the foregoing reasons, Plaintiff/Defendant respectfully requests that this Court issue an Order referring this case to mediation.
5. Selection of Mediator
This Party is willing to discuss and agree upon a qualified mediator. In the alternative, they request that the Court appoint a mediator from its approved list.
6. Conclusion
Mediation provides a valuable opportunity to resolve this dispute efficiently and amicably. Plaintiff urges this Court to grant this Motion and refer this case to mediation.
WHEREFORE, Plaintiff respectfully requests that this Court issue an Order:
Referring this case to mediation;
Directing the parties to participate in a mediation session with a qualified mediator; and
Granting such other relief as the Court deems just and equitable.
Dated: 03/20/2024
Respectfully submitted,
Chase Xander
/s / Chase Xander
Re: ALL PLEADINGS
The judge will rule against this too, he is infuriatingly intrigued by me, he wants to see what i can do
Re: ALL PLEADINGS
I have been so slacking here, i really want to give ANY pro se the POWER they need to WIN.
We will be moving to a new site soon, maybe AmericanMedicalResponse.org?
the next site will be HUGE, of course what we have here already then so very very very much more <3
STATE OF NEW MEXICO
COUNTY OF CHAVES
FIFTH JUDICIAL DISTRICT COURT
CHASE XANDER
plaintiff,
vs. Case No. D-504-CV-202300223
AMERICAN MEDICAL RESPONSE AMBULANCE SERVICE, INC.
defendant,
EASTERN NEW MEXICO MEDICAL CENTER INC.
defendant,
MOTION FOR CLARIFICATION
Your Honor, I feel as I stated in my complaint that I intended to use a 10 year pattern or practice from
the defendants as a big part of my case. Pattern-or-Practice Case Law and Legal Definition
Pattern-or-practice case means a lawsuit, often a class action, in which the plaintiff attempts to show
that the defendant has systematically engaged in discriminatory activities. Also that such engagement in
discriminatory activities was especially by means of policies and procedures. Typically, such a case
involves employment discrimination, housing discrimination, or school segregation. A plaintiff needs to
show that a defendant's behavior forms a pattern of actions or is embedded in routine practices;
however, inferences of executive or official complicity may be drawn from a consistent failure to
respond to complaints or implement corrective measures.
I also understand that the Chaves County Sheriffs are (not yet) involved in this case or any other, tho
they participated in the defendants pattern of malpractice.
Yet any time I try and use the decades of abuse as a show of pattern or practice, you dispute my ability
to do this. I do not understand. Please clarify.
I also do not understand how you can claim they ambulance has a right to protect their self from ME
when it was THEM who started the abuse, they come with a full county of back up BEFORE I ever
even thought of suing them. It is me who needs protected against them, and I believe that the case I
settled in federal court against the sheriffs is evidence of their participation in the decade of pattern of
practice. Please clarify.
I also believe you have been accusatory against me almost claiming I have sued everyone multiple
times, and warned me how the defenses in my cases have to hire attorneys as they did the single time I
sued the ambulance before then let it dismiss. I think I saved them a LOT of money by now winning 1
million over what they did to me. Also Your Honor to be clear many of those cases were consolidated
and moved to federal court where I settled. I believe that all those cases only prove my inexperience
when I started. I would hope I am better now.
I have extensively studied the use of a pattern of practice in a court room. I believe I have every right to
do it, and I believe I can mention unnamed conspirators (chaves county sheriffs and the city of roswell)
in my evidence.
WHEREFORE
I ask the Court to clarify why I am unable to use the defense's AMR pattern of malpractice and their
conspiracy for harassment/malpractice with the sheriff’s.
We will be moving to a new site soon, maybe AmericanMedicalResponse.org?
the next site will be HUGE, of course what we have here already then so very very very much more <3STATE OF NEW MEXICO
COUNTY OF CHAVES
FIFTH JUDICIAL DISTRICT COURT
CHASE XANDER
plaintiff,
vs. Case No. D-504-CV-202300223
AMERICAN MEDICAL RESPONSE AMBULANCE SERVICE, INC.
defendant,
EASTERN NEW MEXICO MEDICAL CENTER INC.
defendant,
MOTION FOR CLARIFICATION
Your Honor, I feel as I stated in my complaint that I intended to use a 10 year pattern or practice from
the defendants as a big part of my case. Pattern-or-Practice Case Law and Legal Definition
Pattern-or-practice case means a lawsuit, often a class action, in which the plaintiff attempts to show
that the defendant has systematically engaged in discriminatory activities. Also that such engagement in
discriminatory activities was especially by means of policies and procedures. Typically, such a case
involves employment discrimination, housing discrimination, or school segregation. A plaintiff needs to
show that a defendant's behavior forms a pattern of actions or is embedded in routine practices;
however, inferences of executive or official complicity may be drawn from a consistent failure to
respond to complaints or implement corrective measures.
I also understand that the Chaves County Sheriffs are (not yet) involved in this case or any other, tho
they participated in the defendants pattern of malpractice.
Yet any time I try and use the decades of abuse as a show of pattern or practice, you dispute my ability
to do this. I do not understand. Please clarify.
I also do not understand how you can claim they ambulance has a right to protect their self from ME
when it was THEM who started the abuse, they come with a full county of back up BEFORE I ever
even thought of suing them. It is me who needs protected against them, and I believe that the case I
settled in federal court against the sheriffs is evidence of their participation in the decade of pattern of
practice. Please clarify.
I also believe you have been accusatory against me almost claiming I have sued everyone multiple
times, and warned me how the defenses in my cases have to hire attorneys as they did the single time I
sued the ambulance before then let it dismiss. I think I saved them a LOT of money by now winning 1
million over what they did to me. Also Your Honor to be clear many of those cases were consolidated
and moved to federal court where I settled. I believe that all those cases only prove my inexperience
when I started. I would hope I am better now.
I have extensively studied the use of a pattern of practice in a court room. I believe I have every right to
do it, and I believe I can mention unnamed conspirators (chaves county sheriffs and the city of roswell)
in my evidence.
WHEREFORE
I ask the Court to clarify why I am unable to use the defense's AMR pattern of malpractice and their
conspiracy for harassment/malpractice with the sheriff’s.