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DKH111411 SECURITY - 15 USC THIS IS A U.S.S.E.C. TRACER FLAG, NOT A POINT OF LAW*

District court for the United States In Care of THE UNITED DISTRICT COURT DISTRICT OF Pennsylvania for the Eastern District DEREK KIMBALL HAIRSTON Sramineus Homo, US Vessel Plaintiff 

)

Case # 11-cv 04152 ) Within the Admiralty

) ) V. ) ) MANUFACTURES AND TRADERS TRUST ) COMPANY, US Vessel ) ) US Vessel and ) DOES, ROES, and MOES 1 -100 et al ) Defendants )  ___________________________________________  _______________________________________ ____ ) Derek Kimball; Hairston, ) Lien Holder of the Vessel, the Real Party ) In Interest, Lawful Man ) Injured Third Party Intervener/Petitioner ) /Libellant ) ) V. ) ) MANUFACTRES AND TRADERS TRUST ) COMPANY, US Vessel And ) DOES, ROES, and MOES 1 -100 et al ) US VESSELS- CORPORATION, ) INDIVIDUALLY ) This website stores data such as AND SEVERALLY Third Party Defendants/Libellees ) cookies to enable essential site ) functionality, as well as marketing,

personalization, and analytics. You PLAINTIFF’S MOTION FOR SUMMARY SUMMARY JUDGMENT JUDGMENT may change your settings at any time or accept the default settings.

The so-called, defendant DEREK KIMBALL HAIRSTON (“Derek Kimball Hairston Privacy Policy Real Party in Interest Living, Breathing, Man, Blood Flowing through his veins”) is/was

under injury at all times by and through its acts of counsel Klehr, Harrison, Harvey & Marketing Branzburg LLP, and Manufactures and Traders Trust Company. Personalization Analytics Save

1. Defendant’s Defendant’s nor its its counsel counsel has ever rebutted rebutted any Affidavi Affidavitt submitted submitted by Plaintiff Plaintiff.. Accept All

 

2. Defendant’s Defendant’s and and its counsel counsel operate operate under limit limited ed liability liability has has at all times times stultified all filings by defendant and lied. 3. Plaintif Plaintiff, f, does not not understand understand nor ever understood understood the the position position taken taken by Defendant’s and their counsel all documents/instruments filed by Plaintiff  were/are lawful as well as legal. 4. Defendant’s Defendant’s counsel counsel denies denies my last last filing filing which which is contrary contrary to the the Comptroller Comptroller of  the Currency Defendant’s as well as its counsel committed gross fraud upon u pon Real Party in Interest, it is well founded in the record both in Montgomery County and Delaware County as well as this court, as none no ne has plausible deniability. 5. The record record is clear clear as it stands stands Defendant Defendant’s ’s and its its counsel counsel committed committed ultra ultra vires acts against the defendant and acted way outside of their corporate charters. 6. The jju udge may or may have not committed treason, but has failed and/or refused to fully research the facts of the entire case in all so-called jurisdictions as established in this case. 7. The The reco record rder er of of deed deedss erred when she followed the order of Idee C. Fox, judge of  court of common pleas of Philadelphia County to strike the lien on the Real Party in Interest Property as described in the record. 8. And And at all all time timess the the defend defendan antt Violated, both federal/state laws as well as Real  party in Interests rights under the law at all times. 9. I Jur Jurisd isdic ictio tion n Gen Gener erall ally y 10 10.. A. Cons Consti titu tuti tion onal al and and St Stat atut utor ory y Base Basess of Am Amer eric ican an Mar arit itim imee Law Law 11. -§ 2, Art. III of Const.: The judicial Power Power shall extend to all Cases . . . of 

admiralty and maritime Jurisdiction

This website stores 12. dataa)such Hasas been interpreted to allow allow federal sovereign the power tto o prescribe the cookies to enable essential site cou rt functionality, as well as substantive marketing, law in maritime cases pending in federal court -Federal state law in maritime maritime cases personalization, and13. analytics. Youlaw preempts any state may change your settings at any timeary Act of 1789 enacted maritime 14. -First Judiciary Judici maritime jurisdiction statute: or accept the default settings.

15. The distri district ct cour courts ts shall shall have have origin original al juri jurisdi sdicti ction, on, excl exclusi usive ve of of tthe he cour courts ts of the States, of: Privacy Policy 16. (1) Any civil civil case case of of admira admiralty lty or mar mariti itime me jurisd jurisdict iction ion,, savi saving ng to sui suitor torss in all cases all other remedies to which they are otherwise entitled. Marketing 17. (2) Any prize prize brough broughtt into into the United United St State atess and all proceed proceeding ingss for the Personalization condemnation of property taken as prize. Analytics Save

18. -§ 1333 generally provides federal and state courts w/ concurr concurrent ent jurisdiction to adjudicate maritime matters ( see  see “saving to suitors” clause). Accept All

 

19. -Need for for uniformity uniformity is key key 20. - In  In rem proceedings, generally actions brought against a vessel and binding against the world, are subject to exclusive federal jurisdiction b/c in rem actions were unknown at common law 21. -Federal courts generally generally have no right jury trial trial save for when created by statute, in state court, determined by state law 22. Defendant’s at all times willfully willfully misled plaintiff by misrepresenting misrepresenting the facts of  the case as in the entire record in the counties listed in the record.  

THEREFORE, Based upon the foregoing and the record, the fraud as admitted and confessed by Defendant’s, and by right and by law, plaintiff has Demanded a Maximum Cure on his behalf from this court “bar’l, bar, bar”. Plaintiff never understood this whole matter from the on-set”, Plaintiff’s, request that this Court vacate and set aside the judgment of foreclosure and subsequent sale of  the subject premises, dismiss Plaintiff’s case with prejudice, re-convey title of  subject premises to Plaintiff’s and Order all other remedy this Court deems appropriate.

November 14, 2011

Respectfully submitted,

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Derek Kimball Hairston,

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