Defendant's Response To State's Motion To Quash Subpoena Duces Tecum 29apr09 Faxed
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PREVIOUSLY FACSIMILED TRANSMISSION ON 29APR09 STATE OF INDIANA
COUNTY OF MARION
STATE OF INDIANA, Plaintiff, vs.
)
IN THE MARION COUNTY SUPERIOR COURT
) SS:
CRIMINAL DIVISION F08
)
CAUSE NO. 49F08-0811-CM-254608
) ) ) )
KAY KIM,
) Defendants.
)
DEFENDANT’S RESPONSE TO STATE'S MOTION TO QUASH SUBPOENA DUCES TECUM
Comes now the Defendant, Kay Kim, Pro Se filed her Defendant’s Response to State's Motion to Quash Subpoena Duces Tecum Filed on April 28, 2009 on this 29th Day of April 2009 as follows and not limited to: Deputy Prosecutor Andrew Wignall stated in his motion as follow: “Rule 2….. the court to quash or modify the subpoena…. and it is unreasonable and oppressive…… WHEREFORE, …..the Defendant’s Sub Duces Tecum be quashed.” 1.
Deputy Prosecutor Andrew Wignall failed to state what exactly he wants the court
to quash. 2.
There is no such law allow either State of Indiana/Deputy Prosecutor Andrew
Wignall or Defendant(s) request abstractly to quash only to provide cause no.
Page 1 Of 2 IN CM4 Def RESPONSE to State's Mot to Quash Subpoena Duces Tecum CM254608 FILED-28APR09 29APR09 faxed
PREVIOUSLY FACSIMILED TRANSMISSION ON 29APR09 3.
When Deputy Prosecutor Andrew Wignall failed to state as described above in
line 1 & 2, his reciting of Rul2 or 2000 does not matter as to MOOT. 4.
There is no law allow in any levels courts the way Deputy Prosecutor Andrew
Wignall to request Quash the Defendant’s Subpoena Duces Tecum. WHEREFORE, Defendant Kay Kim, Pro Se respectfully requests that the Court to take appropriate action against the Deputy Prosecutor Andrew Wignall with its own motion. Respectfully submitted Dated: April 29, 2009
By: Kay Kim, Pro Se CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been delivered to the court F8 and prosecutor (‘box by F8 clerk) either by U.S. First Class Mail, FAX or server.
Kay Kim, Pro Se 4250 Village pkwy c e apt2., Indiana polis, IN 46254 Tel# 317-641-5977 DISTRIBUTION: Prosecutor: NW Dist outgoing box in F08 Special Judge F08:ph317-327-3202, Fax317-327-1432, clk317-327-5665
ref 1:
Special Judge Judith S. Proffitt E643 City-County Building 200 East Washington St., Indianapolis, IN 46204 f8clk 317-327-5665/3202, f8f# 317-327-1432
ref 2:
Andrew Wignall, Deputy Prosecuting Attorney, NW Dist. 3821 Industrial Blvd., Indianapolis, IN 46254., P#317-327-6652, Page 2 Of 2 IN CM4 Def RESPONSE to State's Mot to Quash Subpoena Duces Tecum CM254608 FILED-28APR09 29APR09 faxed
COUNTY OF MARION
STATE OF INDIANA, Plaintiff, vs.
)
IN THE MARION COUNTY SUPERIOR COURT
) SS:
CRIMINAL DIVISION F08
)
CAUSE NO. 49F08-0811-CM-254608
) ) ) )
KAY KIM,
) Defendants.
)
DEFENDANT’S RESPONSE TO STATE'S MOTION TO QUASH SUBPOENA DUCES TECUM
Comes now the Defendant, Kay Kim, Pro Se filed her Defendant’s Response to State's Motion to Quash Subpoena Duces Tecum Filed on April 28, 2009 on this 29th Day of April 2009 as follows and not limited to: Deputy Prosecutor Andrew Wignall stated in his motion as follow: “Rule 2….. the court to quash or modify the subpoena…. and it is unreasonable and oppressive…… WHEREFORE, …..the Defendant’s Sub Duces Tecum be quashed.” 1.
Deputy Prosecutor Andrew Wignall failed to state what exactly he wants the court
to quash. 2.
There is no such law allow either State of Indiana/Deputy Prosecutor Andrew
Wignall or Defendant(s) request abstractly to quash only to provide cause no.
Page 1 Of 2 IN CM4 Def RESPONSE to State's Mot to Quash Subpoena Duces Tecum CM254608 FILED-28APR09 29APR09 faxed
PREVIOUSLY FACSIMILED TRANSMISSION ON 29APR09 3.
When Deputy Prosecutor Andrew Wignall failed to state as described above in
line 1 & 2, his reciting of Rul2 or 2000 does not matter as to MOOT. 4.
There is no law allow in any levels courts the way Deputy Prosecutor Andrew
Wignall to request Quash the Defendant’s Subpoena Duces Tecum. WHEREFORE, Defendant Kay Kim, Pro Se respectfully requests that the Court to take appropriate action against the Deputy Prosecutor Andrew Wignall with its own motion. Respectfully submitted Dated: April 29, 2009
By: Kay Kim, Pro Se CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing has been delivered to the court F8 and prosecutor (‘box by F8 clerk) either by U.S. First Class Mail, FAX or server.
Kay Kim, Pro Se 4250 Village pkwy c e apt2., Indiana polis, IN 46254 Tel# 317-641-5977 DISTRIBUTION: Prosecutor: NW Dist outgoing box in F08 Special Judge F08:ph317-327-3202, Fax317-327-1432, clk317-327-5665
ref 1:
Special Judge Judith S. Proffitt E643 City-County Building 200 East Washington St., Indianapolis, IN 46204 f8clk 317-327-5665/3202, f8f# 317-327-1432
ref 2:
Andrew Wignall, Deputy Prosecuting Attorney, NW Dist. 3821 Industrial Blvd., Indianapolis, IN 46254., P#317-327-6652, Page 2 Of 2 IN CM4 Def RESPONSE to State's Mot to Quash Subpoena Duces Tecum CM254608 FILED-28APR09 29APR09 faxed
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