BANSC-RE-2010-187-Defendants Proposed Order n Cert

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STA TE O F MAIN E

CIVIL

COUNTY OF PENOBSCOT

SU PER IO R D IST RIC T COURT

TD BANK N .A . fjkja FIRST

M AS SA CH US ET TS B AN K N .A .

Plaintiff

Case No .: BANSC -RE -2 0 10 -1 87

Judge:

INJUNCTIVE RELIEF SOUGHT

[P RO PO SED ORDER ]v.

J URY TRIA L DEMANDED

[Filed concurrently the following: Notice of

Motion, Defendant's Separate Statement of

Undisputed Facts, Motion to Disqualify Opposing

Counsel, Defendants Objection to Plaintiffs

Witnesses, Affidavits and Exhibits Incorporated

Motion to Strike and Memorandum of Law,

Defendant Twila A. Butler f/k/a Wolfs SwornAffidavit of Fact, Defendant's Motion For

Compensation For Time Incorporated

Memorandum of Law, Supporting Exhibits On

Defendant's Objection to Plaintiffs Motion to Lift

Stay and Motion for Final Judgment Incorporated

Motion for Sanctions, Declaratory and Injunctive

Relief and Memorandum of Law. [Proposed Order

Granting Defendants Motion]

TW lLA A. BUTLER fjkja WOLF

AND

CH AR LTO N A. B UTLE R JR. pro seso

~-. . . .

c r : s

§@

Defendant

and

Defendant-Intervenor.

Date of Hearing: _

Time of Hearing: _

U ! R O P O S E D 0 R U J ; :R l

D efe nd an ts O bje ctio n O f A nd M otio n T o S trike P la in tiff's A ffid avits, W itn ess es , A nd E xhibits.



ST AT E O F M AIN E

CIVIL

COUNTY OF P ENOB SCOT

SU PERIOR D IST RIC T COURT

Order Granting Motion of Defendants Twila A. Butler fjkja Wolf and Charlton A. Butler

Jr. for:

PlanA: _

A: Permanent Declaratory and Injunctive Relief as follows: Plaintiffs and their

counsel are further prohibited for the present, now and at any point in the future,

forever and a day, and restrained from taking any further or new action against

Defendants Twila A Butler or Charlton A. Butler [r., their heirs and assigns or anyone

they may; or may not, sell, give, transfer or otherwise convey the deed and title to said

property located at 44 Patten St. Bangor Maine 04401.

B: That for the record, declared openly as such, and published, as so that the

word and deed of Perkins Thompson Attorneys are circumspect and that any matter

before the bar of any court in the state of Maine Federal or State, they may have or will

have in the future, should receive the most detailed of scrutiny." That the entire State of

Maine have it known and the State's Judicial System, State and Federal, shall know that:

"Any actions involving Perkins Thompson Attorneys be given extra attention and

scrutiny and that Perkins Thompson Attorneys be required to show, demonstrate or

otherwise prove up any and all claims they may make against any adversary, in any case,

and are complying with, the complete and total adherence to, both letter and spirit, all

applicable state and federal laws, before any judgment or prevailing ruling be given or

D efe nda nts O bje ctio n O f A nd M otio n T o S trike P la intiff's A ffida vits , W itn es se s, A nd E xhibits .



ST ATE O F M AIN E

CIVIL

C OU NT Y O F PE NO BSC OT

SU PE RIO R D IST RIC T C OU RT

granted; in any case they may bring or are currently bringing before the bar in any court,

State ofMaine, Federal Court or otherwise.

C: The Court Moves and Directs the District Attorney for the County of

Penobscot to investigate and to bring criminal indictments for the crimes that are prima

facie declared openly here.

PlanB: _

A: Declaratory and Injunctive Relief as follows: Plaintiffs and their counsel are

further prohibited and restrained from taking any further or new action against

Defendants Twila A Butler or Charlton A.Butler [r., their heirs and assigns until and only

then, if then, any and all claims they, Defendants, have against Plaintiffs, have been

settled and disposed by the court, in Federal District and/or State Court, concerning title,

in any way, to, said property located at 44 Patten St. Bangor Maine 04401.

B: That for the record, declared openly as such, and published, as so that the

word and deed of Perkins Thompson Attorneys are circumspect and that any matter

before the bar of any court in the state of Maine Federal or State, they may have or will

have in the future, should receive the most detailed of scrutiny." That the entire State of

Maine have it known and the State's Judicial System, State and Federal, shall know that:

"Any actions involving Perkins Thompson Attorneys be given extra attention and

scrutiny and that Perkins Thompson Attorneys be required to show, demonstrate or

Defe nd an ts Ob je ctio n O f A nd Mo tio n T o S trik e P la in tiff's A ffid av its , W itn es se s, A nd E xh ib its .



STAT E O F M AINE

CIVIL

COUNTY OF P ENOB SCOT

SU PE RIO R D IST RIC T C OU RT

otherwise prove up any and all claims they may make against any adversary, in any case,

and are complying with, the complete and total adherence to, both letter and spirit, all

applicable state and federal laws, before any judgment or prevailing ruling be given or

granted; in any case they may bring or are currently bringing before the bar in any court,

State ofMaine, Federal Court or otherwise.

C: The Court Moves and Directs the District Attorney for the County of



PlanC:, _

A: Injunctive Relief as follows: Plaintiffs and their counsel are further prohibited

and restrained from taking any further or new action against Defendants Twila A Butler

or Charlton A. Butler [r., their heirs and assigns until and only then, if then, any and all

claims they, Defendants, have against Plaintiffs, have been settled and disposed by the

court, either in Federal District and/or State Court, concerning title, in any way, to, said

property located at 44 Patten St. Bangor Maine 04401.

B: The Court Moves and Directs the District Attorney for the County of



D efe nd an ts O bje ctio n O f A nd M otio n T o S trike P la in tiff's A ffid av its , W itn es se s, A nd E xh ib its .



CERTIFICATE OF MAILING

I hereby certify that I have this day served the foregoing document upon the parties of record in thisproceeding set forth below (by delivering a copy thereof in person) and/or (by mailing a copy thereof,

pre-paid and properly addressed by first class mail).

Perkins Thompson Attorneys:

Stephanie A. Williams

David B. McConnell

One Canal Plaza

P.O. Box 426

Portland Me. 04112-0426

Paul NiklasAssistant City Solicitor

for the City of Bangor Maine.

73 Harlow St.

Bangor Me. 04401

DATED this day of 29th , 2012.

Signature

Charlton A. Butler Jr. Defendant-Intervenor

BANSC-RE-2010-187-Defendants Proposed Order n Cert

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