Brief - Appellant (1).pdf 00000000000001

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IN THE
INDIANA COURT OF APPEALS
Cause No. 21A-CT-02309
PASTOR MARIO SIMS, )
Plaintiff, )
)
v. ) CAUSE NO.: 71C01-2109-CT-3...

Brief of Appellant Pastor Mario L. Sims
TABLE OF CONTENTS
TABLE OF AUTHORITIES...............................................

Brief of Appellant Pastor Mario L. Sims
upon a on nonexistent motion to dismiss, raising two affirmative
defenses for the ...

Brief of Appellant Pastor Mario L. Sims
TABLE OF AUTHORITIES
Cases page
A.N. v. K.G., 3 N.E.3d 989 (Ind. Ct. App. 2014), a...

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Brief of Appellant Pastor Mario L. Sims
Other authorities:
Article 7, Section 4 of the Indiana Constitution..................

Brief of Appellant Pastor Mario L. Sims
STATEMENT OF ISSUES
I. The trial court's findings of collateral estoppel law of th...

Brief of Appellant Pastor Mario L. Sims
STATEMENT OF THE CASE
Course of proceedings
Plaintiff Pastor Mario L. Sims (Sims) ...

Brief of Appellant Pastor Mario L. Sims
of state and federal constitutions, ethical violations and of commissions of crime...

Brief of Appellant Pastor Mario L. Sims
the Trial Court, inexplicably, entered the following:
Order
“This Court has review...

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Brief of Appellant Pastor Mario L. Sims
Decision 20A-CT-2390 Brief of Appellant Pastor Mario L. Sims of April 14, 2021,
va...

Brief of Appellant Pastor Mario L. Sims
“new” element as set out in the proposed Verified Complaint is the conduit of thes...

Brief of Appellant Pastor Mario L. Sims
to the church.
3. Shortly after her call she arrived at the church with a camerama...

Brief of Appellant Pastor Mario L. Sims
immediately.
6. As she left, she advised Pastor Sims to hold off for at least a we...

Brief of Appellant Pastor Mario L. Sims
9. Reporter Alexis Rivas Shear stated it was okay though for Pastor Sims
to act on...

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Brief of Appellant Pastor Mario L. Sims
incurred damage to his reputation and been publicly humiliated by
people identifyi...

Brief of Appellant Pastor Mario L. Sims
17.At this time, it is difficult to determine the full extent of the damages
my/ou...

Brief of Appellant Pastor Mario L. Sims
their request, Pete Buttigieg, Mike Schmul as then Mayor Buttigieg's
Chief of Staf...

Brief of Appellant Pastor Mario L. Sims
racist. Corbett has even committed perjury by denying under oath he
worked on Past...

Brief of Appellant Pastor Mario L. Sims
ARGUMENTS
Standard of Review
“[W}e presume that the trial court will ‘act in accor...

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Brief of Appellant Pastor Mario L. Sims
Sims complied with Scopelitis and the trial court was required to allow the
case t...

Brief of Appellant Pastor Mario L. Sims
The law-of-the-case doctrine mandates that an appellate court's
determination of a...

Brief of Appellant Pastor Mario L. Sims
case. Dutchmen Mfg., Inc. v. Reynolds , 891 N.E.2d 1074, 1083 (Ind. Ct. App. 2008)...

Brief of Appellant Pastor Mario L. Sims
The trial court abused its discretion as the decision is clearly against the logic...

Brief of Appellant Pastor Mario L. Sims
on October 8, 2021 pursuant to Ind. Trial Rule 55 provides: (A) Entry . When a
par...

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Brief of Appellant Pastor Mario L. Sims
mistakenly designates a defense as a counterclaim or a counterclaim as a defense,
...

Brief of Appellant Pastor Mario L. Sims
failure to answer the opposing party's counterclaim invoked T.R.8(D) and, therefor...

Brief of Appellant Pastor Mario L. Sims
default” variety. Id. at 1288.
“With respect to affirmative defenses, Indiana Tria...

Brief of Appellant Pastor Mario L. Sims
or where the trial court has misinterpreted the law.” Skeffington v. Bush, 846
N.E...

Brief of Appellant Pastor Mario L. Sims
motion (as shown above the 9 defendants counsel admits they were aware of the
comp...

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Brief of Appellant Pastor Mario L. Sims
VI. In taking the acts above the St. Joseph County Circuit Court violated
numerous...

Brief of Appellant Pastor Mario L. Sims
Code of Judicial Conduct provision stating that a judge shall disqualify himself o...

Brief of Appellant Pastor Mario L. Sims
Respectfully submitted;
/s/Johnny W. Ulmer
Johnny W. Ulmer #2737371
Ulmer Law Offi...

Brief of Appellant Pastor Mario L. Sims
CERTIFICATE OF FILING AND SERVICE
The undersigned hereby certifies that we electro...

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