MOTION FOR A PERMANENT INJUNCTION

CaseNo.
The First Judicial District Court of the State of Nevada, In andfor Carsoncity.

Comes now the Movant in the above entitled matter and respectfullysubmits this Motion for a Permanent Injunctive relief from thiscourt.

The facts which have given the movant cause for seeking this relief are as follows:

On, December 24, 2015, at approximately, 3:00 PM, the movant was motioned by two agents of the Carson City Police Department, to pull off of vehicular traffic with her 1993 Toyota Forerunner, at Stewart and Long Streets. Upon doing so, the agents informed her that they intended to issue a moving violation citation for, operating a motorized vehicle without a current valid driver license, fictitious registration platesand for no insurance. When the movant explained the situation and offered her cooperation with the matter, the agents made threats that unless the movant greed to having the vehicle impounded by them and accepted their citation, she would be arrested. These agents refused tocommunicate and be of assistance when the movant attempted to communicate with them in her reasonable nature.

The following is the movant’s anecdotal account of the situation andwhy she believes her motion should begranted:

The motor vehicle in question, a 1993 Toyota Forerunner, VIN#jt3vn39w5p0125817, has been rendered a vital necessity for themovant in maintaining her chosen way of life by having established her rustic rural inhabitant of 20+ years in Storey County, Nevada outside the township of Virginia City, Nevada. Additionally, the movant has been an established Nevada resident since 1979, starting at 19 years ofage.

Movant lost out on her DMV standing when due to her permitting a local automotive repair shop to perform minor welding upon her 1988 FordRanger failed to unhook the wiring harness to the alternator before performing the welding caused gradual yet progressive damage to her Ranger. At this same time, the movant was awaiting a QDRO settlement.

Further, the movant is unable to register or re-establish her Nevada driver’s license unless permitted reasonable means and time to do so. Movant is not in control of Nevada dmv, or other regulatoryconstraints not permitting reasonable time for the persuit andrestoration
of this vitalmeans.

Such constraints gravely interfere with andthreaten
The movants continual means for self preservation of an alreadyreasonably established and preserved meaningful way of life unique to eachindividual unique character as is seen in the movants case. Inspite of setbacksand
challenges which come with such rural based living, the movant hasalways persevered in restoring full independence in remaining free to live out her individual values which gohand-in-hand.

Therefore, the movant seeks prayer of relief from the court to restore this vital right by ordering that movant be fully exonerated of impound vehicle fees and her vehicle being restored to her possession.

Further the movant requests that the court order the Nevada dmv director to grant movant a moving permit as necessary until the Storey County court makes a ruling on granting movant a title of ownership of thevehicle
in question, and, the vehicle in questioned becomes registered so that the movant can be restored her Nevada driver’slicense.
This includes nv dmv be ordered to allow movant to use the vehicle in question after it is registered in order for the movant to use it for the physical aspect of the Nevada Driver’s License test in order to restore her vitaldl.

As to the question of title ownership. Because this is actively a unresolved civil matter between two private parties it was inappropriate for the acting police agency to impound the vehicle on the grounds of ownership, as they claimed to the movant. 

This therefore remains a civil matter between the movant and the Storey County Justice Court where she has filed for a bonafide title to the vehicle which had already been in her possession upon her land. 

Therefore, disrupting a private party court action therefore, it is not a police criminal matter. But it is an ex post facto action violating the movant’s rights to her right to pursue her legal dtanding in order to secure a personal possession.

There's also the question of civil latches with regards to the prior owner having not raised an issue since the transaction was settled between them and the movant as to the squared away transaction between they and the movant of the vehicle. The prior owner of the vehicle would had to had raised that question on their own recognizance for it to be a valid counter claim. 

The police cannot serve as counter claimants in the matter. SO the question as to prior title is MOOT. The prior title holder cannot be treated as a party to this dispute, nor to the movant applying for a grant of title due to a lost title or Bill ofSale.

This recent interference by police impounding the movant’s vehicle in question, also poses obvious unreasonable, undue hardship situation for the movant. As, the movant’s habitation is 20 miles out of locationwhere police had left her stranded on a snowy Christmas eve from her rightfully acquired vehicle, habitation, and the rightful enjoyment of her personal effects. In spite of certain types and their notions, the movant has a life to return to. Homeless shelter is not an acceptable compensationfor such a vital loss. Someone like the movant views a vehicle asa
vital commodity and not as a luxury to be taken for granted. In thesame way the movant doesn't take for granted using 200 gallons of water she acquires by using her watertrailer.

Most around the planet go through 200 gallons in a matter of hours.The same amount lasts the movant three months used effectively to meet her weekly and daily vital needs. Further, the movant had been utterly interfered with having owned the vehicle over one yearnow
with regard to movant having already invested the required usual ongoing skilled maintenance and care for it herself. This is a further testament as to the character of a multi skilled person and her many life skills acquired as part of the life long process of her continued pursuits ofan authentically multi-skilled no frills way of life as required andenjoyed by her perusing self reliant rural living as requiredtoday.

It's often been the case that persons throughout history had to separate themselves from mainstream society in order for them to be able to properly pursue the challenges required in order for themselves to become multi-skilled. This same factors of reliable life-long knowledge andabove average, highly skilled experience cross applies with regards to the movant’s manner in which her in operating a motorvehicle.

Further, unless immediate relief of returning the vehicle to movant and waiving the impound costs, as well as the other citations issued her by the respondents, the movant faces further loss of her rightful private possession and will be forced, on top of paying already settled $ 200 court fine in the Sparks Justice Court,, paying another additional $300 to some unknown person with a suitable vehicle to take her and what remains of her tools, groceries, etc waiting withinthe
vehicle in question to her establishedhabitation.

Therefore movant prays this court rend this matter in the movant’sfavors asnoted.

Movant toAction MariaMetko
C/o EasyMail
550 N.MacCarranBlvd Sparks, Nevada89431 775-276-3233

POINTS ANDAUTHORITIES

Reflective of the depraved state of civil liberties over the past 100 years, upon this continent as well as abroad, and especially with regards to the rights of non affluent persons in general, there seems to be a great lack of strong and meritorious precedent that's reflective of genuinely meet the criteria designed to protect the most crucialfreedoms, and, what remains instead is plainly unfit to truly be used as primary authority regarding the elements raised within the movant’s cause of action for a Preliminary Injunction being sought by themovant.

As a result, and to her knowledge, the movant has no choice but touse precedents of original intent as laid out by the founders of theU.S.
Constitution as well as the Federalist andAnti-federalist
works aka., John Q. Public. as a means to persuade this court tocorrect action.

The respondents, aside from the Nevada DMV woes, and under the color of authority, attempted to make a baseless claim as to the movant’sownership of her vehicle. They've done this by attempting to create an ex postfacto condition as to her acquiring the vehicle, which is her right to do so, proof of bill of sale or lost title is irrelevant. Nine- tenths of thelaw is the possessionitself.

And, therefore, the movant was in proper possession of the personaleffect of the vehicle in question when it was unlawfully, forcefully under threats, stolen from her under the color of someone's authority as a public official in the distinction of a militarized policeforce.
This action against the movant was, therefore, done complicity in sort against the movant, being as there was no criminal element involvingthe movant in their obtaining and retaining possession of theirvehicle.

This makes it necessary for any soundly reasoned person to concludepolice intended by their own actions to knowingly overreach their constitutionally limited bounds by baselessly interfering alone based upon, as they police agents admitted to the movant themselves, an already resolved civil transaction they had no direct knowledge about, save the vehicle was in the movant’s possession, and, that that very transaction took place over one year ago, between two privatepartieIt appears, therefore, that they [ police ] have confiscated thisvehicle in order to deprive another by use of a pervertedrationale
of their own making. It also appears that to these acting agents thatthe written law on licensure and registration only served as their too convenient pretextural for them to carry out this wrongful actiontowards themovant.

This type of situation is exactly why the foundations of theoriginal intent behind the USC and expressly the Bill of Rights therein init, strictly curtails the powers of the three branches VERY SPECIFICALLY against these types of encroachments involving private citizens inalienable rights. Rights, both, in minor and gross contexts and definitions. The Declaration of Independencealone,
is what layed down the basis for any constitutional foundation to everbe formed for this very reason and the hairspliting and often baseless notions against personal effects were put to restthen.

The only exception to this consideration is those who act within a bona fide criminal context and element, of which the movant is certainlynot. And, such factors would of already establish themselves over an entire lifetime pattern had it been the case ofcriminality.

Criminal siezure, rules of evidence. police jurisdiction and civil matters. dirty hands and acting in good faith. Police admittedly hadprior knowledge as to the hardship of movant losing her investment so police could deprive her person of something she works harder than most within her chosen rural niche to worthilykeep.

Further, this impound took place right on Christmas eve to steal from one of genuine need to be auctioned off to someone who has what they already need. The movant was threatened and made to feel like scuwith threats of arrest. What respectable person wouldn't be rightfully insulted just by that alone ? Add, that the movant was treated overtly rude whenquestioned by police by baseless threats of arrest while she making civilized attempts to update and clarify the Nevada dmv related situation and the recent court disposition. Movant was told that unless she agreed to citation and impound of the vehicle, she'd be arrested. She was left stranded, vehicle and vital possessions like tools, groceries for home etc., impounded. Peace officers ? Lawmen?

Police knew everything about it all in advance ofinterfering
with the movant. Therefore, these particular ones had only one intention in order to impress themselves, as well as their demented associates.Same police made the inference to movant that they, police, lived the same rigourous and rugged rural folk life the movant has chosen most her life but that they have a job and not a pension as the movant does.
Lack of probable cause of crimes - Such a search or seizure is unconstitutional under the Fourth Amendment (applied to the states by the Fourteenth Amendment), and evidence obtained from the unlawful searchmay not be introduced in court. (See also: fruit of the poisonoustree)

The movant properly used a light waterproof vestibule to keep out inclement forces due to an intermittent malfunction of her tailgate window. As, she'd intended to fix it within the familiarity ofher resources in the order of priority of other matters as she reliably deems fit. This is a private civil matter, and not apolice safety issue.

The use of an expired LP off of an abandoned vehicleleft
at movant’s habitation was used by her not to engage in acts to bringharm but to avoid being vulnerable to what she felt were nuisance pull oversby police - as she openly claimed to police and even recently established suitable acquaintances she met at local merchant stops during her monthly errands over the past year. As, she sensed '' people, including cops, knew it anyways.

I acknowledged it with others, they handled it fine,no one made a nuisance of it nor did anybody put a big sign out about it either. '' I didn't perceive anything ill spirited about it in either direction. I only intend to live a life in meeting my vitalneeds
and comfort, just to be a happy person (distinct persona) and all those around me.''

There's a difference between a person breaking the written law whenthey have absolutely no reason to do what's reasonable to follow it, versusa written law being used somehow in order to prevent one from followingit in order to keep one from accessing a vital right claimed protected by such written laws. Written laws that fail to pass such tests were meant to be unconstitutional by their very nature when the means alone whiare used to enforced them violates vital rights of those they are enforced against.

In this case, the written law is being used by those whose only intention it is to covet another’s belongings which they acquired through a discounted monetary compensation from another as an act of generosity towards the movant.

FOOTNOTE
This likely ties into the four rats, one of them on the new storeycounty police had incriminated themselves in their field report by tying themselves in with the primary suspects who were thwarted by my personas a private wilderness ranger from committing nuisance trespass and vandalism upon the land land when they thought I'd be away from my habitation at 'church service, etc 'When I later tied them in with the others, a few months later my habitation was severely burglarized, outright. I've kept regular field reports as well as other records inthe capacity of a private wilderness ranger and land manager over thepast
20 years. Although, much of the corroborating evidence has beensubverted by various means of espionage type theft against my person, I recognize that it's still just as valid to cite and use especially due to the sabotage which only serves as further confirmation as to the facts known tome.

Movant, Maria Metko, c/o Easymail
550 N. MacCarran Blvd Sparks, Nevada89431
775-276-3233

mariametko@gmail.com