![\"\"](\"http:\/\/stateofthenation.co\/wp-content\/uploads\/2024\/08\/Motion-to-Recuse-featured-image-1024x670-1.jpg\")
<\/p>\nJim Fetzer, Ph.D.<\/a><\/h3>\n
\n![\"\"](\"https:\/\/jameshfetzer.org\/wp-content\/uploads\/2024\/08\/Defendants-Reply-top--300x146.jpg\")
<\/p>\n
\n\u00a0 \u00a0 \u00a0 DEFENDANT\u2019S REPLY<\/strong><\/p>\nNOW COMES James H. Fetzer, Ph.D., Pro Se Defendant, with a Reply to the Response<\/p>\n
from Plaintiff\u2019s attorneys filed on July 24, 2024, to Dr. Fetzer\u2019s Motion to Recuse Judge<\/p>\n
Frank Remington Pursuant to Wis. Stats. 757.19(2)(g) filed July 9, 2024. Plaintiff\u2019s Response<\/p>\n
observes (correctly) that ruling against a party\u00a0per se<\/em>\u00a0does not require a circuit court to<\/p>\nrecuse. But this case involves conduct by Judge Remington that has been egregiously<\/p>\n
biased in favor of the Plaintiff and against Dr. Fetzer, including (most recently) repeated<\/p>\n
violations of basic due process rights under Wisconsin Rules of Civil Procedure.<\/p>\n
Plaintiff argues that Dr. Fetzer cannot meet his burden for recusal, alleging that there<\/p>\n
is not even the appearance of partiality and that there is no basis for objecting on due<\/p>\n
process grounds. Both are in blatant contradiction with Judge Remington\u2019s conduct in<\/p>\n
this case from the beginning, which Dr. Fetzer has previously documented and will (at<\/p>\n
least, in part) summarize here. All previous submissions in Case No. 18CV3122 are<\/p>\n
incorporated and adopted for the purpose of this Reply.<\/p>\n
\u00a0\u00a0\u00a0\u00a0BACKGROUND<\/strong><\/p>\nWis. Stats. Chapter 757. General Provisions Concerning Courts of Record, Judges,<\/p>\n
Attorneys and Clerks, under Section 757.19 Disqualification of judge, specifically 757.19<\/p>\n
(2) asserts,\u00a0Any judge shall disqualify himself or herself from any civil or criminal action\u00a0<\/em>\u00a0<\/em><\/p>\nwhen one of the following situations occurs: (g) when a judge determines that, for any<\/em><\/p>\nreason, he or<\/em>\u00a0she cannot, or it appears he or she cannot, act in an impartial manner<\/em><\/p>\n(emphasis added). In relation to the 26 exhibits A-Z supporting Dr. Fetzer\u2019s Motion to<\/p>\n
Open Judgment Pursuant to Extrinsic Fraud and Fraud Upon the Court filed on June 20,<\/p>\n
2024 (cited below as \u201cMOJ\u201d), Dr. Fetzer submits the following proofs of clear bias and<\/p>\n
partiality by Judge Remington, who was acting in collusion with the Pozner attorneys.<\/p>\n
ARGUMENT<\/strong>\u00a0<\/strong><\/p>\n\n- (1) Judge Remington Suppressed the Affidavit of Kelley Watt<\/strong><\/li>\n<\/ul>\n
Judge Remington\u2019s approach was to manufacture a predetermined outcome by<\/p>\n
finding that Dr. Fetzer had libeled Leonard Pozner by declaring a death certificate<\/p>\n
that Pozner himself had provided to Dr. Fetzer\u2019s research colleague, Kelley Watt,<\/p>\n
to be fake. It was done by substituting a different and complete death certificate in<\/p>\n
the Complaint. The published death certificate, unlike the substitution, had no file<\/p>\n
number nor state or town certification. Under CT law, not even parents are allowed<\/p>\n
to possess incomplete death certificates. Kelley Watt\u2019s Affidavit exposes the fraud<\/p>\n
and vitiates the case against Dr. Fetzer but was suppressed by Judge Remington in<\/p>\n
collusion with the Pozner attorneys (MOJ, Exhibits J, K, and V).<\/p>\n
\n- (2) Judge Remington Dismissed Proof that Nobody Died at Sandy Hook<\/strong><\/li>\n<\/ul>\n
Judge Remington excluded Dr. Fetzer\u2019s proof that nobody died at Sandy Hook on<\/p>\n
both legally and logically absurd grounds, when he declared that, \u201cwhether or not Sandy<\/p>\n
Hook ever happened or not is not relevant to this \u2013 the \u2013 the truthfulness or the accuracy<\/p>\n
of the death certificate\u201d. But the death certificate states the decedent died at Sandy Hook<\/p>\n
on December 14, 2012, of \u201cmultiple gunshot wounds\u201d (MOJ, Exhibit M). Once again,<\/p>\n
the proof amassed in Dr. Fetzer\u2019s co-edited book,\u00a0Nobody Died At Sandy Hook: It was a\u00a0<\/em>\u00a0<\/em><\/p>\nFEMA Drill to Promote Gun Control<\/em>\u00a0(2015; 2nd<\/sup>\u00a0ed., 2016), was inconsistent with Pozner\u2019s<\/p>\nposition, thereby producing disputed facts that, had they been admitted, required a jury.<\/p>\n
\n- (3) Judge Remington Set Aside Reports of Two Forensic Document Experts<\/strong><\/li>\n<\/ul>\n
Having restricted the issue to the authenticity or truthfulness of the death certificate<\/p>\n
and having disallowed extensive and detailed proof Dr. Fetzer had submitted in defense,<\/p>\n
Dr. Fetzer provided reports of two (2) forensic document experts\u2014Larry Wickstrom and<\/p>\n
A.P. Robertson\u2014who found not only that the incomplete death certificate published by<\/p>\n
Dr. Fetzer was fake but that the complete death certificate attached to the Complaint was<\/p>\n
also fake (along with two others obtain from the Town of Newtown and from the State),<\/p>\n
Judge Remington simply dismissed them as \u201csomeone else\u2019s opinion\u201d and said, \u201cI just<\/p>\n
don\u2019t think they were helpful\u201d (MOJ, Exhibit R, pages 163 and 165).\u00a0 Their uncontested<\/p>\n
reports (again) vitiated the case against Dr. Fetzer by proving his statements were true.<\/p>\n
\n- (4) Judge Remington denied Dr. Fetzer Discovery on his Counterclaims<\/strong><\/li>\n<\/ul>\n
To ensure that Dr. Fetzer not discover more proof of the non-occurrence of mass<\/p>\n
murder or that the decedent had not died at Sandy Hook, Judge Remington took the<\/p>\n
further step of bifurcating the case to deny Dr. Fetzer discovery on his counterclaims<\/p>\n
of Abuse of Process, Fraud and Theft by Deception, and Fraud upon the Court, a deft<\/p>\n
maneuver to cut off Dr. Fetzer\u2019s access to new evidence that might strengthen his case<\/p>\n
(MOJ, Exhibit N). This denial of Dr. Fetzer\u2019s right to discovery has now been used to<\/p>\n
claim that Dr. Fetzer had not made allegations of Fraud upon the Court in a timely<\/p>\n
manner, brought about by Judge Remington\u2019s denial of Dr. Fetzer\u2019s discovery rights.<\/p>\n
\n- (5) Judge Remington Refused to Admit Proof that Noah Pozner is a Fiction<\/strong><\/li>\n<\/ul>\n
Dr, Fetzer repeatedly advanced proof that the alleged decedent, Noah Pozner, was not a<\/p>\n
real person but a legal fiction created out of photographs of his purported older half-brother,<\/p>\n
Michael Vabner. Dr. Fetzer raised the issue by moving to expand DNA testing to include,<\/p>\n
not just Noah Pozner and Leonard Pozner, but Michael Vabner and Reuben Vabner, whom<\/p>\n
Dr. Fetzer had concluded to be the basis for \u201cNoah\u201d and for \u201cLeonard\u201d (MOJ, Exhibit O).<\/p>\n
This fact has now been substantiated by the Affidavit of Brian Davidson, P.I., who has also<\/p>\n
established that the party who testified as \u201cLeonard Pozner\u201d in Madison is not the same<\/p>\n
person as the \u201cLeonard Pozner\u201d of Sandy Hook, whose image has appeared millions of<\/p>\n
times around the world (MOJ, Exhibits W, X, and Y). This has enormous importance,<\/p>\n
not least of all because it implicates Pozner\u2019s attorneys in the subornation of perjury.<\/p>\n
\n- (6) Judge Remington Refused to Acknowledge Dr. Fetzer as a Media Person<\/strong><\/li>\n<\/ul>\n
To lower the bar for finding Dr. Fetzer liable, Judge Remington declined to rule<\/p>\n
that Dr. Fetzer had media standing as an investigative journalist, even though Dr. Fetzer<\/p>\n
had submitted a brief laying out his experience as an investigative journalist\/reporter<\/p>\n
for decades, including paid assignments (MOJ, Exhibit U). Even more blatantly, Dr.<\/p>\n
Fetzer was being sued over three sentences in a book he had co-edited and another in<\/p>\n
a separate publication to which he had contributed. How could Judge Remington,<\/em><\/p>\nwho insisted that he read every document submitted to the court, have missed this?<\/em><\/p>\n\n- (7) When Dr. Fetzer tried to Expose the Impostor, he was Sanctioned<\/strong><\/li>\n<\/ul>\n
Among the most important tells that Judge Remington was acting in concert<\/p>\n
with the Pozner attorneys is that, when Dr. Fetzer attempted to expose the party<\/p>\n
who had testified under the name of \u201cLeonard Pozner\u201d as an impostor (because<\/p>\n
he was too young and too small to be the Sandy Hook Pozner), Dr. Fetzer sent<\/p>\n
the video deposition to Wolfgang Halbig for confirmation. Judge Remington took<\/p>\n
offense and held Dr. Fetzer in Contempt of Court, adding attorney fees in the<\/p>\n
amount of $650,000 to the $450,000 that would be awarded by the jury for<\/p>\n
his purported defamation of Leonard Pozner, thereby protecting himself and<\/p>\n
the Pozner attorneys, when Dr. Fetzer had told the truth (MOJ, pages 11-15).<\/p>\n
Judge Remington has been so eager to avoid his exposure that he has now<\/p>\n
violated Dr. Fetzer\u2019s due process rights by abandoning the Wisconsin Rules of<\/p>\n
Civil Procedure, Chapter 802, not once or twice, but three times: (1) by rejecting<\/p>\n
Dr. Fetzer\u2019s Motion to Open Judgment Pursuant to Extrinsic Fraud and Fraud<\/p>\n
upon the Court filed on June 20, 2024; (2) by rejecting Dr. Fetzer\u2019s Request for<\/p>\n
Relief from Judgment or Order filed on June 20, 2024, and (3) by granting Plantiff\u2019s<\/p>\n
Motion to Seal or Redact a Court Record filed on June 24, 2024.<\/p>\n
The Pozner Response thus fails. It was not making decisions\u00a0per se<\/em>\u00a0that deprived<\/p>\nDr. Fetzer of his legal rights but the decisions that Judge Remington made. The pattern<\/p>\n
of ruling to deny Dr. Fetzer\u2019s motions and facts to produce no disputed facts when the<\/p>\n
case was factually contradictory from the beginning reveals that Judge Remington was<\/p>\n
acting with partiality and bias\u2014of a rather extreme variety given he manufactured the<\/p>\n
absence of disputed facts to apply Summary Judgment\u2014in a case that had to be sent<\/p>\n
to a jury for fact resolution. This goes far beyond the\u00a0appearance<\/em>\u00a0of partiality and bias.<\/p>\n.\u00a0\u00a0\u00a0 \u00a0Judge Remington, together with the Pozner attorneys in opposition\u2014including Jake<\/p>\n
Zimmerman (Pro Hac Vice<\/em>), Genevieve Zimmerman (WI #1100693), and Emily M. Feinstein<\/p>\n(WI SBN: 1037924)\u2014acted in concert to deprive Dr. Fetzer his right to present a valid<\/p>\n
defense by violating the Wisconsin Rules of Civil Procedure and denying Dr. Fetzer his<\/p>\n
right to a trial by jury. They (separately and jointly) sabotaged these proceedings by going<\/p>\n
so far as to suborn perjury by an impostor witness. And when Dr. Fetzer attempted to<\/p>\n
expose the fraud, he was (in no uncertain terms) smacked down by Judge Remington, lest<\/p>\n
the deception become known.<\/p>\n
They don\u2019t want to be held to account for multiple violations of Supreme Court Rules<\/p>\n
and Rules of Civil Procedure whereby they committed Fraud upon the Court (Dekker,<\/em><\/p>\n214 Wis. 2d at 21) by eliminating disputed facts and fabricating a case against him.<\/p>\n
RELIEF SOUGHT<\/strong><\/p>\nBy suppressing the Affidavit of Kelley Watt, dismissing proof that nobody died<\/p>\n
at Sandy Hook and that Noah Pozner was a legal fiction, setting aside the reports of<\/p>\n
two forensic document experts, denying Dr. Fetzer discovery on his counterclaims,<\/p>\n
failing to acknowledge Dr. Fetzer as a media person and holding him in contempt when<\/p>\n
he sought to expose the impostor witness\u2014together with his more recent procedural<\/p>\n
violations to suppress the proof of his egregious misconduct as quickly as possible\u2014<\/p>\n
Judge Remington has egregiously violated Wis. Stats. Chapter 757. General Provisions<\/p>\n
Concerning Courts of Record, Judges, Attorneys and Clerks, under Section 757.19(2)(g)<\/p>\n
Disqualification of Judge. Dr. Fetzer therefore again moves that Judge Remington recuse<\/p>\n
himself from this case and any further associated proceedings.<\/p>\n
Respectfully submitted,<\/p>\n
\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0<\/em>\u00a0Electronically signed by:\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0<\/em>\/s\/ James H. Fetzer, Ph.D.<\/em><\/p>\nJames H. Fetzer, Ph.D.<\/p>\n
Pro Se Defendant<\/p>\n
800 Violet Lane<\/p>\n
Oregon, WI 53575<\/p>\n
(608) 835-270<\/p>\n
Submitted the 31st day of July 2024.\u00a0\u00a0\u00a0\u00a0\u00a0 \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0jfetzer@d.umn.edu<\/a><\/p>\n
\nFor more on my\u00a0Motion to Open Judgment Pursuant to Extrinsic Fraud and Fraud upon the Court<\/a>, click here.<\/strong><\/p>\n![\"\"](\"https:\/\/jameshfetzer.org\/wp-content\/uploads\/2024\/08\/MOTION-TO-OPEN-image--286x300.jpg\")
<\/p>\n
Or visit my GiveSendGo site at\u00a0GiveSendGo.com\/fundingfetzer<\/a><\/strong><\/p>\n
<\/p>\nNOW COMES James H. Fetzer, Ph.D., Pro Se Defendant, with a Reply to the Response<\/p>\n
from Plaintiff\u2019s attorneys filed on July 24, 2024, to Dr. Fetzer\u2019s Motion to Recuse Judge<\/p>\n
Frank Remington Pursuant to Wis. Stats. 757.19(2)(g) filed July 9, 2024. Plaintiff\u2019s Response<\/p>\n
observes (correctly) that ruling against a party\u00a0per se<\/em>\u00a0does not require a circuit court to<\/p>\n recuse. But this case involves conduct by Judge Remington that has been egregiously<\/p>\n biased in favor of the Plaintiff and against Dr. Fetzer, including (most recently) repeated<\/p>\n violations of basic due process rights under Wisconsin Rules of Civil Procedure.<\/p>\n Plaintiff argues that Dr. Fetzer cannot meet his burden for recusal, alleging that there<\/p>\n is not even the appearance of partiality and that there is no basis for objecting on due<\/p>\n process grounds. Both are in blatant contradiction with Judge Remington\u2019s conduct in<\/p>\n this case from the beginning, which Dr. Fetzer has previously documented and will (at<\/p>\n least, in part) summarize here. All previous submissions in Case No. 18CV3122 are<\/p>\n incorporated and adopted for the purpose of this Reply.<\/p>\n \u00a0\u00a0\u00a0\u00a0BACKGROUND<\/strong><\/p>\n Wis. Stats. Chapter 757. General Provisions Concerning Courts of Record, Judges,<\/p>\n Attorneys and Clerks, under Section 757.19 Disqualification of judge, specifically 757.19<\/p>\n (2) asserts,\u00a0Any judge shall disqualify himself or herself from any civil or criminal action\u00a0<\/em>\u00a0<\/em><\/p>\n when one of the following situations occurs: (g) when a judge determines that, for any<\/em><\/p>\n reason, he or<\/em>\u00a0she cannot, or it appears he or she cannot, act in an impartial manner<\/em><\/p>\n (emphasis added). In relation to the 26 exhibits A-Z supporting Dr. Fetzer\u2019s Motion to<\/p>\n Open Judgment Pursuant to Extrinsic Fraud and Fraud Upon the Court filed on June 20,<\/p>\n 2024 (cited below as \u201cMOJ\u201d), Dr. Fetzer submits the following proofs of clear bias and<\/p>\n partiality by Judge Remington, who was acting in collusion with the Pozner attorneys.<\/p>\n ARGUMENT<\/strong>\u00a0<\/strong><\/p>\n Judge Remington\u2019s approach was to manufacture a predetermined outcome by<\/p>\n finding that Dr. Fetzer had libeled Leonard Pozner by declaring a death certificate<\/p>\n that Pozner himself had provided to Dr. Fetzer\u2019s research colleague, Kelley Watt,<\/p>\n to be fake. It was done by substituting a different and complete death certificate in<\/p>\n the Complaint. The published death certificate, unlike the substitution, had no file<\/p>\n number nor state or town certification. Under CT law, not even parents are allowed<\/p>\n to possess incomplete death certificates. Kelley Watt\u2019s Affidavit exposes the fraud<\/p>\n and vitiates the case against Dr. Fetzer but was suppressed by Judge Remington in<\/p>\n collusion with the Pozner attorneys (MOJ, Exhibits J, K, and V).<\/p>\n Judge Remington excluded Dr. Fetzer\u2019s proof that nobody died at Sandy Hook on<\/p>\n both legally and logically absurd grounds, when he declared that, \u201cwhether or not Sandy<\/p>\n Hook ever happened or not is not relevant to this \u2013 the \u2013 the truthfulness or the accuracy<\/p>\n of the death certificate\u201d. But the death certificate states the decedent died at Sandy Hook<\/p>\n on December 14, 2012, of \u201cmultiple gunshot wounds\u201d (MOJ, Exhibit M). Once again,<\/p>\n the proof amassed in Dr. Fetzer\u2019s co-edited book,\u00a0Nobody Died At Sandy Hook: It was a\u00a0<\/em>\u00a0<\/em><\/p>\n FEMA Drill to Promote Gun Control<\/em>\u00a0(2015; 2nd<\/sup>\u00a0ed., 2016), was inconsistent with Pozner\u2019s<\/p>\n position, thereby producing disputed facts that, had they been admitted, required a jury.<\/p>\n Having restricted the issue to the authenticity or truthfulness of the death certificate<\/p>\n and having disallowed extensive and detailed proof Dr. Fetzer had submitted in defense,<\/p>\n Dr. Fetzer provided reports of two (2) forensic document experts\u2014Larry Wickstrom and<\/p>\n A.P. Robertson\u2014who found not only that the incomplete death certificate published by<\/p>\n Dr. Fetzer was fake but that the complete death certificate attached to the Complaint was<\/p>\n also fake (along with two others obtain from the Town of Newtown and from the State),<\/p>\n Judge Remington simply dismissed them as \u201csomeone else\u2019s opinion\u201d and said, \u201cI just<\/p>\n don\u2019t think they were helpful\u201d (MOJ, Exhibit R, pages 163 and 165).\u00a0 Their uncontested<\/p>\n reports (again) vitiated the case against Dr. Fetzer by proving his statements were true.<\/p>\n To ensure that Dr. Fetzer not discover more proof of the non-occurrence of mass<\/p>\n murder or that the decedent had not died at Sandy Hook, Judge Remington took the<\/p>\n further step of bifurcating the case to deny Dr. Fetzer discovery on his counterclaims<\/p>\n of Abuse of Process, Fraud and Theft by Deception, and Fraud upon the Court, a deft<\/p>\n maneuver to cut off Dr. Fetzer\u2019s access to new evidence that might strengthen his case<\/p>\n (MOJ, Exhibit N). This denial of Dr. Fetzer\u2019s right to discovery has now been used to<\/p>\n claim that Dr. Fetzer had not made allegations of Fraud upon the Court in a timely<\/p>\n manner, brought about by Judge Remington\u2019s denial of Dr. Fetzer\u2019s discovery rights.<\/p>\n Dr, Fetzer repeatedly advanced proof that the alleged decedent, Noah Pozner, was not a<\/p>\n real person but a legal fiction created out of photographs of his purported older half-brother,<\/p>\n Michael Vabner. Dr. Fetzer raised the issue by moving to expand DNA testing to include,<\/p>\n not just Noah Pozner and Leonard Pozner, but Michael Vabner and Reuben Vabner, whom<\/p>\n Dr. Fetzer had concluded to be the basis for \u201cNoah\u201d and for \u201cLeonard\u201d (MOJ, Exhibit O).<\/p>\n This fact has now been substantiated by the Affidavit of Brian Davidson, P.I., who has also<\/p>\n established that the party who testified as \u201cLeonard Pozner\u201d in Madison is not the same<\/p>\n person as the \u201cLeonard Pozner\u201d of Sandy Hook, whose image has appeared millions of<\/p>\n times around the world (MOJ, Exhibits W, X, and Y). This has enormous importance,<\/p>\n not least of all because it implicates Pozner\u2019s attorneys in the subornation of perjury.<\/p>\n To lower the bar for finding Dr. Fetzer liable, Judge Remington declined to rule<\/p>\n that Dr. Fetzer had media standing as an investigative journalist, even though Dr. Fetzer<\/p>\n had submitted a brief laying out his experience as an investigative journalist\/reporter<\/p>\n for decades, including paid assignments (MOJ, Exhibit U). Even more blatantly, Dr.<\/p>\n Fetzer was being sued over three sentences in a book he had co-edited and another in<\/p>\n a separate publication to which he had contributed. How could Judge Remington,<\/em><\/p>\n who insisted that he read every document submitted to the court, have missed this?<\/em><\/p>\n Among the most important tells that Judge Remington was acting in concert<\/p>\n with the Pozner attorneys is that, when Dr. Fetzer attempted to expose the party<\/p>\n who had testified under the name of \u201cLeonard Pozner\u201d as an impostor (because<\/p>\n he was too young and too small to be the Sandy Hook Pozner), Dr. Fetzer sent<\/p>\n the video deposition to Wolfgang Halbig for confirmation. Judge Remington took<\/p>\n offense and held Dr. Fetzer in Contempt of Court, adding attorney fees in the<\/p>\n amount of $650,000 to the $450,000 that would be awarded by the jury for<\/p>\n his purported defamation of Leonard Pozner, thereby protecting himself and<\/p>\n the Pozner attorneys, when Dr. Fetzer had told the truth (MOJ, pages 11-15).<\/p>\n Judge Remington has been so eager to avoid his exposure that he has now<\/p>\n violated Dr. Fetzer\u2019s due process rights by abandoning the Wisconsin Rules of<\/p>\n Civil Procedure, Chapter 802, not once or twice, but three times: (1) by rejecting<\/p>\n Dr. Fetzer\u2019s Motion to Open Judgment Pursuant to Extrinsic Fraud and Fraud<\/p>\n upon the Court filed on June 20, 2024; (2) by rejecting Dr. Fetzer\u2019s Request for<\/p>\n Relief from Judgment or Order filed on June 20, 2024, and (3) by granting Plantiff\u2019s<\/p>\n Motion to Seal or Redact a Court Record filed on June 24, 2024.<\/p>\n The Pozner Response thus fails. It was not making decisions\u00a0per se<\/em>\u00a0that deprived<\/p>\n Dr. Fetzer of his legal rights but the decisions that Judge Remington made. The pattern<\/p>\n of ruling to deny Dr. Fetzer\u2019s motions and facts to produce no disputed facts when the<\/p>\n case was factually contradictory from the beginning reveals that Judge Remington was<\/p>\n acting with partiality and bias\u2014of a rather extreme variety given he manufactured the<\/p>\n absence of disputed facts to apply Summary Judgment\u2014in a case that had to be sent<\/p>\n to a jury for fact resolution. This goes far beyond the\u00a0appearance<\/em>\u00a0of partiality and bias.<\/p>\n .\u00a0\u00a0\u00a0 \u00a0Judge Remington, together with the Pozner attorneys in opposition\u2014including Jake<\/p>\n Zimmerman (Pro Hac Vice<\/em>), Genevieve Zimmerman (WI #1100693), and Emily M. Feinstein<\/p>\n (WI SBN: 1037924)\u2014acted in concert to deprive Dr. Fetzer his right to present a valid<\/p>\n defense by violating the Wisconsin Rules of Civil Procedure and denying Dr. Fetzer his<\/p>\n right to a trial by jury. They (separately and jointly) sabotaged these proceedings by going<\/p>\n so far as to suborn perjury by an impostor witness. And when Dr. Fetzer attempted to<\/p>\n expose the fraud, he was (in no uncertain terms) smacked down by Judge Remington, lest<\/p>\n the deception become known.<\/p>\n They don\u2019t want to be held to account for multiple violations of Supreme Court Rules<\/p>\n and Rules of Civil Procedure whereby they committed Fraud upon the Court (Dekker,<\/em><\/p>\n 214 Wis. 2d at 21) by eliminating disputed facts and fabricating a case against him.<\/p>\n RELIEF SOUGHT<\/strong><\/p>\n By suppressing the Affidavit of Kelley Watt, dismissing proof that nobody died<\/p>\n at Sandy Hook and that Noah Pozner was a legal fiction, setting aside the reports of<\/p>\n two forensic document experts, denying Dr. Fetzer discovery on his counterclaims,<\/p>\n failing to acknowledge Dr. Fetzer as a media person and holding him in contempt when<\/p>\n he sought to expose the impostor witness\u2014together with his more recent procedural<\/p>\n violations to suppress the proof of his egregious misconduct as quickly as possible\u2014<\/p>\n Judge Remington has egregiously violated Wis. Stats. Chapter 757. General Provisions<\/p>\n Concerning Courts of Record, Judges, Attorneys and Clerks, under Section 757.19(2)(g)<\/p>\n Disqualification of Judge. Dr. Fetzer therefore again moves that Judge Remington recuse<\/p>\n himself from this case and any further associated proceedings.<\/p>\n Respectfully submitted,<\/p>\n \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0<\/em>\u00a0Electronically signed by:\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0<\/em>\/s\/ James H. Fetzer, Ph.D.<\/em><\/p>\n James H. Fetzer, Ph.D.<\/p>\n Pro Se Defendant<\/p>\n 800 Violet Lane<\/p>\n Oregon, WI 53575<\/p>\n (608) 835-270<\/p>\n Submitted the 31st day of July 2024.\u00a0\u00a0\u00a0\u00a0\u00a0 \u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0jfetzer@d.umn.edu<\/a><\/p>\n For more on my\u00a0Motion to Open Judgment Pursuant to Extrinsic Fraud and Fraud upon the Court<\/a>, click here.<\/strong><\/p>\n Or visit my GiveSendGo site at\u00a0GiveSendGo.com\/fundingfetzer<\/a><\/strong><\/p>\n\n
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