July 9th, 2018

TO WHOM IT MAY CONCERN

This is a NEW complaint against Kansas attorney Michael J. Abrams (KS #15407) of
Lathrop Gage LLP, 2345 Grand Blvd., Suite 2200, Kansas City, MO 64108-2618

I recently sent a complaint, dated June 18th, 2018, against the above named attorney. The
complaint was centered on the attorney filing pleadings in the case, and not sending me
any copies of these pleadings.

Even after sending the previous attorney complaint this attorney went ahead, and yet
again, filed two pleadings on June 21st, 2018 in the subject matter case without sending
the pleadings, or notifying me in any shape, or form, that new pleadings had been
filed. See the attached summarized docket printout.

Ifound out that there had been new pleadings filed when Iwent online to check on the
case docket on July Bth, 2018.

It should be noted that since my June 18th, 2018 attorney compliant this attorney has
mailed me a four-page pleading from a separate pending federal court case using priority
mail. See the attached copy of the envelope and pleading.

It is important to note that this is not the first time that pleadings have not been sent to me
by attorneys from the same Lathrop Gage LLP law firm. Attorney Matthew Hubbard
similarly had not been mailing hard copy pleadings to me as per his certificate of services.
Attorney Matthew Hubbard does not dispute this fact. The difference being that
attorney Matthew Hubbard had sent me a copy of his court fillings via email but neglected
to send me hard copies as per his certificate of service. See the attached, Nov 16th, 2016,
email communication.

Here no service of filed pleadings of any kind have been sent to me since January
25th,2018.

Please investigate this matter.

Respectfully submitted,

By: arC, tA/)JJ.

Eric Muathe,
P.O. Box 224,
Pittsburg, Kansas, 66762
(913) 980-7286
Cc:

./ Office of the Disciplinary Administrator

./ Michael J. Abrams @ mabrams@lathropgage.com
./ Lathrop Gage LLP
7/8/2018 Office of Judicial Administration - Kansas District Court Records Search

Crawford County District Court Search - Case Display

------- ------- ----------_._--- ------
Case Number: 86

Case Year: 2014 Case UID: 2014-CV-000086-P

Case Type: CV Filed: 2014-08-11
Case Sub-type: Mortgage Foreclosure Last Updated: 2015-06-17 at 14:26:56
Advisement Date: Remand Date:
Appealed: N Appealed Date:
Status Code: 1 Status Date:
Status Description: Pending

Defendants

Party 1

IDefendant Number: 1

Last Name (or Business Name): Muathe

First Name: Eric Middle: M Suffix:

Description

Defense Attorney

Last Name: Pro Se First: 1~{jddJe:

Primary Attorney: Y Court Appointed: N IConflict Attorney: N

Withdrawn: N Send Notices: Y

Practice or Office:

Party 2

IDefendant Number: 2

Last Name (or Business Name): Mortgage Electronic Registration Systems Tnc
First Name: Middle: Suffix:

Description

sex: IRace:

I
================================================
=H=e=lg:l=lt=: _W_e...:ig::;,'_'t_: _
Party 3

IDefendant Number: 3

Last Name (or Business Name): Citimortgage Inc

First Name: Middle: Suffix:

Description

https:/Iwww.kansas.gov/countyCourts/search/records?execution=e1 s4 1/20
7/8/2018 Office of Judicial Administration - Kansas District Court Records Search

Action 1.52

Action Date: 2018-05-31 \Action Type: INFE

Action Agent: Richard M Smith

Description: F INF: Exhibit

Action 153

Action Date: 2018-06-14 IAction Type: MOT

Action Agent: Richard M Smith
Description: Motion for Sanctions and Request for Oral Arguments Document ID Number: 414243

Action 154

Action Date: 2018-06-14 IAction Type: MOT

Action Agent: Richard M Smith
Description: Motion to Strike Plaintiffs Pleadings and Request For Oral Arguments Document 1D Number: 414246

Action 155

J\ction Date: 2018-06-21 IAction Type: MOTG

Action Agent: Richard M Smith
Description: PLi\INTIFF'S RESPONSE TO DEFENDANT MOTION TO STRIKE PLAINTTFF'S PLEADINGS MOT: Motion (Generic)

Action 156

Action Date: 2018-06-21 IAction Type: MOTG

Action Agent: Richard M Smith
Description: PLAINTTFF WILMINGTON TRUST RESPONSE TO DEFENDANT MOTION FOR SANCTIONS MOT: Motion (Generic)

Action 157

Action Date: 2018-07-06 IAction Type: RESET

Action Agent: Richard M Smith
Description: Hearing Rescheduled (Check Status 07/20/2018 05:00 PM) Motion for Summary Judgment rescheduled?

© 2018 Office of Judicial Administration-CIillp://www.kscourts.org).

https:/Iwww.kansas.gov/countyCourts/sea rchlrecords ?execution= e1s4 20/20

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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF KA.NSAS
AT KAt~SAS CITY

ERlC M. MUATHE, )
)
Plaintiff, )
v. )
Case No. 2:18-CV-02064-CM-JPO
)
WELLS FARGO BANK, N.A., et al., )
)
Defendants. )
)

ORDER

Having considered Defendants' unopposed Motion for Extension of Time to File their

Reply in Support of Defendants' Motion to Dismiss Plaintiffs Amended Complaint, and finding

that Plaintiff has agreed to the requested extension of time and good cause has been shown for

the relief requested, it is hereby:

ORDERED that Defendants Motion for Extension of Time is hereby GRANTED.

Defendants are granted a 7-day extension of time, through and including July 19, 2018, within

which to file Defendants' Reply in support of their Motion to Dismiss Plaintiffs Amended

Complaint.

IT IS SO ORDERED.

Entered on this _ day of July, 2018.

JUDGE
 Case 2:18-cv-02064-CM-T JJ Document 16 Filed 06/29/18 Page 2 of 2

filed in good faith. Accordingly, good cause exists for the requested extension of time.

WHEREFORE, Defendants respectfully request that the Court enter an order granting

Defendants a 7-day extension of time, until July 16,2018, within which to file Defendants'

Reply in support of their Motion to Dismiss Plaintiffs Amended Complaint. A proposed Order

has been submitted to the Court.

Respectfully submitted,

LATHROP GAGE LLP

By: /s/ Jehan Kamil Moore

R. Kent Sellers D. Kan. # 70019
Michael J. Abrams KS #15407
Jehan Kamil Moore KS #22081
2345 Grand Avenue, Suite 2200
Kansas City, Missouri 64108-2684
Telephone: 816.292.2000
Facsimile: 816.292.2001

ATTORNEYS FOR DEFENDANTS

CERTIFICATE OF SERVICE
The undersigned hereby certifies that a copy of the foregoing was filed electronically

with the Court on June 29, 2018, and sent via U.S. Mail to the following:

Eric Muathe, Defendant (pro se)

1410 Bitner Terrace
Pittsburg, Kansas 66762

Isl Jehan Kamil Moore

An Attorney for Defendants

2
?07?.<I.<IQlv'
 Case 2:18-cv-02064-CM-TJJ Document 16 Filed 06/29/18 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF KANSAS
AT KANSAS CITY

ERIC M. MUA THE, )

)
Plaintiff, )
v. )
Case No.2: IS-CV -02064-CM-JPO
)
WELLS FARGO BANK, N.A., et aI., )
)
Defendants. )
)

DEFENDANTS' MOTION FOR EXTENSION OF TIME TO FILE REPLY

IN SUPPORT OF MOTION TO DISMISS PLAINTIFF'S AMENDED COMPLAINT

Defendants, by and through their attorneys, Lathrop Gage, LLP, hereby move the Court

for a 7-day extension of time within which to file Defendants' Reply in support of their Motion

to Dismiss Plaintiff's Amended Complaint. In support of this motion, Defendants' state and

allege as follows:

I. On June 25, 20 IS, Plaintiff filed his response to Defendants Motion to Dismiss

Plaintiff's Amended Complaint.

2. Defendants' Reply is currently due on July 9, 2018.

3. Defendants respectfully request a 7-day extension of time, until July 16,2018, to

file their Reply in support of Defendants' Motion to Dismiss Plaintiff's Amended Complaint.

Defense Counsel will be out of town next week and Defendants need additional time in order to

thoroughly analyze and respond to Plaintiff's arguments.

4. Counsel for Wells Fargo communicated with Plaintiff on June 29,20182018, via

email and Plaintiff agreed to the proposed extension.

5. This is Wells Fargo's first request for an extension of time to file its Reply in

support of its Motion to Dismiss. This request for an extension will not cause undue delay and is

29724491v5
- SUBMITTED BY:

LATHROP & GAGE LLP

By:/si Jehan Kamil Moore

Michael 1. Abrams (15407)
Jehan Kamil Moore (22081)
2345 Grand Avenue, Suite 2400
Kansas City, Missouri 64108-2684
Telephone: 816.292.2000
Telecopier: 816.292.2001
mabrams@lathropgage.com
jmoore@lathropgage.com

CERTIFICATE OF SERVICE
The undersigned hereby certifies that on June 29, 2018, a copy of the foregoing was sent

via U.S. Mail to the following:

Eric Muathe, Defendant (pro se)

1410 Bitner Terrace
Pittsburg, Kansas 66762

Isl Jehan Kamil Moore

An Attomey for Defendants

2
6/13/2018 Gmail- Wilmington v. Muathe: WF rfa answers, WF rfp responses, WF irog answers pdf

Eric Muathe <muathedotcom@gmail.com>

Wilmington v. Muathe: WF ria answers, WF rip responses, WF ir09 answers pdf

Eric Muathe <muathedotcom@gmail.com> Wed, Nov 16, 2016 at 1:05 PM
To: "Hubbard, Matthew (LG)" <MHubbard@lathropgage.com>

Good Afternoon Matt,

I have been waiting for your discovery responses via regular mail over the last few days I have NOT yet received anything' via regular mail as per your November 11 th,
2016 certificate of service.

'The mailman just came by today - November 16th, 2016.

I have to, and will, object that there is a disturbing pattern you have now established right from the beginning where your certificates of service say you mailed a
pleading but it never arrives via regular mail, or even worse in one instant it was mailed several days well after the date stated on the certificate of service.

This is improper!

I have been busy with two federal cases and two Kansas court appeals (one moving to the KSC soon) so would like to take a look at your discovery responses but they
have NOT arrived in the mail as per your certificate of service.

Could you send the discover pleadings since I haven't received them.

Thanks for your cooperation.

Eric Muathe
{Quoted text hidden]

"And therefore our contemplation of this source. as the power which we want, gives us the ability to use that power. And the way we use this process is to contemplate
ourselves as surrounded by the conditions which we want to produce." - Thomas Troward.

Namaste.
Eric Muathe
CEO 1 Founder
Encare Financial Inc.
htto:/iw'.\w.muathe.com
6/13/2018 Gmail - Wilmington v. Muathe: WF rfa answers, WF rfp responses, WF irog answers pdf

j.
•
or1 -.J.,
-~ m'':'~
,,..I, Eric Muathe <muathedotcom@gmail.com>

Wilmington v. Muathe: WF rfa answers, WF rfp responses, WF irog answers pdf

Hubbard, Matthew (LG) <MHubbard@lathrapgage.com> Wed, Nov 16, 2016 at 1:13 PM
To: Eric Muathe <muathedotcom@gmail.com>

Eric:
We are fed-exing you the hard copies of the discovery pleadings and documents for ovemight delivery. We get used to emailing everything these days and
sometimes forget that you have requested hard copies. Let me know if you have any questions.

Thanks,

Matt
t
From: Eric Muathe [mailto:muathedo!com@gmail.com]
Sent: Wednesday, November 16, 2016 1:05 PM
To: Hubbard, Matt
Subject: Re: Wilmington v. Muathe: WF rfa answers, WF rfp responses, WF irag answers pdf

[Quoted text hiddenl