STATE OF MINNESOTA IN COURT OF APPEALS

CASE TITLE:

Nancy C. Lazaryan,proceeding in propria persona,in summo jure, jus regium, Appellant,

vs.

H. Alan Kantrud, attorney for the City of Maplewood, in his personal and professional capacity, City of Maplewood, and Karen Guilfoile, Respondents

REPLY BRIEF OF THE APPELLANT

TRIAL CT. CASE #: C2-05-6546

Appellate Court Case # A-08-276

Nancy C. Lazaryan, Appellant, hereby replies to the briefs of all Respondents as follows:

Respondent Kantrud asserts that Lazaryan's sole argument concerning the jurisdiction of the jury, and not the judge, to decide this cause of action was not raised before the trial court judge.

It is well-settled that jurisdiction can be challenged in any court at any time.

All other arguments made by Respondent Kantrud are moot.

Respondent city of Maplewood et al asserts:

1.Lazaryan cites no legal authority to support her argument.

2.There is no "magic" language ("propria persona, in summo jure, jus regium) that removed the district court's personal jurisdiction.

1.The legal authority that Lazaryan has cited is the Minnesota and United States constitutions, documents that secure and set forth the Rule of Jurisdiction contained in Natural/Organic Law. See as follows:

CONSTITUTION OF THE PEOPLE OF THE STATE OF MINNESOTA

ARTICLE ONE SECTION FOUR

The right of trial by jury shall remain inviolate, and shall extend to all cases at law without regard to the amount in controversy. A jury trial may be waived by the parties in all cases in the manner prescribed by law… (emphasis added)

CONSTITUTION OF THE PEOPLE OF THE UNITED STATES OF AMERICA

AMENDMENT VII

In suits at common law, where the value in controversy shall exceed twenty dollars, the right of trial by jury shall be preserved, and no fact tried by a jury, shall be otherwise reexamined in any court of the United States, than according to the rules of the common law.

AMENDMENT IX

The enumeration in the Constitution, of certain rights, shall not be construed to deny or disparage others retained by the people.

AMENDMENT X

The powers not delegated to the United States by the Constitution, nor prohibited by it to the states, are reserved to the states respectively, or to the people.

Contained within the record of the trial court is the DEMAND for a jury trial, and the $75 fee that was paid to the court administrator.

The "rules of the court" that allow a district court judge the jurisdiction to grant a motion for summary judgment (or sanctions) against a natural person have no authority of law. As such, said rules violate the right the People secured to themselves; the right to have a jury decide all matters in a Complaint at Law brought in the district court. The orders of the district court judge, granting summary judgment, dismissal and sanctions for the Respondents are void ab initio, a nullity then and now.

2."In propria persona, in summo jure, jus regium" are not magic words. These words are NOTICE to the court as to the standing of the Appellant when she brought her Complaint At Law to the district court. The district court is NOT the district court judge. Rather the district court is part of the government, an artificial entity that was created by the People of the state of Minnesota.

When the People, by the action of establishing the state and federal constitutions created the government, an artificial entity, the People declared the restraints they placed upon the government.

The People preserved their sole power to adjudicate any and all Complaints at Law that concern a member of the Sovereign People.

Appellant's complaint AT LAW clearly declares the restrictions and limitations of the constitutions upon the jurisdiction of the trial court judge. See as follows (Appendix to Respondent's Brief, page R.A.-2):

"NOW COMES, by complaint, Nancy C. Lazaryan and William M. Kayser being native born Citizens of the state of Minnesota, complaint in propria persona, proceeding without prejudice, conferring nor consenting to any jurisdiction excepting for the Article VI § 1 judicial power of Minnesota, and as such will waive no secured rights and willfully enforces all constitutional limitations and prohibitions upon the equity jurisdiction of the District Court."

"In propria persona, in summo jure, jus regium" are not magic words.

Just as the words of the constitutions are not magic, but rather, these are words declare the rights that We the People have secured to Ourselves.

Appellant brought a Complaint at Law. Appellant noticed the trial court judge in her complaint, "…and willfully enforces all constitutional limitations and prohibitions upon the equity jurisdiction of the District Court."

The record is clear the Appellant declared her secured rights and enforcement of the constitutions upon the actions of the district court judge. In a Complaint at Law, thus pled, the district court judge is absent jurisdiction to grant the equity relief of dismissal of Appellant's claims and of sanctions. The judge did not have "discretion" to grant any relief for the Respondents.

Appellant rests.

Nancy C. Lazaryan
Proceeding in propria persona, in summo jure, with all rights secured
10734 West Lake Road
Rice, MN 56367