[Codee]

It is like this Wies...

The big motion to dismiss gets file FIRST because it has "in personam jurisdiction" ellements that can be accidentaly waived. So before any unexpected waiver lets get that out of the way... even if it is an "overuled." Then there is SMJ in it as well. That is what usually works. the PJ stuff,,, very hard (oooohhh but possible.) The SMJ in the big argument is really the big shabang!!! It has just about everything in it. After you file and serve you have effectivly stopped the case because court cannot proceed after the challenge (not the hearing on the challenge.)

Then you want to make an iron clad record so the motion for the court reporter is now brought in. (Because even though the hearing has not taken place the challenge for PJ preserves it for later appeal.) Now you can motion your eyes out... SMJ is never waived.

Then with the motion for the court reporter you go to trial date. Right before the trial date you file motion to dismiss again for specifically the SMJ. If there is no court reporter on your trial day you object to that too. You write your objection right there in court and serve it into the record. You get that clerk to stamp it in court "recieved."

Then after the judge drives his train up your ass, if it even gets this far, you simply say that is all fine, why the hostility? If I am right I will just win on appeal then I am comming after your house and everything else,,, if you are right you get $400. Gee whiz. I am shaking,,, how 'bout you?

You then have thirty days to file a notice of appeal.

After the notice of appeal the clerk will have to certify the case for appeal and give you notice when that is done. Then you have 20 days to file a first appeal brief.