Motion to Restore Jury Award of Court Costs
Motion to Compel the Court to produce the Jury Award
 

Since on September 12th the Court had been adjourned and the Jury dismissed and the Jury had been gone from the Court and from the court house building when the Defendant asked the Judge ex parte of the Jury and ex parte of the Plaintiff, to dismiss the award to Plaintiff of court costs, based on the award "being otherwise substantially in the same dollar amount" as the non-negotiable checks produced by the Plaintiff for the first time at a time substantially after the filing of the lawsuit by Plaintiff on the last day of the statute of repose, And also Since the decision by the Jury had been, in whole or in part, based on the perjury of the Defendant employee witness, And also Since the Defendant's employee witness perjury has been proven beyond reasonable doubt by written signed sworn notarized affidavit by the party involved and produced to the Court and the Judge by Plaintiff, And also Since the perjury which was relied upon by the Jury for finding of fact had been in whole or in part restated by Defendant's attorney in sworn testimony to the Judge at the reconvening of the Court on October 19th, And also Since the Defendant's employee attorney perjury has been proven beyond reasonable doubt by written signed sworn notarized affidavit by the party involved and produced to the Court and the Judge by Plaintiff, Therefore Plaintiff hereby files a motion to restore the award of court costs to the prevailing Plaintiff.

Furthermore, referencing attached exhibit one, since there is cause to believe that the judgment entered by the Court against the Defendant has been produced to the Court, Therefore Plaintiff hereby files a motion to compel the court to award said proceeds to the prevailing Plaintiff.

I pray the court to set a date for restoration and production of the full judgment based on the finding of the jury, and based on the production of the proof of perjury by the Defendant's various employees, inclusive of Defendant's employee attorney, which the Judge relied upon, in whole or in part, for his decision to, ex parte of the Plaintiff, remove the court costs from the judgment, and to produce that judgment in the Court's possession.
 

Respectfully
 
 
 

B. Keith Peshak
Plaintiff