IN THE GENERAL COURT OF JUSTICE DISTRICT COURT DIVISION ROCKINGHAM COUNTY, NC

SARAH R. PALMER On behalf of NICHOLAS PALMER-BECK (a minor child) 501 REDD ST. REIDSVILLE, NC 27320 Pro Se Plaintiff Case No. 15 CVD 2055 v. WILLIAM M. SCHMALFELDT, SR 3209 S. Lake Drive, Apt. 108 Saint Francis, WI 53235 Pro Se Defendant ANSWER TO CIVIL SUMMONS, NO CONTACT ORDER FOR STALKING, MOTION

FOR DISMISSAL OF PETITION ---------------------------------------------------------------------------------------------------------------------

Now comes pro se defendant William M. Schmalfeldt to answer the above-titled

summons, and move for dismissal of the complaint. Defendant alleges as follows:

Defendant Does Not Meet Criteria of North Carolina Long-Arm Statute.

1. Defendant is not a natural person present in the state of North Carolina.

2. Defendant is not a natural person domiciled in the state of North Carolina.

3. Defendant is not a domestic corporation.

4. Defendant is not engaged in substantial activity within North Carolina, whether that

activity is wholly interstate, intrastate or otherwise.

5. As a result, Defendant does not rise to the level of an out of state person who can be

bound by the State of North Carolina under its long-arm Statute (NC ST 1-75.4), and this

honorable court does not have personal jurisdiction over this defendant.

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Plaintiffs Petition for a No Contact Order is Rife with Mistruths and Omissions

6. Plaintiff fails to note that Defendant has never made contact with her grandson.

7. Plaintiff fails to note that the single photograph he has published of her grandchild

had his face blurred to make the child unrecognizable.

8. Plaintiff fails to note that the pictures Defendant posted on his website of her her non-

party daughter, Brianna, were taken from her Facebook page, where she made them available to

the world at large.

9. Plaintiff claims to have sent a cease and desist contact letter to defendant.

Defendant does not recall receiving any such letter, nor does Plaintiff establish any proof of said

letter in her petition.

10. In her descriptions of Defendants alleged stalking and harassing behavior, Plaintiff

fails to tell the court that she is the proprietor of a website that is responsible for daily taunting of

the defendant, using the defendants name against his stated wishes in the title of the website.

(EXHIBIT 1)

11. Defendant learned of the alleged incident which led her to become her grandsons

guardian from the Plaintiff herself in a series of e-mails Plaintiff sent to Defendant believing him

to be someone else. (EXHIBIT 2)

12. Plaintiff fails to note for the court that she is a defendant in a Federal Lawsuit filed

by Defendant in the U.S. District Court for the Eastern District of Wisconsin, Milwaukee

Division, alleging harassment, defamation per se, intentional infliction of emotional distress,

among other torts.

13. Plaintiff is aware that Defendant has suffered from Parkinsons disease for 16 years

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and cannot walk more than a few yards without assistance. He has no drivers license and cannot

drive. Travel to North Carolina either to answer this petition or harm Plaintiffs grandson

would be impossible without significant assistance to Defendant.

THEREFORE, Defendant asks this honorable court to dismiss Plaintiffs petition with

prejudice due to this courts lack of personal jurisdiction over the Defendant.

In the alternative, Defendant asks this honorable court to review the evidence supplied in

this brief and come to the same conclusion this court made in Plaintiffs request for a temporary

order. The Plaintiff has failed to prove grounds for issuance of a temporary no-contact order.

December 31, 2015 Respectfully Submitted,

____________________________________

William M. Schmalfeldt, Sr., Pro Se 3209 S. Lake Dr., Apt. 108 Saint Francis, WI 53235 414-249-4379 Email: bschmalfeldt@twc.com

EXHIBIT 1 Plaintiff runs a hate-blog directed at defendant at the website http://billysez.wordpress.com where she takes things I may or may not have actually said and applies her own defamatory spin to them. Defendant is suing Plaintiff in Federal Court for her role in this.

On occasion, Plaintiff has served as a guest blogger for an even more purulent hate-blog,

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http://thinkingmanszombie.com, which is also completely dedicated to defaming the Defendant.

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EXHIBIT 2 Defendant learned about shaken baby charges against Plaintiffs daughter from Plaintiff herself.