Only We Can Bend the Spoon – HALTOM – V

Plaintiff’s Notice to the Court Regarding Defense’s Confusional Tactics and Improper Allegations of Untimeliness

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TO THE HONORABLE MAGISTRATE JUDGE JON YORK AND DISTRICT JUDGE THOMAS ANDERSON:

COMES NOW Plaintiff, Joshua HALTOM (Josiah), sui juris and ordained clergy, respectfully submits this Notice to apprise the Honorable Court of the Defendant City of Henderson Police Department’s persistent attempts to obfuscate the factual record, derail proceedings through misdirection, and prejudice the Plaintiff through the continued use of derogatory and legally inaccurate terminology. Plaintiff further notifies this Court that any characterization by the Defense of Plaintiff’s prior filings as untimely is itself a tactic designed to confuse and conflict, and is wholly without merit as to the substance of Plaintiff’s well-founded claims.

I. THE DEFENSE’S MOTIONS: A PATTERN OF CONFUSION AND DISREGARD FOR THE ESTABLISHED RECORD

Plaintiff has previously alerted this Court to the Defense’s troubling disregard for the gravity of the allegations and its indifference to the established factual record. The Defense’s posture demonstrates a fundamental disconnect between their approach and the demonstrably established factual record. Plaintiff has irrefutably proven the agency’s wrongdoing, yet the Defense persists in downplaying the seriousness of these violations.

This pattern extends to the Defense’s claims regarding the untimeliness of Plaintiff’s prior motions to strike or deny. The Defense asserts that Plaintiff’s Motion to Strike was filed more than 21 days after their motion to dismiss and that Plaintiff’s objections were filed after the 28-day response deadline and the 14-day objection deadline for Judge York’s report and recommendation. However, the docket entries clearly demonstrate that the Defense filed their Motion to Dismiss (Doc. 24) on February 25, 2025. Plaintiff then filed a “Response to Motion” (Doc. 26) on March 5, 2025, which included a motion to dismiss the Defense’s motion to dismiss. This filing occurred only ten days after the Defense’s motion, directly refuting any claim of a 77-day window as a fabrication or mistake. Plaintiff’s subsequent filings, including the Motion for Diplomatic Resolution incorporating Ballard v. United States (1948) and the Motion to Strike Color of Law Violations, were made in good faith and in accordance with Plaintiff’s understanding of the Federal Rules of Civil Procedure and the unique, constitutionally-mandated nature of this case. The Defense’s focus on these procedural aspects, to the exclusion of the substantive merits, serves to generate confusion and conflict, preventing the just resolution of this matter.

II. IMPROPER USE OF DEROGATORY TERMINOLOGY AS A CONFUSIONAL TACTIC

Plaintiff has formally noticed both this Honorable Court and Defense Counsel regarding the continued improper and legally prejudicial use of the term “sovereign citizen” in reference to the Plaintiff. This terminology is a recognized misnomer and oxymoron under prevailing law, and its continued use by the Defense lacks legal basis and improperly prejudices the Plaintiff. Courts nationwide, including the Sixth Circuit, have consistently rejected its validity.

The Defense’s persistent employment of this misleading and inflammatory label, despite prior admonishments, constitutes a clear attempt to associate Plaintiff with stigmatized rhetoric, violating principles of equity and justice. Such conduct, especially when coupled with their claims of untimeliness, reflects a tactic to confuse the legal issues, obscure the true nature of Plaintiff’s claims, and improperly prejudice the Plaintiff before the Court. These actions raise serious concerns under Federal Rule of Civil Procedure 11, which mandates that filings are not presented for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation. As articulated in Chambers v. NASCO, Inc., 501 U.S. 32 (1991), courts possess inherent power to sanction parties for bad-faith conduct, including dilatory and abusive tactics during litigation.

III. THE ECCLESIASTICAL JURISDICTION AND THE DISTINCTION BETWEEN LAWFUL AND LEGAL

Plaintiff, as an ordained clergy member operating under lawful ecclesiastical authority, asserts violations of the First Amendment (Free Exercise Clause and Church-State Separation), the Fourteenth Amendment (Due Process and Equal Protection), and fundamental rights under 42 U.S.C. § 1983 and 18 U.S.C. § 242 (Color of Law).

Plaintiff’s claims are rooted in a foundational understanding that the power and authority of true clergy, derived from biblical and natural law principles, stand in contrast to the delegated, statutory authority of corporate governments. Biblically, clergy operate under a divine mandate, their authority coming from God rather than human institutions. The Church, as granted the power to “bind and loose” in Matthew 16:19, possesses a spiritual jurisdiction that transcends civil governance, aligning with the legal concept of diplomatic immunity in ecclesiastical matters where the Church historically held autonomy from state interference. Unlike corporate governments, which derive power from legal fictions and operate under positive law, true clergy hold indelible character through holy orders, making their authority irrevocable by secular institutions. This distinction is critical, as evidenced by tax exemptions for churches (IRS Code § 501(c)(3)) where the state implicitly recognizes the Church’s separate sovereignty. Courts have often deferred to the ministerial exception (Hosanna-Tabor v. EEOC, 2012), affirming clergy’s higher jurisdictional claim in conflicts involving religious freedom.

Plaintiff Joshua Haltom, identifying as an Ambassador for and Citizen of Heaven, asserts that he travels by Right, not by Privilege, and relies on the Pure Cambridge Authorized 1611 King James Version Bible as his evidence of Law. This stance reflects a theological perspective where sovereignty, in ultimate terms, is ascribed solely to divine authority, not individuals in a secular sense. His baptism signifies a legal severance from the world’s systems and a transition to God’s Kingdom, rejecting contractual identifiers like the SSN, birth certificate, and government-issued licenses which he views as binding individuals to a “corporate citizen” status within the federal government’s system.

The Defense’s motions, by attempting to dismiss or deny Plaintiff’s claims on procedural grounds and by employing derogatory labels, fail to acknowledge the profound distinction between “lawful” (rooted in divine and natural law, which Plaintiff asserts governs his actions) and “legal” (referring to positive, statutory law, which Plaintiff contends is often misapplied in his ecclesiastical context). This approach constitutes “structural violence” and “spiritual wickedness” against the Plaintiff, as outlined in his filings.

IV. THE CALL FOR RIGHTEOUS JUDGMENT AND TRANSFORMATION

Plaintiff’s pursuit of justice is deeply informed by a call for “righteous judgment,” a concept that embodies both strict adherence to truth and the transformative power of divine mercy. The biblical prophecy of Zechariah 3, involving Joshua the High Priest, facing accusation and being cleansed by divine decree, serves as a powerful metaphor for this proceeding. Just as Joshua was purified and his priestly authority restored despite accusations, Plaintiff seeks a cleansing of the “filthy garments” of governmental misconduct and an affirmation of his divinely ordained authority, free from coercive secular mandates. This aligns with the principle of Ballard v. United States, 329 U.S. 187 (1948), which underscores the judiciary’s duty to protect the free exercise of sincerely held spiritual beliefs, holding that courts may not adjudicate the truth or falsity of religious doctrines.

Plaintiff’s vision extends beyond mere litigation to a desire for “redemption” and “transformation” of the State’s conduct, urging the Court to uphold the sacred divide between church and state and restore God-given and constitutional liberties. This aligns with broader aspirations for social change, aiming for a “Jubilee” that promotes healing, equity, and forgiveness through constitutional and spiritual principles, such as those articulated in “A Call for Honorable Leadership and Vision.” Plaintiff’s legal actions are thus a means to use truth to power, exposing the alleged “de facto” nature of certain governmental actions and advocating for a legal and societal framework that truly reflects “God’s Law” as the ultimate authority.