When the caption is “Motion To Dismiss This Bulls**t” (sans the wussyterisks we are forced to employ at ATL for certain words to protect your virgin eyeballs) you know you’ve got a winning motion. A pro se defendant felt compelled by circumstance to file a motion to dismiss for lack of personal jurisdiction. On some level you’ve got to feel for the guy because “bulls**t” is how the judicial system feels to the average bloke.

On another, more accurate level, you’ve got to sit back and revel in the 7 pages of unfiltered brilliance spewing forth from an unhappy pro se defendant….

Let’s walk through a mere sampling of the highlights. The tale begins with an email subject heading:

Fw: Just a heads up of my Motion to Dismiss. I know it’s ruff and all but, it’s me. I’m filing it Piasan, as is because it’s the truth.

You had me at “ruff.”

The caption for this bad boy may be the greatest ECF docket entry ever.

Motion To Dismiss This Bulls**t. The court has received Knowingly False and, Fraudulent Mis-leading Information in the filings from this Plaintiff through, and COMPLICIT with, her Attorney, Perpetrating this fraud and blantenly lying to the Court regarding DEFENDANTS Georgia Residency in effort to mis-lead the court to rule in favor of Plaintiff to Defeat The Georgia Long Arm Restrictions

Ultimately, this motion gets struck from the docket — which is a travesty, because I’d use PACER to visit that docket entry every day.

Judge, may it please the court, Comes now the DEFENDANT, Mr. Grambling T. Dominique, Jr acting PRO-Se, for now anyway, in the above styled case. Judge, the court has has a fraud perpetrated on it by the Plaintiff and her counsel and is not in procession of the full facts in this case as Fraudulently presented to by these two. The Plaintiff, Ms. Kristal Holmes through her attorney Sandy Filth-Le Can herein refer to as “I-85”, due to her WELL KNOWN HISTORY OF EXTREME PROMISCUITY OF MEN UP AND DOWN THE I-85 expressway from South Carolina to Alabama and, for her abuse of CRACK COCAINE. Please take that thought inconsideration when you receive another one of their filings. If they would lie to the court about this little s**t in order to defeat the Georgia Long Arm Statue, you can bet your ass they are lying about the whole goddamn thing.

In case you were wondering, in addition to run of the mill defamation claims, this is a full-blown RICO suit. By way of background, the complaint alleges that Grambling T. Dominque Jr. defamed Kristal Holmes — by posting a bunch of statements about her on Reportyourex.com. The logical leap that takes this to RICO is the claim that the brains behind Reportyourex.com have quite the ingenious little business plan: allow people to post potentially defamatory rants about former lovers and then charge the target hundreds of dollars in exchange for removing the post. Because Kristal Holmes is an attorney, she looked to the courts for relief.

And Dominique does not like I-85 — er, Sandra Finch Lekan.

SO, you mean to tell me the despite being on drugs, she is also a dumbass lawyer too?

Not to get all Nancy Reagan, but I think he misused “despite” there.

Further, like I said, I have some e-mails of my own Judge, those that I have have direct barring on THIS CASE… I-85 sent to Defendants Counsel Marc Randazza. In these e-mails, I-85 claims that she has hired an private investigator to assist her in locating me when I told her in that out of sequence e-mail that I reside in Miami Beach, Florida. Well Judge, as I told you above, her investigator must have been on Crack too or the dumbest muthaf**king investigator in Georgia, which dealing with I-85, that’s not to much of a surprise, Judge.

Howdy there, friend of ATL Marc Randazza! He must be loving this case.

Now let’s take a moment to credit Dominique for his attention to detail and ability to paint a scene with words:

When I first met I-85 it was at their law office Kristal and her shared. She and a guy got out of a f**ked up rusty damaged red late model Nisan Z. She walked in with the another crack head guy (who later I was told by Kristal worked for them off the books and was a dis-barred lawyer) who’s clothes were disshoveled wrinkled and dingy as hell, as were I-85. He was a white guy with dirty blond hair and steel blue eyes. He had on a pair of the dirtiest kacki brown cargo shorts I have ever seen in my life, and dingy white (but looked gray) button up shirt with the sleeves rolled up to the elbow. His eyes were blood shot and he also smelled of some sort of liquor. I-85 had on dingy Wrangler blue jeans and a white t-shirt. She looked like she slept in her clothes from the night before, and her hair was pulled back from her face, and unwashed. His (and her) nose was bright red, like a f**king stop light and he reeked of cocaine and crack.

Then he waxes philosophic about Lekan eating Kentucky Fried Chicken or something.

Time for some real talk with the judge:

She was trying get me to down play Judge, get this now, the fact that Kristal told me that our child was dead stating that KNOWONE WOULD CARE THAT SHE TOLD ME THAT F**KING BULS**T TO KEEP ME FROM FILING FOR A PUBLIC CUSTODY HEARING?!!!!! So lets agree to a out of court agreement and Kristal won’t appose my visitation???!!! What? Like I give a f**k what she apposes? F**k her, SHE LIKE AND TOLD ME ALL THIS TIME MY CHILD, MY BABY WAS DEAD! DIED AT BIRTH!!! F**k outta here, I told her I dont know your ass but I do remember you, and if your represent Kristal please send me a letter of representation signed by her. I got it all in writing Judge.

Let me take a time out and remind everyone of the importance of funding our public schools.

If you think Dominique is too informal with the judge, well…

Judge, I will also include that e-mail and hey, if you find the time, e-mail my HOTMAIL ACCOUNT for yourself and see for yourself.

Yeah, you know, if you got time.

Hummmmm????? Sounds and looks like bulls**t to me Judge but, you get the last word, I’m just giving you the facts supported by her own s**t, her e-mails. You tell me. **** That’s it Judge, That’s all I got.

And stuck the landing.

If you enjoyed these excerpts, let me assure you that it’s only the tip of the iceberg. Settle in and read the whole thing. I actually shed a tear laughing at some of this stuff. As always, the whole filing is available on the next page….