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Kansas Commission on Judicial Qualifications

301 SW. 10th Avenue

Topeka Ks 66612

August 30, 2017

I have included new evidence for more possible violations of the code of judicial conduct
for my docketed complaint of 1332 in the matter of AJ. Wachter case numbers 13cv32P
Wells Fargo vs. Julie Brunskill and 2017CV72P Kasey Kingvs. MyTown Media, Lori Bolton-
Fleming, and Kurtis Loy that is set for October 6, 2017

OUSTERCOMPLAINT

Pursuant to KS.A 60-1206(a)(b)

This is an "Ouster Complaint against Chief Judge of the 11thjudicial district in Crawford
County AJ. Wachter" under K.S.A.60-1206(a)(b). Proceedings to oust a state officer shall
be commenced only by the attorney general. This complaint needs to be also forwarded to
the attorney generals office because of the "willfulnes~" Judge Andrew James Wachter
showed by removing an entry out of the (ROA) in case number 13CV32P Wells Fargo vs.
Julie Brunskill which is commonly known as the court docket because Julie Stover-King had
gotten him previously an admonishment reprimand/caution from the Kansas commission
on judicial qualification for a docketed ethic complaint in the matter of AJ. Wachter docket
number 1114 on June 7, 2011 for his inappropriate comment of "peanut gallery". Judge AJ.
Wachter dismissed her case after 3 1h years because her husband Kasey King filed a lawsuit
against the judges brother attorney Bill Wachter who owns the radio station (My Town
Media) on June 26, 2017 in the court case titled case number (2017CV72P Kasey Kingv. My
Town Media, Inc., Lori Bolton Fleming, and Kurtis Loy filed in Crawford County Civil Court
The very next day on June 27, 2017 Judge AJ. Wachter retaliated with willfulness and
dismissed her counterclaim but did not dismiss Wells Fargo even though their was a
previous dismissal hearing that was entered on 3/5/14 that was "deleted" from the court
file. This is a violation of Cooperation with Disciplinary Authorities Rule 2.16(A)(B) under
the code of judicial conduct from her previous docketed caution complaint in June 7,2011
in 1114 in the matter of AJ. Wachter.

Judge A.J.Wachter would love nothing more than to see my friends kicked out on the street
from 303 S.Jefferson for the (peanut gallery) reprimand and the grand jury petition in case
number 2015MR2P and civil lawsuits that have been filed against Judge AJ. Wachter in
15CV79P and his brother Bill Wachter the attorney. This is the whole reason the code of
judicial conduct has Rule 2.7 Responsibility to Decide which says "Ajudge shall hear and
decide matters assigned to the judge, except when disqualification is required by Rule 2.11
or other law.

The ouster statute requires "(willfulness), "the acts complained of must be willfully
and intentionally done." State ex reI. Stovall v. Meneley, 2000 WL 34001576 at *28 (Kan.
Dist. Ct, Feb. 24, 2000) (citing State ex reI. v. Scates, 43 Kan. 330, 23 P.479 (1890); State ex
reI. v. GTrinkle, 70 Kan. 396, 78 P. 854 (1904); State ex reI. v. Foley, 107 Kan. 608, 193 P.
361 (1920) State ex rel. v. Wilson, 108 Kan. 641, 196 P. 758 (1921); State ex reI. v. Duncan,
134 Kan. 85, 4 P.2d 443 (1931). Although the ouster statutes do not contain a definition of
willfulness, the term has been defined to mean an act "performed" with a designed purpose
or intent on the part of a person to do wrong or to cause an injury to another." PIK Civ. 3d
Section 103.04. The intention of the officer is the key. S. Gard and R Casad, Kansas Code of
Civil Procedure Arinotated 3d Section 60-1205 (1997) (citing State ex rel, Hopkins v, Foley,
107 Kan. 608,193 P. 361 (1920).

Honorable AJ. Wachter failed to consider Constitutional grounds for recusal and Julie
Stover-Kings constitutional 5th and 14th amendment rights were violated in case number
13CV32P Wells Fargo vs. Julie Brunskill under the U.S.Constitution under color of law.
Plaintiff has been deprived of due process and equal protection under the law. (See Peters
v. KifJ; 407. U.S. 493,502 (1972).)

Honorable AJ. Wachter finally recused himself from case number 13CV32P but not until
July 24,2017 which was (3) years later than the September 23,2013 hearing where he
took the matter under advisement and just three (3) days later on July 27, 2017 at 12:02
p.m. Judge AJ. Wachter gave an (OUT-OF-DISTRICTASSIGNMENTORDER)in case number
2017CV72P Kasey King vs. My Town Media, Lori Bolton Fleming, Kurtis Loy to Chief Judge
of the 31st judicial district Daniel D. Creitz whose son Daniel Crietz formerly worked for Bill
Wachter at the Law Firm of Wilbert and Towner in Pittsburg Kansas in 2014 and 2015. On
the same day of July 27,2017 at 2:05 pm. AJ. Wachter gave another (OUT-OF-DISTRICT
ASSIGNMENTORDER)in case number 2013CV32P Wells Fargo Bank vs. Julie S. Brunskill to
the same chief judge Daniel D. Creitz of the 31st judicial district.

Honorable AJ. Wachter did not comply with K.S.A.20-311d(b)(c) change of judge;
procedure since no judge was required to hear the affidavit or assign the affidavit in the
11 th district Judge AJ. Wachter should have notified the departmental justice to assign the
out of district assignment order and not chief judge A.}.Wachter who was disqualified from
hearing or assigning case number 2017CV72P Kasey King vs. My Town Media, Lori Bolton
Fleming. Kurtis Loy because K.S.A.20-311 Disqualification of judge to sit in certain cases
says that if any attorney of record or any party to such case is related. by blood or marriage
to the judge before whom the same is pending. as a spouse, parent, child, grandchild.
grandparent, brother or sister is related to such judge as a result of being a spouse of any
such parent, child, grandchild, grandparent, brother or sister, the judge shall be disqualified
from hearing said case.

Judge A.J.Wachter also was disqualified in case number 2013CV32P Wells Fargo vs.
Julie Brunskill on 7/24/2017 under K.S.A 20-311d so therefore Judge AJ. Wachter did not
have any subject-matter jurisdiction to assign the case to judge Daniel Creitz on 7/27/2017
and should have notified the departmental justice to assign the case since AJ. Wachter was
disqualified from assigning orders in both of the above mentioned cases.

I also recently sent in a complaint on A.J.Wacther where the commission on judicial


qualifications met on August 4,2017 and docketed AJ. Wachter in the matter of AJ.
Wachter docket no. 1332 on August 16, 2017 and I have enclosed the complaint that I sent
to the Kansas Commission on Judicial Qualifications for you to view for evidence to be
included for the above requested ouster complaint on AJ. Wachter. This is the third (3rd)
different time that AJ. Wachter has been docketed. He was also docketed from a complaint
by Lester Moore in 2013. Please oust this judge for the malicious acts or retaliation and
manipulation of court dockets.

213 E. Carlton
ELECTRONICALLY FILED
2017 Jul 27 PM 2:05
CLERK OF THE CRAWFORD-PITTSBURG DISTRICT COURT
CASE NUMBER: 2013-CV-000032-P

IN THE ELEVENTH JUDICIAL DISTRICT


STATE OF KANSAS

TO: Hon Daniel D. Creitz


Chief Judge
1 North Washington Ave.
lola, KS 66749

OUT-OF-DISTRICT ASSIGNMENT ORDER

In accordance with Supreme Court Assignment Nos. 20, and 21, Judicial

Department No.4, each dated April 19,2017, K.S.A. 20-319 and Supreme Court Rule

No. 1.03, you are hereby assigned to hear and determine the following case presently

pending in Crawford County, Kansas, at Pittsburg:

Wells Fargo Bank, NA., Plaintiff, )


)
vs, ) Case No. ~<J13 - (\j -~ p
)
Julie S. Brunskill. et al.. Defendants. )

It is so Ordered by the date on the electronic file stamp.

BY ORDER OF:

Chief Judge
Eleventh Judicial District

APPROVED BY:

Electronic Copy to: Ms. Linda Tarpley

Printed copy to: Julie Stover-King, fin/a Julie Brunskill


ELECTRONICALLY FILED
2017 Jut 27 PM 12:02
CLERK OF THE CRAWFORD-PITTSBURG DISTRICT COURT
CASE NUMBER: 2017-CV-000072-P

IN THE ELEVENTH .JUDICIAL DISTRICT


STATE OF KANSAS

TO: Hon Daniel D. Creitz


Chief Judge
1 North Washington Ave.
lola, KS 66749

OUT ..OF-DISTRICT ASSIGNMENT ORDER

In accordance with Supreme Court Assignment Nos. 20, and 21, Judicial

Department No.4, each dated April 19,2017, K.S.A. 20-319 and Supreme Court Rule

No. 1.03, you are hereby assigned to hear and determine the following case presently

pending in Crawford County, Kansas, at Pittsburg:

Kasey King, Plaintiff, )


)
vs. ) Case No. 2017 CV 72 P
)
My Town Media, Inc., )
Lori Bolton Fleming, )
Kurtis Loy .. Defendants. )

It is so Ordered by the date on the electronic file stamp.

BY ORDER OF:
dttJ~
AJ. Wachter
Chief Judge
Eleventh Judicial District

APPROVED BY:

Electronic copy to: Prince Adebayo Ogunmeno


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(!Connnission on 31ubitial C!aualifitationg
KANSAS JUDICIAL CENTER
30 I SW ROOM 374
TENTH AVE.,
TOPEKA, KANSAS 66612
785-296-2913
judicialqual@kscourts.org

MEMBERS OF August 16_ 201 "7

PANEL A

Thomas Walters
CHAIR:
213 E. Carlton
Brenda ~L Cameron
Judge :"lember
Pittsburg, Kansas 66762

VICECHAIR: Re: Docket No. 1332. In the Matter of A. J. Wachter


James S. Cooper
~on-Lawrer Member
Dear Mr. Walters:
T errence J. Campbell
Lawyer Member The Commission met August 4, 2017, at which time the above-captioned
complaint was considered. It was the decision of the Commission that appointment of
Robert \\'. Fairchild
Judge :-'Ielnber
a temporary commission was not warranted. It was further the decision of the
Commission to docket your complaint and make further inquiry. The matter will be
Norman R" Kelly placed on the Commission's October 6, 2017, meeting agenda.
Lawyer Member

b~/F
Mary B. Thrower
Judge Member

Rep. \ -aldenia C. \'"ll11l


Non-Lawyer Xlember 4.
Douglas Shima,
Secretary
SECRETARY:
Douglas T. Shima mm
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August 30, 2017

The Attorney Generals Office

120 SW 10th St. Memorial Building 2nd Floor

Topeka Ks 66612

OUSTERCOMPLAINT

Pursuantto K.S.A.60-1206(a)(b)

This is an "Ouster Complaint against ChiefJudge of the 11thjudicial district in Crawford


County AJ. Wachter" under KS.A.60-1206(a)(b). Proceedings to oust a state officer shall
be commenced only by the attorney general. This complaint needs sent to the attorney
generals office because of the "willfulne~s" Judge Andrew James Wachter showed by
removing an entry out of the (ROA)which is commonly known as the court docket because
Julie Stover-King had gotten him previously an admonishment reprimand/caution fr?m the
Kansas commission on judicial qualification for a docketed ethic complaint in the matter of
AJ. Wachter docket number 1114 on June 7, 2011 for his inappropriate comment of
"peanut gallery" and Judge AJ. Wachter dismissed her case after 3 lh years because her
husband Kasey King filed a lawsuit against the judges brother attorney Bill Wachter who
owns the radio station (My Town Media) on June 26, 2017 in the court case titled case
number (2017CV72P Kasey King v. My Town Media, Inc., Lori Bolton Fleming, and Kurtis
Loy filed in Crawford County CivilCourt The very next day on June 27, 2017 Judge AJ.
Wachter retaliated with willfulness and dismissed her counterclaim but did not dismiss
Wells Fargo even though their was a previous dismissal hearing "deleted" from the court
file. This is a violation of Cooperation with Disciplinary Authorities Rule 2.16(A)(B) under
the code of judicial conduct from her previous docketed caution complaint in June 7, 2011
in 1114 in the matter of A.J.Wachter.

Judge AJ. Wachter would love nothing more than to see my friends kicked out on the street
from 303 S. Jefferson for the (peanut gallery) reprimand and the grand jury petition in case
number 2015MR2P and civil lawsuits that have been filed against Judge A.J.Wachter in
15CV79P and his brother BillWachter the attorney. This is the whole reason the code of
judicial conduct has Rule 2.7 Responsibility to Decide which says "Ajudge shall hear and
decide matters assigned to the judge, except when disqualification is required by Rule 2.11
or other law.

The ouster statute requires "(willfulness). "the acts complained of must be willfully
and intentionally done." State ex rel, Stovall v. Meneley, 2000 WL 34001576 at *28 (Kan.
Dist. Ct., Feb. 24, 2000) (citing State ex rel, v. Scates, 43 Kan. 330, 23 P. 479 (1890); State ex
reI. v. GTrinkle, 70 Kan. 396, 78 P. 854 (1904); State ex rel, v. Foley, 107 Kan. 608, 193 P.
361 (1920) State ex reI. v. Wilson, 108 Kan. 641,196 P. 758 (1921); State ex rel. v. Duncan,
134 Kan. 85, 4 P.2d 443 (1931). Although the ouster statutes do not contain a definition of
willfulness, the term has been defined to mean an act "performed" with a designed purpose
or intent on the part of a person to do wrong or to cause an injury to another. II PIK Civ.3d
Section 103.04. The intention of the officer is the key. S. Gard and R. Casad, Kansas Code of
Civil Procedure Annotated 3d Section 60-1205 (1997) (citing State ex reI. Hopkins v. Foley,
107 Kan. 608,193 P. 361 (1920).

Honorable AJ. Wachter failed to consider Constitutional grounds for recusal and Julie
Stover-King's constitutional 5th and 14thamendment rights were violated in case number
13CV32P Wells Fargo vs. Julie Brunskill under the U.S.Constitution under color oflaw.
Plaintiff has been deprived of due process and equal protection under the law. (See Peters
v. Kift 407, U.S. 493,502 (1972).)

Honorable AJ. Wachter finally recused himselffrom case number 13CV32P but not until
July 24, 2017 and just three (3) days later on July 27, 2017 at 12:02 p.m, Judge A.J.Wachter
gave an (OUT-OF-DISTRICTASSIGNMENTORDER)in case number 2017CV72P Kasey King
vs. My Town Media, Lori Bolton Fleming, Kurtis Loy to Chief judge of the 31st judicial
district Daniel D.Creitz whose son Daniel Crietz formerly worked for BillWachter at the
Law Firm of Wilbert and Towner in Pittsburg Kansas in 2014 and 2015. On the same day of
July 27,2017 at 2:05 pm. A.J.Wachter gave another (OUT-OF-DISTRICTASSIGNMENT
ORDER)in case number 2013CV32P Wells Fargo Bank vs. Julie S. Brunskill to the same
chief judge Daniel D. Creitz of the 31st judicial district.

Honorable A.J.Wachter did not comply with K.S.A.20-311d(b)(c) change of judge;


procedure since no judge was required to hear the affidavit or assign the affidavit in the
11th district Judge A.J.Wachter should have notified the departmental justice to assign the
out of district assignment order and not chief judge A.J.Wachter who was disqualified from
hearing or assigning case number 2017CV72P Kasey King vs. My Town Media, Lori Bolton
Fleming, Kurtis Loy because K.S.A.20-311 Disqualification of judge to sit in certain cases
says that if any attorney of record or any party to such case is related. by blood or marriage
to the judge before whom the same is pending, as a spouse, parent, child, grandchild,
grandparent, brother or sister is related to such judge as a result of being a spouse of any
such parent, child, grandchild, grandparent, brother or sister, the judge shall be disqualified
from hearing said case.

Judge A.J.Wachter also was disqualified in case number 2013CV32P Wells Fargo vs.
Julie Brunskill on 7/24/2017 under K.S.A20-311d so therefore Judge AJ. Wachter did not
have any subject-matter jurisdiction to assign the case to judge Daniel Creitz on 7/27/2017
and should have notified the departmental justice to assign the case since AJ. Wachter was
disqualified from assigning orders in both of the above mentioned cases.

I also recently sent in a complaint on AJ. Wacther where the commission on judicial
qualifications met on August 4, 2017 and docketed AJ. Wachter in the matter of A.J.
Wachter docket no. 1332 on August 16, 2017 and I have enclosed the complaint that I sent
to the Kansas Commission on Judicial Qualifications for you to view for evidence to be .
included for the above requested ouster complaint on AJ. Wachter. This is the third (3rd)
different time that A.I. Wachter has been docketed. He was also docketed from a complaint
by Lester Moore in 2013. Please oust this judge for the malicious acts or retaliation and
manipulation of court dockets.

~~trJd~
Thomas Walters

213 E. Carlton

Pittsburg Ks 66762