Per Rule 59(e), Plaintiff respectfully ***** ***** Honorable Judge Kenneth E. Fulp, Jr. to reconsiderBarrister,
I'm working on a motion for ct to alter its August 16, 2016 Order granting Summary Judgment to the Defendant on Plaintiff’s Claims for, among other reasons,1. Mistake (SCRCP Rule 60(b) regarding the use of res judicata;
2. Estate atty (EA) for Defendant/PR/R/ex's brother/trustee LIED ABT my ADMISSIONs not being timely filed/answered.EA's application of res judicata as his defense against my (Plaintiff/Petitioner’s) claims for the Annuity w. death benefits
and for the Hidden Assets does not apply to this case. In fact, res judicata does not apply to any of Petitioner’s claims in this case because the issues / causes of action are different in each case.• First case: Causes of action – to obtain divorce, due to adultery, and equitable division of marital property;
• Second case: Issue - to set aside only the financial aspects of divorce decree*;
• Third case (pending): Causes of action – to obtain reparation and enforcement of Judge’s divorce orders which ex promised to fulfill, but did not.
Contrary to opposing attorney’s insistence, Petitioner has NOT been attempting to re-litigate her divorce terms. She simply wants the divorce orders to be carried out.*NOTE: The judge denied my motion to set aside. I believe that upholds the judge’s divorce orders in the first case. It is these orders that Petitioner seeks the help of Judge xxx to uphold and enforce.