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DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION FOR DETERMINATION OF DAMAGES AND
FOR DETERMINATION OF THE AMOUNT OF SUPERSEDEAS BOND – 1
Eric Freeze
Eric’s Address
City, ST ZIP Code
Phone | Fax
Email
Defendant in pro per
IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
IN AND FOR SKAGIT COUNTY
XXX , AS TRUSTEE
OF THE ANN G. FREEZE REVOCABLE
TRUST AND OF THE XXX. FREEZE
REVOCABLE TRUST,
Plaintiff,
vs.
ERIC FREEZE,
Defendant
Case No.: XXX
DEFENDANT’S OPPOSITION TO
PLAINTIFF’S MOTION FOR
DETERMINATION OF DAMAGES AND
FOR DETERMINATION OF THE
AMOUNT OF SUPERSEDEAS BOND
NOW COMES Eric Freeze, Defendant, and files this Opposition to Plaintiff’s Motion for
Determination of Damages and for Determination of the Amount of Supersedeas Bond. The
Opposition will be based on the attached Declaration of Eric Freeze. For the reasons stated
therein, Defendant respectfully requests this Honorable Court to DENY Plaintiff’s Motion for
Determination of Damages and for Determination of the Amount of Supersedeas Bond.
Dated this ___ day of August, XXX
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DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION FOR DETERMINATION OF DAMAGES AND
FOR DETERMINATION OF THE AMOUNT OF SUPERSEDEAS BOND – 2
Respectfully Submitted,
___________________________________
XXX,
Defendant in pro per
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DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION FOR DETERMINATION OF DAMAGES AND
FOR DETERMINATION OF THE AMOUNT OF SUPERSEDEAS BOND – 3
DECLARATION OF ERIC FREEZE
I, Eric Freeze, do hereby declare under penalty of perjury as follows:
1. I am a law-abiding male adult citizen competent to make this declaration.
2. I am the Defendant in this matter.
3. Elizabeth Gallagher states that my cohorts and intimidation made prospective buyers and
the current tenant to drop their offer to purchase the property. XXX has failed to
demonstrate Defendant’s acts of intimidation.
4. I was not a party to any transaction regarding the sale of the property that is the subject of
this lawsuit. I have never done anything to intimidate anyone. None of my actions has
caused any loss to Plaintiff. In that regard, I am not liable to pay any purported damages
or interests regarding the alleged failed sale of the property.
5. Elizabeth blames the failing health of Ann Freeze and Ronald Freeze on me. She has
failed to demonstrate which of my actions is causing their health to fail. She has also
failed to demonstrate how exactly my actions have led to deterioration.
6. I am in the process of asserting my rights to the property without an attorney. I have
limited to no knowledge of the law yet I am coming up against an experienced attorney.
7. There is no connection whatsoever between my actions to assert my rights and the
declining health of Ann Freeze and Ronald Freeze. They have a trustee and an attorney
who are handling this case on their behalf. They do not have to deal with any
technicalities of this case. By comparison, I am the one whose health is declining as a
result of this case because I do not have an attorney to represent me.
8. XXX has not brought any evidence to support her claim that the health of XXX Freeze
and XXX has declined as a result of my actions.
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DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION FOR DETERMINATION OF DAMAGES AND
FOR DETERMINATION OF THE AMOUNT OF SUPERSEDEAS BOND – 4
9. XXX seeks award of attorney fees against Defendant. She has not provided any basis
for the attorney fees and costs.
10. XXX seeks award of lost wages from her former role as an elementary school
teacher. It was her decision as an adult of sound mind to quit working as an elementary
teacher. Her former employment as an elementary school teacher has no bearing
whatsoever on this case.
11. XXX, Plaintiff’s attorney, admits that the motion for reconsideration on the order
for sanctions against me has not yet been decided. He further terms it as meritless, which
is a matter for this Court to decide. It is only proper to follow due process and wait for
determination of the motion for reconsideration to compel me to pay sanctions.
12. Paul states that I should be sanctioned for filing frivolous motions. All along, I have been
asserting my rights to the subject property, which Defendants are infringing upon. As a
self-representing litigant, I have followed due process in asserting my rights. I should not
be sanctioned for doing so.
13. Paul states that my actions and conduct continue to significantly harm innocent people.
He has failed to specify which of my actions and conduct have caused “significant” harm.
There is no evidence that any of my actions has caused harm to anyone.
14. Paul states that the sale of the property did not proceed because I refused to move out. He
fails to mention that I responded by stating that I conducted a lot of work for my father,
Peter Freeze, over the years, totaling $700,000.00. He told me that I could stay on the
property for as long as I wanted if I forfeited payment for the work I conducted on the
property, which I agreed to. Peter Freeze had title to the property, which he transferred to
me.
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DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION FOR DETERMINATION OF DAMAGES AND
FOR DETERMINATION OF THE AMOUNT OF SUPERSEDEAS BOND – 5
15. I have not been aggressive in any manner towards the Acuna family. All my actions have
been in utmost good faith.
Dated this ___ day of August, XXX.
Respectfully Submitted,
___________________________________
XXX,
Defendant in pro per
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