Lonnie LuPardus Date: Mar 28, 2023

829 Creekside Drive

Gardner, KS 66030
(913) 912 2255
lupardusvshomesite@gmail.com

IN THE DISTRICT COURT OF KANSAS, COUNTY OF JOHNSON

Lonnie LuPardus
Counterclaim Plaintiff .

&. Case NO: 22CV6473

Homesite Insurance et al.

Counterclaim Defendant

LUPARDUS’ MOTION TO DISMISS HOMESITE’S OBJECTION TO BUSINESS

SUBPOENAS AND REQUEST TO QUASH

NOW COMES LONNIE LUPARDUS ("LuPardus") pro se counterclaim plaintiff against

counterclaim defendant HOMESITE INSURANCE (“Homesite”) and third-party AMERICAN

FAMILY INSURANCE (“AFICS”), submitting this response to Homesite’s preposterous Objection to

the Subpoena of Business Records:

Homesite’s objection to the subpoena of business records is frankly preposterous and a clear

waste of the courts time. Homesite in the past has disputed ownership facts when presented with a

receipt of purchase from LuPardus when he submitted items on claims. Homesite had demanded

several other proof of purchase to validate the items, which was provided to them. Homesite would

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Clerk of the District Court, Johnson County Kansas
3/31/2023 12:56:15 TS
still try to assert the argument that “LuPardus has not substantiated ownership of the items” in their

denial letters; thus LuPardus sought direct records from the vendors in order to put to rest any

argument of ownership Homesite would try to state. It is completely ridiculous that Homesite would

object to LuPardus attempting to retrieve receipts directly from the vendors in order to additionally

satisfy Homesite in their request for additional validations of ownership. LuPardus has received

several calls/emails from vendors already concerning the subpoenas; which none of the vendors have

objected to any of the request nor has any vendor stated any type of objection of the request being too

broad or burdensome.

Therefor LuPardus request the courts dismiss Homesite’s preposterous objection to the

submission of the request for business records; and ask the court to stop Homesite from interfering

with LuPardus’ attempts to receive documents that will put to rest any disputes Homesite may assert

concerning ownership of items claimed as they have in the past and still do so on their claim denials,

and allow the third party vendors to assert any claims of broad or burdensome complaints to the courts

themselves and not allow Homesite to stop a process that only furthers their request for additional

information from ownership disputes that they themselves have submitted. Homesite has a duty to

investigate claims fully and has refused to do so. Quashing any request that only further assists in an

investigation and provides Homesite with more information that they requested would not be an act of

good faith and fair dealings, and would further demonstrate LuPardus’ position that Homesite is in

breach of contract, not properly investigating, along with many of the other claims that LuPardus has

made against them.

Respectfully,

Submitted to DCC-Civil Clerks: 3/30/2023

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Clerk of the District Court, Johnson County Kansas
3/31/2023 12:56:15 TS
 829 Creekside Drive
Gardner, KS 66030

Certificate of Service

I certify a true copy of this document was submitted to he Johnson County Court via email at:

dcccivilclerks@jocogov.org on Mar 30, 2023 , and was mailed via prepaid mail at my own

expense to the following parties:

● Klenda Austerman Law

○ ℅ Chris McEglunn
301 N Main
#1600
Wichita, KS 67212
cmcelgunn@klendalaw.com

Respectfully,

829 Creekside Drive

Gardner, KS 66030

Submitted to DCC-Civil Clerks: 3/30/2023

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Clerk of the District Court, Johnson County Kansas
3/31/2023 12:56:15 TS