ORGINAL COPY

TO THE KANSAS SUPRME COURT

No. 100420

IN THE SUPREME COURT OF THE STATE OF KANSAS

DANIEL JOSEPH JACKSON
PETITIONER

vs.

Honorable Judge DANIEL L. HEBERT

RESPONDENT

28TH JUDICIAL DISTRICT COURT

300 WEST ASH
SALINE COUNTY
SALINA KANSAS 67401

PETITION FOR WRIT OF MANDAMUS

DANIEL JOSEPH JACKSON

1124 EAST ASH
POST OFFICE BOX 3506
SALINA KANSAS
67402
785-823-3365
785-577-9979
DANIEL JOSEPH JACKSON )
Plaintiff, )
) No. 100420
vs )
)
Honorable DANIEL L. HEBERT )
Respondent )
__________________________________________)

PETITIONER’S MOTION
REQUESTING

EMERGENCY
STAY OF JUDICIAL PROCEEDINGS

WITHIN
THE 28TH JUDICIAL DISTRICT COURT
FOR THE
DISTRICT OF SALINE COUNTY

COMES NOW THE PETITIONER, DANIEL JOSEPH JACKSON, appearing in properia

personam, and hereby Moves this High Honorable Court, to issue an EMERGENCY ORDER to STAY
the JUDICIAL PROCEEDINGS in the following cases now pending within the 28th JUDICIAL
DISTRICT COURT FOR THE DISTRICT OF SALINE COUNTY, SALINA KANSAS.
TO WIT:
STATE OF KANSAS -vs- DANIEL JOSEPH JACKSON, 2006 – CR -1219
STATE OF KANSAS -vs- DANIEL JOSEPH JACKSON, 2007 – CR - 1201

WHEREFORE IN SUPPORT for the Petitioner’s EMERGENCY MOTION TO STAY

JUDICIAL PROCEEDINGS in the aforementioned, this Petitioner states that in the interest of
repairing a MANIFEST INJUSTICE by the Respondent herein.
 REASONS FOR GRANTING
EMERGENCY STAY
IN SUPPORT OF PETITIONER’S EMERGENCY STAY is stated as follows:
1) That The Petitioner, Daniel Joseph Jackson, is scheduled for Jury Trial to commence
on June 4th 2008 @ 9:00 AM, and that the Trial Judge will not allow the defendant any
more continuances in that action of 2007-CR-1201.
2) That the Petitioner, has filed a Pro Se Motion to Disqualify Defense Counsel Mitchell
Christians for a conflict of Interest, which is presently scheduled for June 2nd 2008
3) That the Petitioner hereby alleges that the Respondent the Honorable Judge Daniel
Hebert refuse to acknowledge pro se status of any criminal defendant, and refuses to
make rulings on Pro Se Motions, as that a Pro Se litigant is not qualified to represent
themselves in criminal matters before his Honorable Court.

FURTHERENCE of the Petitioner’s request that if this EMERGENCY STAY is granted that
neither party will suffer any grievous injury from this High Court granting Petitioner’s Motion.
IN SUPPORT this Petitioner further states that any Judicial Stay of Proceedings in the
aforementioned cases herein, the Petitioner here would voluntarily waive any Constitutional and or
Statutory Right to a speedy trial as set forth in the Kansas Statutes Annotated and the Kansas
Constitution.
Respectfully Submitted;

Daniel Joseph Jackson

1124 East Ash
Post Office box 3506
Salina Kansas 67402-3506
 CERTIFICATE OF SERVICE

THIS CERTIFIES that an accurate photocopy of the document(s) to which this

Certificate is affixed will be served upon the Party identified below by

delivering a copy of same to the person at the address stated below; to wit:

SALINE COUNTY ATTORNEY

300 West Ash – Room 302
Salina, Kansas 67401
ATTORNEY FOR STATE OF KANSAS

AND that a courtesy copy of same will be delivered to the chambers of the presiding judge.

DATED at Salina, Kansas, May 27, 2008

_____________________________________________
/s/ DANIEL JOSEPH JACKSON PRO SE
1124 EAST ASH
POST OFFICE BOX 3506
SALINA KANSAS, 67402

785-823-3365
785-577-9979

PROOF OF SERVICE
I do swear or declare that on this date,__________________ , 2008
I have served the enclosed the PETITION FOR A WRIT OF MANDAMUS on each
party to the above proceeding or that to the opposing party’s counsel,
and on every other person required to be served, by depositing in the
United States mail properly addressed to each of them and with first-
class postage prepaid, or by delivery to a third-party commercial carrier
for delivery within 3 calendar days, and or hand delivering said Writ of
Mandamus personally and or by facsimile delivery to expedite delivery

The names and addresses of those served are as follows:

Honorable Judge Daniel Hebert
Saline County Courthouse
300 West Ash – Room 301
Salina Ks., 67401
Jon Witton
Saline Courthouse – Room 302
300 West Ash
Salina Ks., 67401

Mitchell Christians
316 North Santa Fe
Salina Ks 67401

I declare under penalty of perjury that the foregoing is true and

correct. Executed on this _________day of _________________, 2008

_____________________________
Signature of Movant-Petitioner
DANIEL JOSEPH JACKSON
POST OFFICE BOX 3506
1124 EAST ASH
SALINA KANSAS
67402
785-823-3365
785-577-9979