Motion to Strike Appearance - Vicki

              IN THE CIRCUIT COURT GREENE COUNTY MISSOURI


Marc Perkel - pro se              )
         plaintiff,               )
                                  )
vs.                               )  No. 197CC0170
                                  )
William A. Wear Jr.               )
James R. Sharp                    )
The Law Firm of Wear and Sharp    )
Vicki Stringfellow                )
Donald A. Duncan - pro se         )
The Law Firm of Turner, Reid,     )
Duncan Loomer and Patton, P.C.,   )
         defendants,              )



        MOTION TO STRIKE APPEARANCE AND ENTER DEFAULT JUDGEMENT
                     AGAINST VICKI L. STRINGFELLOW
        -------------------------------------------------------

COMES NOW, Plaintiff Marc Perkel and asks the court to strike the
motions and the appearance of Mr. Sharp who appears as counsel
representing Ms. Stringfellow. His appearance should be stricken on the
basis that the Rules of Professional Conduct Rule 3.7 prohibits Mr.
Sharp from representing these defendants in this action when he has
already been informed that he will be called as a necessary witness. And
his representation is also innapropriate because of Rule 1.7 confilct of
interest.

Plaintiff also asks the court to enter a default judgement against Ms.
Stringfellow for not appearing to answer the pleading. In support of his
motion Pliantiff states as follows:

1) That the Rules of Professional Conduct Rule 1.7 prohibits
   representing opposing parties in litigation and states:

      "Lawyer's Interest. The lawyer's own interests should not be
      permitted to have an adverse effect on the representation of a
      client."

      "Conflict in litigation. Paragraph (a) prohibits representation of
      opposing parties in litigation. Simultaneous representation of
      parties whose interests in litigation may conflict, such as
      co-plaintiff or co-defendants is governed by paragraph (b). An
      impermissable conflict may exist by reason of substantial
      discrepancy in the parties' testimony, incompatibility in
      positions in relation to an opposing party or the fact that there
      are substantially different possibilities of settlement of the
      claims or liabilities in question."

2) Mr. Sharp is a lawyer and knows or should know that he is breaking
   the rules. The Plaintiff is pro se and he knows what the rules are.
   Mr. Sharp is a seasoned lawyer, he went to law school and has a
   degree. He passed the Missouri Bar exam. He therefore is estopped
   from claiming he doesn't already know that this representation is a
   deliberate attempt to tamper with the administration of justice and
   to undermine the judicial process and deny the plaintiff and and his
   client their due process rights to a fair and impartial hearing.
   Plaintiff contends that the conduct of Mr. Sharp shows a deliberate
   and contumacious disregard for the authority of the court. (Fredco
   Reality Inc. v. Jones, 904 S.W.2d 818 Mo. Ct. App. 1995)

3) That because the representation is prohibited, that Mr. Sharp has no
   standing to answer pleadings or to make motions in behalf of Ms.
   Stringfellow. Therefore, the court should strike his motions and
   treat them as if they never existed and she failed to appear.

4) Mr. Sharp maintains a triple role as defendant, advocate, and witness
   which is strictly prohibited by Rules 1.7 and 3.7.

5) Since Ms. Stringfellow has failed to appear to defend herself, the
   Plaintiff is entitled to default judgement.

6) Mr. Sharp and Mr. Wear have already demonstrated why one defendant
   representing another should be prohibited. Mr. Sharp and Mr. Wear
   have failed to file an answer to Plaintiff's amended petition within
   the time allotted and their client, Ms. Stringfellow, is now in
   default for being late.

7) Since Mr. Sharp has already delayed this proceeding for six months
   he should be denied time to obtain different counsel and file a
   responsive pleading or motion. If Ms. Stringfellow wants to respond
   she should get proper counsel now, and file a response according to
   the rules and do so within the time frame allowed under Rule 44. If
   Mr. Duncan, Mr. Wear and Mr. Sharp knowingly and deliberately break
   the rules and Ms. Stringfellow goes along with it, she should suffer
   the consequences.

8) The Plaintiff is sure that if he were to tamper with the Rules the
   way that the defendants are doing that the court wouldn't hesitate to
   grant a default judgement against him. Plaintiff contends that what's
   good for the goose is good for the gander.

WHEREFORE, Plaintiff, having given the defendants plenty of warning
about the improper representation and tampering with the administration
of justice, prays for an order of the court striking the appearance of
Mr. Sharp and to enter a default judgement against Ms. Stringfellow in
favor of the Plaintiff.