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circumstances, the Court must find that the pro se parties knew or should have known that their <br />defense was frivolous or substantially groundless. <br />The Defendants concede in their opening brief that County Court is a Court of general <br />jurisdiction. They then proceed to characterize the Honorable Frederic Rodgers, Judge ofthe County <br />Court, as a "common criminal" who was supporting an "ongoing criminal enterprise" by allowing the <br />trial to continue in this matter. Black's Law Dictionary is cited for the proposition that the County <br />Court Judge was a "trespasser" and therefore acting unlawfully in trying this case. Defendants <br />further rely upon 19th century United States Supreme Court decisions, relating to courts of special or <br />? limited jurisdiction, none of which decisions have any conceivable bearing upon the jurisdiction of <br />the Gilpin County Court in this case. <br />The Defendants' do not base their azguments here upon the evidence presented at trial, and for <br />good reason. I{nowing [hat the evidence of their violations of the County zoning resolution was <br />uncontroverted, they have conjured up a "legal" challenge to the Court's jurisdiction. Defendants <br />knew they were both served with a summons and complaint in this matter, personally, by the Gilpin <br />County Sheriffs Department. Both Defendants, upon reading the Complaint, would know of the <br />existence of the statute (including civil penalty provisions) under which this case was prosecuted by <br />the County. With this knowledge, no reasonable person would conclude that there was any basis <br />whatsoever for an appeal challenging the Court's jurisdiction. <br />CONCLUSION <br />The County Court's statutory jurisdiction to entertain the complaint in this matter is cleaz. The <br />Court's personaljurisdiction over the Defendants is likewise cleazly established. Defendants have <br />not challenged the validity of personal service by the Gilpin County Sheriffs Department and, in <br />fact, have appeared and defended by way of general appearance. The decision by the County Court <br />