MOTION DISQUALIFYING GOP JUDGES FRANK H. EASTERBROOK, RICHARD D. CUDAHY, TERRENCE T. EVANS ET AL

 Greetings to all of my readers in the United States and a special warm greeting to my readers in the International Countries Brazil, Germany and Russia it gives great pleasure to post legal literature that amasses America's interest.

 1.) This Motion is to Disqualify Frank H. Easterbrook Chief Judge, Richard D. Cudahy, Terrence T. Evans for Bias and or Prejudice and Reinstate all Petitions and Motions Dismissed against the Laws of the U.S. Constitution.

It further amplifies that men of color are not granted EQUALITY EQUAL PROTECTION OF THE LAWS and the necessary unlawful procedures exhausted using the laws unlawfully as a weapon preventing men like the Appellant from receiving equality in the courts.

In Germany the African American Pilots Tuskegee Airmen were not allowed to be Democrats but as Republican fighter Pilots they skillfully defeated Hitler saving the Jews from Heinous Ethnic Cleansing of being exterminated in Concentration Camps.

Unlike the era of Racism, Jim Crowism it was the GOP who created precedents in the laws protecting blacks as well as Republicans because the only men who perpetrated vicious Racist Criminal Acts on people of color were the DEMOCRATS! 

Slave Life in America, James S. Olson,(1946) Huntsville Texas, stated, "legal freedom, however, did not mean equality. In Ohio, Indiana, and Illinois white settlers from the South segregated free blacks whenever possible. White workers there feared economic competition from blacks, and black youths were often placed in long-term apprenticeships closely resembling slavery. ..........And throughout the North black people were segregated in public facilities and widely discriminated against in the job market. The North was hardly the promise land".    


2.)  The second document captures an unqualified judge abusing the law in it's entirety where a Rule to Show Cause was properly filed and presented with Affidavits but was DENIED!

3.)  The third document Motion to Disqualify Judge Aurelia Pucinski for Bias (Civil Rights Violations) and or Prejudice pursuant to Canon 3 (c) (1) and to Vacate all orders W/ AFFIDAVIT but was DENIED.
This document demonstrates how Corrupt Judges used their robes and authority to COMMIT DIABOLICAL HEINOUS CIVIL RIGHTS VIOLATIONS AS ex-wife allowed herself to be PIMPED as White Judges orchestrated the falsification of a COMPLAINT for an ORDER OF PROTECTION against Appellant.

In furtherance, to the above said Judges helped his ex-wife receive Welfare unlawfully gave her a job with the Veteran's Administration in Chicago as her reward for helping them as they created and caused CHILD ABUSE AND CRIMINAL NEGLECT ON SAID CHILDREN.

4.)  Appellant filed and presented a Brief before Judge William O'Maki, Danielle Steimel was the Assistant Attorney General, law professor allegedly Loyola University was not able to DEFEND Against said Brief.

The accounts in the Brief demonstrates sordid unimaginable events to the extent RACISM AND NIGGERCISM contributed to undermine a man standing by his children, supporting his children and loving his children with out a scintilla of any type of abuse perpetrated on the children.

It is clear ILLINOIS CITY OF CHICAGO IS NOT A PLACE FOR A FREE BLACK MAN LIKE APPELLANT OR ANY PERSONS OF COLOR (LOOK AT THE JAILS) IF THE SYSTEM OF DEMOCRATIC RACIST ARE NOT ABLE TO INCARCERATE A JUST MAN LIKE THE APPELLANT THEY CREATE ANOTHER METHOD USING A GENOCIDAL APPROACH AS DEMONSTRATED IN THE FOLLOWING DOCUMENTS.

APPELLANT HAS BEEN JOB SECURITY FOR THESE BAND OF TERRORISTS THEY COLLECTED WAGES TRYING TO DEFEAT HIM HE IS ON WELFARE WITH NO INCOME! 

Stay tune to the next post how Judges associate black menBORN FREE AS INMATES AND HOMOSEXUALS.

   

             

                                                    Certificate of Service

  

I Joe Louis Lawrence, plaintiff, certify that I have on this day deposited said Notice of Motion and Motion to Disqualify Judge Frank H. Easterbrook Chief Judge Richard D, Cudahy, Terrence T. Evans et al., in said Notice of Motion via regular mail.

Dated February 22, 2008

                                                                                  _____________________          

                                                                                    Joe Louis Lawrence

                                                            IN THE

                                  UNITED STATES COURT OF APPEALS

                                         FOR THE SEVENTH CIRCUIT

                                            CHICAGO, ILLINOIS 60604

Joe Louis Lawrence                          )       Appeal from the United States

   Plaintiff-Appellant                           )       District Court for the Northern

    No. 07-2287 VS.                           )       District of Illinois, Eastern Division

                                                          )       No. 07 C 1191

Interstate Brands Corporation           )

Chicago Transit Authority                  )

Chicago Police Department               )     

   Defendant-Appellee                        )

                                                 NOTICE OF MOTON

Please be advised that on February 22, 2008, A Motion to Disqualify Frank H. Easterbrook Chief Judge, Richard D. Cudahy, Terrence T. Evans for Bias and or Prejudice and Reinstate all Petitions and Motions Dismissed against the Laws of the U.S. Constitution, has been filed before the United States Court of Appeals.

 Cook County States Attorney                  I.B.C./Wonder bread

        Dick Devine                                     12 East Armour Blvd.

         28 North Clark Street, Suite 300      Kansas City, MO. 64111

         Chicago, Ill. 60602                           Legal Dept.

       Chicago Transit Authority Legal Dept.      Chicago Police Department

       Rachael L. Kaplan                                           Phil Cline                         

       567 West Lake Street Chicago, IL. 60603    3510 South Michigan

       Chicago, Ill. 60661-1498                              Chicago, Ill. 60616

                              

        Director Mueller FBI Wash. D.C.

         Agent James Chatto FBI Chg.

                                                                                            Respectfully Submitted

                                                                                             Joe Louis Lawrence

                                                                                               P.O. Box 490075

                                                                                             Chicago, Ill. 60649

                                                                                               Plaintiff-Appellant

                                                         IN THE

                               UNITED STATES COURT OF APPEALS

                                       FOR THE SEVENTH CIRCUIT

                                          CHICAGO, ILLINOIS 60604

                                                CHIEF JUDGE

                                          Frank H. Easterbrook

Joe Louis Lawrence                          )       Appeal from the United States

   Plaintiff-Appellant                           )       District Court for the Northern

    VS                                                 )       District of Illinois, Eastern Division

   No. 07-2287                                   )       No. 07 C 1191

Interstate Brands Corporation           )

Chicago Transit Authority                  )   MOTION TO DISMISS

Chicago Police Department               )

   Defendant-Appellee                        )

        MOTON FOR – DISQUALIFICATION OF JUDGES- (Frank H. Easterbrook, Terrence T. Evans, Richard D. Cudahy) PERSONAL BIAS OR PREJUDICE {28 USCA 144, 455 (b) (1)} AND REINSTATE ALL PETITIONS AND MOTIONS DISMISSED AGAINST THE LAWS OF THE United States CONSTITUTION

   Now comes Joe Louis Lawrence, Attorney Pro Se Appellant in this cause  files herewith his affidavit as required by Title 28, United States Code, Section 144, to show that the Honorable Frank H. Easterbrook, Chief Judge, Terrence T. Evans, Richard D. Cudahy has a personal bias with compelling evidence or prejudice against him because of his skin color and legally sufficient motions put before the court as a non-licensed attorney and has cited a law relating to an inmate towards appellant in that this is his view of an African American male I (we) are criminals; and is attempting to cover up the systemic legal applications of racism that Appellant has diligently put before the courts, where certain judges and lawyers have participated in said conspiracies.     

   Based thereon, plaintiff-appellant respectfully moves that the Honorable Frank H. Easterbrook, Chief Judge, Richard D. Cudahy, Terrence T. Evans proceed no further herein and that another Judge who is not Bias and understands how to enforce the laws in accordance to the United States Constitution and according to Federal Rules of Civil Procedure to hear this proceeding who is not intimidated or fear reprisals from these individuals.

             February 22, 2008

                                                                               Respectfully Submitted

                                                                                Joe Louis Lawrence

                                                                                 P.O. Box 490075

                                                                                 Chicago, Illinois 60649-0075

                                                      IN THE

                               UNITED STATES COURT OF APPEALS

                                       FOR THE SEVENTH CIRCUIT

                                          CHICAGO, ILLINOIS 60604

                                         AFFIDAVIT

                                 In Support of Motion

     To Disqualify Frank H. Easterbrook, Chief Judge Terrence                            Evans, Richard D. Cudahy For Personal Bias or Prejudice

                              {28 USCA 144, 455 (b) (1)}

And Reinstate All Petitions And Motions Dismissed Against the Laws of the United States Constitution

I Joe Louis Lawrence, being duly sworn on oath states:

1.)          This is the third such motion put before this court against Judge Terrance Evans case#03-3359 where he was successfully recused.

2.)      I am informed and believe and based on such belief with said facts in hand that establishes veracity, that Judge Easterbrook has denied legal representation based upon laws applied to prisoners, inmates behind bars;

A-  That because said Judge do not recognize Appellant as a Free man of color, a United States citizen, regardless to how well or legally sufficient his pleadings has been presented to the courts, due to said Judges Biasness, and Prejudice;

B-  That Judge Easterbrook is aware of the “Systemic” Racial application of Unjust Laws Dispensated against Appellant, where affidavits had been unchallenged and filed before the courts demonstrating he was up against the Ku Klux Klan, attorneys and Judges with racial affiliations, Political Machine operatives with Racial Affiliations with the City etc,. said Judge ignored every unlawful criminal act;

C-    That because he was the architect of the precedented case Farmer V. Haas, demonstrated Racial Hostile Animus Venomous Retaliation Bias against appellant, by unlawfully denying him counsel so as to prevent others of learning of the type of Injustice exercised in the courts, said Judge usurped his powers and authority ignored the United States Supreme Court and other compelling citations that warranted the Appointment of an Attorney;

3.)      Appellant filed a legally sufficient Motion with an Affidavit September 19, 2007 (unchallenged by all attorneys thereby validating the veracity of everything recorded in said Motion) for Disqualification of Judge –Personal Bias or Prejudice {28 USCA 144, 455 (b) (1)} and Reconsideration for Appointment of Counsel (Standish Willis) and Extension of Time to File Brief, August 24, 2007;

4.)      That Chief Judge Frank H. Easterbrook without any legal precedence authority RULED on the Motion filed against him denied it entirely; August 30, 2007;            Prior

5.)      June 11, 2007, Appellant filed a Motion For Appointment of Counsel;

6.)      June 12, 2007, The court immediately entered an order SUSPENDING any briefings pending a Ruling on Motion to Appoint Counsel;

7.)       July 26, 2007, Chief Judge Frank H. Easterbrook, Denied Appointment of Counsel citing Farmer v. Haas, which is an unmerited citation which has no relationship to Appellant, in that “he is no prisoner” .

8.)  August  9, 2007, Appellant filed Motion for Reconsideration for Appointment of Counsel with incredible legal applicable citations demonstrating the Courts error;

9.)  August 15, 2007, Chief Judge, Frank H. Easterbrook took a Personal Bias and Prejudicial stand against Appellant went beyond the jurisdiction of his judicial authority and jurisprudence of the United States Constitution, Denied said Motion for Reconsideration of Appointment of Counsel;

10.)               August 24, 2007, Appellant filed an Unchallenged legally sufficient Motion for Disqualification of Judge-Personal Bias or Prejudice with affidavit {28 USCA 144, 455 (b) (1)} and Reconsideration for Appointment of Counsel (Standish Willis) and Extension of Time to File Brief;

11.)August 30, 2007, Chief Judge, Frank H. Easterbrook DENIED said Motion in it’s entirety;

12.)               September 13, 2007, The court, said judge who authored said Order was not apparent, issued a Rule To Show Cause Order, to Appellant to Show Cause within 14 days why said appeal should not be Dismissed for lack of prosecution pursuant to  Circuit Rule 31 (c) (2);

13.)               September 19, 2007, Appellant responded in a timely Due-Diligent manner with an unchallenged Affidavit and Medical statement from Board Certified Psychiatrist, Traci Powell, the psychological trauma said legal matters has impacted upon appellant and family;

14.)  January 22, 2008, Appellant filed a Petition For Rule To Show Cause/Mandatory Injunction Prohibiting Appellant And Any Other Public Aid Recipient (Work First, Tanf) From Working in Any Capacity Below Minimum Wage W/Affidavit;

15.)   January 22, 2008, Appellant filed a “Motion For Sanctions Pursuant To Federal Rule 11 (b) (c) (1) with Affidavit Compel them to pay to Appellant directly $50,000.00 - $100,000.00 for said Fraudulent Conspiracies”

16.)  January 22, 2008, Appellant filed a “Motion Objecting Appellee’s Request For Extension of Time With Affidavit” Compel them to Pay to Appellant directly $50,000.00 -$100,000.00 for said extension;

17.)    January 24, 2008, Appellant filed a “Emergency Motion For Sanctions Pursuant To Federal Rule 11 (b) (c) (1) with Affidavit Compel CTA to Reinstate & Pay Appellant Back Wages From 1994 To Present In 48 Hours for Said Fraudulent Conspiracies And Admissions And Letter to Credit Bureau His Negative Credit Rating;”

              18.)   January 24, 2008“Appellant filed an EMERGENCY PETITION FOR RULE TO SHOW CAUSE   AGAINST APPELLEE (CTA) & all related Attorneys, PUBLIC Aid employees, DCFS employees, Medical Doctors & employees at Rush Hospital” For FRAUD CONTEMPT AND OTHER RELATED CIVIL RIGHTS VIOLATIONS & CONSPIRACIES INSTANTER w/AFFIDAVIT”

             19.)   Said Judges DENIED every legally Sufficient Instrument presented before the court in an Unlawful Un Constitutional Manner;

                                                                                     COUNT  II

         

1.)          Pursuant to Illinois Rules of Professional Conduct (RPC) (2) fail to disclose to a tribunal a material fact known to the lawyer when disclosure is necessary to avoid assisting a criminal or fraudulent act by the client; (7) engage in other illegal conduct in violation of these rules, said judges violated all of the above and some other laws’

In addition to the above violations, said judges in accordance to the laws Pursuant to Canon 2  from Appellant’s Brief,(13) Commentary to Canon 2 offers a test for the appearance of impropriety: “whether the conduct would create in reasonable minds a perception that the judge’s ability to carry out judicial responsibilities with integrity, impartiality and competence is impaired.” ABA Model Code of Judicial Conduct, Commentary to Canon 2A, paragraph 2 (1990). A reference to the Commentary under 2C alerts one to the fact that the appearance of impropriety can also be created by a judge’s membership in or knowing approval of organizations that engage in invidious discrimination.

(4) Bozarth, 604 A. 2d 100 (N.J. 1992) See also Public Admonishment of Drew (Cal. Comm’n on Judicial Performance, July 1996) (judge admonished for numerous violations including denying a defendant his right to appointed counsel on the grounds of the ability of others to pay for legal representation and the possibility of future employment 

(15) Dash, 564 S.E. 2d 672 (S.C. 2002). The District Court failed to follow and apply said laws in an applicable legal manner.

2.)        Judges Frank Easterbrook, Terrence Evans, and Richard Cudahy have demonstrated unison and further corroboration in desecrating Appellant’s Civil Rights with said Court Orders by not addressing the Unlawful Criminal Acts perpetrated by the Appellee’s and their chain conspirators;

            3.)   Said judges have failed to follow the laws under Canon 2A and the failure to apply the laws to matters that come before them (13) and (15) of Brief, (13) A judges disrespect for the rules of court demonstrates disrespect for the law. Judges are disciplined under Canon 2 A for violating court rules and procedures. Judged ignored mandated witness order in attempt to accommodate witnesses’ schedules; Citing Canon 2A the court noted, “[a] court’s indifference to clearly stated rules breeds disrespect for and discontent with our justice system. Government can not demand respect of the laws by its citizens when its tribunals ignore those very same laws”)

(14) Crawford v. State, 770 N.E. 2d 775 (Ind.)   

(15) Dash, 564 S.E. 2d 672 (S.C. 2002).

          4.)   Judge Cudahy, having complete cognizance Appellant’s Civil Rights were being violated had an ethical duty to report misconduct by other judges(74) Leslie W. Abramson, 25 Hofstra L. Rev. 751 (1997). The Judges Ethical Duty to Report Misconduct by Other Judges and Lawyers and its effect on Judicial Independence. But instead elected, to demonstrate Bias and or Overt Conspiracy in dismissing said Petitions and Motions put before the court, their statement was clear “As Judges they are Above the Law, Federal Officials (FBI) have to Invoke their Authority because they are not Honoring any Laws of the United States Constitution where Appellant is concerned and have demonstrated that fact;”

            5.)   Said judges are cognizant and is deliberately Violating Appellant’s Civil Rights because he stood up to Racial Injustice, the court having cognizance of the FBI’s involvement and has received notice of said facts (30)  Jennings v. Patterson, 488 F. 2d 442, equal access to public facilities. The court found that the plaintiffs had been “denied the right to hold and enjoy their property on the same basis as white citizens.” Jennings suggests the potential usefulness of the equal benefit clause in guaranteeing full and equal enjoyment of public property and public services.” Developments  in the Law section 1981, 15 Harv. Civ. Rts. ---- Civ. Lib. L. Rev 29, 133 (1980). Said judges have demonstrated no regard for the FBI or Appellant in his attempt to obtain Equal Access to the Courts (58)  Scott, 377 Mass. 364, 386 N.E. 2d 218, 220 (1979) See Lopez-Alexander, Unreported Order No. 85-279 (Colo. May 3, 1985) (Judge removed for, inter alia, a persistent pattern of abuse of the contempt power. The Mayor of Denver accepted the findings of the Denver County Court Judicial Qualification Commission that the judge’s conduct could not be characterized as mere mistakes or errors of law and that the conduct constituted willful misconduct in office and conduct prejudicial to the administration of justice that brings the judicial office into disrepute). Canon Ethics where there is a pattern of disregard or indifference, which warrant discipline.

         6.)   Said judges have demonstrated they are “Above the Law” and has employed tactics validating the veracity they are “Untouchable” (69) Vaughn 462 S.E. 2d 728 (Ga. 1995), The Supreme Court of Georgia removed a judge from office for disregarding defendant’s constitutional rights.

          7.)   Said judges have corroborated and demonstrated incredible Bias, in that they have allowed Appellee (City Attorneys) two extensions to submit a brief as they aid and assist said conspirators in trying to defeat Appellant;

       A- Said judges have DENIED every legally sufficient document Appellant put before the court(64) Turner 24 F. Cas. 337 (No. 14247) C.C.D. Md. 1867) The “equal benefit” clause is cited in what would appear to be the earliest reported case enforcing the section. The plaintiff was an emancipated slave who was indentured as an apprentice to her former master. Although both whites and blacks could be indentured as an apprentice, under the law of Maryland, indentured blacks were not accorded the same educational benefits as whites and, unlike whites, were subject to being transferred to any other person in the same county. Circuit Judge Chase granted a writ of habeas corpus upon finding that the purported apprenticeship was in fact involuntary servitude and a denial under the Civil Rights Act of 1866 of the “full and equal benefit of all laws. And most important, (11)Civil Rights Act of 1866- first section, enacted by the Senate and House of Representatives of the United States of America in Congress assembled. That all persons born in the United States and not subject to any foreign power, excluding Indians not taxed, are hereby declared to be citizens of the United States; and such citizens of every race and color, without regard to any previous condition of slavery or involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall have the same right, in every State and Territory in the United States, to make and enforce contracts, to sue, be parties, and give evidence, to inherit, purchase, lease, sell, hold and convey real and personal property, and to full and equal benefit of the laws and proceedings for the security of person and property, as is enjoyed by white citizens, and shall be subject to like punishment, pains, and penalties, and to none other, any law, statute, ordinances, regulation, or custom, to the contrary notwithstanding, Act of April 9, 1866, ch. 31, 1, 14 Stat. 27, 42 U.S.C.A. 1981 (a)   

        8.)   Appellant has notified the FBI formally of the criminal acts perpetrated by said judges as it’s affect how it has traumatized his entire family and is awaiting intervention due to numerous Criminal Violations Overshadowing the Civil aspects of the case;             

         9.)   Appellant’s landlord Tamara Smith is seeking to have him evicted after five years with no problems, Hmm wonder why?

        A- Said judges have done everything unimaginable in trying to destroy Appellant, Unlawful Court Order separating him from his children, False charges of Abuse to children, forced on welfare, being treated as a Prisoner/criminal and because none of their scholar attorneys are able to defeat the Appellant they have elected to destroy him through his children and wife, they have demonstrated corroboration beyond human imagination;

Arkansas Code of Judicial Conduct Commentary to Canon 2 (1988) provides that “(A)” judge must avoid all impropriety” And appearance of impropriety.” Accordingly, (A) judge should disqualify himself in a proceeding in which his impartiality might be questioned. . . . . . “Arkansas Code of Judicial Conduct, Canon 3 (c) (1) 1988.

Where a judge exhibits bias or the appearance of bias, the court will reverse. Patterson V. RT., 301 Ark. 400, 784 S. W. 2d 777 (1990); Farley V. Jester, 257 Ark. 686, 520 S. W. 2d 200 (1975) “ The proper Administration of the requires not only that judges refrain from actual bias, but also that they avoid all appearances of unfairness. “Bolden V. State, 262 Ark 718, 561 S.W. 2d 281 (1978).  

                                                                                         CANON 1

    A judge should uphold the integrity and independence of the judiciary.

The integrity and independence of judges depend in turn upon their acting without fear or favor. Although judges should be independent, they should comply with the law, as well as provisions of this code. Public confidence in the impartiality of the judiciary is maintained by the adherence of each judge to this responsibility. Conversely, violation of this code diminishes public confidence in the judiciary and thereby does injury to the system of government under law.        

   The Miseducation of the Negroe Political Education Neglected

Carter G. Woodson, 1933

The opponents of freedom and social injustice decided to work out a program which would enslave the negroes’ mind in as much as the freedom of body had to be conceded. It was well understood that if by teaching of history the white man could be further assured of his superiority and the negroe could be made to feel that he always been a failure and that the subjection of his will to some other race is necessary for the freedman, then, would still be a slave. If you can control a man’s thinking you do not have to worry about his action. When you determine what a man shall think you do not have to concern yourself about what he will do. If you make a man feel that he is inferior, you do not have to compel him to accept an inferior status, for he will seek it himself. If you make a man think that he is justly an outcast, you do not have to order him to the back door. He will go without being told, and if there is no back door, his very nature will demand one.          

A-  Judge Easterbrook et al judges just like his counter-parts in this matter has demonstrated Biasness and Prejudice at appellant, one can easily infer, due to his status and position as Chief Judge he could deny appellant on any grounds he felt necessary in that no one would question his intellect against a Pro Se Public Aid Litigant after all he is an Ivy league legal Scholar.

Section 1983 of USCS contemplates the depravation of Civil Rights through the unconstitutional application of a law by conspiracy or otherwise. Mansell V. Saunders (CA 5 Fla) 372 F 2d 573, especially if the conspiracy was actually carried into effect and plaintiff was thereby deprived of any rights privileges, or immunities secured by the Constitution and laws, the gist of the action may be treated as one for the depravation of rights under 42 USCS 1983 Lewis V. Brautigam (CA 5 Fla) 227 F 2d 124, 55 Alr 2d 505.        

B-    Judge Easterbrook et al judges has satisfied and met the full criteria’s  of Biasness and Prejudice at appellant in that, Farmer V. Haas is a universal stereotypical analogy how powerful Caucasians view African Americans especially the men (we) are criminals first before we are termed as a man, it is clear he and those that embraces his philosophy oppresses people of color;

794 S.W. 2d 692 (Mo. App. 1990) “No system of justice can function at its best or maintain broad public confidence if a litigant can be compelled to submit his case in a court where the litigant sincerely believes the judge is incompetent or prejudicial …………{T}hat is the price to be paid for a judicial system that seeks to free a litigant from a feeling of oppression”. State ex Rel. McNary V. Jones, 472 S. W. 2d 637, 639-640 (Mo. App. 1971) Indeed, the right to disqualify a judge is “one of the keystones of our legal administration edifice” State ex Rel. Campbell V. Cohn, 606 S.W. 2d 399-401 (Mo. App. 1980). It is vital to public confidence in the legal system that the decisions of the court are not only fair, but also appear fair. Thus whether the disqualification of a judge hinges on a statute or rule in favor of the right to disqualify. A liberal construction is necessary if we wish to promote and maintain public confidence in the judicial system. Kohn, 606 S.W. at 401; State ex Rel. Ford Motor Co. V. Hess S.W. 2d 147, 148 (Mo. App1987).                 

Wherefore the aforementioned reasons  recorded above appellant moves this Honorable court grant the motion in it’s entirety Disqualifying Frank H. Easterbrook, Terrence T. Evans, Richard D. Cudahy from this matter and Reinstate all Petitions and Motions Dismissed against the Laws of the United States Constitution

                                           Further Affiant Sayeth Not 

   Appellant does not feel as if he is a United States Citizen a Free man in America, what Injustice and Racial Oppression Biasness could not do in incarcerating him physically and mentally they accomplished it in the Legal Forum, corruption was allowed to ravish his aspirations, his will, his finances, his family so as to continue their Biasness Prejudicial Doctrine of an African American Man’s place in this society.    

                                                         Respectfully submitted,

                                                           Joe Louis Lawrence

                                               CERTIFICATE OF ATTORNEY PRO SE

   I hereby certify that I am the Attorney Pro Se plaintiff-appellant in the above entitled cause, and as such prepared the above affidavit and is cognizant of the proceedings there is and that such affidavit and application are made in good faith and not for the purpose of hindrance or delay.

                                                               Respectfully Submitted

                                                                 Joe Louis Lawrence

                                                                   Attorney Pro Se

                                                                 P.O. Box 490075  

                                                            Chicago, Illinois 60649-0075  

Friday February 22, 2008

          

   

             

                                                    Certificate of Service

  

I Joe Louis Lawrence, plaintiff, certify that I have on this day deposited said Notice of Motion and Motion to Disqualify Judge Frank H. Easterbrook Chief Judge and Appointment of Counsel to all parties recorded in said Notice of Motion via regular mail.

Dated August 27, 2007

                                                                                  _____________________          

                                                                                    Joe Louis Lawrence

                                                            IN THE

                                  UNITED STATES COURT OF APPEALS

                                         FOR THE SEVENTH CIRCUIT

                                            CHICAGO, ILLINOIS 60604

Joe Louis Lawrence                          )       Appeal from the United States

   Plaintiff-Appellant                           )       District Court for the Northern

    No. 07-2287 VS.                           )       District of Illinois, Eastern Division

                                                          )       No. 07 C 1191

Interstate Brands Corporation           )

Chicago Transit Authority                  )

Chicago Police Department               )     

   Defendant-Appellee                        )

                                                 NOTICE OF MOTON

Please be advised that on January14, 2008, “A PETITION FOR RULE TO SHOW CAUSE/MANDATORY INJUNCTION REMOVAL OF JUDGESFROM BENCH/FRAUD/CONSPIRACY et al” has been filed before the United States Court of Appeals.

: Cook County States Attorney                  I.B.C./Wonder bread

        Dick Devine                                     12 East Armour Blvd.

         28 North Clark Street, Suite 300      Kansas City, MO. 64111

         Chicago, Ill. 60602                           Legal Dept.

       Chicago Transit Authority Legal Dept.      Chicago Police Department

       Rachael L. Kaplan                                           Phil Cline                         

       567 West Lake Street Chicago, IL. 60603    3510 South Michigan

       Chicago, Ill. 60661-1498                              Chicago, Ill. 60616

                              

See Attached Rider

I affirm the above as being true.

                                                                                            Respectfully Submitted

                                                                                             Joe Louis Lawrence

                                                                                               P.O. Box 490075

                                                                                             Chicago, Ill. 60649

                                                                                               Plaintiff-Appellant

                                                         

                                                     IN THE

                               UNITED STATES COURT OF APPEALS

                                       FOR THE SEVENTH CIRCUIT

                                          CHICAGO, ILLINOIS 60604

                                                

                                          

Joe Louis Lawrence                          )       Appeal from the United States

   Plaintiff-Appellant                           )       District Court for the Northern

    VS                                                 )       District of Illinois, Eastern Division

   No. 07-2287                                   )       No. 07 C 1191

Interstate Brands Corporation           )

Chicago Transit Authority                  )  

Chicago Police Department               )

   Defendant-Appellee                        )

 “A MOTION TO SUPPLEMENT (JAN. 14, 2008) RULE TO SHOW CAUSE/MANDATORY INJUNCTION ET AL JUDGES CORROBORATION IN ACTS OF CHICANERY CONSPIRACY”

   Now comes Joe Louis Lawrence, Attorney Pro Se Appellant in this cause files herewith his affidavit as required by Title 28, attesting the veracity and accuracy of all statements recorded within.      

   Based thereon, plaintiff-appellant respectfully moves this Honorable Court who is not Bias and understands how to enforce the laws in accordance to the United States Constitution and according to Federal Rules of Civil Procedure not to act on said matter presented before this court and grant Special Consideration in this matter, due to the unlawful injustices recorded in said Affidavit compelling this court to act in accordance to the Laws of the United States Constitution Instanter to execute jurisdiction over the parties involved in this proceeding who is not intimidated or fear reprisals from these individuals.

             February 13, 2008

                                                                               Respectfully Submitted

                                                                                Joe Louis Lawrence

                                                                                 P.O. Box 490075

                                                                                 Chicago, Illinois 60649-0075

                                                        IN THE

                               UNITED STATES COURT OF APPEALS

                                       FOR THE SEVENTH CIRCUIT

                                          CHICAGO, ILLINOIS 60604

                                         AFFIDAVIT

                                   In Support of Motion

 “A MOTION TO SUPPLEMENT (JAN.14,2008) RULE TO SHOW CAUSE/MANDATORY INJUNCTION ET AL JUDGES CORROBORATION IN ACTS OF CHICANERY CONSPIRACY”

I Joe Louis Lawrence, being duly sworn on oath states:

1.)   That on Jan. 8, 2008, Judge Aurelia Puncski without Legal Constitutional Authority violated Appellant’s Civil Rights in a Chicane attempt to Dispose of the Unlawful Emergency Order of Protection, which named all of Appellant’s children;

        A- That because of Appellant’s skin color said judge ignored everything he had to say, disregarded every legal document he presented to the court;

        B- Said judge demonstrated incredible bias

       

Wherefore the aforementioned reasons recorded above appellant moves this Honorable court to grant the Petition for Rule To Show Cause/ Mandatory Injunction For Removal of Judges From Bench/Fraud/Conspiracy & Compel State To Enforce Subpoenas in it’s entirety before this court and grant Special Considerations due to Medical and extraneous hardships on him and family.

                                                  Further Affiant Sayeth Not 

                                                         Respectfully submitted,

                                                           

                                                           Joe Louis Lawrence

Subscribed and Sworn

Notary

                                                                                            Joe Louis Lawrence

                                                                                                                                       __________________

                                                              CERTIFICATE OF ATTORNEY PRO SE

   I hereby certify that I am the Attorney Pro Se plaintiff-appellant in the above entitled cause, and as such prepared the above affidavit and is cognizant of the proceedings there is and that such affidavit and application are made in good faith and not for the purpose of hindrance or delay.

                                                               Respectfully Submitted

                                                                 Joe Louis Lawrence

                                                                   Attorney Pro Se

                                                                 P.O. Box 490075  

                                                            Chicago, Illinois 60649-0075  

Monday January 14, 2008

          

Rider

Director Mueller FBI, Wash. D.C., Agent James Chatto, Chicago Crime Commission.

Hon. Bruce Lester, Administrative Law Judge              Donald P. Jonker                                                                               

Department of Children and Family Services                Litigation Attorney

Administrative Hearings Unit                         Illinois Dept. of Children & Family Services

17 North State Street, 7^th floor                                     7600 West 183^rd St. Pine Hall-2^nd Fl

Chicago, Illinois 60602                                                   Tinley Park, Illinois 60477

                                         

Carolyn Lawrence                                            Hon. Aurelia Pucinski Presiding Judge

720 West Marquette Road                                       555 West Harrison    (07 OP-2625)

Chicago, Ill. 60621                                                 Chicago, Ill. 60607 Cal. 71

Jessica Johnson UIC Fax 312 413-4684

Dr. Powers Community Mental Health Fax 734-6447 or 734-5994

L.K. McIntosh Local Office Administrator Public Aid Fax 602-4344

Linda Medical Records Riveredge Hospital Fax 708 771 8409

John Robinson/via Pamela Jeffries DCFS Fax 312 793-3546

Dr. Joyce Smith Near North Health Services Fax 312 337-7616

Mary Thompson Office of Emergency Fax

Connie Smith Rush Psychiatry Fax 312 942-5372

David L. Fox Senior Vice-President Kids Hope United Fax 847 245-6714

IN THE CIRCUIT COURT

OF

COOK COUNTY, ILLNOIS

DOMESTIC RELATIONS DIVISION

Carolyn Lawrence

            Petitioner                                                                                 Case # 07 OP 2625

                                                                                                            Calendar 71

            V

Joe Louis Lawrence.

            Respondent

Motion for Disqualification of Judge (Aurelia Pucinski) Due to Bias (Civil Rights Violations) and or Prejudice pursuant to Canon 3(C) (1) /Vacate all Orders

  “FRAUD” “ERROR” & “CRIMINAL CONSPIRACY” WITH AFFIDAVIT

 In Accordance to The Cook County Circuit Court Rule 13.2

Now comes defendant, Joe Louis Lawrence, Attorney Pro Se, in this cause, files herewith his affidavit, factually establishing the Bias (Civil Rights Violations) Prejudice alleged herein, with exhibits, in accordance to Supreme Court of Illinois and Canon rules in accordance to the American Jurisprudence and pleadings (rev.) to show that the Honorable Aurelia Pucinski, has a personal bias or prejudice against the defendant and has demonstrated such in violating his civil rights and is attempting to cover up corroboration and criminal conspiracy by Judge Carr she has personal knowledge of disputed evidentiary facts concerning the proceeding; she is acting as Carolyn’s lawyer in the proceeding for the adverse party in an attempt to cover up the unprecedented criminal conspiracy fraud perpetrated on the courts;

Based thereon defendant respectfully moves that the Honorable Aurelia Puncski proceed no further herein, and that the Honorable Timothy Evans, Chief Judge of the Circuit Court of Cook County assign this matter accordingly.

This is the first motion in this cause made by the movant, attacking said Judges credibility in this division.

Respectfully Submitted,

By:   ________________________

Attorney Pro Se 

 Joe Louis Lawrence        

STATE OF ILLINOIS   )

                                        )

COUNTY OF COOK    )

                                                                 AFFIDAVIT

In support of Motion to Disqualify Judge Aurelia Pucinski for Bias (Civil Rights Violations) and or Prejudice pursuant to Canon 3 (c) (1) and to Vacate all orders:

1.)   I am Joe Louis Lawrence, Attorney Pro Se, defendant in this cause, being first duly sworn on oath deposes and states, as follows;

2.)     I am informed and believe and based on such information and belief, allege that the Honorable Aurelia Pucinski whom this cause has pended before, has a Personal Bias and or Prejudice at respondent and has violated his Civil Rights and favors Carolyn Lawrence because she has falsified every document necessary to help said Judges of a Racial Conspiratory network; attempt to demoralize and denigrate respondents character as a father and husband and prohibited her from responding to any of respondents motions; 

             Arkansas Code of Judicial Conduct Commentary to Canon 2 (1988) provides that “{A} judge must avoid all impropriety.” And appearance of impropriety.” Accordingly, “{A} judge should disqualify himself in a proceeding in which his impartiality might reasonably be questioned …..”Arkansas Code of Judicial Conduct, Canon 3 (C) (1) 1988.

        Where a judge exhibits bias or the appearance of bias, the court will reverse. Patterson v. R.T., 301 Ark. 400, 784 S.W. 2d 777 (1990); Farley v. Jester, 257 Ark. 686, 520 S.W. 2d 200 (1975) “The proper administration of the law requires not only that judges refrain from actual bias, but also that they avoid all appearances of unfairness. “Bolden v. State, 262 Ark. 718, 561 S.W. 2d 281 (1978).

3.)     The facts and reasons for the belief that such Bias and or Prejudice and Civil Rights Violations exists, are that, the following laws were noticeably maliciously violated, Judge Pucinski having complete knowledge and was aware of all “fraudulent” acts perpetrated by Judge Carr and Carolyn Lawrence, ignored all legally sufficient instruments respondents filed before the courts;

Judge Pucinski had knowledge respondent never attacked his daughter, had knowledge Carolyn and Pre’shious committed fraud on the courts, and ignored all criminal acts because said judges were seemingly the architects behind this “diabolical scheme”

A-   August 16, 2007, respondent filed Motion to Vacate Emergency Order of Protection & Impose Sanctions for Fraud on the Court; said motion demonstrated Carolyn had a history of filing “Bogus” Order of Protections, Judge Miranda Dismissed the prior Order of Protection, told her, “these are issues for family therapy not a court room and not to bring this mess back to court” judge told respondent, “go home to his children; Judge ignored said motion;

B-   Oct. 1, 2007, Respondent filed a motion to supplement the DCFS Record with Affidavit, said record reflected Carolyn informed Police “my husband never hit our daughter, she was attacking him trying to hit and kick him, I was right there behind him”, Judge ignored said DCFS record;

C-   Said judge ignored all evidence where Psychiatrists and other professionals applauded and commended respondents position as a father keeping his family together, in spite of Carolyn remaining in denial of her mental illness;

D-   Oct. 17, 2007, Respondent filed a Motion again to Vacate Order of Protection due to Lies Inconsistencies and Falsehoods, Judge Pucnski ignored every document that respondent filed before her validating the veracity, she has corroborated her role in said Criminal Conspiracy, Demonstrated Diabolical Racial Prejudice Bias at Respondent;

E-   Said judge was determined to Violate any and all Laws necessary to prove to respondent as Judge she was able to do whatever she wanted because she is above the Law; respondent thanks her because this is what the FBI requested corroboration.

F-    Dec. 26, 2007, Respondent filed a Petition for Rule To Show Cause for Direct and Indirect Civil Contempt and Compel the Production of Records Instanter & Impose Sanctions, Adm Law Judge Bruce Lester needed her Contempt Power to Compel the production of records because the parties were in contempt of court, She refused to Intervene and did not rule on any document respondent filed before her;      

G-   February 26, 2008, Judge Pucinski informed respondent there is no other court order in the files and presented the Agreed Order, hereto attached, Ex. A, hereto attached, Ex. B, Court Order contradicting and demonstrating her part in said conspiracy;

Said judge has demonstrated she is “Above the Law” and has employed tactics validating the veracity, she is “Untouchable” (69) Vaughn 462 S.E. 2d 728 (Ga. 1995), The Supreme Court of Georgia removed a judge from office for disregarding defendant’s constitutional rights.

H-  Said judge had an ethical duty to Report Misconduct by other judges but instead elected to take on respondent litigiously thinking she could defeat him (74) Leslie W. Abramson, 25 Hofstra L. Rev. 751 (1997). The Judges Ethical Duty to Report Misconduct by Other Judges and Lawyers and its effect on Judicial Independence.

I-              Said judge is Criminally Bias and has overwhelmingly validated the veracity of every assertion recorded in said Brief, hereto attached, Courtesy Copy of the actual Brief filed in the Court of Appeals;

The CTA’s top litigators could not effectively defend or attack said brief, the judge’s posture in said manner has decimated any credible response by the City’s attorneys.)   Said judges have failed to follow the laws under Canon 2A and the failure to apply the laws to matters that come before them (13) and (15) of Brief, (13) A judges disrespect for the rules of court demonstrates disrespect for the law. Judges are disciplined under Canon 2A for violating court rules and procedures. Judge ignored mandated witness order in attempt to accommodate witnesses’ schedules; Citing Canon 2A the court noted, “[a] court’s indifference to clearly stated rules breeds disrespect for and discontent with our justice system. Government can not demand respect of the laws by its citizens when its tribunals ignore those very same laws”)

(14) Crawford v. State, 770 N.E. 2d 775 (Ind.)   

(15) Dash, 564 S.E. 2d 672 (S.C. 2002).

J-   Said judge was more concerned with respondent divorcing his wife, she demonstrated no integrity, and has truly corroborated her involvement in said conspiracy and recognizable Bias said judge can explain to the FBI the real motive for her encouraging divorce, rather than upholding the tenements of the law.     

                                                 CANON 1

       A Judge should uphold the INTEGRITY and independence of           the JUDICIARY.

      The integrity and independence of judges depend in turn upon their acting without fear or favor. Although judges should be independent, they should comply with the law, as well as the provisions of this code. Public confidence in the impartiality of the judiciary is maintained by the adherence of each judge to this responsibility. Conversely, violation of this code diminishes public confidence in the judiciary and thereby does injury to the system of government under law.

K-   Judge Pucinski was aware used this unlawful Order of Protection matter in which to advance her Racial Retaliatory Conspiratory acts of “FRAUD” against the respondent so as to harm him,

While the trial court has a duty to ensure that “no falsehood or other fraud is perpetrated in court;” Cameron v. Cameron, supra, 187 Conn. At 170, 444 A. 2d 915; and may in its discretion question witnesses; La bow, Supra, 13 Conn. App. At 335, 537 A. 2d 157; the trial judge also has a duty to maintain a calm demeanor, the decorum of the court room and avoid any action which might suggest partiality.   

               Economically Oppress him, Economical Murder, demonstrated Racial Hatred Prejudice Bias, demonstrated Unequal treatment of the laws, demonstrated Disparate Dispensation of the laws at the defendant due to his skin color, demonstrated how effective she was able to Induce Reliance on the Court  in conspiring against defendant, in that, said individuals of this Secret Fraternal Order Invoked Racial Apartheid, Invoked Genocidal applications of the laws in accordance to their by-laws of the fraternity, and total disregard to any laws of the United States Constitution;

4.)   Judge Pucinski violated defendants Civil Rights so as to demonstrate regardless to how well defendant maybe in the knowledge and applications of the laws despite his innocence, despite 20 plus attorneys, assistant States Attorneys and law professors could not handle him litigiously, he is a criminal and a nigger, what the judge could not say verbally was articulated in her unlawful applications of the laws; 

794 S.W. 2d 692 (Mo. App. 1990) “No system of justice can function at its best or maintain broad public confidence if a litigant can be compelled to submit his case in a court where the litigant sincerely believes the judge is incompetent or prejudicial…… {T}hat is the price to be paid for a judicial system that seeks to free a litigant from a feeling of oppression”. State ex Rel. McNary v. Jones, 472 S.W. 2d. 637, 639-640 (Mo. App. 1971) Indeed, the right to disqualify a judge is “one of the keystones of our legal administration edifice“ State ex Rel. Campbell v. Kohn, 606 S.W. 2d 399-401(Mo. App. 1980). It is vital to public confidence in the legal system that the decisions of the court are not only fair, but also appear fair. Thus whether the disqualification of a judge hinges on a statute or rule in favor of the right to disqualify. A liberal construction is necessary if we wish to promote and maintain public confidence in the judicial system. Kohn, 606 S.W. 2d at 401; State ex Rel. Ford Motor Co. v. Hess S.W. 2d 147, 148 (Mo. App. 1987).

5.)    Judge Puncski resented respondent being a great father, a African American man is not suppose to be family oriented, look at the Jails;

this was admitted via affidavit by Judge Murphy;

             A- Judge Pucnski had the “racist audacity” to state in open court petitioners daughter is unstable, and that she could not in any way grant her an extension on the Order of Protection on the testimony of a 15 year old; 

Section 1983 of USCS contemplates the depravation of Civil Rights through the unconstitutional application of a law by conspiracy or otherwise. Mansell V. Saunders ( CA 5 FLa) 372 F 2d 573,especially if the conspiracy was actually carried into effect and plaintiff was thereby deprived of any rights privileges, or immunities secured by the Constitution and laws, the gist of the action may be treated as one for the depravation of rights under 42 USCS 1983 Lewis V. Brautigam (CA 5 Fla) 227 F 2d 124, 55 Alr 2d 505.

No judge makes respondent sign an Agreed Order unlawfully and not expect a legal

Retaliation, hereto attached, February 22, 2008, Motion for Disqualification of Judges (Frank H. Easterbrook, Terrence T. Evans, Richard D. Cudahy) Personal Bias or Prejudice {28 USCA 144, 455 (b)(1) and Reinstate all Petitions and Motions Dismissed against the Laws of the United States Constitution;

On May 29, 2007, Judge John T. Carr without Legal Constitutional Authority endorsed an Emergency Order of Protection against respondent unlawfully, hereto attached, Ex. C, Petition For Rule To Show Cause/Mandatory Injunction Removal Of Judges From Bench/Fraud/Conspiracy & Compel State To Enforce Subpoenas;

A-    Said Judge having complete cognizance of the procedural applications of the law, realized Pre’shious complaint in no way warranted any type of Emergency Court Orders against respondent;

  B-  Said Judge had Carolyn Lawrence to Amend the complaint, she gave a Fraudulent account to the events alleged with Judicial support Fraud admissibility great latitude is permitted in proving fraud C.J.S. Fraud 104 ET Seg. Fraud 51-57. where a question of fraud and deceit is the issue involved in a case, great latitude is ordinarily permitted in the introduction of evidence, and courts allow the greatest liberality in the method of examination and in the scope of inquiry Vigus V. O’Bannon, 1886 8 N.E 788, 118 ILL 334. Hazelton V. Carolus, 1907 132 ILL. App. 512.    

        

6)   Pre’shious records, “my dad was telling me to go to my room”

7)    Carolyn records, “my husband push my daughter Pre’shious in the back in to her room. Once he got her into the room I could’nt see what was going on”

8)    That on May 29^th, 2007, Carolyn abandoned the household and had her Ex. Boyfriend (Andre Taylor) who happens to be her sister’s Sonia Dorsey children’s father. Said individual moved all of Carolyn’s possessions in his Conversion van to her mother’s Section 8 complex;

9)    That because of the above, she no longer had legal jurisdiction over the children because everything was transferred into husband’s name, Carolyn was removed from the grant;

10)  That she realized because of the aforementioned, she had no means of support or income;

a.     She used the courts to exercise her diabolical scheme to engage in incredible criminal acts, so as to receive Public Aid using mothers Section 8 residence;

              B- The courts used her to exercise their Racial Conspiratory Acts in an attempt to destroy respondent using said wife by allowing her to falsify any document necessary to destroy him and children, the court has engaged in Fraud, assisting Carolyn; INDUCING RELIANCE

To prevail in a cause of action for fraud, plaintiff must prove that defendant made statement of material nature which was relied on by victim and was made for purposes of inducing reliance, and that victim’s reliance led to his injury. Parsons V. Winter, 1986, 1 Dist., 491 N.E. 2d 1236, 96 ILL Dec. 776, 142 ILL App 3d 354, Appeal Denied.

     In Carter V. Mueller 457 N.E. 2d 1335 ILL. App. 1 Dist. 1983 The Supreme Court has held that: “The elements of a cause of action for fraudulent misrepresentation (sometimes referred to as “fraud and deceit” or deceit) are: (1) False statement of material fact; (2) known or believed to be false by the party making it; (3) intent to induce the other party to act; (4) action by the other party in reliance on the truth of the statement; and (5) damage to the other party resulting from such reliance.

7)   That Judge Puncski having complete cognizance of legal procedures ignored every legally sufficient instrument respondent filed in the courts with Affidavits, establishing his innocence, Properly alleged facts within an affidavit that are not contradicted by counter affidavit are taken as true, despite the existence of contrary averments in the adverse party’s pleadings. Professional Group Travel, Ltd. v. Professional Seminar Consultants Inc., 136 ILL App 3d 1084, 483 N.E. 2d 1291; Buzzard v. Bolger, 117 ILL App 3d 887, 453 N.E. 2d 1129 et al.

           A- Jan. 8^th, 2008, Judge Puncski ignored Carolyn’s Amended Petition, Judge Carr signed off on made reference to an unauthorized Complaint Pre’shious signed as a basis for which she could not grant an Emergency Order of Protection, that which she Dismissed; Although some trial judges may not review the orders of other judges, because that would not be consistent with the orderly administration of justice or with our judicial system People ex rel. Kelly, Ketting Furth, Lnc. V. Epstein, 61 ILL 2d, 229, 335 N.E. 2d 430 (1974) (Appeal of order as proper remedy); Cruz v. Columbus-Cuneo-Cabrini Medical Center, 194 ILL App. 3d 1037, 551 N.E. 2d 1345, 141. Dec. 817 (1^st Dist. 1990)

ILL. App. (1^st Dist. 2000). A “VOID JUDGEMENT OR ORDER” is one that is entered by a court lacking jurisdiction over the parties or the subject matter, or lacking the inherent power to enter the particular order of judgment, or where the order was procured by FRAUD- in re Adoption of E.L., 248 ILL. Dec. 171, 733 N.E. 2d 846, 315 ILL. App. 3d 137- Judgm 7, 16, 375.  

    Review of the orders of one judge by another in the same case is not consistent with effective judicial administration. W. R. Grace & Co. v. Baker Industries, Inc., 128 ILL. App. 3d 215, 470 N.E. 2d 577, 83 ILL. Dec. 451 (1^st Dist. 1984).

     Although the chancery division of the County Department of the Circuit Court and the Municipal Department of the Circuit Court have concurrent jurisdiction of actions to demolish buildings, where the municipal department first acquired jurisdiction of the subject matter and entered an order of demolition, the county department could not properly assume jurisdiction and enter an order preventing municipal departments from entering an order of demolition. Pepin v. City of Chicago, 79 ILL. App. 2d 295, 224 N.E. 587 (1^st Dist. 1967).             

b.     Judge Carr Induced incredible Reliance upon the Court when he signed court orders unlawfully;

Judge Pucnski demonstrating Conspiratory involvement trying to save said Judge by dismissing said Emergency Order of Protection using the Complaint Pre’shious signed, which was a “Draconian Error” U. S Sup Court Digest 24(1) General Conspiracy

U.S. 2003. Essence of a conspiracy is an agreement to commit an unlawful act.—U.S. v. Jimenez Recio,; 123 SCt. 819, 537 U.S. 270, 154 L.Ed.2d 744, on remand 371F.3d 1093

         Agreement to commit an unlawful act, which constitutes the essence of a conspiracy, is a distinct evil that exist and be punished whether or not the substantive crime ensues.-Id.

         Conspiracy poses a threat to the public over and above the threat of the commission of the relevant substantive crime, both because the combination in crime makes more likely the commission of other crimes and because it decreases the part from their path of criminality.-Id.

CONSPIRACY

Fraud maybe inferred from nature of acts complained of, individual and collective interest of alleged conspirators, situation, intimacy, and relation of parties at time of commission of acts, and generally all circumstances preceding and attending culmination of claimed conspiracy Illinois Rockford Corp. V. Kulp, 1968, 242 N.E. 2d 228, 41 ILL. 2d 215.

 

      Conspirators to be guilty of offense need not have entered into conspiracy at same time or have taken part in all its actions. People V. Hardison, 1985, 911 Dec. 162, 108. Requisite mens rea elements of conspiracy are satisfied upon showings of agreement of offense with intent that offense be committed; Actus reas element is satisfied of act in furtherance of agreement People V. Mordick, 1981, 50 ILL, Dec. 63

c.     Said Judge stated, the agreed order would be in effect for only 5-6 months;

Said respondent was unaware, said judge finagled an entry extending the order until Jan. 8^th, 2009; Supreme Court Rule [137] provides in pertinent part:

            If a pleading, motion, or other paper is signed in violation of this Rule, the court, upon motion or upon its own initiative, may impose upon the person who signed it , a represented party, or both, an appropriate sanction, which may include an order to pay to the other party or parties the amount of reasonable expenses incurred because of the filling of the pleading, motion, or other paper, including a reasonable attorney fee. Not only will the courts consider an award of sanctions for active false statements: failures to disclose material facts to the court can also justify an award of sanctions.

BRUBAKKEN v. Morrison, No. 1-9-1670, 1992 Ill App. LEXIS 2144 (1^st Dist. Dec. 30, 1992). Additionally, the fact that a false statement or omission is the result of an honest mistake is no defense to entry of a sanction. ID. To the extent that an individual lawyer has engaged in sanctionable conduct, that lawyer’s firm can also be jointly and severally liable with the lawyer.

d.     Said Judge was cognizant Judge Carr did not have a court reporter present when he signed the Amended Complaint, this was an attempt to conceal his involvement working with the conspirators;

The Judges violated page 18 of respondents brief before the court of Appeals

Respondents Brief has 80 (legal Citations) footnotes, page 19, due to said judges ethnic make up demonstrates a fraternal unification (13) Commentary to Canon 2 offers a test for the appearance of impropriety: “whether the conduct would create in reasonable minds a perception that the judge’s ability to carry out judicial responsibilities with integrity, impartiality and competence is impaired.” ABA Model Code of Judicial Conduct, Commentary to Canon 2A, paragraph 2 (1990). A reference to the Commentary under 2C alerts one to the fact that the appearance of impropriety can also be created by a judge’s membership in or knowing approval of organizations that engage in invidious discrimination.

                                                                     Respectfully Submitted

                                                                     Joe Louis Lawrence

                                                                      P.O. Box 490075

                                                                     Chicago, Illinois 60649-0075

   

WHEREFORE the aforementioned reasons respondent respectfully requests:

 Disqualify Judge Aurelia Pucinski for Bias (Civil Rights Violations) and or     Prejudice pursuant to Canon 3 (c) (1) and to Vacate all orders:

1.)  Order Pre’shious Lawrence, Carolyn Lawrence into the Mental Hospital for their Bipolar Disorder, to reinstate medication;

2.)  Impose Sanctions on Parties and any other members complicit in said conspiracies;

3.)  Invoke any Sanctions and all remedies not mentioned this court deems just on parties not complying with Court Subpoena;

   Under penalties as provided by law pursuant to 735 1265 5\1-109, the undersigned certifies that the statements set forth in this instrument are true and correct, except as to matters therein stated to be on information and belief and as to such matters, the undersigned certifies as afore said that he verily believe the same to be true.

                                                                                            Respectfully Submitted,

                                                                                               Joe Louis Lawrence

                                                                                                Attorney Pro Se

NOTARY

                                                                                            Joe Louis Lawrence

                                                                                       ______________________     

   NOTICE OF RESPONDENT’S MOTION OF JUDGE (AURELIA PUNCSKI) DUE TO BIAS (CIVIL RIGHTS VIOLATIONS) AND OR PREJUDICE PURSUANT TO CANON 3 (C) (1) ET AL.

Rider:

Director Mueller FBI, Wash. D.C., Agent James Chatto, Chicago Crime Commission.

Cook County Sheriff will serve said Notice to Disqualify Judge Aurelia Puncski et al. to the noted parties

(1) Chief Judge Timothy C. Evans Room 2600 Daley Center

(2) Domestic Relations Presiding Judge Mosche Jacobius Room 1905 Daley Center

(3) Hon. Bruce Lester, Administrative Law Judge   (4) Donald P. Jonker                                                                               

Department of Children and Family Services                Litigation Attorney

Administrative Hearings Unit                         Illinois Dept. of Children & Family Services

17 North State Street, 7^th floor                                     7600 West 183^rd St. Pine Hall-2^nd Fl

Chicago, Illinois 60602                                                   Tinley Park, Illinois 60477

                                         

(5) Carolyn Lawrence                                           

720 West Marquette Road                                      

Chicago, Ill. 60621                                                

All parties violated Chief Administrative Law Judge Meryl Paniak’s subpoenas requesting the production of medical records:

(6) Jessica Johnson UIC Child Psychiatry Records Department 912 South Wood, Bsmt. Chg. Ill

(7) Dr. Powers Community Mental Health 8701 South Constance, Chicago, Ill 60617

(8) L.K. McIntosh Local Office Administrator Public Aid 8001 South Cottage Grove, Chicago Ill 60619;

(9) Linda Medical Records Riveredge Hospital, 8311 West Roosevelt Road, Forest Park Ill 60130

(10)  John Robinson/via Pamela Jeffries DCFS records department 6201 South Emerald Chicago Ill 60621;

(11)  Dr. Joyce Smith Near North Health Services 1276 North Clyborn Ave Chicago, Ill

(12)  Mary Thompson Office of Emergency 1411 West Madison Chicago, Illinois 60607

(13)  Connie Smith Rush Psychiatry 1720 West Polk Street Chicago, Ill

(14)  David L. Fox Senior Vice-President Kids Hope United 215 North Milwaukee Lake Villa, Illinois 60046.

IN THE CIRCUIT COURT OF COOK COUNTY ILLINOIS

CHANCERY DIVISION

 Joe Louis Lawrence                                                             Case # 09 CH 1773

        Plaintiff-Appellant

          VS                                                                                         

                                                                                              Hon. William O. Maki

 Erwin McEwen, Dir. of DCFS                                            

 Et al

        Defendants-Appellees   

                                          

                                                Brief of Appellant

                                                                       Respectfully Submitted

                                                                        Joe Louis Lawrence

                                                                         Plaintiff-Appellant

                                       TABLE OF CONTENTS

Table of Contents………………………………………………………………………..1

Memorandum of Law…………………………………………………………………....2

Statement of The Issues………………………………………………………………….4

Statement of the Case……………………………………………………………………5

Statement of the Facts…………………………………………………………………...6

Summary of Argument…………………………………………………………………..11

Argument………………………………………………………………………………...12

Reply Brief filed before the U.S.C.A April 4, 2008…………………………………......

Exhibits attached to Reply Brief…………………………………………………………

Medical Pages deleted from record…………………………………………………1a-4d

A- Standard of Review………………………………………………………………….13

B - The Administrative Law Judge and Attorneys Erred in abusing the adversarial process violating the Illinois Rules of Professional Conduct, RPC a lawyer shall not violate and the fact that numerous municipal customs exercised and practiced by various Judges on all levels, State agencies ignored the Civil Rights violations perpetrated against Appellant, Exhibits A – X demonstrates multiple acts of systemic applications of constitutional violations, in that judges and State Agencies acted as decision makers possessing final authority, Brown v. Bryan County, OKL., 67 F. 3d 1174 (1995), Stokes v. Bullins, 844 F. 2d 269, 275 (5^th Cir. 1988), Wassum v. City of Bellaire, Texas, 861 F. 2d 453, 456 (5^th Cir. 1988), Benavides v. County of Wilson, 955 F. 2d 968, 972 (5^th Cir.) cert. denied,__ U.S.__, 113 S.Ct. 79, 121 L. Ed. 2d 43 (1992), “Liability will accrue for the acts of a municipal official when the official possess “final policymaking authority” to establish municipal policy with respect to the conduct that resulted in a violation of constitutional rights. Pembaur v. City of Cincinnati, 475 U.S. 469, 483, 106 S. Ct. 1292, 1300, 89 L.Ed. 2d 452 (1986) (plurality opinion),Smith v. Wade U.S. 30, 35, 103 S. Ct.1625, 1629, 75 L Ed 2d 632 (1983) ....………………………………………………………………………………………… …6, 7, 8, 9,12  See Reply Brief

C - (70) Vigus v. O’Bannon, 1886 N.E. 788, 118 Ill. 334; Hazelton v. Carolus, 1907 132 Ill. App. 512; Carter v. Mueller 457 N.E. 2d 1335 Ill. App. 1 Dist. 1983, The Supreme court has held that: “The elements of a cause of action for fraudulent misrepresentation (sometimes referred to as “(fraud and deceit)”are: (1) False statement of material fact; (2) known or believed to be false by the party making it; (3) intent to induce the other party to act; (4) action by the other party in reliance on the truth of the statement; and (5) damage to the other party resulting from such reliance……………15 See Brief of Record

 D-  (1) Beatie v. People, 33 Ill. App 651, 189 WL 2373 (1st Dist.1989). As is making false representations to the court. People v. Katelhut, 332 Ill. App. 693, 54 N.E. 2d 590, (1st Dist. 1944). Misconduct of an officer of the court is punishable as contempt. People ex rel. Rusch v. Levin, 305 Ill. App. 142, 26 N. E. 2d 895 (1st Dist. 1939).  

E- (39) Section 1983 of U.S.C.S. contemplates the depravation of Civil Rights through the Unconstitutional Application of a Law by conspiracy or otherwise. Mansell v. Saunders (CA 5 F 1A) 372 F 573, especially if the conspiracy was actually carried into effect, where an action is for a conspiracy to interfere with Civil Rights under 42 U.S.C.S. 1985 (3), or for the depravation of such rights under 42 U.S.C.S. 1983, if the conspiracy was actually carried into effect and plaintiff was thereby deprived of any rights, privileges, or immunities secured by the United States Constitution and Laws, the gist of the action maybe treated as one for the depravation of rights under 42 U.S.C.S. 1983, Lewis v. Brautigam (CA 5 F 1a) 227 F 2d 124, 55 Alr 2d 505, John W. Strong, 185, 777-78 (4 th ed. 1992)……………………………………………………………………………………………….. ….12 See Brief of Record      

IN THE CIRCUIT COURT OF COOK COUNTY ILLINOIS

CHANCERY DIVISION

 Joe Louis Lawrence                                                             Case # 09 CH 1773

        Plaintiff-Appellant

          VS                                                                                         

                                                                                              Hon. William O. Maki

 Erwin McEwen, Dir. of DCFS                                            

 Et al

        Defendants-Appellees   

                                           

                                                MEMORANDUM OF LAW

Order Entered: September 13, 2008;

Appeal/Administrative Review filed: January 16, 2009;

STATUTES: FRAUD, PERJURY, UNEQUAL PROTECTION OF THE LAWS VIOLATIONS, JUDICIAL ERRORS, JUDICIAL IMPERSONATION, JUDICIAL ABUSE OF DISCRETION, DISPARATE UNEQUAL PROTECTION OF THE LAWS, PUBLIC, POLITICAL, FRATERNAL CORRUPTION CONSPIRACY, VIOLATIONS OF CANON ETHICS 3D (1) REPORTING JUDICIAL MISCONDUCT, VIOLATIONS CANON ETHICS 3D (2) REPORTING LAWYER MISCONDUCT

Appellant is appealing for a Judicial Review of the Department’s decision under the provisions of the Admin. Rev. Law, 735 ILCS 5/3-101 for total EXPUNGEMENT with SANCTIONS or in the alternative refer this matter to the appropriate JURISDICTION for the foregoing stated above;

The Circuit Court Chancery Division has the Jurisdiction to correct any errors had in the Administrative Law Division;

Appellant is before the Circuit Court Chancery Division because as a “Pro Se” litigant certain JUDGES/Attorneys for the State and a host of others have been allowed to falsify and submit any FRAUDULENT document necessary to INDUCE RELIANCE on any party they sought to deceive;

Appellant is before the Circuit Court Chancery Division because as a “Pro Se” litigant, he has been treated as a NOBODY certain Judges have ignored every Legally sufficient instrument with Affidavits unchallenged, he has filed before the Administrative Hearings Unit, Circuit Court of Cook County validating the VERACITY of numerous FRAUDS, and other Irregularities that was systematically IGNORED;

The Circuit Court Chancery Division will recognize that said record reflected Appellant committed no acts of ABUSE of any sorts by the Preponderance of the evidence presented, especially where Judge Pucinski who had Jurisdiction in said matter had an obvious BIAS against Appellant could not uphold any charges against Appellant despite changing the rules in her own court in allowing VERBAL testimony ignoring all documentations and evidence proving Appellant committed no abuse;

The Circuit Court Chancery Division will recognize the Admin. Law Judge lacked Jurisdiction and the inherent power to enter any Judgment against the Appellant.

I affirm the above as being true.       

  

                                                                       Respectfully Submitted

                                                                        Joe Louis Lawrence

                                                                         Plaintiff-Appellant

                                                                            

                              STATEMENT OF THE ISSUES

1.)     Whether the Administrative Law Judge Bruce Lester “Gregariously” Erred by assuming jurisdiction of a legal matter where he had no jurisdiction;

2.)    Whether the Administrative Law Judge Bruce Lester had knowledge prior conspiring with Meryl Paniak, Associate Deputy Director as he IMPERSONATED the AUTHORITY and POSITION as  CHIEF ADMINISTRATIVE LAW JUDGE when he endorsed CERTIFIED SUBPOENAS when it was proper for Philip C. Dalmage, Chief Administrative Law Judge to endorse any and all Subpoenas;

A-     Administrative Law Judge Bruce Lester acknowledged and admitted, see Exhibit B of Appellant’s Brief filed in the 7^th Circuit Court of Appeals, April 4, 2008, hereto attached, and referenced within and throughout this Brief;

3.)     Whether Donald P. Jonker, Beth Solomon and Larry Alberg were meticulously involved in “fixing” said matter corroborating with Judge Lester’s Directives as Civil Rights Violations were being perpetrated against Appellant or working with another anonymous source not mentioned or identified in any present legal documents;

4.)   Whether the aforementioned stated within share the same perception as their colleague Chief Judge of the 7^th Circuit Judge Frank H. Easterbrook, that a black man is deemed a Prisoner and not a FREE MAN, See Motion for Disqualification of Judge Affidavit et al., of Record 840-849, See Page 841 B-C  (B) That Judge Easterbrook is aware of the “Systemic” Racial application of Unjust Laws Dispensated against Appellant, where affidavits had been unchallenged and filed before the courts demonstrating he was up against the Ku Klux Klan, attorneys and Judges with racial affiliations, Political Machine operatives with Racial Affiliations with the City etc,. said Judge ignored every unlawful criminal act;

( C)  That because he was the architect of the Precedent case Farmer V. Haas, demonstrated Racial Hostile Animus Venomous Retaliation Bias against appellant, by unlawfully denying him counsel so as to prevent others of learning of the type of Injustice exercised in the courts, said Judge usurped his powers and authority ignored the United States Supreme Court and other compelling citations that warranted the Appointment of an Attorney;

5.)    Whether the aforementioned stated within followed his Directives, See Record 845 D-E of Affidavit Judge Easterbrook just like his counter-parts in this matter who demonstrated Biasness and Prejudice at appellant, one can easily infer, due to his status and position as Chief Judge he could deny appellant on any grounds he felt necessary in that no one would question his intellect against a Pro Se Public Aid Litigant after all he is an Ivy league legal Scholar.

Judge Easterbrook has satisfied and met the full criteria’s  of Biasness and Prejudice at appellant in that, Farmer V. Haas is a universal stereotypical analogy how powerful Caucasians view African Americans especially the men (we) are criminals first before we are termed as a man, it is clear he and those that embraces his philosophy oppresses people of color;

             No Attorney in any Venue Challenged or Objected to said Affidavit.

                               STATEMENT OF THE CASE

As referenced on Page 12 of Appellant’s Brief, of Record 395 first Par. As it relates to this very case, Adm. Law Judge Bruce Lester ignored the entire record of criminal acts of Fraud as he assisted all related conspirators as they engaged in systematic Racial Acts of Civil Rights Violations, See Reply Brief, Table of Contents  iD, Bruce Lester and all related conspirators violated all of D, furthermore, “Liability will accrue for the acts of a municipal official when the official possess “final policy making authority” to establish municipal policy with respect to the conduct that resulted in a violation of Constitutional rights.” Brown v. Bryan County, OKL., 67 F. 3d 1174 (1995), Stokes v. Bullins, 844 F. 2d 269, 275 (5^th Cir. 1988), Benavides v. County of Wilson, 955 F. 2d 968, 972 (5^th Cir.) cert. denied,____U.S. ___, 113 S. Ct. 79, 121 L.Ed. 2d 43 (1992),

(30)  Jennings v. Patterson, 488 F. 2d 442, equal access to public facilities. The court found that the plaintiffs had been “denied the right to hold and enjoy their property on the same basis as white citizens.” Jennings suggest the potential usefulness of the equal benefit clause in guaranteeing full and equal enjoyment of public property and public services.” Developments in the Law section 1981, 15 Harv. Civ. Rts. ---- Civ. Lib. L. Rev 29, 133 (1980) See Page 14 of Brief.

68) U. S. Sup Court Digest 24(1) General Conspiracy, U.S. 2003, Essence of a conspiracy is an agreement to commit an unlawful act.----U.S. v. Jimenez Recio,; 123 S Ct. 819, 537 U.S. 270, 154 L. Ed 2d 744, on remand 371 F. 3d 1093 See Page 14, 17.

(11) Civil Rights Act of 1866- first section, enacted by the Senate and House of Representatives of the United States of America in Congress assembled. That all persons born in the United States and not subject to any foreign power, excluding Indians not taxed, are hereby declared to be citizens of the United States; and such citizens of every race and color, without regard to any previous condition of slavery or involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall have the same right, in every State and Territory in the United States, to make and enforce contracts, to sue, be parties, and give evidence, to inherit, purchase, lease, sell, hold and convey real and personal property, and to full and equal benefit of the laws and proceedings for the security of person and property, as is enjoyed by white citizens, and shall be subject to like punishment, pains, and penalties, and to none other, any law, statute, ordinances, regulation, or custom, to the contrary notwithstanding, Act of April 9, 1866, ch. 31, 1, 14 Stat. 27, 42 U.S.C.A. 1981 (a) See Page 12 of Brief.                

(64) Turner 24 F. Cas. 337 (No. 14247) C.C.D. Md. 1867) The “equal benefit” clause is cited in what would appear to be the earliest reported case enforcing the section. The plaintiff was an emancipated slave who was indentured as an apprentice to her former master. Although both whites and blacks could be indentured as an apprentice, under the law of Maryland, indentured blacks were not accorded the same educational benefits as whites and, unlike whites, were subject to being transferred to any other person in the same county. Circuit Judge Chase granted a writ of habeas corpus upon finding that the purported apprenticeship was in fact involuntary servitude and a denial under the Civil Rights Act of 1866 of the “full and equal benefit of all laws, See Page 12, 17 of Brief.

                            STATEMENT OF THE FACTS

 

1)      January 16, 2009, Plaintiff filed Judicial Review Appeal et al., Ref as C00003 of Vol. 1 with Affidavit;

2)      February 18, 2009, Appellee filed Defendant’s Motion to Strike Unnecessary and Misjoined Defendant’s and Defendant’s Motion to Extend the time for the filing of it’s answer in Administrative review and to seal the record on Adm. Review, Ref as C00071;

3)       March 10, 2009, Plaintiff filed a Motion Objecting Defendant’s Motion to Strike Unnecessary and Misjoined Defendant’s/Objecting Record be Sealed Rule To Show Cause for “Fraud”  “Civil Rights Violations” “Contempt of Court” “Perjury” “Criminal Conspiracy/Cover-up Conspiracy” “Judicial Impersonation Corruption” Other Irregularities and Impose Sanctions with Affidavit, Ref as C00079 of Vol. 1;

A-    Defendant did not Object or Deny any of the issues raised  in said Affidavit, Ref as C00080 of Vol. 1;  

B-    March 11, 2009, Circuit Court stated to Plaintiff “  said, “up here we do things differently, he was not getting a hearing on his Motion;”

C-    March 11, 2009,

4)      March 11, 2009, Circuit Court ignored Plaintiff’s motion Ref as C00079 and granted Defendant’s motion Ref as C00088 of Vol. 1, said order in #3 identifies ALJ’s 1,2 and 3 as Judges #3 is not a Judge he is an attorney, (Associate Deputy Director), the court signed the order and was not given the copy to review before presenting it to the court;

5)      April 9, 2009, Plaintiff  filed a Motion for Disqualification  of Judge due to Bias (Civil Rights Violations and or Prejudice pursuant to Canon 3 (C) (1) and to Vacate all her Orders/Change Venue, Ref as C00089 of Vol. 1;

6)      April 9, 2009, Plaintiff filed a  Motion for Default Judgment Remand/Body Attachment et al., Ref as C00103 of Vol. 1; Defendant’ never answered or responded to the Plaintiff

7)      April 16, 2009, Circuit Court Judge ignored the Default Motion and counsel was allowed to rephrase his motion “Plaintiff’s motion is deemed a substitution of judge et al” Ref as C00106 of Vol. 1;

8)      Appellee never responded nor did she mail any records to Appellant;

9)      Appellant ReNoticed Motion for Default May 18, 2009, and ReNoticed Motion Objecting Defendant McEwen’s Motion to Strike Unnecessary et al., this Motion somehow went ignored, but the Default was set for hearing Aug. 31, 2009 @11 am, thereby avoiding any type of Restitution to Appellant for this Frivolous Litigation;

10)  Appeared before Judge Maki with Danielle May 27, 2009, on Appellant’s Motions, he informed her he was not able to access the records because they were impounded not sealed and questioned why? Said Judge informed Appellant he could file a Motion anytime in his court and asked him if he wanted Sanctions imposed on Counsel, his reply was that, “it was premature to make that admission without the records” Counsel was Ordered to produce the records and provide the court Courtesy Copies of the entire record;

11)    Circuit court Judge signed the court order , May 27, 2009, “Plaintiff’s Motion For Default is entered continued to Aug. 31 @ 11am”, Ref as C00111 of Vol. 1;     

12) On May 27, 2009, Assistant Attorney General, with deliberate malice and intentions “LIED” Induced Reliance upon the Circuit court made a fabricated admission to him in court saying she mailed to petitioner copy of said record which has 932 pages; and requests strictest proof thereof;

A-    Said attorney recorded in writing under Certificate of Service, the undersigned an attorney certifies that a copy of this notice was served upon the above named at the address, postage prepaid, by depositing the same in the United States mail chute at 100 W. Randolph St.

B-    Said attorney having falsified the necessary documents so as to undermine and deceive this court and prevent Petitioner from ascertaining said documents so as to prolong this “Frivolous” litigation;

C-    Said attorney was cognizant Meryl Paniak, Associate Deputy Director, unlawfully impersonated the position of the Chief Administrative Law Judge in endorsing Subpoenas, See Exs. 412-424 of Record;

D-    Said Chief Administrative Law Judge, Philip C. Dalmage certified the records March 10, 2009, see record 932;

E-    Said attorney was cognizant DCFS officials James Chism fabricated accounts along with Erwen McEwen, Carolyn Lawrence minor Pre’shious Lawrence, Marcia Ward, and a host of others;

F-     That James Chism DCFS reported in his report Officer Paul Downing stated, “Joseph got upset and hit Pre’shious with a closed fist to the top of the forehead, Page 14 of 69 of Rationale: of Record 44

G-    Page  41 of 69, of Record 71 & 59 of 69, of Record 89 reports James Chism made a call to Officer Downing, left a voice message for a return phone call twice:

H-    Page 60 of 69, of Record 90 James Chism went to the Police station and attempted to see officer Wiedenski, and was informed the officer was not in and told he could not leave a message;

   12.)  May 29, 2009, Appellant diligently filed a Petition for Rule To Show Cause for Willful Misrepresentations to Court /Fraud on Court Perjury/ Criminal Conspiratory Acts/ Civil Rights Violations/ Contempt of Court other Irregularities Remand/ Body Attachment Instanter Impose Sanctions with Affidavit, Danielle did not Object or Deny any of the facts presented to the court, said Judge Maki Demonstrated a different Demeanor in the court room DENIED said Petition, See Page 12 of Petitioners Brief (11) of Record 395 Civil Rights Act of 1866 “of the full and equal benefit of all laws” also (64) Turner 24 F. Cas. 337 (No. 14247) C.C.D. Md. 1867) It is clear State Courts have satisfied and demonstrated a Disparate dispensation on how laws are adjudicated when it involves Blacks as noted on page 10 of the Reply Brief; And have demonstrated throughout both Briefs and Reply Briefs the architecture in how cases are systematically dispensated as illustrated in both separate documents in a Racist Unequal Protection of the Laws manner thereby validating the veracity to every assertion recorded in said Briefs;

  13.)  That Page 9 Par. 4 of the Reply Brief throughout unequivocally demonstrate the negative control systematically Racism has over the Courts certain Judges, State Agencies in eluding the laws of the United States Constitution as they invoke Racial Hate crimes using Laws that which to achieve and demonstrate Racial Supremacy in the Courts in Oppressing the Black Man with Tortuous Racial Apartheid Acts Surpassing human imagination in a country where said Draconian acts have been abolished.

 

   14.)  Page 35 of 69, of Record 65 Said Supervisor of DCFS Patricia Young, stated in her Supervisory note, “the following is needed to assess, service and complete this case” Do a body chart; inquire with all children to what happened, CRITICAL DECISION OPEN THIS CASE UP FOR INTACT SERVICES et al;

   15.)  Page 48 of 69, of Record 78 Patricia Young of the Supervisory Note, “the following is needed to complete this investigation and assess the safety of the alleged victim, locate the minor, obtain written consents from the mother and Pre’shious covering all psych history et al.;

   16.)  Page 93, 94, of Records 123, 124 Letters from Paul Carter, MD, Supervisor Judy White-Worthy, “given several on going psychosocial factors, it is my recommendation that Mr. Joe Lawrence be as involved as possible with the family on a daily basis”, Ms. Rahman was involved with the Lawrence family for approximately 10 months. While servicing the family she worked on several goals, such as individual and family counseling through Rush Hospital, Mother remains in denial of needing meds for her emotional stability. The accomplishments that has occurred in this family is due to Mr. Lawrence tenacity and cooperation. He did what was expected of him as a father.

   17.)  Page 86 of 96, of Record 116 December 29, 2004, Becky Batiz, LSW, Child Protection Specialist, INDICATED a finding of Substantial Risk of Physical Injury/Environment Injurious to Health and Welfare by Neglect against Carolyn Lawrence;

   18.)  Hereto attached, Exs. 1a-4d Said Medical pages deleted from record so as to cover-up Marcia Wards cover-up in falsifying Medical dx of Pre’shious Lawrence should be in between pages 640-646;

    A- Ex 2b of Medical records deleted sent to DCFS under Subpoena records 8-09-05 13 yold AAF h/o BAD & ODD, page 2a Bio M: Bipolar D/O 5-11-05 medical records reveal mother bipolar diagnosed 93; From the Reply Brief Ex U and V page 9, specific diagnosis was recorded despite the obvious removal of said documents;

   19.)  Page 2, Ex 238 of  records tendered, University of Ill Family Clinic, Jewel Tomlinson, MSW, LCSW, Social Worker interviewing last par. States “Pre’shious who has been diagnosed as having bi polar disorder and who her father described during the second interview as exhibiting behavior similar to the central character in the movie “Exorcist” including “foaming” at the mouth. During the first interview the family history of bipolar disorder was discussed and Mrs. Lawrence became tearful when talking about how she feels , including her difficulty in getting out of bed.”  

    Fraud admissibility great latitude is permitted in proving fraud C.J.S. Fraud 104 ET Seg. Fraud 51-57. where a question of fraud and deceit is the issue involved in a case,  great latitude is ordinarily permitted in the introduction of evidence, and courts allow the greatest liberality in the method of examination and in the scope of inquiry Vigus V. O’Bannon, 1886 8 N.E 788, 118 ILL 334. Hazelton V. Carolus, 1907 132 ILL. App. 512.

   20.)   Court Transcript Records:

Page 8, Line 8  of record 268, Judge asked Carolyn if she seen the incident?, Line 9 Carolyn responded, “I didn’t actually see how it started, I seen how it ended”

Page 9, Line 17 of record 269, Carolyn said, “and once they got back past the shelf in her room I couldn’t see what took place, Line 20, “so by the time I seen them they had went into her room also”.

Page 20, Line 11 of record 271, Petitioner asked Pre’shious, “did you and I ever make it into your room?, her response, “no we did not”

21.)  Pre’shious records, before Judge Carr “my dad was telling me to go to my room”, “when I refused he ran towards me with closed fist and hit me with them against my chest which made me almost lose my balance into almost falling but when I got back to my feet he grabbed me in a choke hold position and rammed my face and forehead into several walls”.

22.)  Carolyn Amends the Complaint Pre’shious signed records, “my husband push my daughter Pre’shious in the back in to her room. Once he got her into the room I couldn’t see what was going on but when I saw them again Joseph had Preshious in some kind of hold”

23.)  That because of the above, she no longer had legal jurisdiction over the children because everything was in husband’s name, Carolyn was removed from the grant;

24.)  That she realized because of the aforementioned, she had no means of support or income;

A-    She used the courts to exercise her diabolical scheme to engage in incredible criminal acts, so as to receive Public Aid using mothers Section 8 residence;

              B-  The courts, State employees and everyone else necessary used her to exercise their Racial Conspiratory Acts in an attempt to destroy Appellant, using said wife by allowing her to falsify any document necessary to destroy him and children, the courts and others have engaged in Fraud, and causing Child Abuse and Child Endangering assisting Carolyn ; INDUCING RELIANCE

To prevail in a cause of action for fraud, plaintiff must prove that defendant made statement of material nature which was relied on by victim and was made for purposes of inducing reliance, and that victim’s reliance led to his injury. Parsons V. Winter, 1986, 1 Dist., 491 N.E. 2d 1236, 96 ILL Dec. 776, 142 ILL App 3d 354, Appeal Denied.

     In Carter V. Mueller 457 N.E. 2d 1335 ILL. App. 1 Dist. 1983 The Supreme Court has held that: “The elements of a cause of action for fraudulent misrepresentation (sometimes referred to as “fraud and deceit” or deceit) are: (1) False statement of material fact; (2) known or believed to be false by the party making it; (3) intent to induce the other party to act; (4) action by the other party in reliance on the truth of the statement; and (5) damage to the other party resulting from such reliance.

25.)  That Judge Puncski having complete cognizance of legal procedures ignored every legally sufficient instrument Petitioner filed in the courts with Affidavits, establishing his innocence,   Motion for Disqualification of Judge (Aurelia Pucinski) Due to Bias (Civil Rights Violations) and or Prejudice pursuant to Canon 3 (c) (1)/ Vacate all Orders “FRAUD” “ERROR” & CRIMINAL CONSPIRACY WITH AFFIDAVIT In accordance to the Cook County Circuit Rule 13.2

a.     Said judge never denied or objected to any of the facts recorded in said affidavit;

b.     Page 4, Lines 6-7 of record is 264 omitted, it should state, “I have filed numerous documents you have ignored demonstrating no abuse of any sort took place”, Line 8-18 Judge responded, “Sir, you have filed a number of things. However, not all of them are actually motions or pleadings. A lot of paper work that you have filed and did not have a date spindled on it to consider it. so if we were to consider everything that is going on in this case today, we would be starting from scratch with Carolyn Lawrence providing to you and the Court information of her testimony about why she feels that she needs an order of protection on behalf of Pre’shious. And you being allowed to answer those allegations. That’s why we are here today”.

c.     Line 19-21, Petitioners response, “so you are saying that the documents that I submitted, the D.C.F.S. records, and my response is not going to be considered?

d.     Line 22-24, Page 4, 5 Judge Pucinski, “Well, as far as I can tell, sir, the D.C.F.S. records doesn’t have anything to do with---Did you give it to her first of all? Page 5, Line 1, of record 265, her response was “yes”, Judge Pucinski, “Okay. The D.C.F.S. records—I don’t believe that there are any findings from D.C.F.S. I didn’t see any findings; am I wrong”? Petitioner was very angry with emphatical gestures, his response was “yes”

e.     Lines 7-13 Judge stated, Where are the findings? I see all sorts of stuff to the Illinois Department of Children & Family Services from you. And I see all sorts of filings. I see a list of documents. I see communications. I looked through this pretty carefully last night and I could not find anything that was actually from D.C.F.S. related to Pre’shious. Do you have any documents like that?”  Petitioner’s response, “yes, you have a courtesy copy of the actual record. ( Petitioner is looking at the judge with the D.C.F.S. records in her hands as she sat there lying about not having the records)

f.      Lines 19-23 Page 5 of Record Petitioner stated, “The motion to supplement the record with the D.C.F.S. affidavits. They indicated me as the perpetrator, based upon the number of inconsistencies. And this matter is pending before the Administrative Hearings unit” (the judge seemed to be doing everything trying to irritate Petitioner and confuse the issues trying to knock him off his square)

g.     Line 24, Line 1, page 6, of record 266, Judge stated, Well, then that judge is going to decide what is going to happen. Is it still pending? Carolyn’s response, “I have no ideal” Judge was angry, said “You have no ideal? It is your daughter. Line 6-7, Carolyn’s response, And investigation against what? I don’t understand what he’s talking about?, Judge, he’s saying that there is a case still pending with D.C.F.S., is that correct? Her response, “Yes. He had D.C.F.S. come back to my mother’s house, as far as I know it is going to be dropped.”             

             E.- Assistant Attorney General has  Induced incredible Reliance upon this Court when she frivolously litigated this matter and prolonging it so as to wear down and oppress Petitioner and his children for standing up to racial injustice lodged at him by numerous conspirators, in that, Appellant filed a Motion for Medical Board Investigation/Referral to Attorney General for Prosecution/Fraud Ex 541-543, of Record Judge Lester along with Donald P. Jonker ignored the Criminal allegations and Denied said MOTION;

    26.)   To further establish Carolyn Lawrence’s criminal conspiratory involvement with the actions of Assistant Attorney General and other conspirators, Page 33, 34, Line 7- 13, of Record 363-364, clearly, a vivid account of the facts presented in Petitioners testimony; Line 18 Judge Pucinski asks Carolyn “Anything else to add? Her reply, Line 19 “No that is what took place”

              A-  Judge Pucinski stated, “Page 38, Line 22-24, of record 368, I am worried about Pre’shious. I mean Pre’shious appears to be an intelligent fifteen years old. Everybody that has ever raised a fifteen year old daughter knows that from the starting point they could be difficult. But I would say that based on the testimony that we have Pre’shious is a couple notches above just ordinary difficulty, she is a runaway. She got issues with her dad, and her brothers. She’s testified that she has been seen by doctors. I’m not going to put a whole lot of emphasis on that because this is not really the Court to deal with that”.

Line 11-17 page 39, of record 369, Judge stated, “But I don’t see how an order of protection is going to necessarily be a good thing. I don’t see how an order of protection so that her father can be arrested if he has contact with her is a good thing to put in the hands of a fifteen year old that I would consider to be at least moderately unstable, I don’t think that is the right remedy, I can’t do that.”

Line 18-24, she further stated, “And as I told you before about the petition, and her testimony did not match her petition. I know she is only fifteen, and I understand she may have forgotten part of it, but is real specific about specific hitting. She never testified about any hitting. I’m really not inclined to enter an order of protection in this matter. But on the other hand I don’t really just want to wash my hands of this family and say go out there and fin for yourselves”.    

27.)        June 8, 2009, Circuit Court Judge ignored Plaintiff’s unchallenged motion with affidavit, “Petition For Rule To Show Cause For Willful Misrepresentations To The Court/Fraud on Court Perjury/Criminal Conspiratory Acts/ Civil Rights Violations/Contempt of Court other Irregularities Remand/Body Attachment Instanter Impose Sanctions, Ref as C00205 of Vol. 1;

28.)        June 17, 2009, Plaintiff filed a Motion To Reset Hearing Date and Appellee Response Date w/ Affidavit, Ref as C00265 of Vol. II;

A-    Plaintiff submitted his order with his motion Ref as C00268 of Vol. II;

29.)        June 23, 2009, Circuit Court Judge ignored Plaintiff’s motion, it was neither challenged or objected to by opposing counsel, and was denied, Ref as C00416 of Vol. II;

30.)        July 30, 2009, Plaintiff filed an Emergency Petition For Rule To Show Cause Reconsideration of Order Due to Corroboration of Perjury/Criminal Mail Fraud Civil Rights Violations/Contempt of Court other Irregularities Remand/Body Attachment Instanter Impose Sanctions, Ref as C00269 of Vol. II;

A-    That said Emergency Petition Ref as C00269 of Vol. II was accompanied by affidavit Ref as C00270 of Vol. II;

31.)        July 23, 2009, Circuit Court denied said Emergency Petition et al Ref as C00417 of Vol. II, said Petition was never denied or objected to by counsel;

32.)        June 11, 2009, Plaintiff filed his brief, Ref as C00363 of Vol. II in compliance to court order Ref as C00111 of Vol. II;

33.)        August 3, 2009, Asst. Atty. Gen. circumvented and disobeyed court order, Ref as C00111 of Vol. II filed “Defendant’s Memorandum of Law in Support of the Final Administrative Decision” did not respond or answer Plaintiff’s brief or answer or respond to any documents Plaintiff presented before the courts;

34.)        August 18, 2009, Plaintiff filed “Petitioner’s Reply to What is Captioned Defendant’s Memorandum of Law in Support of the Final Administrative Decision”, Ref as C00460 of Vol. II, in compliance to court order, Ref as C00111 of Vol. II, with an affidavit;

35.)        August 31, 2009, Circuit Court Judge did not validate or certify court order with his signature, Ref as C00567 of Vol. III;

A-    That the clerks never received his original copy with signature pursuant to S. Ct. Rule 272, the Asst. Atty. Gen. did submit a draft order, Plaintiff reviewed it before it was presented to the court;

B-    That this is the only court order the Circuit Court did not sign, which caused vexatious delays in presenting the record before the Appellate Court in a timely manner;

36.)        September 1, 2009, Plaintiff filed his Notice of Appeal, Ref as C00568 of Vol. III, along with his Jurisdictional Statement, Ref as C00570 of Vol. III;

37.)        October 6, 2009, Plaintiff filed his “Notice of Filing Motion For Order Releasing Record For Preparation on Appeal, Ref as C00575;

A-    That said motion was accompanied by an affidavit Ref as C00577;

B-    The Clerks in Chancery needed a Court Order because the record was Sealed and Impounded—It was sealed and Impounded because an attorney impersonated the position and authority of the Chief Adm. Law Judge endorsing subpoenas;

C-    That the Asst. Atty. Gen prepared a draft order, (the court did not allow Plaintiff to draft the order) it was reviewed and presented before the court, Ref as C00578 of Vol. III, where it was signed;

     

Certain Judges in this matter violated page 18 of Appellants brief 401 of Record before the court of Appeals (13) A judge’s disrespect for the rules of court demonstrates disrespect for the law. Judges are disciplined under Canon 2 A for violating court rules and procedures. Judge ignored mandated witness order in attempt to accommodate witnesses’ schedules; Citing Canon 2A the court noted, “[a] court’s indifference to clearly stated rules breeds disrespect for and discontent with our justice system. Government can not demand respect of the laws by its citizens when its tribunals ignore those very same laws”)

                                                 SUMMARY OF ARGUMENT

Properly alleged facts within an affidavit that are not contradicted by counter affidavit are taken as true, despite the existence of contrary averments in the adverse party’s pleadings. Professional Group Travel, Ltd. v. Professional Seminar Consultants Inc., 136 ILL App 3d 1084, 483 N.E. 2d 1291; Buzzard v. Bolger, 117 ILL App 3d 887, 453 N.E. 2d 1129 et al.

           A- Jan. 8^th, 2008, Judge Puncski ignored Carolyn’s Amended Petition, Judge Carr signed off on made reference to an unauthorized Complaint Pre’shious signed as a basis for which she could not grant an Emergency Order of Protection, that which she Dismissed; Although some trial judges may not review the orders of other judges, because that would not be consistent with the orderly administration of justice or with our judicial system People ex rel. Kelly, Ketting Furth, Lnc. V. Epstein, 61 ILL 2d, 229, 335 N.E. 2d 430 (1974) (Appeal of order as proper remedy); Cruz v. Columbus-Cuneo-Cabrini Medical Center, 194 ILL App. 3d 1037, 551 N.E. 2d 1345, 141. Dec. 817 (1^st Dist. 1990)

B-    Administrative Law Judge circumvented the legal applications of the law where precedents has already been established forbidding Judges from engaging in such practices;

C-    That because Judge Pucinski having had proper Jurisdiction over the parties and had a hearing on the Order of Protection regardless to numerous Civil Rights Violations against Petitioner as noted in the record, Administrative Law Judge Bruce Lester could not assume jurisdiction and rule against the Petitioner and Indicate any Findings against him;

D-    That because of the noted Criminal acts of Conspiracy Fraud in said DCFS matter on all accounts makes said Administrative Law Judge Order a VOID JUDGEMENT; 

ILL. App. (1^st Dist. 2000). A “VOID JUDGEMENT OR ORDER” is one that is entered by a court lacking jurisdiction over the parties or the subject matter, or lacking the inherent power to enter the particular order of judgment, or where the order was procured by FRAUD- in re Adoption of E.L., 248 ILL. Dec. 171, 733 N.E. 2d 846, 315 ILL. App. 3d 137- Judgm 7, 16, 375.  

    Review of the orders of one judge by another in the same case is not consistent with effective judicial administration. W. R. Grace & Co. v. Baker Industries, Inc., 128 ILL. App. 3d 215, 470 N.E. 2d 577, 83 ILL. Dec. 451 (1^st Dist. 1984).

     Although the chancery division of the County Department of the Circuit Court and the Municipal Department of the Circuit Court have concurrent jurisdiction of actions to demolish buildings, where the municipal department first acquired jurisdiction of the subject matter and entered an order of demolition, the county department could not properly assume jurisdiction and enter an order preventing municipal departments from entering an order of demolition. Pepin v. City of Chicago, 79 ILL. App. 2d 295, 224 N.E. 587 (1^st Dist. 1967).             

                                                        ARGUMENT

                            STANDARD OF REVIEW LEGAL ANALYSIS

Appellant has presented to this Jurisdiction the “BluePrint” on how systemic Racial Dispensation of the Laws are adjudicated and circumvented in the courts to elude the laws and authorities on the STATE LEVEL, and how STATE AGENCIES cooperate in said Conspiracies.

How can a statute be considered a statute and the clock be against an injured party who is unable to bring a claim before the courts, when judges and attorneys  are working with criminals violating all sorts of laws obtaining an unfair advantage over parties who have already been harmed by said illegal Fraternal Unconstitutional Conspiracies and Acts , See Page 16 of Brief (35) Par. 3 Lisa L. Milford, The Development of the ABA Judicial Code 24-25 (1992);

In that, 42 U.S.C. 1981 and Title VII of the Civil Rights Act of 1964 (Color) and (Race) U.S.C. {1331, 28 U.S.C. {1343 (a) (3) and 42 U.S.C. {2000e 5 (F) (3) over U.S.C. {1981 and 1983 by 42 U.S.C. {1988; over the A.D.E.A. by 42 U.S.C.{12117.

The above statutes need to be updated, precedents added to include judicial officers and attorneys violating the laws they were elected or appointed to uphold in any office (State City or otherwise). 

In addition, See Page 14, 17 of Record 397, 400, Appellants Brief (69) Vaughn 462 S. E. 2d 728 (Ga.1995), The Supreme Court of Georgia removed a Judge from office for disregarding defendant’s Constitutional rights; (22) Hammel, 668 N. E. 2d 390 (N.Y. 1996) (Judge removed for improperly jailing defendants for their alleged failure to pay fines and make restitution which the judge had imposed, disregarding the defendants basic constitutional rights;   

Appellants Brief has 80 (legal Citations) footnotes, page 19, due to said judges ethnic make up demonstrates a fraternal unification (13) Commentary to Canon 2 offers a test for the appearance of impropriety: “whether the conduct would create in reasonable minds a perception that the judge’s ability to carry out judicial responsibilities with integrity, impartiality and competence is impaired.” ABA Model Code of Judicial Conduct, Commentary to Canon 2A, paragraph 2 (1990). A reference to the Commentary under 2C alerts one to the fact that the appearance of impropriety can also be created by a judge’s membership in or knowing approval of organizations that engage in invidious discrimination.

                                                     CONCLUSION

 

For the foregoing reasons, Appellant requests that this Honorable Court Impose Unprecedented Sanctions, Dismiss and Expunge all related charges Indicated against him by DCFS due to Fraud Criminal Conspiracies Civil Rights Violations  by all Appellees;

That because of the number of years Appellant and family have been harmed by said Civil Rights Violations and no one objected to said assertions put before this tribunal, Appellant is seeking  $900,000.00 a month from the inception of this matter, until this matter is finally adjudicated and for the heinous Racial Hate acts associated in these matters causing some of Appellants children to be hospitalized for various psychological traumas where therapy was necessary but said medical information was used unlawfully in an attempt to destroy Appellant;

    (17) Smith v. Wade, 461 U.S. 30, 35, 103 S. Ct. 1625, 1629, 75 L Ed 2d 632 (1983)  Justice Brennen “The threshold standard for allowing punitive damages for reckless or callous indifference applies even in a case, such as here, where the underlying standard of liability for compensatory damages because is also one of recklessness. There is no merit to petitioner’s contention that actual malicious intent should be the standard for punitive damages because the deterrent purposes of such damages would be served only if the threshold for those damages is higher in every case than the underlying standard for liability in the first instance. The common-law rule is otherwise, and there is no reason to depart from the common-law rule in the context of {1983}”          

Finally, this brief is best closed by a jurist who has stated”; Citing Canon 2A the court noted, “[a] court’s indifference to clearly stated rules breeds disrespect for and discontent with our justice system. Government can not demand respect of the laws by its citizens when its tribunals ignore those very same laws”)

Most recently stated in Federal Court FEDERAL JUDGE GETTLEMAN: stated, Tuesday March 10, 2009, where he found Superintendent of police Jody Weiss in Contempt of Court and Ordered the City to Pay $100,000.00, “No one is above the Law”, he cited a 1928 decision by Supreme Court Justice Louis Brandeis, that said, “If the Government becomes the law breaker, it breeds Contempt for the Law, It invites everyman to become a law unto himself. It invites Anarchy.”           

                                                                           Respectfully submitted,

                                                                              Joe Louis Lawrence

                                                                     ___________________________

                                                                                 Plaintiff-Appellant

                                                                                   Pro Se Attorney

                                          CERTIFICATE OF SERVICE

I hereby certify that on June 11, 2009, I served opposing counsel a cop of Plaintiff-Appellant’s  Brief with all attachments, and by depositing/hand delivering it in the United States mail addressed to:

AAG Danielle J. Steimel                     Said Courtesy Copies will be personally Del.

Child Welfare Litigation Bureau          in a timely manner:

100 West Randolph                            Robert Grant/James Chatto FBI Chicago

Chicago, Illinois 60601                       U.S. Atty. Patrick Fitzgerald

Appointed Child Rep.                         Hon. William S. Boyd Room 1605

Lester Barclay                                     Hon. William O. Maki Room 2302

39 South LaSalle Suite 900

Chicago, Illinois 60603

Brian E. Wright, Esq.

5151 North Harlem

Chicago, Illinois 60656

     

                                                                                Respectfully submitted

                                                                                  Joe Louis Lawrence

                                                                            _________________________

                                                                                       Plaintiff-Appellant

                                                                                         Pro Se Attorney