DEMOCRATS SAY VOTE FOR THE BLACKS BUT THE SAD REALITY WHEN YOU VOTE FOR BLACK JUDGES LIKE THIS HE BECOMES A SELLOUT TO EVERYBODY BUT THE WHITE MEN THAT CONTROLS HIM:
ANYBODY WHO HAS A MOTHER FATHER OR FAMILY MEMBER WHO LOST A HOME DUE TO FORECLOSURE OR ANY CRIMINAL ACT IN COOK COUNTY COURTS LIKE OTIS LEE LOVE, JR. WHO WAS SEEKING A RELATIONSHIP WITH HIS DAUGHTER PAYING CHILD SUPPORT BUT NOT ABLE TO SEE HIS NATURAL BIOLOGICAL DAUGHTER NEED TO SEE HOW CASES ARE "FIXED" BY JUDGES ACTING AS TERRORIST WITHIN THE DEMOCRATIC POLITICAL MACHINE.
________________________________________________________________________
IN THE
CIRCUIT COURT
OF
COOK
COUNTY, ILLNOIS
CHANCERY
DIVISION
)
In Re Racial Discrimination ) 2015 CH 01670
/Source Income Violations )
Housing Matters:
) Hon. F. U. Valderrama
Joe Louis Lawrence ) Room 2305
Petitioner )
)
V
)
420 East Ohio, Chicago Housing Authority)
345 East Ohio, City of Chicago,Commission)
On Human Relations K2
Apt )
Respondents )
________________________________________________________________________
NOTICE OF FILING
YOU ARE HEREBY NOTIFIED that on Mar. 11,
2016 Plaintiff has filed his Motion Objecting Defendant’s response et al. due
to “Fraud” & a plethora of other Civil Rights Violations w/Affidavit.
Commander
& Chief Attorney General of United States
President Barack Obama Loretta Lynch
The White
House U.S. Department of Justice
1600 Pennsylvania Avenue NW 950 Pennsylvania Avenue, NW
Washington, DC 20500 Washington, DC 20530-0001
1600 Pennsylvania Avenue NW 950 Pennsylvania Avenue, NW
Washington, DC 20500 Washington, DC 20530-0001
Chief
Judge Timothy Evans
Judge Moshe Jacobius
50 West Washington, Suite 2600 50 West Washington,
Suite 2403
Chicago, Illinois 60601 Chicago, Ill. 60601
Judge Mary Lane Mikva Clerk of
Circuit Court, Dorothy Brown
50 West Washington, Suite 50 West
Washington, Suite 1000
Chicago, Ill 60601 Chicago, Ill. 60601
Atty.
Gen, Lisa Madigan
Asst. Atty. Gen Tyler Roland
100 West Randolph, Suite 1200 100 West Randolph, Suite 1200
Chicago, Ill. 60601 Chicago, Ill. 60601
States Attorney, Anita Alvarez, Daley
Center, Chg. Ill. 60601
Sec
of State
Asst Deputy Dir. Candace Cheffin
Asst
Gen Counsel Terrence McConville 60 East Van Buren, 8th floor
100 West Randolph, Suite 500 Chicago, Ill. 60601
Chicago, Ill. 60601
CHA
Mobility
CHA Mobility, HCP Counselors
Chris
Klepper, Executive Dir. Tracey Robinson/Joann Harris
28 East Jackson Blvd. 4859 S.
Wabash, Suite 2nd Floor
Chicago, Ill 60604
Chicago, Ill. 60615
CHA
Mobility, Real Estate Specialist
Recorder of Deeds
Jessie
McDaniel
Karen Yarbrough
4859 S. Wabash
118 N. Clark, Room 120
Chicago, Ill. 60615
Chicago, Ill. 60602
City
of Chicago, Department of Buildings
Sabre Investments
Christopher
Lynch
120 West Madison Street
121 North LaSalle, Room 900 Chicago, Ill
60601
Chicago, Ill. 60601
Seyfarth
& Shaw
Anne D. Harris, Jeffrey K. Ross, Kyle A. Petersen, Sara Eber
Fowler Suite 2400
131 South Dearborn
Chicago, IL. 60603
Chicago
Housing Authority
Office of the General Counsel, Maria Sewell Joseph, Thomas B.
King
60 East Van Buren
Chicago, IL. 60605
Cary G. Schiff &
Associates Gordon & Rees LLP
Christopher
R. Johnson, Yuleida Joy Lindsay
Watson, Christian T. Novay
134
N. LaSalle Street, Suite 1720
1 North Franklin, Suite 800
Chicago,
Ill. 60602
Chicago, Illinois 60606
Stephan R. Patton, Mary E. Reuther, Rey A. Phillip Santos
Corp
Counsel, Deputy Corp. Counsel, Asst Corp Counsel
30 N. LaSalle Street, Suite 800
Chicago, Ill 60602
Wilson
Elser Moskowitz Edelman & Dicker LLP
Christian Novay
55 West Monroe, Street, Suite 3800
Chicago, Ill. 60603
Jessica
Mallon, Gen Counsel CHA Roy Martinez Manager 420
East Ohio
60 East Van Buren 420
East Ohio
Chicago, Ill 60601
Chicago, Ill. 60611
Eve Aywaz, Sales Consultant Sarah
Aredia, Leasing Consultant
345
East Ohio
420 East Ohio
Chicago, Ill. 60611
Chicago, Ill. 60611
John-Paul Loseto, Executive Manager
345
East Ohio
Chicago, Ill. 60611
Courtesy
Copies:
US Attorney FBI
Dir. Michael J. Anderson
Zachary
T. Fardon 2111 West Roosevelt Road
219
S. Dearborn, 5th floor Chicago, Ill. 60612
Chicago, Ill 60604
Hon
Judge Neil Cohen Lewis Brisbois Bisgaad & Smith
50 West Washington, Suite 2308 550 West Adams
Chicago, Ill 60601 Chg Ill. Christian Novay, Lewis Carillo
Mayor
Deputy Regional Adm., Field Office Dir.
Rahm
Emanuel Beverly E.
Bishop
City Hall
77 West Jackson Boulevard
Chicago, Ill. 60601 Chicago, Ill.
60604
Governor
Hon Mark Kirk
525
South 8th St. 607 East
Adams, Suite 1520
Springfield,
Ill. 62703
Springfield, Ill. 62701
Bruce Rauner
100
West Randolph
Chicago,
Ill. 60601
Cook
County President
Cook County Sheriff
Toni Preckwinkle Thomas J. Dart
118 N. Clark, Room 517 Richard J. Daley
Center, Room 701
Chicago, Ill. 60602
Chicago, Ill. 60602
Hon Dick Durbin Hon. Judge
525
South 8th St.
Frederick Bates
Springfield,
Ill. 62703 50 West Washington
Chicago, Ill. 60601
CERTIFICATE OF SERVICE
The
undersigned hereby certifies that the above notice and all attachments were
caused to be personally delivered, emailed or via facsimile or deposited in the
U.S. mail to the above parties at the addresses provided before 5:00 pm on Mar.
11, 2016.
PLEASE BE ADVISED that on March 17, 2016,
Plaintiff will appear before Judge Valderrama at 10:00 am in room 2305 and
present said reply motion.
_________________________________
Joe Louis Lawrence, Counsel Pro Se
Name Joe Louis Lawrence
Attorney for Pro Se
Address P.O.
Box 490075
City, State Chicago,
Illinois 60649-0075
Phone (312)
927-4210
Email joelouislaw@yahoo.com
Twitter
@joelouis7
________________________________________________________________________
IN THE
CIRCUIT COURT
OF
COOK
COUNTY, ILLNOIS
CHANCERY
DIVISION
)
In Re Racial Discrimination ) Case # 2015 CH 01670
/Source Income Violations )
Housing Matters:
) Hon. F. U. Valderrama
Joe Louis Lawrence ) Room 2305
Petitioner )
)
V
)
420 East Ohio, Chicago Housing Authority )
345 East Ohio, City of Chicago, Commission)
On Human Relations K2
Apt )
Respondents )
________________________________________________________________________
PLAINTIFF’S
MOTION OBJECTING DEFENDANTS RESPONSE TO
PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT AND CROSS-MOTION TO QUASH SERVICE OF
PROCESS PURSUANT TO 735 ILCS 5/2-301 (a) DUE TO FRAUD JUDICIAL BIAS AND OR
PREJUDICE PURSUANT TO CANON 3 (C) (1) & PLETHORA OF OTHER CIVIL RIGHTS VIOLATIONS
W/AFFIDAVIT
Now comes
Plaintiff Counsel Pro Se, Joe Louis Lawrence respectfully moves this court on his
Motion Objecting Defendant’s response to Plaintiff’s motion for default
judgment and cross-motion to quash service of process pursuant to 735 ILCS 5/2-301 (a) due to “Fraud” judicial bias and or prejudice pursuant to Canon 3 (c) (1) &
a plethora of other Civil Rights violations with affidavit in the above
entitled cause.
Reasons in
support of this motion are set forth in the attached affidavit.
Respectfully Submitted,
Joe
Louis Lawrence
By:____________________________
Counsel Pro Se
Post Office Box 490075
Chicago,
Ill. 60649
(312) 927-4210
Twitter @joelouis7
STATE OF ILLINOIS
)
)
COUNTY OF COOK
)
AFFIDAVIT
Joe Louis Lawrence being first duly sworn on oath deposes
and states as follows:
1 I
am Joe Louis Lawrence, Counsel Pro Se.
2 That
Christian Novay former District Attorney from New York is attempting to make a
mockery out of the court violating Supreme Court Rule 137, he was an attorney
for the law firm of Wilson, Elser, Moskowitz, Edelman, & Dicker LLP, 55
West Monroe, Chg. Il. Law firm of Gordon & Rees, 1 North Franklin, Chg. IL.
Now Lewis, Brisbois, Bisgaard & Smith, LLP, 550 West Adams, Chg. IL.
3 That on
Feb. 27th, 2015, Judge Valderrama demonstrated Bias and or Prejudice
conduct assisting said defendant 345 East Ohio via attorney Christian Novay
who was with the law firm of Gordon & Rees, stated Page 4, Lines 18-20 “No. The clerk’s office doesn’t serve
anybody by certified mail. Let me back up”. Lines 1-6, Page 5, “When I say service, I don’t mean mailing
anything. When I say service, I mean providing a copy of the complaint and
summons on the entity that you have named in your complaint, 420 East Ohio, the
housing authority, 345 east Ohio and it looks like the City of Chicago and
Commission on Human Relations.”
A-
Christian Novay stated, Page 5, Lines 18-24, Page 6, Lines 1-6, “Judge, thank you.
When we received a copy of the Rule to Show cause, I had a clerk from my office
go down. There was in fact a complaint that relates to this Rule to Show Cause.
It is well over 500 pages long. So I know we didn’t receive a copy; I know my
client didn’t receive a copy. I am familiar with Mr. Lawrence. He has sued many
of my clients over the course of several years. Generally he usually actually
hand delivers all of the--- or I think his son usually hand delivers it
directly to us. This was not delivered to us. I can imagine why because it
would be quite burdensome and tedious to do so. But as of yet we have not been
served”.
B- Attorney
from 420 East Ohio, Ms. Harris, Page 6,
Lines 8-13, “Your Honor, my client did receive something in via mail. It was not
500 pages. So I’ll be honest, I’m not quite sure whether it was the same thing
or not. My client did receive something in the mail saying request for review.
And then I know we received the petition for Rule to Show Cause”.
4 That
the judge mysteriously had this matter continued until March 10, 2016 at 10:30
which was the earliest date in which he recorded in his Red Book to hear this matter, an attorney for 345 was in
court that day, the judge informed her they were not a part of this court
order, when Petitioner asked the judge, “what
about the parties who have not responded or replied? his reply, “you know what to do file the appropriate
motions”
5 Petitioner
filed a Motion for Prove-Up Motion for Default Judgment properly Noticed the
matter to Feb. 5, 2016 at 9:30 #4 on
the Motion call, pursuant to the judge’s instructions;
A-
That on Feb. 5, 2016, law firm Gordon & Rees
representing 345 East Ohio via attorney Goli Rahimi appeared before the court
not filing the appropriate appearance documents got the judge to grant
unlawfully 28 days to respond to a default, that because of the judges Prejudice and or Bias conduct towards the
Petitioner signed an order absent his authority or jurisdiction due to “Fraud” ILL. App. (1st
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
B- That due to the plethora of Civil Rights Violations and judges role
upholding all criminal acts Gordon & Rees failed to honor or respond to the
court order entered Feb. 5, 2016;
C- That Christian Novay without Notice or knowledge to the court or the
Petitioner of law firms withdrawing from representing 345 East Ohio joined a
third law firm in his quest to try and defeat the Petitioner with the judges
support when in fact the case has been lost when his client Frank Fioreonino
Manager signed for the Summons and Complaint Feb. 6, 2015;
D- That because of the aforementioned
Defendant’s Response Motion to Plaintiff’s Motion for Default Judgment et al.
is not only defective in many ways but at best “Fraudulently” presented
so as to Induce Reliance upon the
court for a favorable verdict in which given the judges history in this matter
would have granted this motion;
E- That because Judge Valderrama has
methodically denied every legally certified Motions Petitions accompanied with
Affidavits and made Perjured statements about petitioners pleadings
demonstrating Bias and or Prejudice conduct allowed his court
room to culminate into a 4 ring circus, had the judge properly Defaulted the
Defendants Feb. 5, 2016, Christian Novay never would have been able to have
filed said Motion;
F- That because the law firm Gordon & Rees never legally withdrew
from this matter begs the question who is to share in this matter if Remands or
Indictments are in order the attorneys working at Gordon & Rees or
attorneys at Lewis Brisbois Bisgaad & Smith LLP?
6 That
Plaintiff has prepared said pleadings so as to trap any judge under Alderman
Edward Burkes authority and control it was expected a top Irish or Good Ol Boy
personnel judge would be presiding over this matter trying to “FIX” this case, so as to
demonstrate to the most racist or hated judges on the bench they can be caught
within the laws;
A-
Plaintiff was already informed by credible intel no
Irish, Polish and Black male judges were going to Rule in his favor where this
matter was concerned for example when this matter appeared on Judge David
Atkins call he had Dismissed the case calling it an Order of Protection and got
off after he was allegedly admonished;
7 Pursuant
to Illinois Civil Procedure Rules, failure to file an answer, where an answer
is required, results in the admission of the allegations of the complaint, Ill. S. Ct. R. 286 (a) Pinnacle Corp. v.
Village of Lake in the Hills, 258 Ill. App 3d 205, 196 Ill. Dec 567, 630 N.E.
2d 502 (2d Dist. 1994)
8 That
because Plaintiff properly plead all facts correctly in said complaint negates
any extension of time for the Defendant to respond, due to there not being “Good Cause Shown” Bright v. Dicke, 166 Ill. 2d 204, 209 Ill.
Dec. 735 652 N.E. 2d 275 (1995)
Justice Harrison delivered the opinion of the
court:
The
issue in this case is whether a circuit court may permit a party to respond to
a request for the admission of facts or the genuineness of documents once the
28 day time limit specified by Rule
216 (c) (134 Ill. 2d R. 216 (c) has
expired. For the reasons that follow, we hold that the court may allow an
untimely response where the delinquent party has shown good cause for the delay
in accordance with Rule 183 (134
Ill. 2d R. 183) Because No Good Cause
was shown here, permission to make a late response was properly denied. The
circuit court’s order denying such permission and the judgment of the appellate
court affirming the circuit court’s order are therefore affirmed.
9 FACTS: That Defendants having been
properly served by the Clerk of the Circuit Court of Cook County via certified
mail with summons, and Cook County Sheriff and Plaintiff personally and hand
delivered;
10 FACTS: That the representing law firms
and attorneys were in receipt of all documents Motions, Petitions for Rule to
Show Cause, 2nd Amended Complaints et al. Seyfarth & Shaw, Anne D. Harris, Jeffrey K. Ross, Kyle A.
Petersen and Sara Eber Fowler; Gordon
& Rees, Christian Novay, Lindsay Watson; Cary G. Schiff, Christopher R. Johnson, Yuleida Joy; City of Chicago, Rey A. Phillips
Santos, Stephan R. Patton, Mary E. Reuther; Chicago Housing Authority, General Counsels Thomas B. King, Maria
Sewell Joseph, Jessica Mallon;
11 That
on Feb. 5, counsel 345 East Ohio appeared before the court without filing an
appearance where the judge had an impromptu Hearing on a Motion Call where the
judge received and accepted an Affidavit Printout from Dorothy Brown, Clerk of
the Circuit Court and green card receipt establishing the veracity a person
from 345 East Ohio accepted the summons and complaint;
12 Counsel
informed the court that they thought this was a Civil matter and not an
Administrative Review case and that they appeared in court not as being served
but as a strategy to learn or stay abreast of what the court was doing so that
they could have an effective defense for their client because documents were
being served on the law firm not their client and they were not accepting
service on behalf of their client and nowhere in any of the documents is 345
East Ohio mentioned;
A-
That the judge asked, the Plaintiff a series of
questions seeking to ascertain his legal understanding as to why and how 345 is
named in the suit;
B-
Plaintiff responded reminding the court of a plethora of
“Fraudulent Acts” the City’s
Commission on Human Relations have engaged in upholding housing and source
income discrimination where whites with vouchers were allowed to use their
Section 8 vouchers to live in the buildings but when the building managers
learned of my ethnicity they denied me access to move into the units, took my
money never returning it someone on the city level without authority mailed to
my attention orders claiming the complaints were in fact dismissed absent any
authorized signatures, which enabled them
to Induce Reliance upon everyone which is the basis how the review ended
up in Chancery because the proper motions addressing the “Fraudulent Acts” and Conspiracies went ignored because the City
Commission on Human Relations is absent Contempt Power to address the
irregularities is how this matter ended up in Chancery on Administrative Review,
the judge nodded as if he was understanding what was articulated by the
Plaintiff, he has a habit of pretending to gesture in Plaintiff’s behalf but
then DENY every Motion or Petition that is presented before him;
C-
The judge surprisingly asked Counsel for 345 East Ohio “so what are you going to do counsel”?
he appeared agitated, he said, “I am
about to grant his Motion”! The attorney became nervous as Hell, he repeated
himself and said angrily, and I am not going to tell you what to do! Then she
said can I have 28 days? The judge immediately said GRANTED! I’m like what the
Hell!
D-
That if that is not clear enough the court heard
testimony of how K2 was served did not grant Plaintiff any relief on that
motion said he would continue that matter until March 17, 2016;
E- That
Plaintiff filed a Petition for Rule To Show Cause et al. (Nov. 5, 2015)
Vacating the Nov. 2, 2015 Court Order et al. unequivocally demonstrating brazen
contempt and “Fraud” by City attorneys, Page
7 Par. 14 pursuant to CCHR Reg. Rule 240.349 of the City of Chicago Human
Relations Commission (2) Issues a written order after the pre-hearing conference which
describes the motion or objection and sets forth the decision.
F-
That pursuant to a Motion for Disqualification et al.
filed (April 2, 2015) Par 8, 9, Page 9 the judge ignored the service had on 345 East Ohio; Par. 10 of Page 10 validates the veracity of Judge Valderrama engaging
in an Organized Conspiracy;
G- That
pursuant to the same Motion Par. 10,
Page 6 Judge acknowledged receiving
the very court orders he kept asking the Plaintiff about how this court have
jurisdiction, said, “I have read it but I
am not sure how that ties in though”
H- That
pursuant to Page 2, Par. 2 of
Affidavit Motion for Reconsideration Vacate Order et al. filed (April 21, 2015)
and Page 3 Par C Judge Valderrama stated, “The
clerk’s office doesn’t serve anybody certified mail et al”
I-
Said judge and Defendant’s attorneys deliberately
violated Plaintiff’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 didn’t care 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 judge and the attorneys have demonstrated no
regard for the FBI or Plaintiff’s Civil Liberties 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.
J-
That Judge
Valderrama have DENIED every legally
certified document filed and presented before this court, due to Plaintiff’s
skin color never opposed and has GRANTED
every and any “FRAUDULENT” document
any white attorney absent affidavits or legal precedents which
corroborates Directed evidence of his
role in said conspiracy;
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.
K-
That 345 East Ohio (Village Green management) never
filed an Appearance and the City of
Chicago like the other Defendants never presented an affidavit with their
defective motions having already admitted to all facts properly plead in
Plaintiff’s 2nd Amended Complaint it is a general rule that a failure to deny an
allegation results in it being admitted, in addition to this legal precedent
and because they have failed to articulate
sufficient cause pursuant to In Re
Estate of Michalak, 404 Ill. App3d 75; 343 Ill. Dec 373, 934 N.E. 2d 697 (1st
Dist. 2010), appeal pending, (Jan. 1, 2011), makes it impossible for any
court to apply discretion allowing an extension of time;
Pursuant
to Roth v Roth, 45 Ill. 2d 19, 256 N.E.838 (1970), Pleading—Failure to respond to adversary pleading may constitute
admission of all facts well pleaded. As a purpose of pleading is to develop
the issues to be determined, a failure to respond to an adversary pleading may constitute
an admission of all facts well pleaded by the adversary, and admissions thus
drawn from failure to plead may be considered as evidence. (See Mooney v. Underwriters at Lloyd’s
London, 33 Ill. 2d 566. People ex rel. Lacanski v. Backes, 19 Ill. 2d 541, 543;
see also, Ill. Rev Stat. 1967, ch 110 par. 40(2); Nichols, Illinois Civil
Practice, 1960, sec 1233.
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. 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 cannot 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).
8 Defendant City of Chicago, having
admitted to the facts recorded Page 6,
Par 3 and 5, 8B is expecting the
court to ignore these admissions and continue to deny Plaintiffs 2nd
Amended Complaint because as Page 28,
Par 47 A-B is clear without a scintilla of falsity articulates the
contemptuous arrogance perpetrated upon this court knowing said acts are in
fact unlawful, but because of Plaintiffs skin color Defendants are expecting
the Judge who supports their racist agenda within the Democratic Machine to
continue to ignore the laws and deny anything Plaintiff files and grant the
Defendants anything they put before the courts as demonstrated in all prior
rulings;
9
Defendants having admitted to all pleadings properly
plead corroborates the systematic fraudulent acts, in that men of color like
the Plaintiff is not supposed to work in providing for his family, he is not
supposed to be educated, not supposed to stand up to racist corrupt white
Democrats in the Political Machine, he is not to have good credit scores to
live “Freely” as he desires within the city of Chicago, he is to accept a
lifestyle of inferiority, maintain a lifestyle of criminal employment and be a
member of the penal institution existing on welfare, to attempt to rise above
the racist atrocities is not tolerated by the Democratic Machine operatives; in
that, any man like the Plaintiff who attempts to rise above racial oppression
or racial terrorism, they are met with all of the facts within the 2nd
Amended Complaint and the aforementioned;
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.
To further amplify the veracity and credence
of the above, Plaintiff having appeared before Judge William Maddux (93 L
10772) in relation to Page 28 Par. C, Joe Louis Lawrence v Chicago
Transit Authority Wrongful Discharge, Ken Stephen Ray falsified all types of
documents, as we stood before Judge Patrick McGann he was very angry and in a
rage, Plaintiff lodged allegations of wrong doing by the CTA administrators
because he would falsify how his injury was sustained and apply for Public Aid
use the medical card to absorb the medical costs, Ken stood before the judge
licking his lips inciting the judge to become even more irate as he called the
plaintiffs filings garbage, said who do he think he is saying this garbage?
The Judge stood up as if he was
going to come down off the bench, the deputy starred at him, the judge sat back
down, Ken told the judge, “he thinks
there is a great big grand conspiracy against him” wailing his hands all
over the place like a female, he told the judge, he has no proof of any
discharge and don’t belong here judge, Plaintiff respectfully objected to the
judges behavior and admitted he never received any documents of a discharge but
CTA said, that, I was discharged terminating my medical benefits for sick
daughter with an ear infection while off work due to a work related injury, the
judge berated the Plaintiff with insults saying you don’t come to court on
hearsay! This Judge replaced Judge Willard K. Lassers who said he was going to
help (me) the Plaintiff, he told Ken S. Ray “he
better wipe that smirk off his face and when we returned back to court this
matter better be straighten out” somebody, had the judge removed from the
case
Plaintiff filed a Motion for
Disqualification of Judge and appeared before Judge Maddux he had the demeanor
of a powerful person surpassing judicial authority, said that what the
Plaintiff was asserting was in fact true, “but
up here things are done differently, you need a sponsor (Plaintiff ‘s
interpretation a white man) to represent
your issues because you are out of your league on this one you are a bright
kid, “I commend you, but the union is supposed to handle this matter, it
was explained to the judge nobody will talk to me or address this matter,” he
said, “go back to the union, they will
talk to you, I will not entertain this Motion for the reasons, I have explained
to you”
The Cook County Sheriff stated
this have to be reported Judge McGann was later transferred from the Law Division
to traffic court 312 N. LaSalle, the CTA did in fact forward documents of
status as a certified Bus Operator to the union but was never reinstated because
the CTA did not have the money in the budget because someone stole all of Plaintiff’s
back wages while off injured on duty according to Vice President of Operations
Hilcox and if anyone reinstated Badge 26115 they would have been terminated!
That allegedly due to Judge
Maddux influence and authority the Chicago
Transit Authority released employment records pursuant to Gr Ex A, Vol. II, Nov. 23, 1994 letter
from Michael Cook Manager Personnel, and the above information is furnished
in reply to your request for verification of employment from the CTA. He was
never DISCHARGED. AND Oct 20, 1994 Printout from database where someone tried
to erase Plaintiff from the database to prevent anyone’s knowledge he was an
employee but was unsuccessful along with medical statement finding him fit to
return to regular duty 12-1-1994 along with emails and letters grievances to
the ATU 241 that went ignored;
That Chairman Valerie Jarrett
tried having the Plaintiff reinstated and was met with some serious
oppositions.
That because Chicago is so
racist and segregated they attack the young boys exercising genocide likened to
the Laquan McDonald case where police shot him 16 times as officers of color
stood by and watched, in this case Plaintiff’s son on the Honor Roll at Leo
kicked out of School because administrators falsified records saying a debt was
owed when grants scholarships and sponsors cleared all debts due to Plaintiff
living on welfare, See Nov. 20, 2015
Notarized Affidavit;
That despite Gr Ex B, Judicial Complaint of Vol. II of the 2nd
Amended Complaint clearly demonstrate how the attorneys properly plead to
the facts of Chicago Public School officials corroborated their roles in
engaging in Terrorist Acts against son a talented hard hitting football player
denied the opportunity to pursue his passion to continue playing as Coach
McAlister and Principal Matthew Sullivan of Phillips High School engaged in
Racist Conspiracies keeping said son from receiving recognition in order to
receive a scholarship at prominent Universities but students living with the
white teachers of the school were given priority and scholarships not the
Plaintiffs son because of his skin color and father standing up to racial
injustice, “Jim Crow” .
10
The Defendants must assert some independent ground
as to why their untimely response should be allowed. Hernandez, 73 Ill. 2d at 96; Greene, 73 Ill. 2d at 107.
11
That Rule
183 does give judge’s discretion to allow responses to be served beyond the
28 day limit, that discretion does not come into play under the rule unless the
responding party can first show good cause for the extension. Hernandez v. Power Construction Co. (1978)
73 Ill. 2d 90, 95-97).
12
That
Plaintiff having been informed by his white colleagues that Irish or Polish
judges would never rule in a brothers favor against their own referring to said
ethnicity and furthermore, he was to forget about the so called Afro American
Brother on the bench they have to do what they are told none of them will stand
up to the white man, they are worse on your people that is how and why they
were selected.
From the above tutor ledge Plaintiff had to develop pleadings that
would enable “Corrupt Racist White men” to trap themselves and everybody
regardless to their skin color was able to legally snitch on one another
through Plaintiff’s pleadings.
So the old adage it’s who you know don’t fair in this case because it
is what you should know that will determine many outcomes a real judge with
integrity can now rule from the bench without political retaliation or
oppression in the end Justice wins!
A city’s
top attorney (Jordan Marsh) resigned Monday (Jan.4, 2016) after a federal judge
said he intentionally hid evidence while defending two Chicago police officers
in a wrongful-death lawsuit.
The judge
Edmond Chang has now ordered a new trial and is forcing the city to pay
attorney’s fees.
This
revolves around a wrongful death lawsuit filed by the family of Darius Pinex
against the city.
“He said the attorney for the city had intentionally
hidden evidence, which is very troubling,” says Steve Greenberg, the attorney
for Pinex’s family.
“It shows
that this culture of indifference to finding out the truth, to holding people
accountable, goes up to the highest levels,” Greenberg adds.
Chicago
police shot Pinex on a South Side street in January 2011, saying the car he was
in matched the description of a vehicle wanted in a shooting.
U.S.
District Judge Edmond Chang on Monday said city attorney Jordan Marsh
withheld information that may have cast doubt on those claims.
Marsh resigned
Monday, the city’s Department of Law said. “The conduct outlined by the
court in today’s decision is unacceptable,” the department said in a prepared
statement.
Greenberg says Pinex’s mother is “ecstatic” about the federal
judge’s ruling.
As for Marsh, he said, “I haven’t run into anything like
what Mr. Marsh did in this case.”
Marsh, who handled civil rights cases for the city, knew
about the recording before the lawsuit went to trial in March 2015, Chang said
in a 72-page opinion.
Jordan Marsh |
Facebook photo
“The court has no choice but to conclude, based on the
record evidence, that Marsh intentionally withheld this information from the
court,” the judge wrote.
Another city attorney, Thomas Aumann, “failed to make a
reasonable inquiry, as required by the discovery rules, to search for the
recording,” Chang added.
Aumann resigned on Aug. 31, city officials say.
The conduct by Marsh and Aumann thwarted the ability of
lawyers for Pinex’s family to prepare for trial, Chang said.
Attorneys for Pinex asked the city for the recording so
they could show the officers were not acting on information that would have
justified an aggressive traffic stop resulting in Pinex’s death.
Mosqueda had initially claimed he stopped the Oldsmobile
Aurora that Pinex was driving based on an Englewood District police radio
broadcast that warned the car might have been involved in a shooting in a
different police district about three hours earlier.
Because
people of color lives are of no merit the Mayor and many others within the
political system continue to engage in heinous lynching acts perpetrating
criminal acts within the legal system or violating the Civil Rights of the
Plaintiff because Chicago is still of the Confederate Democracy engaging in Jim
Crow practices.
FURTHER AFFIANTH SAYETH NAUGHT
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
aforesaid that he verily believe the same to be true.
Respectfully submitted,
Joe Louis
Lawrence
Counsel Pro Se
WHEREFORE the aforementioned reasons Plaintiff
respectfully Prays for the Relief of Denying
any Motions or Responses by the Defendants & Enforce Remands Body Attachments in accordance to $25 Million
Dollar sought as Bond and Sanctions
pursuant to Supreme Court 137 Instanter;
2.) For the entry of
an Order awarding to the Plaintiff for such other relief and any other relief
necessary as equity may require of which this court deem overwhelmingly just;
3.) For the
reimbursement of all fees and costs associated in this matter.
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 aforesaid that he verily
believe the same to be true.
Respectfully submitted,
Joe Louis Lawrence
Counsel Pro Se
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