FULL ADMISSION BY THE DEMOCRATIC PARTY JUDICIARY PURSUANT TO Local Rule 56.1 The rule is very clear that "all material facts set forth in the statement required of the moving party will be deemed admitted unless controverted by the statement of the opposing party." Local Rule 56.1(b)(3)(B).
MOST BLACK AND CERTAIN HISPANIC JUDGES ARE THE WORSE PERSONS A BLACK OR COLORED PERSON CAN GO BEFORE BECAUSE MANY OF THEM ARE WILLING TO SACRIFICE THEIR CAREERS OR FREEDOM TO PROTECT THEIR MASSAS IN THE POLITICAL MACHINE
WHEN THE MACHINE RUN OUT OF THEIR OWN ETHNIC GROUPS TO ENGAGE IN RACIST ACTS THEY CAN ALWAYS RELY ON A BLACK OR BROWN JUDGE TO GO AGAINST THEIR OWN ETHNIC GROUPS.
JUDGE BAPTISTE A NEGRO SAID HE DOES NOT SEE ANY RACISM IN THIS CASE, BUT WHAT HE DID NOT REALIZE IS HE HAS IMPLICATED HIMSELF BECAUSE JUDGE ROMANEK PRETENDED TO BE THE ACTING PRESIDING JUDGE FORUM-SHOPPED HIM SPECIFICALLY TO DENY A MOTION NEITHER OF THEM HAD ANY JURISDICTION.
MANY OF YOU WON'T BE ABLE TO SEE ABBEY ROMANEKS NAME LOOK ABOVE THE JULY 2, 2026----IT SAYS ACTING PRESIDING JUDGE
IT'S APPARENT PRESIDING JUDGE REGINA SCANNICCHIO DIDN'T WANT TO PARTICIPATE IN THE ALLEGED CRIMINAL EXTORTION SCHEME TRYING TO EXTORT CHILD SUPPORT FROM ME FOR A CHILD THAT'S AN ADULT NOT ONLY NOT MINE BUT WAS NEVER LEGALLY ORDERED TO PAY ANY CHILD SUPPORT.
THIS IS HOW DEMOCRATS IN COOK COUNTY CRIMINALIZE INNOCENT BLACK AND BROWN MEN OR IN EXTREME CASES TAKE THE CHILDREN FROM MOTHERS WHO MAY BE SEEKING CHILD SUPPORT FROM CERTAIN MEN.
COOK COUNTY IS NOT A PLACE FOR AN INNOCENT MAN OR WOMAN TO RECEIVE JUSTICE BUT THIS IS NOT DISCUSSED BECAUSE WE ARE NOT ILLEGAL IMMIGRANTS.
IN THE CIRCUIT COURT OF COOK
COUNTY, ILLINOIS
COUNTY DEPARTMENT—DOMESTIC
RELATIONS
IN RE
)
)
Francoise
Hightower
) Judge Jean Lionel Baptiste
Petitioner
)
) Cal 42
VS
)
) No. 88 D 079012
Joe Louis
Lawrence
)
Respondent
) Room 2807
Respondent
respectfully moves this Court on Motion for Reconsideration and Vacating, and
declaring null the July 6, 2026 court order:
MOTION
FOR SUMMARY JUDGMENT PURSUANT TO ILLINOIS (735 ILCS 5/2-1005) & FEDERAL
RULES OF CIVIL PROCEDURE CORROBORRATING THE VERACITY COOK COUNTY JUDGES DO NOT
HONOR DUE PROCESS OR CIVIL RIGHTS EQUAL PROTECTION TO IT’S CITIZENS PRO SE OR
WITH ATTORNEYS IN ANY OF THE COURT’S w/AFFIDAVIT
Please be advised that on
July 14, 2025 Respondent has filed before this Domestic Relations Division Motion for Summary
Judgment et al;
When
the party moving for summary judgment supplies evidentiary facts which,
If
not contradicted, would entitle him to judgment, the opposing party cannot
Rely
upon his complaint or answer alone to raise issues of material fact. A counter
Affidavit
is necessary to refute evidentiary facts properly asserted by affidavit
Supporting
the motion or else the facts are deemed admitted.
Here, Defendant
has supplied affidavits, Certified Court transcripts and other evidentiary
material that establishes all of the elements necessary to entitle it to
recovery under the parties’ agreements, including the amount of damages. Plaintiffs
have failed to submit any evidence in opposition to the Motion or Order to
raise any genuine issues of material fact. Thus, summary judgment is proper.
1.) That Pursuant to Steinbrecher
v. Steinbrecher, 197 Ill. 2d 514, 528 (2001) “Pro Se litigants
are presumed to have full knowledge of applicable court rules and procedures”
2.)
That under 18 U.S.C. 242 and 42 U.S.C. 1985 (3)
(b). A judge does not have the discretion on whether or not to follow Supreme
Ct. Rules, but a duty to follow. People v. Gersh, 135 Ill. 2d 384 (1990).
3.)
Motions for Reconsideration are designed to bring to
the court’s attention newly discovered evidence that was unavailable at time of
original hearing, changes in existing law, or errors in court’s application of
law. Continental Cas. Co. v.
Security Ins. Co. of Hartford, App. 1 Dist. 1996, 216 Ill. Dec. 314, 279 Ill.
App. 3d 815, 665 N.E. 2d 374, appeal dismissed, et al.;
4.)
The purpose of a Motion to Vacate is to alert the trial
court to errors it has made and to afford an opportunity for their correction. In re Marriage of King, App. 1 Dist. 2002,
270 Ill. Dec. 540, 336 Ill. App. 3d 83, 783 N.E. 2d 115, rehearing denied
pending appeal; et al.
5.)
Pursuant to 735 ILCS
5/2-612 Counsel never Objected to the sufficiency of Petitioners pleadings,
Objections to sufficiency of pleadings either in form or substance must be made
In trial court, and if not so made, they will be considered waived and cannot
be raised for the first time on appeal. People ex rel. Deynes v. Harris,
App. 1948, 77 N.E. 2d 439, 333 Ill. App. 280.
a. “A Void Judgment from its inception is and forever continues to be
absolutely null, without legal efficacy, ineffectual to bind parties or support
a right, of no legal force and effect whatever, and incapable of confirmation,
ratification, or enforcement in any manner or to any degree. “A void judgment,
order or decree may be attacked at any time or in any court, either directly or
collaterally” Oak Park Nat Bank v. Peoples Gas Light & Coke Col, 46 Ill.
App. 2d 385, 197 N.E. 3d 73, 77, (1st Dist. 1964)
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 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
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.
6.) That Page 11, Par 27 “That
Respondent being aware of Blacks in the Democratic Party-Political Machine are
nothing more than Puppets or Figure heads upholding racism and Jim Crow Laws in
Cook County or the City of Chicago will never and have never attempted to speak
up or try and do what was right by him in standing up to the Caucasians who
were the initial authors of these Ku Klux Klan Criminal Civil Rights
Violations” from the Motion to Disqualify et al.
A- A Negro judge male or
female will find fault or make up one against any Pro se litigant rather than
address any wrongs or racial acts perpetrated by certain Democratic Caucasians
and was already expecting him to deny his Motion never have a Black judge ever
ruled in accordance to the laws of the US Constitution in his favor.
B- Respondent used the actual
template from Par 7 Request for Investigation of Judge Francis A.
Gembala et al. a Caucasian judge before the Judicial Inquiry Board anticipating
Judge Baptistes denial
C- Judge Baptiste implicated
the Daley administration as the cause of the series of irregularities but Respondent
vehemently interjected and informed the Court he never said that and had no
issue with Daley because he dismissed the case September 17, 1987, in my favor.
D- Judge Baptiste stated, I
know you didn’t say that but all of this took place under that administration
and Judge Silva and Powers did not enter these court orders.
E- Judge Baptiste ignored the
Motion accompanied with the Affidavit ignored the States Attorney representing
the Plaintiff never sought clarity of the ASA’s involvement like every other
judge this matter has appeared before and acted as Plaintiff’s defacto
representative in that the States Attorney has been unlawfully representing the
Plaintiff ever since her racist attorney as a former States Attorney colluded
with all of his Irish and Polish ethnic Brethren and judges as they falsified
court orders and documents in the courts.
F-
7.) That Page 6 Par 7 CODE
OF JUDICIAL CONDUCT Eugene Alpern
P.O. Box 672
Morton Grove, IL 60053-0672
September
11, 1997
State
of Illinois
Judicial Inquiry Board
100 W. Randolph St. - 14-500
Chicago, IL 60601
REQUEST FOR INVESTIGATION
OF JUDGE FRANCIS A. GEMBALA
FOR VIOLATION OF THE CODE OF JUDICIAL CONDUCT
I
have information of possible willful misconduct in office, persistent failure
to perform his duties, and other conduct that is prejudicial to the
administration of justice and that brings both his judicial office and the
judiciary into disrepute on the part of Francis A. Gembala of the Circuit Court
of Cook County, Illinois. A judge should strive to maintain confidence in our
judicial system (Preamble to Code of Judicial Conduct), but Judge Gembala's
actions destroy confidence in the judicial system. Unless he is severely
disciplined or removed from office, he will continue to violate the Code of
Judicial Conduct.
Judge
Gembala knew, or should have known, that he had conscientiously, arbitrarily,
capriciously, deliberately, intentionally, and knowingly engaged in conduct in
violation of the Supreme Law of the Land, in violation of his duty under the
law, in "fraud upon the court" and to aid and abet others in criminal
activity, thus making himself a principal in the criminal activity.
8.) On
September 17, 1997 Judge Francis A. Gembala recused himself from case no.
91-D-5122. [NOTE: A judge may not recuse himself, under law, unless he is in
violation of the Rules of Judicial Conduct. By recusing himself, Judge Francis
A. Gembala has admitted that he was acting in violation of the Rules of
Judicial Conduct.
9.)
That as a Negro judge under no circumstances will that
kind of individual rule in favor of a Black or Brown Man, judge Baptiste has
corroborated and validated the verity that only Caucasian or Hispanic/Latinos
can mention racial animus of certain Caucasians when it is perpetrated on Black
or Brown Colored Men
10.)
That MOTION TO RECUSE HON PATRICIA FALLON DUE
TO CONFLICT-OF-INTEREST PRIOR ASSOCIATION TO THE STATES ATTORNEY OFFICE
ET AL. Page 4, Pars 4- 6 ref as Pars 11-13 on this
document articulates the systemic racial hatred no Black, Negro, African
American is allowed to say or defend persons of their ethnic groups.
A-
Caucasian judges have stated no Bros Black judges will
ever rule in my favor, they have to do what they are told and no good ol boys
will ever go against their ethnic group for a Brother, but a good white judge
will help him.
11.)
Kent
Stephen Ray was in an alleged Homosexual intimate relationship with the
Secretary of the ATU Local 241 union who was the Chief Attorney with the CTA and
was responsible for destroying my personnel records where, I filed a
multimillion-dollar lawsuit against the CTA for Retaliatory Discharge case # 93
L 010772.
A-That Par F are
the actual Pleadings Particularized demonstrating horrific Disparate Conditions
of Employment, Racism, Terrorism and most importantly how Blacks are used to
destroy their own ethnic groups upholding Jim Crow Laws protecting their
Political Masters in the Democratic Machine..
12.)
Susan
Scher a Corporation Counsel dispatched on the case under your alleged authority
to help the alleged corrupt Homosexual CTA Attorney Ken S. Ray, where he
informed the racist Judge Patrick McGann, that, I had no proof, I was
DISCHARGED from the CTA and at the time, he was correct it was hearsay, that
caused the filing of the Complaint.
13.)
So,
Judge Forti this is why you never read anything about me or this case because
you are well familiar to my pleadings and is trying to use your racist and
Homosexual connections to allegedly save maybe your ex or former alleged Boo
Kent Stephen Ray because only your kind of people or Black and white trash
would be intertwined in this type of mess.
14.)
That Judge Baptiste rather than Recuse himself like
certain other judges so that the Respondent can get out of Cook County and
receive justice because no justice can ever be sought here he has now
implicated himself by trying to undermine the Respondent by closing his eyes to
all of the racial injustices and void orders and corruption by saying he don’t
see racism and that judge Powers didn’t do anything wrong in assigning Judge
Silva to the case Judge Powers assumed the
authority of the Presiding judge Regina Scannicchio and forum-shopped judges he
thought would embrace racial hatred and his bias disposition against the Respondent,
Rule 23.6
Substitution of Judge of the Illinois Rules of Civil Procedure (C) Orders
granting a substitution of judge shall be accompanied by an order transferring
the case to the presiding judge of the division or district in which the case
is then pending for reassignment.
a. Fraud upon the court is
a basis for equitable relief. Luttrell v. United States, 644 F. 2d 1274, 1276
(9th Cir. 1980); see Abatti v. C.I.R. , 859 F 2d 115, 118 (9th
Cir. 1988) “it is beyond question that a court may investigate a question as to
whether there was fraud in the procurement of a judgment” Universal Oil
Products Co. v. Root Refining Co., 328 U.S. 575, 66 S. Ct. 1176, 90 L. Ed.
1447. The power of the court to unearth such a fraud is the power to unearth it
effectively. See Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238, 64
S. Ct. 997, 88 L. Ed. 1250; Sprague v. Ticonic National Bank, 1184 and United
States v. Throckmorton, 98 U.S. (8 Otto) 61, 25 L. Ed. 93.
b. “A judge is an officer of
the court, as are all members of the Bar. A judge is a judicial officer, paid
by the Government to act impartially and lawfully”. People v. Zajic, 88
Ill. App 3d 477, 410 N.E. 2d 626. “A
void judgment is regarded as a nullity, and the situation is the same as it
would be if there were no judgment. It has no legal or binding force or
efficacy for any purpose or at any place….It is not entitled to enforcement.
30A Am Judgments 43, 44, 45. Henderson v Henderson 59 S.E. 2d 227-232
WHEREFORE,
Respondent respectfully requests that this Court:
A.
Immediately Vacate the Court Order July 6, 2026 Instanter.
B.
Order the reassignment of this case to the Jurisdiction of Willow brook
C.
Direct the State Police or Inspector General or Judicial Inquiry Board to
Investigate systemic allegations of racial corruption.
D.
Rule upon Respondent's previously filed motions for default and summary
judgment; and
E.
Grant such further relief as justice requires.
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 believes the same to be true.
Respectfully
submitted,
Joe Louis Lawrence
Counsel Pro Se
312 965-6455
IN THE CIRCUIT
COURT OF COOK COUNTY ILLINOIS
DOMESTIC RELATIONS DIVISIO1N
IN RE
)
)
Francoise
Hightower
) Judge Jean Lionel Baptiste
Petitioner
)
) Cal 42
VS
)
) No. 88 D 079012
Joe Louis
Lawrence
)
Respondent
) Room 2807
NOTICE
OF
MOTION FOR
RECONSIDERATION DUE TO JUDGE LIONEL-BAPTISTE ENTERED A COURT ORDER JULY 6, 2026
AS VOID/A NULLITY OF NO LEGAL STANDING & OBSTRUCTION OF JUSTICE AND MOTION
TO DISQUALIFY HIM FOR CAUSE INSTANTER ,
I Joe Louis Lawrence, Counsel Pro Se Defendant,
certify that I have on this day deposited said Motion for Reconsideration et
al. to all parties recorded in said Notice via regular/electronic delivery.
Please be
advised that on July 8, 2026 Respondent has filed before this Domestic Relations Division Motion for
Reconsideration ; and will present said legally sufficient instrument before
any Judge 2026
in his or her stead at 9:30 am via zoom
Joe Louis Lawrence
Counsel
Pro Se
Post Office Box 490075
Chicago,
Ill 60649
Courtesy Copies
Provided
Hon Judicial Council of the Seventh
Circuit
Governor JB Pritzker gov.casework@illinois.gov
Secretary of State Alexi Giannoulias hfs.dcssdlu@illinois.gov
To: Chief
Judge Charles Beach U.S.
Attorney Andrew S. Boutras
ocj.chief@cookcountyil.gov 219 S. Dearborn, Street 5th
floor
Hon Lionel Baptiste ccc.domrelcr2807@cookcountyil.gov
Hon Rosa Marie Silva dmpatel@cookcountycourt.com
Hon James Shapiro james.shapiro@cookcountyil.gov
Hon Patrick Powers estefania.dominguez@cookcountyil.gov
Hon Judge Patricia Fallon CCC.DomRelCRCL12@cookcountyil.gov
Hon Judge Patricial Fallon edkouenou@cookcountycourt.com
Hon Michael A. Forti CCC.DomRelCR3004@cookcountyil.gov
Hon Edward Arce Edward.arce@cookcountyil.gov
Hon. Iris Y. Chavira CCC.DomRelCRCL08cookcountyil.gov
Hon. Andrea Webber CCC.DomRelCRCL06@cookcountyil.gov
Hon Maritza Martinez CCC.DomRelCR3006@cookcountyil.gov
Hon Abbey
Romanek CCC.DomRelCR3008@cookcountyil.gov
sao.csed@cookcountyil.gov Yolanda.simmons@cookcountysao.org
Cook County State’s Attorney Chief Judge Timothy C. Evans
Eilene
O’Neil Burke timothy.evans@cookcountyil.gov
statesattorney@cookcountyil.gov
Susan Mendoza Amanda.prentice@illinoiscomptroller.gov
Child Rep Marcellus H. Moore, Jr. 203 N.
LaSalle Street, Suite 2100 marcellus@childadvocatelawgroup.com
Cook County Sheriff’s
Tom Dart
email CCSO@ccsheriff.org
The Crusader Newspaper Group
Managing Editor Sharon Fountain
State Police isp.contact@illinois.gov
Illinois State Police
Chicago Police Superintendent, 3510 S. Michigan Ave,
Chicago Ill. 60653
Email CLEARPATH@chicagopolice.org, CaseManagement@chicagopolice.org
Dir. FBI,
Hon Mayor Brandon
Special Agent in
Charge (FBI)
City Hall 7th floor
Chicago,
IL. 60601
2111 West Roosevelt Road
Chicago, Il 60608
Illinois
Courts Commission
555 West
Monroe, 15th floor
Chicago Ill.
60661
info@IllinoisCourtsCommission.gov
Illinois Court
Commission Members
Justice P.
Scott Neville, Jr. Chairman
Justice Thomas
M. Harris
Justice
Margaret Stanton McBride
Judge Lewis
Nixon
Judge Sheldon
Sobol
Judge Aurora
Abella-Austriaco
Madam Paula
Wolf
ilrb.filing@illinois.gov,
alexandrina.shrove@ilag.gov,
oig.referrals@illinois.gov
rwillis@laboradvocates.com,
jodi.mar@illinois.gov,
helen.j.kim@illinois.gov,
lashonda.channel@illinois.gov,
brianna.klein@illinois.gov,
kimberly.stevens@illinois.gov,
anna.hamburg-gal@illinois.gov,
khill@atu241chicago.org,
frogishtwo65@gmail.com,
CERTIFICATE OF SERVICE
The undersigned hereby certifies
that the above notice and all attachments were caused to be emailed to the
above parties at the addresses provided before 5:00 pm on June 23, 2026 .
Joe Louis Lawrence
Counsel
Pro Se
Post Office Box 490075
Chicago,
Ill 60649
Joelouis565@yahoo.com
AFFIDAVIT
STATE OF ILLINOIS )
)
COUNTY OF COOK )
I Joe Louis Lawrence Counsel Pro Se being duly sworn on
oath states the aforementioned pleadings enumerated within said motion 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 believes the same to be true.
Respectfully Submitted
Notary
____________________
PO Box 490075
Chicago, IL.
60649
