BRIEF BEFORE THE UNITED STATES COURT OF APPEALS 7TH CIRCUIT ADDRESSING GOVERNMENT CORRUPTION IN CHICAGO, ILLINOIS

The attached Brief has been unchallenged members of the Political Machine and Racist Attorneys and Judges were so confident they had everything under control did not expect Judge William J. Bauer to allow a Pro Se litigant to address Government Corruption.

Unlike Trayvon Martin how a smear campaign is attempted to denigrate his character as a minor, (School expulsions, wearing a hoodie etc) in an attempt to justify murdering a minor as Zimmerman "claims self-defense"

Read for yourself how Organized Corrupt Racist Judges acted as multiple Zimmerman's maintained their positions of POWER as they committed the same type of RACIAL INJUSTICE on an INNOCENT MAN OF COLOR without the BULLET!

Read how countless Zimmerman's in Illinois, Chicago, County of Cook circumvented all laws to commit the most Diabolical Depraved Acts ever recorded in any legal documents;

See how the Political Machine deployed an entire State, of Corrupt Attorneys and judges to take on an unlicensed Attorney in an attempt to prevent the very facts from being revealed.

It is sad when a man licks and sucks his way to the top,and determining what Political party he may belongs to or what a politician dictates to a judge or an attorney is how verdicts are reached in the courts is how innocent Black and Hispanic men are exploited in the courts, unjustly, so as to make weak corrupt white men and their followers feel powerful oppressing those who may be academically challenged in the area of law.

To those who maybe intimidated by the volume of pages, I'll make it easy for you Page 2 outlines the Contents and Demonstrates the District Court Errors, Page 11 are questions presented to the Court of Appeals for their responses and legal arguments to what is proposed in the brief.   

Respectfully Submitted,

Joe Louis

joelouislaw@yahoo.com

@joelouis7

                                                              IN THE

                                  UNITED STATES COURT OF APPEALS

                                         FOR THE SEVENTH CIRCUIT

                                           CHICAGO, ILLINOIS 60604

_________________________________________________________________

                                                          No 11-3481

_________________________________________________________________

 Joe Louis Lawrence                                  )   Appeal from the United States District

      Plaintiff-Appellant                                 )        Court for the Northern District

         No. 11-3481                                       )           Of Illinois, Eastern Division

               vs.                                                 )

Sec. of State, Clerk of Circuit Court,          )       JUDGE JOHN  DARRAH

States Atty., Circuit Court Judges,            )

State Judges, ATU 241, CTA Rachael     )              11 CV-6887

Kaplan, Kent S. Ray                                   )

_________________________________________________________________

                                                           Brief of

                                                 Joe Louis Lawrence

                                                   Plaintiff-Appellant

_________________________________________________________________

                                                              vs.

 Cook County States Attorney                       Chief Judge Timothy C. Evans

 Anita Alvarez                                               50 West Washington, Suite 2600

 50 West Washington, Suite 500                    Chicago, Ill. 60601

 Chicago, Ill. 60601                          

                                                                      Presiding Judge Moshe Jacobius

 Chicago Transit Authority Legal Dept.         50 West Washington, Suite 2403

 Kent S. Ray, Rachael Kaplan                        Chicago, Ill. 60601                                                   

 567 West Lake Street Chicago, IL. 60661

 Chicago, Ill. 60661-1498                          Attorney General   

                                                                     Lisa Madigan   

Dorothy Brown                                            100 West Randolph, Suite 1300

50 West Washington, Suite 1001                   Chicago, Ill. 60601            

Chicago, Ill. 60601                                             

                                                                 Asst. Gen. Counsel, Sec. of State                                   

Asst. Atty. Gen.                                             Terrence McConville

Tyler Roland                                                  100 West Randolph, Suite 500

100 West Randolph, Suite 1300                      Chicago, Ill. 60601  

Chicago, Ill. 60601                                               

                                                                 

Amalgamated Transit Union, 241

20 South Clark, Suite 850

Chicago, Ill. 60604

                                                     Attorneys for

                                             Defendant-Appellees

                                              TABLE OF CONTENTS

Table of Contents ……………………………………………………………………………………………………………………………… i

Table of Authorities .……………………………………………………………………………………………………………………….. ii

Jurisdictional Statement ………………………………………………………………….………………………………………9,10

Statement of the Issues ………………………………………………………………………….……………………………………11

Statement of the Case ………………………………………………………………………………………………………………….12

Statement of the Facts ………………………………………………………………………………………………………………….14

Summary of Argument ……………………………………………………………………………………………………………….…16

Argument ………………………………………………………………………………………………………………………………………….…17              A   Standard of Review ………………………………………………………………………………………………………………..23

              B   The District Court engaged in a conspiracy citing a case in the law that was false and constitutes a failure to follow the Canon laws, Matter of Markey, 696 N.E. 2d 523 (Mass.1998), Mississippi Comm’n on Judicial Performance v. Byers, 757 So. 2d 961 (Miss. 2000)……………………………………………………18

              C   The District Court demonstrating an act of Improprieties in an attempt to aid and assist said Appellee’s  named in Suit, In Re Judge No. 93-154, 440 S.E.2d 169 (Ga. 1994), And Deception by falsifying reasons for preventing a legally sufficient Complaint and Motion from being served on Appellee’s, In re Ferrara, 582 N.W. 2d 817 (Mich. 1998),In re Renfer, 493 S.E. 2d 434 (N.C. 1997), In re Kroger, 702 A. 2d 64 (Vt. 1997), Gonzalez v. Commission on Judicial Performance, 33 Cal. 3d 359, 657 P. 2d 372, 377, 188 Cal. Rptr. 880 (1983)………………………………………………………………………………………………………………………………….11, 12, 18

              D   The District Court Erred in abusing the adversarial process, a fundamental aspect of the adversarial system is that proceedings are to be conducted in open court. Judges have been disciplined for disposing of cases without an adversarial proceeding, In re Fitzgerald, Unreported Determination (Ky. Comm’n 1986); Holder, 74 N.J. 581, 379 A. 2d 220 (1977……………………….12, 18

              E  The District Court Engaged in an organized conspiracy violating Section IV of the Ku Klux Klan Act of 1871…………………………………..…10, 11, 17, 22, 26

Conclusion………………………………………………………………………………………………………………………………………23

Certificate of Compliance with Circuit Rule 31……………………………………………………………… 24

Certificate of Compliance with Circuit Rule 32 (a) (7) (B) …………………………………………28

Certificate of Service …………………………………………………………………………………………………………………25

                                                                     ii

                                                  TABLE OF AUTHORITIES

CASES                                                                                                               PAGE

         

 1)  Adoption of E.L.,

248 Ill. Dec. 171, 733 N.E. 2d 846, 315 Ill. App. 3d 137- Judgm 7, 16, 375….14

                                                                                                                                                   

2)   Applications of Miller,

427 F. Supp. 896 (W.D. Tex 1977)………………………………………………………………………………..16, 17

3)   Beatie v. People,

33 Ill. App 651, 189 WL 2373 (1st Dist. 1989)………………………………………………….12, 14, 15

4)   Bozarth,

604 A. 2d 100 (N.J. 1992)…………………………………………………………….……………………………………………..21

5)   Buzzard v. Bolger,

117 Ill. App. 3d 887, 453 N.E. 2d 1129…………………………………………………………………………12, 18

6)   Byrd v. Roadway Express,

687 F. 2d 85, 87 n. 3 29, Fep 1588, (5th Cir. 1982)….…………………………………………………..18

7)   Canon

3D (1) Reporting Judicial Misconduct

Mass. Comm. On Judicial Ethics, Op. 2002-04 (2002)……………………………………11, 16, 17

8)   Canon

3 D (2) Reporting Lawyer Misconduct

Fravel v. Haughey, 727 So. 2d 1033 (Fla. App. Ct. 1999), Illinois Judicial Ethics Op. 2001-06 (2001)…......................................................................................16, 17

9)   Cannon v. Commission on Judicial Qualifications,

14 Cal. 3d 678, 537 P. 2d 898, 122 Cal. Rptr. 778 (1975)……………………11, 12, 14, 18

10)  Carter v. Mueller,

457 N.E. 2d 1335 Ill. App. (1st Dist. 1983)……………………………………………………………11, 17, 18 

                                         

11)  Civil Rights Act of 1866,

Ch. 31, 1, 14 Stat. 27…………………………………………………………………………………………………………….11, 12

12)  Civil Rights Act of 1964,

703 (a) (1), 42 I.S.C.A. 2000e – 2 (a) (1)…………………………………………………………………………………………………………………………………………………..11, 12

13)  Commentary Canon 2, 2A 2C……………………………………………………………17, 18, 19, .21, 25

                                                                  iii

14)  Crawford v. State,

770 N.E. 2d 775 (Ind.)……………………………………………………………………………………………………………………18

15)  Dash,

564 S.E. 2d 672 (S.C. 2002)………………………………………………………………………………………………………………………………14, 18, 21, 22

16)  Developments in the Law Section 1981

15 Harv. Civ. Rts.---- Civ. Lib. L. Rev. 29, 133 (1980)…………………………………………………….12

17)  D. Louisell & C. Mueller,

Federal Evidence { 70, pp. 568-569………………………………………………………………………………………12

18)  Ettinger v. Rolewick,                        

140 Ill. App. 3d 295, 488 N.E. 2d 598, 94 Ill. Dec. 599 (1st Dist. 1986)………………….18

19)  Graham v. Richardson,

403 U.S. 365, 91 S. Ct. 1848, 29 L. Ed. 2d 534 (1971)………………………………………………….22

20)  Hall v. De Falco, App. 1st Dist. 1988, 127 Ill. Dec. 576, 178 Ill. App 3d 408, 533 N.E. 2d 448………………………………………………………………………………………………………………………………..14

  

21)  Halsell v. Kimberly- Clark Corp.,

683 F. 2d 285, 289, 29, FEP 1185 (8th Cir. 1982)……………………………………………………………14

22)  Hammel,

668 N.E. 2d 390 (N.Y. 1996)………………………………………………………………………………………………17, 24

23)  Hazelton v. Carolus,

1907 132 Ill. App. 512……………………………………………………………………………………………………………………14

24)  Heldebrand v. Roadmaster Corp.,

Ill. App. 3d 664, 660 N.E. 2d 1354 (1996)…………………………………………………………………….14, 15

25)  Himmel,

125 Ill. 2d 531, 533 N.E. 2d 790, 127 Ill. Dec. 708 (1988)………………4, 15, 18, 22, 24

26)  Hodge v. Police Officers,

802 F. 2d 58 (2d Cir. 1986)………………………………………………………………………………………………………. 16

27)  Howard v. Zack Co.,

264 Ill. App. 3d 1012, 637 N.E. 2d 1183 (1994)…………………………………………………………………17

28)  Illinois Rockford Corp. v. Kulp,

1968, 242 N.E. 2d 228, 41 Ill.2d 215………………………………………………………………………12, 15, 17

                                                                 IV

29)  Illinois Rules of Professional Conduct,

RPC 3.3………………………………………………………………………………………………………………………………………..18

30)  Jennings v. Patterson

488 F. 2d 442…………………………………………………………………………………………………………………………..12, 14            

31)  Jones v. Alfred H. Mayer Co.,

392 U.S. 409, 424 (1968)……………………………………………………………………………………………………..22

32)  John W. Strong, McCormick on evidence,

185, at 777-78 (4th ed. 1992)………………………………………………………………………………………………12

33)  Kroger Canon 2A,

702 A. 2d 64 (Vt. 1997)………………………………………………………………………………………………….13, 18, 19

34)  Lewis v. Brautigam,

(CA 5 F 1 A), 227 F. 2d 124, 55 Alr 2d 505…………………………………………………………………..12

35)  Lisa L. Milord, The Development of the ABA,

Judicial Code 24-25 (1992)…………………………………………………………………………………………16, 17, 23

36)  Luckie v. Ameritech Corp.,

389 F. 3d 632 (7th Cir. 2004)………………………………………………………………………………………………….22

37)  Mahone v. Waddle,

564 F. 2d 1018, (3d Cir. 1977), cert denied, 438 U. S. 904………………………………………22

38)  Mallard v. U.S. Dist. Court for Southern Dist. Of Iowa,

490 U.S. 296, 109 S. Ct. 1814, 104 L. Ed. 2d 318 (1989)………………………………………….22    

39)  Mansell v. Saunders,

(CA 5 F 1A) 372 F 2d 573………………………………………………………………………………………………………..12

40)  McCormick, Canon 2A,

639 N.W. 2d 12 (Iowa 2002)……………………………………………………………………………………………..18, 19

41)  McCray v. Maryland,

(CA 4 Md.) 456 F 2d……………………………………………………………………………………………………………………..14

42)  Mississippi Comm’n on Judicial Performance v. Fletcher,

686 So. 2d 1075 (Miss. 1996)……………………………………………………………………………………………17, 18

43)  Mississippi Comm’n on Judicial Performance v. Byers

757 So. 2d 961 (Miss. 2000), 462 S.E. 2d 728 (GA 1995)………………………………………….18

                                                                   V

44)  Monroe v. Pape,

365 U. S. 167, 5 L Ed, 2d 492, 81 S. Ct. 473…………………………………………………………….18

45)  Nelson v. Redfield Lithograph Printing,

728 F. 2d 1003 (8th Cir. 1984)………………………………………………………………………………………….17

46)  Parson v. Winter,

1986 1st Dist., 491 N.E. 2d 1236, 96 Ill. App. 3d 354, Appeal Denied…………..22

47)  Pena v. Choo,

826 F. 168 (2d Cir. 1987)…………………………………………………………………………………………………….17

48)  People v. Hardison,

1985, 911 Dec. 162, 108………………………………………………………………………………………………12, 15, 18

49)  People v. Mordick,

1981, 50 Ill., Dec. 63…………………..………………………………………………………………………………………….12

50)  People v. Katelhut,

332 Ill. App. 693, 54 N.E. 2d 590, (1st Dist. 1944)…………………………………………………..18, 19

51)  People ex rel. Rusch v. Levin, 

305 Ill. App. 142, 26 N.E. 2d 895, (1st Dist. 1939)……………………………………………………18, 19

52)  Professional Group Travel, Ltd. v. Professional Seminar Consultants Inc.,

136 Ill. App 3d 1084, 483 N.E. 2d 1291……………………………………………………………………….12

53)  Professor Tenbroek,

39 Cal. L. Rev. 188 (1951)………………………………………………………………………………………………….15

54)  Puckett v. Cox,

(CA 6 Tenn.) 456 F. 2d 233………………………………………………………………………………………………..22

55)  Reed Yates Farms, Inc. v. Yates,

172 Ill. App. 3d 519, 526 N.E. 2d 1115, 122 Ill. Dec. 576 (4th Dist.)……………..15, 18

56)  Resident Advisory Bd. V. Rizzo,

425 F. Supp. 987 (E. D. Pa 1976), modified, 564, F. 2d 126 (3d Cir. 1977), cert. denied, 435, U. S. 908 (1978)………………………………………………………………………………………….…22

57)  Runyon v. McClary,

98 Yale L.J. 565 (1989)……………………………………………………………………………………………….12, 16, 17

                                                                  VI

58)  Scott, Canon Ethics,

377 Mass. 364, 386 N.E. 2d 218, 220 (1979) See Lopez- Alexander, Unreported Order No. 85-279 (Colo. May 3, 1985……………………………………………………………11, 12, 14, 18

59)  S.H.A. Criminal,

Ch. 38, 33-3……………………………………………………………………………………………………………………………..11, 12

60)  Sherman v. Kraft General Foods, Inc.,

272 Ill. 3d 833, 651 N.E. 2d 708 (1995)…………………………………………………………………………….…17

61)  Stone v. City of Indianapolis Public Utilities Div.,

281 F. 3d 640 (7th Cir.) cert. denied, 537 U. S. 879 (2002)………………………………………..22

62)  St. Mary’s Honor Center, et al.,Petitioners v. Melvin Hicks,

1 Civil Rights under McDonnell Douglas scheme Applicable to Title VII…………17, 18

63)  Texas Dept. of Community Affairs v. Burdine,

450 U. S. 248, 254, and n. 7, 101 S. Ct. 1089, 1094, and n. 7, 67 L. 2d 207 (1981); F. James & d, Civil Procedure {7,9, p. 327 (3d ed. 1985)…………………………..…22   

64)  Turner

24 F. Cas. 337 (No. 14247)…………………………………………………………………………………………11, 12, 17

65)  U.S. v. 30.64 Acres of Land situated in Klickitat County, State of Wash.,

795 F. 2d 796, 5 Fed. R. Serv. 3d 415 (9th Cir. 1986)…………………………………………………..16

66)  U.S. Boyland, Canon 2A,

5 F. Supp. 2d 274 (D.N.J.)1998……………………………………………………………………………………….15, 18

67)  United States ex. Rel Jones v. Rundle (DCPA)

358 F. Supp. 939………………………………………………………………………………………………………………………….. 18

68)  U.S. Sup. Court Digest,

24 (1) General Conspiracy, U.S. v. Jimenez Recio, 123 S. Ct. 819, 537 U.S. 270, 154 L. Ed 2d 744, on remand 371 F. 3d 1093………………………………………11, 12, 14, 15,17

69)  Vaughn,

462 S.E. 2d 728 (Ga. 1995)…………………………………………………………………………………12, 17, 18, 24

70)  Vigus v. O’Bannon,

1886 N.E. 788, 118 Ill. 334………………………………………………………………………………………………….. 22

71)  Whirl v. Kern,

 (CA 5 Tex) 407 F. 2d 781, Cert. Den., 396 U.S. 901, 90 S. Ct. 210……………….…18

                                                                  VII

72)  W.R. Grace & Co. v. Baker Industries, Inc.,

128 Ill. App. 3d 215, 470 N.E. 2d 577, 83 Ill. Dec. 451 (1st Dist. 1984)…12, 14, 19

73)  Zoarski, Canon 2A

632 A. 2d 1114 (Conn. 1993)……………………………………………………………………………………..11, 18, 19  

42 U.S.C. 1981 and Title VII of the Civil Rights Act of 1964 (Color)

42 U.S.C. 1981 and Title VII of the Civil Rights Act of 1964 (Race)

U.S.C.{1331, 28 U.S.C. {1343 (a) (3) and 42 U.S.C. {2000e5 (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……………………………………………………………………………………………………………………………………….. 17, 18

(74)  Ferra,

         582 N.W. 2d 817 (Mich 1998)………………………………………………………………………………..12, 18

(75) Fitzgerald, Unreported determination, Ky., Comm’n (1986), Holder, 74 N.J. 581, 379 A. 2d 220 (1977)….……………………………………………………………………………………………...12, 18

      

(76) Gonzalez v. Commission on Judicial Performance,

 33 cal. 3d 359, 657 P. 2d 372, 377, 188 Cal Rptr. 880 (1983)…………………………..11, 18

(77) Judge,

 No. 930154, 440 S.E. 2d 169 (GA. 1994)……………………………………………………………………18, 22    

     

(78) Leslie W. Abramson,

 25 Hofstra L. Rev. 751 (1997). The Judges ethical duty to Report Misconduct by other judges and lawyers and it’s effect on Judicial independence……..………….12, 18 

(79) Ku Klux Klan Act of 1871

Section 1, 2, 4……………………………………………………………………………………………………10, 11, 17, 22, 26

(80) Bolden V. State,

262 Ark 718, 561 S.W. 2d 281 (1978)…………………………………………………………………………………..22 

(81) Farley V. Jester,

257 Ark. 686, 520 S. W. 2d 200 (1975)………………………………………………………………………..……..22

(82) Patterson V. RT.,

301 Ark. 400, 784 S. W. 2d 777 (1990)………………………………………………………………………………..22

                         

                                                            IN THE

                                  UNITED STATES COURT OF APPEALS

                                         FOR THE SEVENTH CIRCUIT

                                            CHICAGO, ILLINOIS 60604

Joe Louis Lawrence                                   )   Appeal from the United States District

      Plaintiff-Appellant                                 )        Court for the Northern District

         No. 11-3481                                       )           Of Illinois, Eastern Division

               vs.                                                  )

Sec. of State, Clerk of Circuit Court,          )       JUDGE JOHN DARRAH

States Atty., Circuit Court Judges,            )

State Judges, ATU 241, CTA Rachael     )

Kaplan, Kent S. Ray                                   )

                                          Jurisdictional Statement

Order entered: 10-19-2011 and 10- 27- 2011 (Disqualify judge Denied)

Notice of Appeal filed: November 1, 2011

Statutes: District Court Judge Committing Fraud, District Court Judge Committing Perjury, District Judge aiding and abetting in a Criminal Conspiracy, District Court Judge committing Unequal Protection of the Laws Violations, District Court Judge engaging in “Treason Like Offenses”, District Court Judge acting outside of the Immunity provisions of his Oath, District Court Judge engaging in “Jim Crowis’m” Laws outlawed by the United States Supreme Court  as he used his robe and jurisdiction to aid and assist Terrorists Judges and Public Officials to cover-up Criminal Civil Rights Violations, Disparate Unequal Protection of the Laws, Retaliatory Racial Harassment, Civil Rights Violations, Racial Terrorism Conspiracy, Public, Political, Fraternal Corruption Conspiracies, and other Un-Constitutional Lawless Violations.

   Plaintiff is appealing to the United States Court of Appeals, for a reversal and remand with instructions based on the foregoing stated above:

   The United States Court of Appeals has the Jurisdiction, to correct any error, Sanction or admonish any person (s) who engages in an organized Chain Conspiracy and establish any precedent in the law where deemed necessary, without fear of reprisals from any political organization, terrorist fraternal orders, elected or otherwise, for the mandate of their decision;

   The United States Court of Appeals has the Jurisdiction and Wisdom to recognize when an individual has not been afforded sapiency in accordance to the United States Constitution;

   Plaintiff is before the United States Court of Appeals because as a”Pro Se” “Informa Pauper’s“ candidate Judge Darrah has maliciously with deliberate depraved indifference for the law has falsified court papers and “LIED” on court documents saying Plaintiff did not file a complaint and has allowed said defendants to commit the aforementioned heinous criminal acts, ignoring affidavits, the Laws of the United States Constitution and Plaintiffs Civil Liberties, validating the veracity Plaintiff is a nobody merely because of his skin color, said Judge have corroborated and demonstrated his role in this Organized Chain Conspiracy; 

Under Section 4 of the Ku Klux Klan Act of 1871: the law is clear, “Whenever in any State or part of a State………unlawful combinations…….shall be organized and armed, and so numerous and powerful et al…………and whenever, by reason of either or all of the causes aforesaid, the conviction of such offenders and the preservation of the public safety shall become…..Impracticable, in every such case such combinations shall be deemed a rebellion against the Government of the United States…..” 

   Plaintiff filed a Notice of Removal Civil Action from State Jurisdiction (July 28, 2011) before the Hon. George W. Lindberg 11 CV 05142 and sought leave to Amend the document September 29, 2011, it was Denied pursuant to 28 USC 144(a) never at any time did said District Judge falsify any documents regarding the plaintiff for reasons preventing him from accessing the Federal Courts;

   Plaintiff is before the United States Court of Appeals because members of the Political Machine Racist Fraternal Order has had its members to Deny or falsify any documents necessary to advance their agenda in the legal forums;  

   Plaintiff is before the United States Court of Appeals because when Justice was sought on the State and Appellate levels, Judges claimed they had no Jurisdiction on a “Bogus case fixed by the Political Machine members of Irish and Polish ethnicity, in that said individuals share a particular “racial hatred” towards ethnic individuals like the Plaintiff and will stoop to any level necessary to achieve the goals sought as demonstrated in this case which is why Plaintiff is before the United States Court of Appeals.

I affirm the above as being true.

                                                                                            Respectfully Submitted

                                                                                             Joe Louis Lawrence

                                                                                          Plaintiff-Counsel Pro Se

                                         STATEMENT OF THE ISSUES

Whether the District Court Judge engaged in a Terrorist Act against the Appellant violating his Civil Rights prohibiting him(11) equal access to the courts,(12) due to his ethnicity as an African American, Black, Brown Man, (Pro Se litigant).

Whether the District Court Judge “Gregariously” engaged and violated Section 2, 4 of the Ku Klux Klan Act of 1871(79) against the Appellant as he violated the oath of his Federal obligation, by conspiring and aiding all parties recorded in said Civil Rights Complaint by dismissing the Complaint unlawfully;

Whether the District Court Judge engaged in “Treason” against the government, when he committed “perjury” “fraud” (10) falsifying the facts preventing the Appellant equal access to the courts;

Whether the District Court Judge acted outside of his Judicial immunity when he conspired with the parties associated in said complaint and petition for rule to show cause (9), (7);

Whether the District Court Judge should be remanded into custody instanter for deliberate heinous Civil Rights Acts against the Appellant;

  

Whether the District Court Judge engaged in a Racist Hate Act against the Appellant ignoring the Complaint legally filed ignoring all of the Civil Rights (64) Violations recorded in the Petition (68) for Rule to Show Cause as Doc. 6 Page ID 102, 103; (58)

Whether the District Court Judge used his position and authority to aid and assist politically connected (59), (64)corrupt powerful white men and those individuals of a fraternal order (73) (76);

Whether the District Court Judge enforced Jim Crow laws that have been outlawed by the United States Supreme Court?

A-Violating the Ku Klux Klan Act of 1871 warrants the removal of all conspirators associated in said matter ignoring the jurisdiction of their offices by not addressing the unlawful acts in this matter;

Whether the District Court Judge should be remanded into custody pending indictments for acting outside of his judicial immunity provisions abusing his judicial oath in assisting in criminal terrorists acts?

  

                                            STATEMENT OF THE CASE

The District Court ignored all evidence in Appellant’s Motion with Affidavit detailing Unprecedented acts of Conspiracy (11), the complaint was presented in a Legally sufficient manner and demonstrated a Prima Facie showing of Civil Rights unlawful acts lodged at appellant (64) and the amazing part is “all” defendant’s have admitted every gregarious Unconstitutional act by not objecting or submitting any counter-affidavits to the courts (52) thereby relying on members of said chain conspiracy to save them and protect them keeping them “above” the Law (3), (39), (68), (69), (59), (28), (12), (74). 

The District Court stated “Lawrence’s Complaint would not survive a motion to dismiss because it fails to state any sufficient claim for relief against the named Defendant’s” (11), if the court ignores the law how can any legal issue of merit prevail in the court? (64), (9), (48), (30), (28), (78), (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)                  

(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.

(52) Professional Group Travel, Ltd. v. Professional Seminar Consultants INC., 136 Ill App. 3d 1084 et al. State Law: 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 parties pleadings,          

(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).

(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).

(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.

(9)  Cannon v. Commission on Judicial Qualifications, 14 Cal. 3d 678, 537 P. 2d 898, 122 Cal. Rptr. 778 (1975).  

(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.

(28) Illinois Rockford Corp. V. Kulp, 1968, 242 N.E. 2d 228, 41 Ill 2d 215.

(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.

(48) People v. Hardison, 1985, 911 Dec. 162, 108; People v. Mordick, 1981, 50 Ill, Dec 63.

(59) S.H.A. Ch 38 33-3, Official misconduct is a criminal offense; and a public officer or employee commits misconduct, punishable by fine, imprisonment, or both, when in his capacity, he intentionally or recklessly fails to perform any mandatory duty as required by law; or knowingly performs an act which he knows he is forbidden by law to perform; or with intent to obtain a personal advantage for himself or another, he performs an act in excess of his lawful authority…….        

   

                                          STATEMENT OF THE FACTS

Said paternity matter was originally filed under 85 D 068184 before Judge D. Adolphus Rivers for almost 2 years was voluntarily non-suited September 17, 1987, by the States Attorney Office Richard J. Daley was the States Attorney, Ref as Page 13 of 39, Par 1, 2, (1), (14), (20), (21), (23), (72)

1.)   Appellant filed a Civil Cover sheet, Ref as Doc. 2, (Page ID 96) September 30, 2011;

2.)   Appellant filed Complaint seeking $350 million dollars, Ref as Doc 1, (Page ID 1) September 30, 2011;

A-    Affidavit accompanying Complaint ref as doc1, (Page ID 6)

3.)   Appellant filed an Application to Proceed Informa Pauperis  Ref as Page 99, (Page ID 97) September 30, 2011;

4.)   Appellant filed a Motion for Appointment of Counsel, Ref as Page 101, (Page ID 99 of Document 4) September 30, 2011;

5.)   Appellant filed an Appearance Form for Pro Se Litigants, Ref as Page 103, (Page ID 101 of Document 5) September 30, 2011;

6.)   Appellant filed a Petition for Rule to Show Cause Judges & Public Officials Corroboration in an Organized Chain Conspiracy Perjury/Contempt of Court & Contempt of the United States Constitution other Irregularities Remand/Body Attachment Instanter, Ref as Page 104, (Page ID 102, 103 of Document 6) October 6, 2011;

7.)   District Court Judge (John W. Darrah) issued an Order dismissing (1) the Complaint, “Plaintiff’s Complaint fails to state a claim for relief”, Ref as Page 131,  (Page ID 129 of Document 8) October 11, 2011;

           A-Said order stated falsely, “On October 7, 2011, Joe Louis Lawrence submitted a Complaint with an application to proceed without paying the customary $350filing fee.” Lawrence’s Complaint seeks a Rule To Show Cause relating to various assertions, (3), (9), (30), (58), (68), (15), (25), (62), (24), (41)   including: (1) the corroboration of judges and public officials in an organized chain conspiracy, (2) perjury, (3) “fraud of all sorts”, (4) contempt of court, (5) “other irregularities”, and (6) “remand/body attachment instanter;

8.)   Appellant filed a Motion For-Disqualification of Judge-Personal Bias Prejudice {28 USCA 144, 455 (B) (1)} Vacate Order of Oct. 21, 2011, Due to Fraud/Error Ref as Page 131, (Page ID 130 of Document 9) October 25, 2011 (62), ;

9.)   Appellant filed an Affidavit Ref as Page 133, (Page 1 of 10, Page ID 131 of Document 10);

10.)                       District Court Judge issued an order Dismissing (59) Plaintiffs motion for Disqualification of judge as moot, Ref as Page 158, (Page 1 of 1, Page 156 of Document 10) October 27, 2011 (3), (66), (25), (53), (55);

11.)                       District Court Judge issued an order Dismissing (24), (28), (48), (68) Plaintiff’s motion for Disqualification of judge as moot, Ref as Page 158, (Page 3 of 3, Page ID 162 of Document 15) October 27, 2011;

12.)                       Appellant filed a Notice of Appeal Ref as Page 159, (Page ID 157 of Document 14) November 2, 2011;

13.)                       District Court Clerk Docketed statement by Joe Louis Lawrence regarding Notice of Appeal, Ref as Page 162,  (Page ID 160 of Document 15) November 1, 2011;

14.)                       Appellant  filed Affidavit Accompanying Motion For Permission To Appeal Informa Pauperis, United States Court of Appeals for the Seventh Circuit, Ref as Page 165, (Page ID 177 of Document 20) November 7, 2011;

  

:

(3) 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).

(66) U.S. Boylan, 5 F. Supp. 2d 274 (D.N.J. 1998), Canon 2A, Zoarski, 632 A. 2d 1114 (Conn. 1993), Kroger, 702 A. 2d 64 (Vt. 1997), McCormick, 639 N.W. 2d 12 (Iowa 2002).  

(1) Although some trial judges may not review the orders of other judges, 

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.  

(25) Himmel, 125 Ill. 2d 531, 533N.E. 2d 790, 127 Ill. Dec. 708 (1988); Ettinger v. Rolewick, 140 Ill. Ap. 3d 295, 488 N.E. 2d 598, 94 Ill. Dec. 599 (1 st Dist. 1986), Reed Yates Farms, Inc v. Yates, 172 Ill. App. 3d 519, 526 N.E. 2d 1115, 122 Ill. Dec. 576 (4 th Dist.)

(62) St. Mary’s Honor Center, et al., Petitioners v. Melvin Hicks 1 Civil Rights 383 under McDonnell Douglas scheme applicable to Title VII Discriminatory treatment cases. Plaintiff must first establish by preponderance of evidence a “Prima Facie” case racial discrimination, thus creating the presumption that employer unlawfully discriminated against employee, Civil Rights Act of 1964, 703 (a) (1) 42 I.S.C.A. 2000e –(a) (1)

(15) Byrd v. Roadway Express, 687 F. 2d 85, 87 n. 3, 29 FEP 1588 (5 th Cir. 1982), Monroe v. Pape, 365 US 167, 5L Ed, 2d 492, 81 S. Ct 473, United States ex. Rel Jones v. Rundle (DCPA) 358 F Supp. 939, Whirl v. Kern (CA 5 Tex) 407 F 2d 781, Cert. Den. 396 US 901, 90 S. Ct. 210.

(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.

(24) Heldebrand v. Road master Corp., Ill. App. 3d 664, 660 N.E. 2d 1354 (1996) An employer found liable for retaliatory discharge may be assessed punitive damages; Howard v. Zack Co., 264 Ill. App. 3d 1012, 637 N.E. 2d 1183 (1994); Sherman v. Kraft General Foods, Inc., 272 Ill. 3d 833, 651 N.E. 2d 708 (1995).             

                                               SUMMARY OF ARGUMENT

1. District Court Erred and corroborated his part and role in said conspiracy by closing his eyes to the “Heinous Atrocities” lodged at appellant, by various Public Officials numerous judges and attorneys in various municipal positions   (57), in accordance to Canon, (7) (8); rather he ignored other procedures (2) and caused further harassment to Appellant, a delay in justice benefits the perpetrators behind the conspiracy and within the conspiracy, (28) (45), (47).

2. Due to this courts gregarious error and intimate involvement is what enabled the State Courts and the organized men Racially connected politically to use the laws as weapons to Oppress and Economically destroy Appellant without any financial means of independence to provide for himself and family in the hope of his demise as everyone soared politically in their careers for 24 years their objective was to lynch Appellant using the law.

3. In the wake of extensive investigations by Federal Law enforcement authorities revealing widespread corruption in the Illinois court system (“Operation Greylord”) and elsewhere, indicating not only that significant professional misconduct was occurring but also that the requirement to report misconduct was frequently ignored, particularly in the cases of judges with regard to the conduct of other judges. (35) 

  

4. The District Court gregariously Erred in not appointing counsel (47)  for appellant violating his constitutional rights (69), the court having complete knowledge of the “Draconian” Unconstitional Violations perpetrated upon appellant, in the State and other areas as recorded in said “Affidavits”, had knowledge the Assistant States Attorneys committed “fraud” on the courts and falsifying numerous documents asserting he owed child support, had knowledge, no judge ever ordered, the defendant to pay any child support in his Default Judgment and unlawfully removed him from the Chicago Transit Authority in retaliation (24), (27), (29), (60) and has admitted this fact through out various unchallenged “affidavits” put before the Illinois Supreme Courts and Appellate courts by Appellant.” Thereby seeking suspension of his driver’s license was an Unconstitutional Act Violating Appellant’s Civil Rights;  

 

5. The District Court exercised the presumption an African American Male is not afforded “Equal Access and Equal Treatment of the laws in Illinois, due to that fact. The court did not afford Appellant any Equal Protection of the Laws in spite of the Laws of the United States Constitution (64). Civil Rights Act in Turner, the law is blatantly clear Appellant was entitled to all Equal benefits and access of the laws (57).

6. The District Court having full-cognizance of State Laws (1) in the Affidavit of Page 3 of 26, (Page ID 104 of Doc. 6, Par 2, states “case 88 D 079012 is a fixed paternity case Political Machine Operatives manufactured to cover-up and protect a Police officer who allegedly impregnated his natural biological daughter”…et al  (69), (45), (22), (42), (10), (13), (35).  

7. The District Court failed to follow the laws under Canon 2A and the failure to apply the law to matters that come before them (13), (15).

8. The District Court Erred as he violated court rules (14), (66), (75), (74).    

9. The District Court Erred gregariously said judge had an Ethical Duty to Report Misconduct by other Judges (74) but instead elected, to demonstrate Bias and or Overt Conspiracy in dismissing said Complaint and Motion before the Court.  

10. The District Court Erred and corroborated his role as a conspirator ignored said Petition for Rule to Show Cause et al., Ref as Page 104, (Page ID 102, 103 of Document 6) falsely recorded the above document as Appellant’s Complaint and additionally, stating Appellant filed a document “On October 7, 2011, Joe Louis Lawrence submitted a Complaint …..“et al Ref as Page 131, (Page ID 129 of Document 8); (77), (78);

11. The District Court demonstrated 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 they were able to Induce Reliance (42) and (10) on several Judges in the Court of Appeals and others in legal authority conspiring against Appellant, 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” (13) (14) (74) (15)

       A- That Par 1-4 of Affidavit Page 3 of 26, (Page ID 104 of Doc. 6) identifies the judges and roles they played as they soared in their careers oppressing an innocent man.

12. That because the District Court has erred in so many areas, in that said judges have been disciplined for trivializing or disparaging a defendant’s right to counsel. (4) In re Bozarth, the District Court did not follow the laws of the United States Constitution in accordance to Federal Rules of Civil Procedure. (15), (42), (74), (14)

13. That the District Court Erred and ignored the facts (15) never disputed or challenged in any of the affidavits put before the courts by the Appellant (5), (29), (52), (58), (76);

14. Said judges have demonstrated they are “Above the Law” and has employed tactics (9),(25), (62) validating the veracity they are “Untouchable” (48),(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.

15.) That the District Court ignored the facts, admissions, and corroborations Recorded in all affidavits demonstrating Judges and a host of other Public Officials and others engaging in Unprecedented Acts of Civil Rights Violations Lodged at Appellant as it related to this legal matter (33), (40), (73), (72), (50) (51);

16. Furthermore, when testing for the “appearance of impropriety” the District Court has a criteria that must be met (13), this Commentary in Canon 2C clearly and unequivocally demonstrate the District Court’s posture towards the membership because the court was unable to lawfully Dismiss the Complaint and Motion in a Legally upright manner, in that, he had to create a law he felt suitable, dismissing Appellant’s claims.

(57) Kaczorowski, The Enforcement Provisions of the Civil Rights Act of 1866: A Legislative History in Light of Runyon v. McCrary, 98 Yale L. J. 565, 567-68 (1989). {T}he framers insisted that this Amendment delegated to Congress as much authority to secure the freedom established by its abolition of slavery as Congress previously had possessed to secure the property right of slaveholders in their slaves. The framers specifically relied on the United States Supreme Court’s interpretation of the constitutional provision that secured the personal property right of slaveholders in their slaves as authority for their view of Congress’ plenary power to secure the personal rights of the slaves emancipated by the thirteenth Amendment. See also Nowak, Federalism and the Civil War Amendments, 23 Ohio N.U.L. Rev. 1209 (1997).

(7,8) Canon 3D (1)(2) A judge who receives information indicating a substantial likelihood that a lawyer has committed a violation of the Rules of Professional Conduct that raises a substantial question as to the lawyer’s honesty, trustworthiness or fitness as a lawyer in other respects shall inform the appropriate authority.   

(2) Applications of Miller, 427 F. Supp.896 (W.D. Tex 1977), other factors include: A- the plaintiff’s ability to investigate, gather, and present crucial facts; B- the type and complexity of the case; C- the complexity of legal issues; D- whether the case’s factual issues turn on credibility, and the need for the trained presentation of evidence and cross-examination; E- the plaintiff’s apparent ability to present the case, Hodge v. Police (45)  Nelson v. Redfield Lithograph Printing, 728 F 2d 1003 (8th Cir. 1984), U.S. v. 30.64 Acres of Land, more or less, Situated in Klickitat County, State of Wash., 795 F 2d 796, 5 Fed. R. Serv. 3d 415 (9th Cir. 1986). finally the court may also determine that the nature of the litigation is such that the court as well as the plaintiff would benefit from the Assistance of Counsel, Officers, 802 F 2d 58 (2d Cir. 1986); the timeliness of the request is also a factor;       

(47) Pena v. Choo, 826 F 168 (2d Cir. 1987), it has been held that a court may deny a plaintiff’s motion for counsel if it concludes that the chances of success are highly dubious, and to reach this conclusion, it may rely on an evaluation by a member of the bar that the claim has no merit.  

(35) Lisa L. Milord, The Development of the ABA Judicial Code 24-25 (1992)                                                                                                

(22)The Supreme Court of Georgia removed a judge from office for disregarding defendant’s Constitutional rights, including refusing to set appeal bonds for two defendant’s in timely fashion, issuing bench warrants without probable cause, and forcing a defendant to enter a guilty plea in the absence of Counsel. The Court stated, that the judge’s “cavalier disregard of these defendants’ basic and fundamental constitutional rights exhibits an intolerable degree of judicial incompetence, and a failure to comprehend and safeguard the very basis of our constitutional structure Id at 735 See also In re 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 defendant’s basic constitutional rights).

(64) Turner, 24 F. Cas. 337 (No. 14247).    

(1) Adoption  of E.L.. “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”.

(42) Mississippi Comm’n on Judicial Performance v. Fletcher, 686 So. 2d 1075 (Miss. 1996); Mississippi Comm’n on Judicial Performance v. Byers, 757 So. 2d 961 (Miss. 2000) inquiry concerning a judge, 462 S.E. 2d 728 (GA 1995) Dash, 564 S.E. 2d 672 S.C.2002).

(10) 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.

(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. 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).

(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.

    

   See that is why, the Ku Klux Klan Act of 1871 (was enacted) - Section 1 (42 U.S.C.) 1983.

       “Of all the Civil Rights legislation enacted in the aftermath of the Civil War, none has had a greater contemporary impact than the Ku Klux Klan Act of 1871. The Act grew out of a special one-paragraph message sent to the 42d Congress on March 23, 1871, by President Ulysses S. Grant, urgently requesting the enactment of legislation”.

Section 2 (42 U.S.C.) In the House of Representatives.

        “Congressional Debate of the second section of the Ku Klux Klan Act was more extensive and enduring than that of Section 1; As originally presented, Sec. 2 made it a felony for any “two or more persons” to conspire to commit certain enumerated crimes “in violation of the rights and privileges, or immunities of any person, to which he is entitled under the Constitution and laws of the United States.

           “Throughout the debates, supporters of the Act made repeated references to the depredations of the Ku Klux Klan; Victims of these atrocities included not only blacks but white Republicans as well. The crimes that were perpetrated, therefore, were not viewed as isolated occurrences, but as part of an “Organized Conspiracy….Political in its origin and aims”, “crimes perpetrated by concert and agreement, by men in large numbers acting with a common purpose for the injury of a certain class of citizens entertaining certain political principles, id, at 457 (remarks of Rep. Coburn). See also e.g., id. At 437 (remarks of Rep. Cobb) (“None but Democrats belong or can belong to these societies”) et al.,

           “Where these gangs of Assassins show themselves the rest of the people look on, if not with sympathy, at least with forbearance. The boasted courage of the South is not courage in their presence. Sheriffs, having eyes to see, see not; judges, having ears to hear, hear not; witnesses conceal the truth or falsify it; grand or petit juries act as if they might be accomplices. In the presence of these gangs all the apparatus and machinery of civil government, all the processes of justice, skulk away as if government and justice were crimes and feared detection. Among the most dangerous things an injured party can do is to appeal to justice. Of the uncounted scores and hundreds of atrocious mutilations and murders it is credibly stated that not one has been punished. Cong. Globe, supra note 2,  app. At 78 (remarks of Rep. Perry). (“While murder is stalking abroad in disguise, while whippings and lynching’s and banishment have been visited upon unoffending American citizens, the local administrations have been found inadequate or unwilling to apply the proper corrective”) et al., …. And the State made no successful effort to bring the guilty to punishment or afford protection or redress to the outraged and innocent.”)    

(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.

                               

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.

17. Where a judge exhibits bias or the appearance of bias, the court will reverse. (82) Patterson V. RT., 301 Ark. 400, 784 S. W. 2d 777 (1990); (81) 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.(80) “Bolden V. State, 262 Ark 718, 561 S.W. 2d 281 (1978). 

             

 18.  The Chicago Daily Law Bulletin, Wednesday April 26, 2006

          Page 1, Illinois Political Machines help breed corruption, Associated Press writer

         Deanna Bellandi states, “Illinois is apparently a Petri dish for corruption. It is a real breeding ground”.        

That Chicago is the most Corrupt City in America, Huffington Post, Internet Newspaper, February 23, 2012;

19. University of Illinois Professor Dick Simpson, “The two worst crime zones in Illinois are the governor’s mansion…..and the City Council Chambers in Chicago.” Simpson a former Chicago Alderman, told the AP “no other State can match us.”

(15), (19), (25), (31), (36), (37), (38), (46), (54), (56), (61), (70), (77).

                                                        ARGUMENT

                            STANDARD OF REVIEW LEGAL ANALYSIS

Appellant has presented to this body of Justices 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 and certain Federal Judges abuse the powers and jurisdiction of their oath to desecrate the laws at will demonstrating no integrity or respect for the laws or the oath of the United States Constitution..

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 attorney’s are working with criminal Terrorists hiding within the laws behind robes and with sinister political affiliations violating all sorts of laws obtaining an unfair advantage over parties like the Appellant who have already been harmed by said illegal Unconstitutional Acts receive any type of justice in this State, County or City? (35)

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, indicting, remanding those parties who do not abide by the laws and ignore the laws based on the ethnicity of an individual as demonstrated in Appellant’s case, precedents added/enforced to include judicial officers and attorneys violating the laws they were elected or appointed to uphold in office. 

Appellant was not nor any family member born or any family members had criminal backgrounds, father was a self employed Locksmith, mother was a State employee where she later retired from a University.

Appellant did not experience the lifestyle of existing on Welfare, being incarcerated for not making unlawful child support payments, until all of the aforementioned recorded in said Brief took place;   

Appellant is a Certified Full-Time Chicago Transit Authority Employee not allowed to return to work, due to powerful corrupt white men controlling the City;

Appellant was Accepted to Attend Northwestern Law school;

Appellant was Accepted and Passed the Police Exam scored in top 13%, Chicago Police Commander was not able to vouch for him attending the Police Academy due to the aforementioned Paternity matter;

Appellant worked as High School Business Instructor/Disciplinarian;

Appellant worked in the Cook County Sheriff’s Dept lost that job due to the aforementioned paternity matter.

Appellant worked as a Truck driver with two bread companies, terminated unlawfully from IBC someone embezzled approximately $50, 000.00, of his disability payments while receiving welfare with a work-related injury;

Appellant is an Academian no Prisoner, Deadbeat dad or any other negative connotation described of a Black, African American Man.   

If an individual has no aspiration beyond his present situation, his presence shall remain the same, an individual is in his Heart what he or she thinks himself to be and out of his “heart” flows the issues of life.

                                                      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.       

Plaintiff has followed all of the Rules of Civil Procedure and Illinois Supreme Court Rules but the Circuit Courts ignored and denied every legally sufficient document that was presented; the Courts ruled along racial ethnic political lines granted and accepted every document opposing  counsel presented;

How can any person whether they are Irish or of Polish ethnicity be the majority in control, see wrong, ignore wrong, close their ears and eyes to wrong when a person of their ethnic group commits fraudulent acts?

How can any Judge whether they be Asian, Mexican or African American etc in the Circuit Courts who is a minority on the bench go up against a majority in control especially if that lawyer or law firm is of the majority’s ethnic make up or part of the Terrorist Order and rule against that lawyer or judge and not expect some type of repercussion from those in control?

That because Plaintiff is of a different heritage non-white, he received a disparate dispensation of the laws demonstrating, that there is a blatant double standard applied in the courts, when he challenges white (Caucasian) men or men mighty in a majority or mighty in a political sense, there is no Justice in this City for persons of color as demonstrated against the Appellant;

In addition, See affidavit of Complaint, where the following legal citation is applicable, Vaughn 462 S. E. 2d 728 (Ga.1995), The Supreme Court of Georgia removed a Judge from office for disregarding defendant’s Constitutional rights; (25)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 (legal Citations)  are precedents, due to said judges ethnic make up demonstrates a fraternal unification  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.

Said Brief demonstrates how corrupt white men really feel about Black, Brown African American men those who are not killed or incarcerated for 25-35 years wrongfully are subjected to a modern day of incarceration being limited to exercise any meaningful freedom and denied equality as demonstrated in this matter;

 like the young man slain in Sanford Florida unjustly (Trayvon Martin) carrying skittles wearing a hoddie, he was killed being black as the white man hunted and killed him in self-defense.

Unlike many young black brown men who have perished at the hands of unjust racism Appellant have been provided protection in a unprecedented manner preparing said Brief to bring about Racial equality for all ethnic groups disenfranchised unlawfully by corrupt powerful white men in organized groups within the legal venues in the State of Illinois, City of Chicago, County of Cook.

In the 20th century, the Supreme Court began to overturn Jim Crow laws on constitutional grounds. In Buchanan v. Warley 245 US 60 (1917), the court held that a Kentucky law could not require residential segregation. The Supreme Court in 1946, in Irene Morgan v. Virginia ruled segregation in interstate transportation to be unconstitutional, in an application of the commerce clause of the Constitution. It was not until 1954 in Brown v. Board of Education of Topeka 347 US 483 that the court held that separate facilities were inherently unequal in the area of public schools, effectively overturning Plessey v. Ferguson, and outlawing Jim Crow in other areas of society as well. This landmark case consisted of complaints filed in the states of Delaware (Gebhart v. Belton); South Carolina (Briggs v. Elliott); Virginia (Davis v. County School Board of Prince Edward County); and Washington, D.C. (Spottswode Bolling v. C. Melvin Sharpe). These decisions, along with other cases such as McLaurin v. Oklahoma State Board of Regents 339 US 637 (1950), NAACP v. Alabama 357 US 449 (1958), and Boynton v. Virginia 364 US 454 (1960), slowly dismantled the state-sponsored segregation imposed by Jim Crow laws.

                                                    CONCLUSION

 

 For the foregoing reasons, Appellant requests that this Honorable Court Reverse the District Court Judgment and not Remand to same District Court due to numerous noted Bias and other noted Irregularities/and or in the alternative the Issuance of a Rule to Show Cause to the CTA and all related attorneys, in this City and State, IBC attorneys and Public Officials all associated Assistant States Attorneys and to whom so ever this Honorable Court deems necessary to answer before this court, for their roles and involvements in “Diabolical Unprecedented Civil Rights Conspiracy and Criminal Extortion Violations Instanter.”

Impose Sanctions/Remands on all related conspirators, pursuant to this court’s jurisdiction, Dismiss and Expunge all related charges  against him by the Secretary of State keeping his drivers license, due to Fraud Criminal Conspiracies Civil Rights Violations by all Appellee’s;

Pursuant to Section 4 of the Ku Klux Klan Act of 1871: the law is clear, “Whenever in any State or part of a State………unlawful combinations…….shall be organized and armed, and so numerous and powerful et al…………and whenever, by reason of either or all of the causes aforesaid, the conviction of such offenders and the preservation of the public safety shall become…..Impracticable, in every such case such combinations shall be deemed a rebellion against the Government of the United States…..” 

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 a Summary Judgment of the $350 Million Dollars sought for in his complaint, not $9,999,999.00.

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”)

                                                                           Respectfully submitted,

                                                                              Joe Louis Lawrence

                                                                     ___________________________

                                                                                 Plaintiff-Appellant

                                                                                   Pro Se Attorney

                    CERTIFICATE OF COMPLIANCE WITH CIRCUIT RULE 31

   I hereby certify that pursuant to Circuit Rule 31 (e), an electronic version of this brief, in Portable Document Format (PDF) has been uploaded to the Court’s website, and that a disk containing a digital version of this brief, in PDF, has been included with the copy of the brief served on Defendant-Appellees. I certify that the items included in the short appendix are not available in non scanned PDF electronic form.

                                                                                Respectfully submitted

                                                                                  Joe Louis Lawrence

                                                                            _________________________

                                                                                      Plaintiff-Appellant

                                                                                        Pro Se Attorney                                                                             

                                              CERTIFICATE OF SERVICE

I hereby certify that on  March 21, 2012, I served a opposing counsels courtesy copies of Plaintiff-Appellant’s Brief, by hand delivery, email transmission via depositing it in the United States mail addressed to:

Cook County States Attorney                          Chief Judge Timothy C. Evans

         Anita Alvarez                                          50 West Washington, Suite 2600

         50 West Washington, Suite 500                Chicago, Ill. 60601

         Chicago, Ill. 60601                          

                                                                       Presiding Judge Moshe Jacobius

       Chicago Transit Authority Legal Dept.      50 West Washington, Suite

       Kent S. Ray, Rachael Kaplan                       Chicago, Ill. 60601                                                  

       567 West Lake Street Chicago, IL. 60603

       Chicago, Ill. 60661-1498                       Hon. Mary Lane Mikva

                                                                         50 West Washington, Suite

                                                                       Chicago, Ill. 60601

Clerk of the Circuit Court                     

Dorothy Brown                                                Attorney General   

50 West Washington, Suite 1001                         Lisa Madigan   

Chicago, Ill. 60601                                         100 West Randolph, Suite 1300

                                                           Chicago, Ill. 60601

Asst. Atty. Gen.                                             

Tyler Roland                                                     Asst. Gen. Counsel, Sec. of State

100 West Randolph, Suite 1300                           Terrence McConville

Chicago, Ill. 60601                                             100 West Randolph, Suite 500

                                                             Chicago, Ill. 60601

Amalgamated Transit Union, 241

20 South Clark, Suite 850

Chicago, Ill. 60604

COURTESY COPIES TO THE FOLLOWING:

Dir. Mueller, FBI, Wash. D.C.     U.S Atty General Eric Holder, Wash. D. C.

Robert Grant                              U.S. Atty Pat. Fitzgerald

FBI                                           219 South Dearborn, Suite 500

2111 West Roosevelt Road          Chicago, Ill. 60604

Chicago, Ill. 60612

 

                                                                                Respectfully submitted

                                                                                  Joe Louis Lawrence

                                                                            _________________________

                                                                                       Plaintiff-Appellant

                                                                                         Pro Se Attorney                                                                                    

        CERTIFICATE OF COMPLIANCE WITH CIRCUIT RULE 32 (a)(7) (B)

I hereby certify that the preceding Brief complies with Circuit Rule 32 (a) (7) (B). The word processing system utilized to prepare Plaintiff’s Appellant’s Brief Microsoft word 2000, indicates the Brief contains 9,836 words, excluding parts exempted by Fed. Rule App. P. 32(a)(7)(B)(iii) which complies with the type volume limitations of Circuit Rule 32(a)(7)(B).

                                                                                       Respectfully submitted

                                                                                        Joe Louis Lawrence

                                                                                         _________________

                                                                                           Plaintiff-Appellant