This is the reply many of you have requested that I post so as to give the readers an understanding what the attorneys have said or their responses to my opening briefs.
This reply Brief demonstrates how I have defeated Chicago's top Corrupt legal scholars they have used the laws as a weapon, but never expected the weapon of the law to to turn on them.
IN THE
UNITED STATES COURT OF
APPEALS
FOR THE SEVENTH CIRCUIT
CHICAGO, ILLINOIS
60604
_________________________________________________________________
No 07--2287
_________________________________________________________________
Joe Louis Lawrence ) Appeal from the United States District
Plaintiff-Appellant )
Court for the Northern District
) Of Illinois, Eastern Division
vs )
) JUDGE KENNELLY
Interstate Brands Corporation )
Chicago Transit Authority ) No. 07 C 1191
Chicago
Police Department )
Defendant-Appellee )
Reply
Brief of
Joe Louis Lawrence
Plaintiff-Appellant
vs.
Chicago Transit Authority
Rachael
L. Kaplan, Law Dept.
567 West Lake Street
Chicago, Illinois
60661-1498
Corporation Counsels
Myriam Kasper
Nadine Wichern
30 North LaSalle
Suite 800
Chicago, Illinois
60602
Interstate Brands
Corporation/Wonder bread
12 East Armour Blvd.
Kansas City, MO 64111
Attn: Law Dept.
Attorneys for
Defendant-Appellees
TABLE
OF CONTENTS
Table
of Contents ……………………………………………………………………………………………………………………………… i
Table
of Authorities .……………………………………………………………………………………………………………………….. ii
Summary
of Argument …………………………………………………………………………………………………………………… 6
Argument
………………………………………………………………………………………………………………………………………….. 11 A Standard of Review
………………………………………………………………………………………………………………..11
B The Appellees Erred by engaging in a
conspiracy committed sanction able errors made misrepresentations to the court,
Mathis v. New York Life Ins. Co.,133 F. 3d 546 (7th Cir. 1998) citing
cases in the law that relates to Prisoners and their civil rights, “knowing”
Appellant is not a Prisoner, Daniels v. Williams, 474 U.S. 327 (1985) ………………………………………………………………………………………………………………9,
10
C The Appellees Erred for intentional
misrepresentations in Briefs, Mathis v. New York Life Ins. Co., 133 F. 3d 546
(7th Cir. 1998), and unlawful reference to USCA 1915 (e) which does not
exist and legal citations referencing inmates and convicted felons, Omnibus
Consolidated Recessions And Appropriations Act of 1996, Title VII Prison
Litigation Reform, Public Law 104, Pub. L. No. 104-134 110 Stat
1321…………………………………………………………………………………..13
D The Appellees Erred in abusing the
adversarial process violating the Illinois Rules of Professional Conduct, RPC a
lawyer shall not violate and the fact that numerous municipal customs exercised
and practiced by various Judges on all levels, State agencies ignored the Civil
Rights violations perpetrated against Appellant, Exhibits A – X demonstrates
multiple acts of systemic applications of constitutional violations, in that
judges and State Agencies acted as decision makers possessing final authority,
Brown v. Bryan County, OKL., 67 F. 3d 1174 (1995), Stokes v. Bullins, 844 F. 2d
269, 275 (5th Cir. 1988), Wassum v. City of Bellaire, Texas, 861 F.
2d 453, 456 (5th Cir. 1988), Benavides v. County of Wilson, 955 F.
2d 968, 972 (5th Cir.) cert. denied,__ U.S.__, 113 S.Ct. 79, 121 L.
Ed. 2d 43 (1992), “Liability will accrue for the acts of a municipal official
when the official possess “final policymaking authority” to establish municipal
policy with respect to the conduct that resulted in a violation of
constitutional rights. Pembaur v. City of Cincinnati,
475 U.S. 469, 483, 106 S. Ct. 1292, 1300, 89 L.Ed. 2d 452 (1986) (plurality
opinion),Smith v. Wade U.S. 30, 35, 103 S. Ct.1625, 1629, 75 L Ed 2d 632 (1983)
....………………………………………………………………………………………… …6, 7, 8, 9,12
Conclusion………………………………………………………………………………………………………………………………………
12
Certificate
of Compliance with Circuit Rule 32 (a) (7) (B) ………………………………………… 14
Certificate
of Service ………………………………………………………………………………………………………………… 13
i
TABLE OF AUTHORITIES
CASES
PAGE
1) Beatie
v. People,
33
Ill. App 651,
189 WL 2373 (1st Dist. 1989)…………………………………………………………….7, 8, 9
2) Benavides
v.County of Wilson,
955
F 2d 968, 972 (5th Cir.)
Cert
Denied………………………………………………………………………………………………………………………………… 6
3) Brown
v. Bryan County, OKL,
67
F. 3d 1174 (5th Cir 1995…………………………………………………………………………………………………. 6
4) Daniels
v. Williams,
474
U. S.
327 1985 ……………………………………………………………………………………………………………….. 9,
10
5) 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)….......................................................................................8,
9
6) City
of Canton v.
Harris,
489
U.S. 378, 390, 109 S. Ct. 1197, 1205, 103 L.Ed. 2d 412 (1989)………………… 6
7)
Carter v. Mueller,
457
N.E. 2d 1335 Ill.
App. (1st Dist. 1983)……………………………………………………………………… 7, 8
8)
Drew v.U.S.,
C.A.D.C.1964,
331 F. 2d 85, 118 U.S.
App.D.C. 11…………………………………………….. 7, 8, 9
9)
Illinois Court Rules & Procedures,
LR
83.58.2, LR 83.58.4, (2007)…………………………………………………………………………………. 6, 7, 8, 9
10)
Illinois Rules of Professional Conduct,
RPC
3.3 A Lawyer Shall not:………………………………………………………………………………………..6, 7, 8, 9
(1) make a statement of
material fact or law to a tribunal which the lawyer knows or reasonably knows
to be false;
(2) fail to disclose to a
tribunal a material fact known to the lawyer when disclosure is necessary to
avoid assisting a criminal or fraudulent act by the client;
(3) fail to disclose to the
tribunal legal authority in the controlling jurisdiction known to the lawyer to
be directly adverse to the position of the client and not disclosed by opposing
counsel;
(4) offer evidence that the
lawyer knows to be false. If lawyer has offered material evidence and comes to
know of it’s falsity, the lawyer shall take reasonable measures remedial
measures;
ii
(5) participate in the
creation or preservation of evidence when the lawyer knows or reasonably should
know the evidence is false;
(6) counsel or assist the
client in conduct the lawyer knows to be illegal or fraudulent;
(7) engage in other illegal conduct or conduct in
violation of these rules;
(8) Fail to disclose the
identities of the clients represented and of the persons who employed the
lawyer unless such information is privileged or irrelevant
(9) Intentionally degrade a
witness or other person by stating or alluding to personal facts concerning
that person which are not relevant to the case;
(10) In trial, allude to any
matters that the lawyer does not reasonably believe is relevant or that will
not be supported by admissible evidence, assert personal knowledge, of facts in
issue, except when testifying as a witness.
Or
state a personal opinion as to the justness of a cause, the credibility of a
witness, the culpability of a Civil litigant, or the guilt or innocence of and
accused, but a lawyer may argue, on analysis of evidence, for any position or
conclusion with respect to the matter stated herein.
11)
Mathis v. New York Life Insurance,
133
F 3d 546 (7th Cir. 1998)………………………………………………………………………………………………………… 9
12) Okla.
Stat. Ann
Tit. 70 3311 (d) (2) (west
1994)……………………………………………………………………………………….. 9
13)
Omnibus Consolidated Rescissions and
Appropriations Act of 1996
Title VIII Prison Litigation Reform
Public Law 104
Pub L. No. 104-134 110 Stat
1321…………………………………………………………………………….. 10
14) People
v. Katelhut,
332
Ill. App.
693, 54 N.E. 2d 590, (1st Dist. 1944)……………………………………………….. 7, 8, 9
15) People
ex rel. Rusch v. Levin,
305
Ill. App.
142, 26 N.E. 2d 895, (1st Dist. 1939)………………………………………………… 7, 8, 9
16) S.H.A.
Criminal,
Ch. 38,
33-3……………………………………………………………………………………………………………………………………… 9
17) Smith
v. Wade,
461
U.S.
30, 35, 103 S.Ct. 1625, 1629, 75 L Ed 2d 632 (1983)……………………….. 6, 12
18) Stokes
v. Bullins,
844
F. 2d 269, 275 (5th Cir. 1988)……………………………………….………………………………………………… 6
19)
Stout v. Broom,
406
F. 2d 758 (1969)……………………………………………………………………………………………………………….. 8, 9
20)
U.S., 113 S. Ct.
79, 121
L.
Ed 2d 43 (1992)………………………………………………………………………………………………………………………. 6
21)
U.S. v. DeSalvo,
Ca.
9 (Cal.)
1994, 41 F 3d 505, Habeas Corpus Denied………………………………………….. 8, 9
22) 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……………………………………………………………….. 9
23) Wassum
v. City of Bellaire, Texas,
861 F. 2d 453, 456 (5th Cir.
1988)…………………………………………………………….………………………… 6
Summary of Argument
“There
is an old adage among lawyers that, when the law is not on your side, you
should attempt to confuse the court or jury with your spin on the facts when
one engages in this practice on appeal, it regrettably makes the court task of
resolving disputes all the more time consuming” Coffey Circuit Judge.
Appellees attorneys for the CTA IBC/wonder bread, and
City of Chicago,
Corporation Counsels (Police Dept.) Erred did not impeach Appellant’s brief with
any credible legal citations, credible affidavits exonerating their clients or
themselves in said criminal conspiratory fraudulent acts, nor did they present
any attempt to investigate Appellant’s assertions to impeach his veracity, (3)(2)
realizing
his constitutional rights were being unconstitutionally violated with
deliberate malice and indifference to his welfare (6) and (18), (17 ).
The
Appellees having full-cognizance of State Laws and Federal Laws in that
Mara S. George, Corp. Counsel for City, knowingly committed fraud (7) and (21),(9),(10) contemptuously
recorded, page 1 of said brief, “the District court granted Lawrence leave to
proceed informa pauperis, but dismissed the case pursuant to 28 USC 1015 (e)
(2) (B) (2000), for failure to state a claim on which
(3)
Brown v. Bryan County, OKL. 67 F. 3d 1174 (5th
Cir 1995) “In light of the law enforcement duties, assigned to deputies, the
obvious need for a thorough and good faith investigation of Burns, and the
equally obvious fact that inadequate screening of a deputy could likely result
in the violation of citizens constitutional rights, Sheriff Moore can
reasonably be said to have acted with deliberate indifference to the publics
welfare when he hired Burns”
(6)
City of Canton v. Harris, 489 U.S. 378, 390, 109 S.Ct. 1197, 1205, 103 L. Ed.
2d 412 (1989) (17) Smith v. Wade, 461 U.S.30, 35, 103 S.
Ct. 1625, 1629;
(18)
Stokes v. Bullins, 844 F. 2d 269, 276 (5th Cir. 1988). “We
require …….. a plaintiff [in cases such as this] to establish actual knowledge
of the seriously deficient character of an applicant or a persistent pattern of
the hiring of policemen, for instance, with a background of unjustified
violence”
(10)
Illinois Rules of Professional Conduct
(RPC 3.3), entitled” Conduct Before a Tribunal” sets forth the standards to be
followed by the trial lawyer during “battle”. Section (a) of that rule states:
(a) In appearing in a professional capacity before a tribunal, a lawyer shall
not: make
a statement of material fact or law to a tribunal which the lawyer
knows or reasonably knows to be false;
fail to disclose to a tribunal
a material fact known to the lawyer when disclosure is necessary to avoid
assisting a criminal or fraudulent act by the client;
fail to disclose to the
tribunal legal authority in the controlling jurisdiction known to the lawyer to
be directly adverse to the position of the client and not disclosed by opposing
counsel;
offer evidence that the lawyer
knows to be false. If lawyer has offered material evidence and comes to know of
its falsity, the lawyer shall take reasonable measures remedial measures;
relief
could be granted”, B- She asserted the same falsehoods on page 3-4, C- she
states, “Section 1915 (e) directs the District court, at the time it evaluates
a litigants IFP petition, to dismiss complaints that are Frivolous or Malicious,
or that fail to State a claim for which relief may be granted”
Rachael
L. Kaplan, Chief Attorney CTA, knowingly committed fraud (9) (10),(7) and (1) in addition
contemptuously recorded on page 4, “Lawrence failed to file his opening brief”
page 6, “Lawrence’s opening brief does not comply with numerous provisions of
the Federal Rules of Appellate Procedure“, A- Page 8, she repeats Appellants
factual assertion, “As for the CTA, Lawrence avers that it engaged in a
veritable laundry list of illegal acts” et al; B- Appellee is cognizant, she
has submitted numerous convoluted false statements to the court, in an attempt
to undermine it’s integrity, (8), Exhibit 3, from Appellants brief, letter from
International President of Amalgamated Transit Union, Warren S. George, states
in letter, “Brother Lawrence seeks our assistance to determine the status of
his pending grievance involving his efforts to return to active service with
the CTA, following an extended absence caused by injury”, Ex. 5, President
sought an update, to no avail no success;
Said
attorney with malicious contempt for the law in an “untouchable manner”
records, page 8, “Lawrence alleges that a former CTA attorney signed an illegal
body attachment warrant against him for an order of protection” and took
Lawrence badge off his body, Ex. B11, copy of Unlawful Unconstitutional
Warrant, Judge Ronald Bartkowicz, former CTA attorney, who signed the warrant,
Ex. 13, Investigator M. Burton of CTA, signed his name acknowledging what was
removed from Appellants body on Sheriff stationery while he was unlawfully
handcuffed; Ex. B4-B5, letters from Carrie E. Smith, Worker’s Compensation
Coordinator, sending Appellant notices to see company physician as a CTA
employee periods of Sept. 1992- March 1993; Ex. B6, Thomas W. Czech,
Chairperson Disability Review Committee, stated Appellant entered the sick book
on April 10, 1994; Ex. B7, letter from Michael Cook, Personnel Manager,
Appellant “He was never Discharged” Nov. 23, 1994.
Participate in the creation or
preservation of evidence when the lawyer knows or reasonably should know the
evidence is false;
Counsel or assist the client
in conduct the lawyer knows to be illegal or fraudulent;
Engage in other illegal
conduct or conduct in violation of these rules;
Fail to disclose the
identities of the clients represented and of the persons who employed the
lawyer unless such information is privileged or irrelevant
Intentionally degrade a
witness or other person by stating or alluding to personal facts concerning
that person which are not relevant to the case;
In trial, allude to any
matters that the lawyer does not reasonably believe is relevant or that will
not be supported by admissible evidence, assert personal knowledge, of facts in
issue, except when testifying as a witness.
Or state a personal opinion as
to the justness of a cause, the credibility of a witness, the culpability of a civil
litigant, or the guilt or innocence of and accused, but a lawyer may argue, on
analysis of evidence, for any position or conclusion with respect to the matter
stated herein.
Said
attorney on page 9, last par. For example, “he asserts that the CTA conspired
with other attorneys and caused false documents to be submitted in court
relative to a paternity matter in which he was named the father (5)
Said
attorney was cognizant Appellant the record and brief clearly and unequivocally
reflect he is a Chicago Transit Authority employee and has demonstrated
incredibly the control and influence exhausted to accomplish their goals, in
spite of all falsehoods, appellant started as a Full Time Temporary Bus
Operator in March 1987;
Appellee
Attorney for IBC, James Holland II, has demonstrated “untouchable sanction able
above the law arrogance” (19), they submitted their brief when they got ready
did not ask leave of the court for an extension of time, he further violated (7)
and demonstrated no integrity (21) page 4, “the District Court Dismissed
Lawrence’s complaint against IBC for failure to state a claim” Mathis v. New York Life Insurance,
133 F. 3d 546 (7th Cir 1998) and (8) (9) (10) including but not
limited to (1) (14) (15);
James
Holland II, appears either to have an inept understanding of the law or a vain
attempt to undermine the court (21) page 5, he records, “Lawrence
simply does not argue anywhere in his brief that the District Court committed
any error”, Page 6 states, “Lawrence’s
brief fails to identify how he
(1)
Beatie v. People, 33 Ill.
App 651, 189 WL 2373 (1st Dist.1989). As is making false representations to the
court. People v. Katelhut, 332 Ill.
App. 693, 54 N.E. 2d 590, (1st Dist. 1944). Misconduct of an officer of the
court is punishable as contempt. People ex rel. Rusch v. Levin,
305 Ill. App.
142, 26 N. E. 2d 895 (1st Dist. 1939).
(7)
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.
(21) U.S. v. DeSalvo, C.A. 9 (Cal.) 1994, 41 F. 3d
505, habeas corpus denied. Videotape of presentation to hospital in
which defendant was shown promoting her lost charge Medicare audit program and
misrepresenting her knowledge and expertise in conducting Medicare audits,
offered to show defendant’s intent to submit false Medicare claims, was
sufficiently similar to her conduct in fraud scheme for which she was charged
to be admissible in fraud prosecution under rule governing evidence of other
crimes or bad acts; defendant was charged with submitting false Medicare
claims, and videotaped presentation falsely proclaiming defendant’s expertise
in Medicare audits showed that when she submitted such claims, she knew them to
be false.
(8)
Drew v. U.S., C.A.D.C. 1964,
331 F. 2d 85, 118 U.S.
App. D.C.11. When two crimes arise out of continuing transaction or same set of
events, evidence is independently that
Contends
the District court erred in dismissing his complaint, page 15-20 of said brief
clearly and unequivocally articulates the errors and legal citations that
supports Appellants argument.
That
every Appellee Attorneys associated in these proceedings have all totally
demonstrated an intolerable interpretation of USCA 1915 (e);
There
is no such citation (22); Furthermore, said attorneys have cited laws that
relates to prisoners and has equated Appellants Civil Rights as one of them (12),
(4) the term ‘prisoner’ means any person
subject to incarceration, detention, or admission to any facility who is
accused of, convicted of, sentenced for, or adjudicated delinquent for,
violations of criminal law or the terms and conditions of parole, probation,
pretrial release, or diversionary program;
To
further justify and demonstrate Appellees racial conspiratory position at
Appellant Exhibits A – X presents Unconstitutional Lawless Applications of the
Laws with Depraved Indifference towards Appellant (1),(5),(8), (9),(10
),(12),(14), (15) and (16),(17),(20),(21),(22) in that every category of
Unconstitutional Acts has been recorded and presented, so as to demonstrate the
plethora of events of how said conspiracies have been used to attack and punish
Appellant for standing up to Racial Hatred;
Exhibits
O and X
clearly demonstrate IBC’s conspiratory relationship with the States Attorney
office;
Exhibits
A, I-M, and W
demonstrates systemic denials ignoring Appelles actions;
Exhibits
P-R, T,U
demonstrates Appellants posture as a father and husband, State Agencies ignored
and violated said Civil Rights;
Exhibits
V demonstrates Doctors and therapists roles in
falsifying medical records so as to create an advantage for the conspirators
involved, where Exhibit V was concerned;
Exhibit
N
demonstrates the control and organization of Agencies participating in
conspiracies;
Exhibits
D-H
demonstrates how State Judges engage in conspiracies to support their members;
Exhibits
B, C
demonstrates how an Administrative Law Judge is ineffective and awaits the
jurisdiction of the Federal Court.
admissible
in separate trials; summarily, if facts surrounding the two or more crimes on
trial show there is a reasonable probability that same person committed both
crimes due to concurrence of unusual and distinctive facts relating to manner
in which crimes were committed, the evidence of one is admissible in the trial
of the other to prove identity.
(19)
Stout v. Broom, 406 F. 2d 758 (1969), In Pro Se case wherein petitioner
for habeas corpus failed to file brief within time fixed by Federal rules of
appellate procedure, it was appropriate to dispose of case summarily pursuant
to local rule of Court of Appeals, Fifth Circuit. Fed. Rules App. Proc. Rule
31, 28 U.S.C.A.; U.S. Ct. of App. 5th
Cir. Rule 9 (c), par. 2, 28 U.S.C.A.
(11)
Mathis v. New York
Life Insurance, 133 F. 3d 546 (7th Cir 1998)
The
Consensus here in this case is that Caucasians (white persons) are at liberty
to exhaust any and whatever remedies necessary in desecrating the laws where an
African American, Black man, Negroid is concerned in that Appellant has been
systematically viewed and treated as a Prisoner, equated in the likes of
prisoners Homosexually Raped while imprisoned, Murderous, Convicted Violent
Offenders;
Because
of said perception and actual practice has given them (Appellees) an unlawful
justification to violate Appellants Civil Rights by Falsifying any and every
document necessary before any Court because the laws of the United States
Constitution has no merit to them because they have falsely declare themselves
to be a superior race and they have
falsely declared themselves to be Untouchable to any Laws of the United States
Constitution”, by misrepresenting in this case the letter of the law by
falsification.
The
consistent denials of legally sufficient documents and affidavits put before
the Courts, and State Agencies systematically demonstrates how control and the
Legal System is under siege.
(13)
Omnibus Consolidated Rescissions and Appropriations Act of 1996 Title VII
Prison Litigation Reform, Public Law 104, Pub. L. No. 104-134 110 stat 1321.
(4)
Daniels v. Williams, 474 U.S. 327
(1985), (b) “The Constitution does not purport to supplant traditional tort law
in laying down rules of conduct to regulate liability for injuries that attend
living together in society. While the Due Process Clause speaks to some facets
of the relationship between jailers and inmates, its protections are not
triggered by lack of due care by the jailers. Jailers may owe a special duty of
care under state tort law to those in their custody, but the Due Process Clause
does not embrace such a tort law concept. Pp. 332-336. 748 F. 2d 229, affirmed.
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.
How
can a statute be considered a statute and the clock be against an injured party
who is unable to bring a claim before the courts, when judges and
attorneys are working with criminals
violating all sorts of laws obtaining an unfair advantage over parties who have
already been harmed by said illegal Fraternal Unconstitutional Conspiracies and
Acts;
In
that, 42 U.S.C. 1981 and Title VII of
the Civil Rights Act of 1964 (Color) and (Race) U.S.C. {1331, 28 U.S.C. {1343
(a) (3) and 42 U.S.C. {2000e 5 (F) (3) over U.S.C. {1981 and 1983 by 42 U.S.C.
{1988; over the A.D.E.A. by 42 U.S.C.{12117.
The
above statutes need to be updated, precedents added to include judicial and
attorneys violating the laws they were elected or appointed to uphold in
office.
CONCLUSION
For
the foregoing reasons, Appellant requests that this Honorable Court Impose
Unprecedented Sanctions, Dismiss said Briefs due to Fraud or Intent by all
Appellees;
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 for their roles and involvements in “Diabolical Unprecedented Civil Rights
Conspiracies and Violations”
That
because of the number of years Appellant and family has been harmed by said
Civil Rights Violations and no one objected to said assertions put before this
tribunal, Appellant is seeking $50,000.00 to $100,000.00 a month until this
matter is finally adjudicated (17) 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}” his
landlord (Tamara Smith) has been stalking and Harassing him for rent of almost
10 years is seeking to Evict him from residence making him homeless, son is
about to graduate on Honor Roll no money for expenses due to the aforementioned
etc.
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 SERVICE
I
hereby certify that on April 4, 2008, I
served a opposing counsel two copies of Plaintiff-Appellant’s Reply Brief with
all attachments, and by depositing/hand delivering it in the United States mail addressed to:
Chicago Transit Authority
Rachael
L. Kaplan, Law Dept.
567 West Lake Street
Chicago, Illinois
60661-1498
Corporation
Counsels
Myriam
Kasper
Nadine
Wichern
30
North LaSalle Suite 800
Chicago, Illinois
60602
Interstate
Brands Corporation/Wonder bread
12 East Armour Blvd.
Kansas City, MO
64111
Attn:
Law Dept.
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
Reply Brief Microsoft word 2000, indicates the Brief contains 4,130 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
EXHIBIT A
Motion
for Reconsideration for Appointment of Counsel/Denied by Chief Judge Frank H.
Easterbrook, citing Farmer v. Haas, a Prisoner.
EXHIBIT B
Administrative
Law Judge Bruce Lester gave Appellant authority to enforce Subpoenas because he
had no contempt power.
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