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Thursday, April 19, 2012

GOOD MORNING ALL

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 …………………………………..s.. On Jth  OKL(5th ilson    ……………………………………………………………………………….. 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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