1.) Brief in Chancery filed in the Illinois Appellate Courts Joe Louis Lawrence V. Erwen McEwen(filed Feb. 25, 2009);
The Brief demonstrates diabolical racist collusion surpassing anything that has been read at this point, the extent a black woman is willing to exhaust to obtain welfare in her name and the necessary procedures exhausted by white people in power was willing to take to destroy a Black Brown Man born Free & Accepted by all laws of the United States Constitution.
2.) Motion to Impose Sanctions on the ATTORNEY GENERAL'S LAW DEPARTMENT PURSUANT TO SUPREME COURT RULE 137 INSTANTER (Filed June 10, 2010); by the Appellant it was Denied.
The Affidavit clearly and unequivocally demonstrate what a white man with the support of others sharing their racist doctrines, what it takes to destroy a black family using the laws unlawfully as the Judges unanimously ignored all aspects of the law went along with these Civil Rights Violations on the State level;
3.) Motion for Reconsideration/Vacate Order due to Judges Corroboration in an Organized Chain Conspiracy “Perjury” “Fraud” Racial Fraternal Civil Rights Violations and other Irregularities; (Filed Nov. 22, 2010) by the Appellant it was Denied;
The Affidavit clearly pointed out the numerous errors and Civil Procedures in the law violated as Judges with Depraved indifference for the law engaged in Diabolical Civil Rights Violations wearing robes as Hoodlums, Thugs Terrorists on the bench.
4.) Motion for Disqualification of Judge Due to Bias (Civil
Rights Violations) and or Prejudice pursuant to Canon 3 (C) (1) and to Vacate
Orders where Civil Rights were Violated. (Filed July 14, 2010) Naming the Governor's brother Patrick J. Quinn who happens to be one of the masterminded FIXERS in Illinois Fixing court cases in favor of Corruption, by the Appellant it was Denied;
Said Judges from the Affidavit, John Owen Steele, Sharon Johnson- Coleman, Joy
V. Cunningham, Thomas E. Hoffman, Themis
N. Karnezis, Mary Jane Theis, Michael J. Murphy, Sheila M. O’Brien.
When White Judges are caught or Complaints are levied against them for racist acts, to avoid issues of racism, they recruit Blacks who are either in the closet with their sexual identity, in a inter-racial marriage, submissive to the "Powerful white man"s directive", impotent in total authority, they Hate themselves and lack any credible integrity, or is simply inferior to the white man, this is Niggercism;
Niggercism is when a white man is feeling ill for any reason one of them will say "We sick master or Boss?
5.) Writ of Mandamus for Mandatory
Injunction/Issuance of a Supervisory Order Vacating Order and Admonishing Judges for “FRAUD” and
Conspiratory Civil Rights Violations and to Impose Sanctions before the Illinois Supreme Court (Filed July 8, 2010) it was Denied.
Because Judges in Illinois are beholding to the Terrorist cell network Political Machine the Judges in the Supreme Court turned their backs on Appellant because of his skin color and and aligned themselves with Corrupt Judges by upholding all unlawful Civil Rights Violations outlined in the Affidavits.
Again I am expressing warm salutations to members of the United Kingdom, France, Canada, Brazil, Germany and Russia for the interest and reading of what people of color have to endure in the American legal tribunals all Black, Brown Hispanic, Latino men are not criminals or low lifes as the media would like to portray us to justify volumes of us incarcerated or beholding to the legal system as demonstrated in my case.
In America Genocide is done differently where it is much more profitable for powerful white men instead of Concentration Camps and Hanging
APPEAL TO THE ILLINOIS APPELLATE COURT
FIRST DISTRICT
FROM THE CIRCUIT
COURT OF
COOK COUNTY
DOMESTIC
RELATIONS DIVISION
________________________________________________________________________
)
Joe Louis
Lawrence
)
) Trial Court No. 09 CH 1773
Plaintiff-Appellant
) General No.
09-2287
) Division
No. 2
V. )
)
Erwin McEwen, Dir. of DCFS )
Et al
)
Defendants- Appellee
)
)
Brief of Appellant
Respectfully
Submitted
Joe Louis Lawrence
Plaintiff-Appellant
TABLE OF
CONTENTS
Table of Contents………………………………………………………………………..2
Statement of The
Issues………………………………………………………………….4
Statement of the
Case……………………………………………………………………7
Statement of the Facts…………………………………………………………………....10
Summary of
Argument…………………………………………………………………..27
Argument………………………………………………………………………………...29
A- Standard of
Review…………………………………………………………………..29
B - The Administrative Law Judge
and Attorneys 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, Ref as C00392-C00415
of Vol. II 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………………………………………………………………………………………………………………………………………………………….33
Appendix……………………………………………………………………………………………………………………………………………………………..34
Certification
of Brief Compliance……………………………………………………………………………………………………………..39
Certificate
of Service………………………………………………………………………………………………………………………………………40
C
- (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……………Ref
as C01103 of Vol. IV.
D- (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).
E-
(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)………………………………………………………………………………………………..
….Ref as C01100 of Vol. IV
STATEMENT OF THE ISSUES
1.) Whether the Administrative Law Judge
“Gregariously” Erred by assuming jurisdiction of a legal matter where he had no
jurisdiction;
A- That
Adm. Law Judge received knowledge and documents from Associate Deputy Director
on stationery identifying him as Chief Adm. Law Judge, Ref as C01579-C01588 of the
Sealed Imp. Records of Vol. VI;
2.) Whether
the Administrative Law Judge had knowledge prior conspiring with Associate Deputy Director as he IMPERSONATED
the AUTHORITY and POSITION as CHIEF
ADMINISTRATIVE LAW JUDGE when he endorsed CERTIFIED SUBPOENAS when it was
proper for Chief Administrative Law Judge to endorse any and all Subpoenas;
A-
Administrative Law Judge acknowledged and admitted, he
had no subpoena power and granted plaintiff a continuance, Ref as C01261 of the Sealed
Imp. Record of Vol. VI;
3.) Whether DCFS attorneys were meticulously
involved in “fixing” said matter corroborating with Adm. Law Judge’s Directives as Civil Rights Violations were
being perpetrated against Plaintiff, Ref
as C001109 of the Sealed Imp. Record
of Vol. IV, Chicago Daily Law Bulletin, Wed. April 26, 2006, Page 1, Illinois
Political Machines help breed corruption, Associated Press writer states, “Illinois is apparently a Petri dish for
corruption, it is a real breeding ground”
4.) Whether the Circuit Court Judge engaged in a
Fraternal Criminal Civil Rights Conspiracy , Ref as C00511of Vol. III, letter to Atty. Gen. C, Cir. Ct. Judge
and Asst. States Atty. “racially conspired against me did not exercise equal
protection of the laws et al.,; shared by the 7th Circuit Judge that
a black man is deemed a Prisoner and not a FREE MAN, Motion for Disqualification of Judge Affidavit
et al., Ref as C01519 of the Sealed Imp.
Record of Vol. VI, B- C (B) That
Judge Easterbrook is aware of the “Systemic”
Racial application of Unjust Laws Dispensated against Appellant, where
affidavits had been unchallenged and filed before the courts demonstrating he
was up against the Ku Klux Klan,
attorneys and Judges with racial affiliations, Political Machine operatives
with Racial Affiliations with the City etc,. said Judge ignored every unlawful
criminal act;
(
C) That because he was the architect of
the Precedent case Farmer V. Haas, demonstrated Racial Hostile Animus Venomous
Retaliation Bias against appellant, by
unlawfully denying him counsel so as to prevent others of learning of the type
of Injustice exercised in the courts, said Judge usurped his powers and
authority ignored the United States Supreme Court and other compelling
citations that warranted the Appointment of an Attorney;
5.) Whether
the Cir. Ct Judge used his robe and authority outside the immunity provisions
of his Judicious authority to enforce the Unconstitutional doctrines of
fraternal laws and not laws in accordance to the United States Constitution?
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).
STATEMENT
OF THE CASE
As referenced in
Plaintiff’s Brief in the Seventh Cir.,
of the first Par. As it relates to this
very case, Ref as C01100 of the Sealed Imp. Record of Vol. IV, Adm. Law Judge ignored the entire record of criminal acts of
Fraud as he assisted all related conspirators as they engaged in systematic
Racial Acts of Civil Rights Violations, Adm. Law Judge and all related
conspirators violated all, furthermore, “Liability will accrue for the acts of
a municipal official when the official possess “final policy making authority”
to establish municipal policy with respect to the conduct that resulted in a
violation of Constitutional rights.” Brown v. Bryan County, OKL., 67 F. 3d 1174
(1995), Stokes v. Bullins, 844 F. 2d 269, 275 (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),
(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 suggest 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), Ref as C01102 of Vol. IV of the Sealed Record
of Vol. IV;
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 See Page 14, 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) Ref as
C01100 of Sealed Imp. Record of Vol. IV;.
(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, See Page 12, 17 of Brief, Ref as C01100, C01105 of the Sealed Imp. Record of Vol. IV;
STATEMENT
OF THE FACTS
1) January
16, 2009, Plaintiff filed Judicial Review Appeal et al., Ref as C00003 of Vol. 1 with Affidavit;
2) February
18, 2009, Defendant filed Defendant’s Motion to Strike Unnecessary and Misjoined
Defendant’s and Defendant’s Motion to Extend the time for the filing of it’s
answer in Administrative review and to seal the record on Adm. Review, Ref as C00071;
3)
March 10, 2009,
Plaintiff filed a Motion Objecting Defendant’s Motion to Strike Unnecessary and
Misjoined Defendant’s/Objecting Record be Sealed Rule To Show Cause for “Fraud”
“Civil Rights Violations” “Contempt of
Court” “Perjury” “Criminal Conspiracy/Cover-up Conspiracy” “Judicial
Impersonation Corruption” Other Irregularities and Impose Sanctions with
Affidavit, Ref as C00079 of Vol. 1;
A-
Defendant did not Object or Deny any of the issues
raised in said Affidavit, Ref as C00080 of Vol. 1;
B- March
11, 2009, Circuit Court Judge stated to Plaintiff, “up here we do things differently, he was not getting a hearing on his
Motion;”
4)
March 11, 2009, Cir. Ct. ignored Plaintiff’s motion Ref as C00079 of Vol. 1, and granted
Defendant’s motion, Ref as C00088 of
Vol. 1, said order in #3 identifies ALJ’s 1,2 and 3 as Judges #3 is not a
Judge he is an attorney, (Associate Deputy Director), the court signed the
order and Asst. Atty. Gen. did not give the copy to Plaintiff to review before
presenting it to the Judge;
5) April
9, 2009, Plaintiff filed a Motion for
Disqualification of Judge due to Bias
(Civil Rights Violations and or Prejudice pursuant to Canon 3 (C) (1) and to
Vacate all Orders/Change Venue, Ref as
C00089 of Vol. 1;
6)
April 9, 2009, Plaintiff filed a Motion for Default
Judgment Remand/Body Attachment et al., Ref
as C00103 of Vol. 1; Defendant never
answered or responded to the Plaintiff’s Motions;
7)
April 16, 2009, Cir. Ct. Judge ignored the Default
Motion and counsel was allowed to rephrase his motion in the Order “Plaintiff’s
motion is deemed a substitution of judge et al” Ref as C00106 of Vol. 1;
A-
Defendant never responded, answered or submitted any
documents to Plaintiff as of this date;
8)
May 18, 2009, Plaintiff Re Noticed Motion for Default
May 18, 2009, Ref as C00107 of Vol. 1,
and Re Noticed Motion Objecting Defendant’s Motion to Strike Unnecessary et al., Ref as C00110, the Default Motion was
set for hearing Aug. 31, 2009 @11 am;
A- Plaintiff
prepared and presented his Order to the Court, Ref as C00108 of Vol. 1;
9)
May 27, 2009,
Plaintiff appeared before the Cir. Ct. Judge with the Asst. Atty. Gen. on his
Motions, said Judge informed the atty. “He
was not able to access the records because they were impounded not sealed and
questioned why”? Said Judge informed Plaintiff, “he could file a Motion anytime in his court and asked him, if he
wanted Sanctions imposed on Counsel”, his reply was that, “it was premature to make that admission
without the records” Counsel was Ordered to produce the records before the
end of the day and provide the court Courtesy Copies of the entire record;
10) That Cir. Ct. Judge signed the court order ,
May 27, 2009, “Plaintiff’s Motion For Default is entered continued to Aug. 31 @
11am”, Ref as C00111 of Vol. 1;
11) On May 27, 2009, Asst.
Atty. Gen. recorded in writing under Certificate
of Service, the undersigned an attorney certifies that a copy of this notice
was served upon the above named at the address, postage prepaid, by depositing
the same in the United States mail chute at 100 W. Randolph St., Ref as C00582 of Sealed Imp. Record of
Vol. of Vol. IV;
A- Said
Asst. Atty. Gen. and Cir. Ct. Judge were
cognizant Associate Deputy Director, unlawfully impersonated the position of
the Chief Administrative Law Judge in endorsing Subpoenas, (August 2008) Ref as C0118-C01130 of Sealed Imp. Records
of Vol.VI;
B- Said
Asst. Atty. Gen. and Circuit Court Judge were cognizant Associate Deputy Dir.
unlawfully impersonated the position of the Chief Adm. Law Judge in endorsing
Subpoenas , (Nov. 2007) Ref as
C01427-C01442 of Sealed Imp. Records of Vol. VI;
C-
Said Chief Administrative Law Judge of another identity,
certified the records March 10, 2009, Ref
as C01610 of Sealed Imp. Record of Vol. VI;
D-
That DCFS
investigator reported in his report
Police Officer stated, “Joseph got upset and hit P. with a closed fist
to the top of the forehead, Ref as
C00761 of Sealed Imp. Record of Vol. IV ;
E-
Asst. Atty.
Gen. was cognizant DCFS investigator never at anytime communicated with the
Police on 5-22-07 and 6-15-07, Ref as
C00788 & C00806 of Sealed Record of Vol.
VI, he left voice messages;
F- Asst.
Atty. Gen. was cognizant DCFS investigator
fabricated State documents, he never interveiwed any Police officers, and was
informed the officer was not in and told he could not leave a message, Ref as C00807 of Sealed Imp. Record of Vol.
IV;
12.) May 29, 2009, Plaintiff diligently filed a Petition
for Rule To Show Cause for Willful Misrepresentations to Court /Fraud on Court
Perjury/ Criminal Conspiratory Acts/ Civil Rights Violations/ Contempt of Court
other Irregularities Remand/ Body Attachment Instanter Impose Sanctions with
Affidavit, Ref as C00112 of Vol. 1,
A- Asst. Atty. Gen., did not Object or Deny any of the facts presented
to the court, said Judge DENIED said Petition, See Ref C01100 of Sealed Imp. Record of Vol. IV; Plaintiff’s Brief
in Seventh Circuit (11) Civil Rights
Act of 1866 “of the full and equal benefit of all laws”
also (64) Turner 24 F. Cas. 337 (No.
14247) C.C.D. Md. 1867) Par. 3 on page
10 of the Reply Brief, Ref C00234
of Vol. 1 And have demonstrated throughout both Briefs and Reply Briefs the
architecture in how cases are systematically dispensated against Plaintiff in
both separate documents in a Racist Unequal Protection of the Laws manner
thereby validating the veracity to every assertion recorded in said Briefs;
13.) That the Asst. Atty. Gen. and Circuit Court
Judge had knowledge and was aware of all Civil Rights Violations, see Page 9 Par. 4, Ref as C00233 of Vol. 1, of the Reply Brief ;
14.) Asst. Atty. Gen and Cir. Ct.
Judge were cognizant of noted irregularities, Ref as C00782 of the Sealed Record of Vol. IV, said Supervisor of
DCFS, stated in her Supervisory note, “the following is needed to assess,
service and complete this case” Do a body chart; inquire with all children to
what happened, CRITICAL DECISION OPEN THIS CASE UP FOR INTACT SERVICES et al;
15.) Asst.
Atty. Gen. and Cir. Ct. Judge were cognizant of the noted irregularities, Ref as C00795 of Sealed Record of Vol. IV,
said Supervisor Noted, “the following is needed to complete this investigation
and assess the safety of the alleged victim, locate the minor, obtain written
consents from the mother and P. covering all psych history et al.;
16.) Asst. Atty. Gen. and Cir. Ct. Judge were cognizant of the
“Fraudulent Acts” by State DCFS employees trumped up charges against Plaintiff,
Ref as C00810 and C00811 of Sealed Record, Medical Physician,
and Supervisor DCFS stated in two separate reports, “given several on going psychosocial factors, it is my recommendation
that Mr. Joe Lawrence be as involved as possible with the family on a daily
basis”, Ms. Rahman was involved with the Lawrence family for approximately 10
months. While servicing the family she worked on several goals, such as
individual and family counseling through Rush Hospital, Mother remains in
denial of needing meds for her emotional stability. The accomplishment’s that
has occurred in this family is due to Mr. Lawrence tenacity and cooperation. He
did what was expected of him as a father”.
17.) Asst. Atty. Gen. and Cir.
Ct. Judge were cognizant of the noted irregularities and trumped up charges
against Plaintiff, Ref as C00833 of
Sealed Record of Vol. IV, December
29, 2004, DCFS, LSW, Child Protection Specialist, INDICATED a finding of
Substantial Risk of Physical Injury/Environment Injurious to Health and Welfare
by Neglect against Plaintiff’s wife;
18.) Hereto attached, Exs. 1a-4d Said Medical pages deleted
from record so as to cover-up Marcia Wards cover-up in falsifying Medical diagnosis
of P. L.,
A- Ex 2b of Medical records
deleted sent to DCFS under Subpoena records 8-09-05 13 yold AAF h/o BAD &
ODD, page 2a Bio M: Bipolar D/O 5-11-05 medical records reveal mother bipolar
diagnosed 93; From the Reply Brief Ex U and V, Ref as C00386 of Vol. II,
page 9 ;
19.) Asst. Atty. Gen. was cognizant of Falsehoods reported by mother, Ref as C00944 of Sealed Record of Vol. IV.
records tendered, University of Ill Family Clinic, MSW, LCSW, Social
Worker interviewing last par. States “P.
who has been diagnosed as having bi polar disorder and who her father described
during the second interview as exhibiting behavior similar to the central
character in the movie “Exorcist” including “foaming” at the mouth. During the
first interview the family history of bipolar disorder was discussed and Mrs.
Lawrence became tearful when talking about how she feels , including her
difficulty in getting out of bed.”
Fraud admissibility great latitude is
permitted in proving fraud C.J.S. Fraud 104 ET Seg. Fraud 51-57. where a
question of fraud and deceit is the issue involved in a case, great latitude is ordinarily permitted in the
introduction of evidence, and courts allow the greatest liberality in the
method of examination and in the scope of inquiry Vigus V. O’Bannon, 1886 8 N.E
788, 118 ILL 334. Hazelton V. Carolus, 1907 132 ILL. App. 512.
20.) Court Transcript Records:
Asst. Atty. Gen. was cognizant of Circuit
Courts involvement and noted inconsistences, contradictions perjury etc., Ref as C00973 of Sealed Record of Vol. IV, Page 8, Line 8 of record, Judge
asked wife if she seen the incident?, Line
9, Carolyn responded, “I didn’t
actually see how it started, I seen how it ended”
Page 9, Line 17 of record C00974, Plaintiff’s wife said, “and once they got back past the shelf in her room I couldn’t see what
took place, Line 20, “so by the time
I seen them they had went into her room also”.
Page 20, Line 11 of record Ref as C00985 of Sealed Record of Vol. I, Plaintiff
questioned P. L., “did you and I ever make it into your room?, her response, “no we did not”
21.) Asst. Atty. Gen. was cognizant of noted
“fraudulent irregularities”, Ref as
C01033 of Sealed Imp. Record of Vol. IV, and P. L. records, before Circuit Court Judge “my dad was telling me to go to my room”,
“when I refused he ran towards me with closed fist and hit me with them against
my chest which made me almost lose my balance into almost falling but when I
got back to my feet he grabbed me in a choke hold position and rammed my face
and forehead into several walls”.
22.) Asst. Atty. Gen. was cognizant of noted “fraudulent
irregularities”, Ref as C01034 of Sealed
Record, Plaintiff’s wife Amends the Complaint P. L. signed, records, “my husband push my daughter P. L. in the back in to her room. Once he got her
into the room I couldn’t see what was going on but when I saw them again Joseph
had P. L. in some kind of hold”
23.) Asst. Atty. Gen. and Circuit Court Judge was
cognizant of “fraudulent irregularities” DCFS was in receipt of medical
discharge summary Rush Medical Center of P. L. recorded date of admission,
11-01-06 date of discharge 12-01-06, Therapist signature 6-12-07 and Medical
Director signature 8-27-07, Ref as
C01307 of Sealed Imp. Record of Vol.
IV;
A-
Rush Medical center, P. L.’s therapist recorded, “P. does not have a
bipolar diagnosis as reported by NF, Mr. Lawrence et al., as C00811 of sealed Imp. Record of Vol. IV;
B-
DCFS Atty. Prepared, Department’s List of Witnesses and Documents,
recorded “Dr. Marcia Ward” Ref as C01556
of Vol. VI of Sealed Imp. Record;
C- Plaintiff’s brief, Ref as C00214 of Vol. 1,
#18 said medical pages deleted from the medical records et al.;
D-
Medical pages deleted from DCFS records obtained
via subpoena, Ref as C00221-C00223 of
Vol. 1;
E- Ref. C00222 records, Psychiatric
History (Patient and Family) 12-2003, diagnosed bi-polar UIC Risperdal, 8-2004,
hospitalized Riveredge, 12-2003 mother bipolar diagnosed 93; Ref as C00223 Bio mother bipolar;
24.) That Plaintiff’s wife requested DCFS
investigator to contact Public Aid, she stated, “since she left her husband, he’s
been refusing to give her any of the Link or money given to her family from
Public Aid”, Ref as C00813 of Vol. IV of
Sealed Imp. Record;
A- Said
investigator said, “he will contact her caseworker to see what can be done to
help her”, Ref as C00813 of Vol. IV;
INDUCING RELIANCE
To prevail in a cause of action for fraud, plaintiff must
prove that defendant made statement of material nature which was relied on by
victim and was made for purposes of inducing reliance, and that victim’s
reliance led to his injury. Parsons V. Winter, 1986, 1 Dist., 491 N.E.
2d 1236, 96 ILL
Dec. 776, 142 ILL App 3d 354, Appeal Denied.
In Carter V. Mueller 457 N.E. 2d 1335 ILL.
App. 1 Dist. 1983 The Supreme Court
has held that: “The elements of a cause of action for fraudulent
misrepresentation (sometimes referred to as “fraud and deceit” or deceit) are:
(1) False statement of material fact; (2) known or believed to be false by the
party making it; (3) intent to induce the other party to act; (4) action by the
other party in reliance on the truth of the statement; and (5) damage to the
other party resulting from such reliance
.
25.) That the Asst. Atty. Gen. and Cir. Ct. Judge
was cognizant of the noted irregularities had knowledge and was in receipt of
said Motion, Ref as C01080 of the Sealed Record of Vol. IV, said Cir.
Ct. Judge ignored every legally sufficient instrument Plaintiff filed in the
courts with Affidavits, establishing his innocence, Motion for Disqualification
of Judge Due to Bias (Civil Rights Violations) and or Prejudice pursuant to
Canon 3 (c) (1)/ Vacate all Orders “FRAUD” “ERROR” & CRIMINAL CONSPIRACY
WITH AFFIDAVIT In accordance to the Cook County Circuit Rule 13.2
a.
Said judge or
wife never denied or objected to
any of the facts recorded in said affidavit;
b.
Asst. Atty. Gen.
was cognizant of the Unequal
Protection of the laws dispensated against the Plaintiff, Ref as C01039 Page 4, Lines 6-7 of
record is omitted, it should state, “I
have filed numerous documents you have ignored demonstrating no abuse of any
sort took place”, Line 8-18 Judge responded, “Sir, you have filed a number of things.
However, not all of them are actually motions or pleadings. A lot of paper work
that you have filed and did not have a date spindled on it to consider it. so
if we were to consider everything that is going on in this case today, we would
be starting from scratch with Carolyn Lawrence providing to you and the Court
information of her testimony about why she feels that she needs an order of
protection on behalf of P. L. And you being allowed to answer those
allegations. That’s why we are here today”.
c.
Asst. Atty.
Gen. and Cir. Ct. Judge were cognizant of all noted Fraudulent acts, Ref as
C01039 of Sealed Record, Line 19-21,
Plaintiff’s response, “so you are saying
that the documents that I submitted, the D.C.F.S. records, and my response is
not going to be considered”?
d.
Asst. Atty. Gen.
and Cir. Ct. Judge were cognizant of all noted Irregularities, Ref as C01040, C01041 of the Sealed Record
of Vol. IV, Line 22-24, Page 4,
5 that Cir. Ct. Judge “Well, as far as I can tell, sir, the
D.C.F.S. records doesn’t have anything to do with---Did you give it to her first of all? Page 5, Line 1, her response was “yes”, Circuit Court Judge “Okay. The D.C.F.S. records—I don’t believe
that there are any findings from D.C.F.S. I didn’t see any findings; am I
wrong”? Plaintiff’s response was “yes”
e.
Asst. Atty. Gen. and Cir. Ct. Judge were cognizant of all Systemic
Disparate Dispensation of Laws and noted irregularities lodged at the
Plaintiff, Ref as C01040 0f the Sealed
Record of Vol. IV, Lines 7-13
Judge stated, Where are the findings?
I see all sorts of stuff to the Illinois
Department of Children & Family Services from you. And I see all sorts of
filings. I see a list of documents. I see communications. I looked through this
pretty carefully last night and I could not find anything that was actually
from D.C.F.S. related to P. L. Do you have any documents like that?” Petitioner’s response, “yes, you have a
courtesy copy of the actual record. (Plaintiff was looking at the judge with
the D.C.F.S. records in her hands as she sat there lying about not having the
records)
f.
Asst. Atty. Gen. and Cir. Ct. Judge were cognizant of all contradictions
and irregularities, Ref as C01040 of the Sealed Record, Lines 19-23 Page 5 of Record Petitioner stated, “The
motion to supplement the record with the D.C.F.S. affidavits. They indicated me
as the perpetrator, based upon the number of inconsistencies. And this matter
is pending before the Administrative Hearings unit”;
g.
Asst. Atty. Gen.
and Cir. Ct. Judge were cognizant of all contradictions and irregularities, Ref as C01041 of the Sealed Record, Line 24, Line 1, page 6, Judge stated, Well, then that judge is going to decide
what is going to happen. Is it still pending? wife’s response, “I have no ideal” Judge was angry, said “You have no ideal? It is your daughter”.
Line 6-7, wife’s response, And investigation against what? I don’t
understand what he’s talking about?, Judge, “he’s saying that there is a case still pending with D.C.F.S., is that
correct”? Her response, “Yes. He had
D.C.F.S. come back to my mother’s house, as far as I know it is going to be
dropped.”
h.
Asst. Atty. Gen.
and Cir. Ct. Judge were cognizant of the Systemic Unequal Dispensation of Civil
Rights Violations lodged at him by numerous parties, in the Courts and State
Agencies, Plaintiff filed a Motion for Medical Board Investigation/Referral
to Attorney General for Prosecution/Fraud Ref as C01246 of the Sealed Record of Vol. VI, ALJ and DCFS Atty. ignored the Criminal allegations and
Denied said MOTION;
26.) To
further amplify the Asst. Atty. Gen. and Cir. Ct. Judges collusion in said
matter, with a plethora of contradictions on the part of his wife, she finally
admitted the TRUTH, Ref as C01068 and
C01068 of the Sealed Record of Vol. IV, Page 33, 34, Line 7- 13,
clearly demonstrates, a vivid account of
the facts presented in Plaintiff’s testimony; Line 18, Circuit Court Judge
asks his wife “Anything else to
add? Her reply, Line 19 “No that
is what took place”
A- Cir. Ct. Judge stated, “Page
38, Line 22-24, Ref as C01073 and
C01074 of the Sealed Record of Vol. IV, “I
am worried about P. L.. I mean P. L. appears to be an intelligent fifteen years
old. Everybody that has ever raised a fifteen year old daughter knows that from
the starting point they could be difficult. But I would say that based on the
testimony that we have P. is a couple notches above just ordinary difficulty,
she is a runaway. She got issues with her dad, and her brothers. She’s
testified that she has been seen by doctors. I’m not going to put a whole lot
of emphasis on that because this is not really the Court to deal with that”.
Page 39, Line 11-17, Ref as C01074, C01075 of the Sealed Imp.
Record of Vol. IV, Judge stated, “But I don’t see how an order of protection
is going to necessarily be a good thing. I don’t see how an order of protection
so that her father can be arrested if he has contact with her is a good thing
to put in the hands of a fifteen year old that I would consider to be at least
moderately unstable, I don’t think that is the right remedy, I can’t do that.”
Page 39, Line 18-24, Page 40, Line 1, she further stated, “And as I told you before about the petition,
and her testimony did not match her petition. I know she is only fifteen, and I
understand she may have forgotten part of it, but is real specific about
specific hitting. She never testified about any hitting. I’m really not
inclined to enter an order of protection in this matter. But on the other hand
I don’t really just want to wash my hands of this family and say go out there
and fin for yourselves”.
27.)
June 8, 2009, Cir. Ct. Judge ignored Plaintiff’s
unchallenged motion with affidavit, “Petition For Rule To Show Cause For Willful
Misrepresentations To The Court/Fraud on Court Perjury/Criminal Conspiratory
Acts/ Civil Rights Violations/Contempt of Court other Irregularities
Remand/Body Attachment Instanter Impose Sanctions, Ref as C00205 of Vol. 1;
28.)
June 17, 2009, Plaintiff filed a Motion To Reset
Hearing Date and Appellee Response Date w/ Affidavit, Ref as C00265 of Vol. II;
A-
Plaintiff submitted his order with his motion Ref as C00268 of Vol. II;
29.)
June 23, 2009, Cir. Ct. Judge ignored Plaintiff’s
motion, it was neither challenged or objected to by opposing counsel, and was
denied, Ref as C00416 of Vol. II;
30.)
July 30, 2009, Plaintiff filed an Emergency Petition
For Rule To Show Cause Reconsideration of Order Due to Corroboration of
Perjury/Criminal Mail Fraud Civil Rights Violations/Contempt of Court other
Irregularities Remand/Body Attachment Instanter Impose Sanctions, Ref as C00269 of Vol. II;
A-
That said Emergency Petition Ref as C00269 of Vol. II was accompanied by affidavit Ref as C00270 of Vol. II;
31.)
July 23, 2009, Cir. Ct. denied said Emergency Petition
et al Ref as C00417 of Vol. II, said
Petition was never denied or objected to by counsel;
32.)
June 11, 2009, Plaintiff filed his brief, Ref as C00363 of Vol. II in compliance
to Court Order Ref as C00111 of Vol. II;
33.)
August 3, 2009, Asst. Atty. Gen. circumvented and
disobeyed court order, Ref as C00111 of
Vol. II filed “Defendant’s Memorandum of Law in Support of the Final
Administrative Decision” did not respond or answer Plaintiff’s brief or answer
or respond to any documents Plaintiff presented before the courts;
34.)
August 18, 2009, Plaintiff filed “Petitioner’s
Reply to What is Captioned Defendant’s Memorandum of Law in Support of the
Final Administrative Decision”, Ref as
C00460 of Vol. II, in compliance to court order, Ref as C00111 of Vol. II, with an affidavit;
35.)
August 31, 2009, Cir. Ct. Judge did not validate or
certify court order with his signature, Ref
as C00567 of Vol. III;
A- That
the clerks never received his original copy with signature pursuant to S. Ct.
Rule 272, the Asst. Atty. Gen. did submit a draft order, Plaintiff reviewed it
before it was presented to the court;
B- That
this is the only court order the Cir. Ct. did not sign, which caused vexatious
delays and numerous Motions for Ext. of time in presenting the record before
the Appellate Court in a timely manner;
36.)
September 1, 2009, Plaintiff filed his Notice of
Appeal, Ref as C00568 of Vol. III,
along with his Jurisdictional Statement, Ref
as C00570 of Vol. III;
37.)
October 6, 2009, Plaintiff filed his “Notice of Filing
Motion For Order Releasing Record For Preparation on Appeal, Ref as C00575;
A- That
said motion was accompanied by an affidavit Ref as C00577;
B- The
Clerks in Chancery needed a Court Order because the record was Sealed and
Impounded;
C- That
the Asst. Atty. Gen prepared a draft order, (the court did not allow Plaintiff
to draft the order) it was reviewed and presented before the court, Ref as C00578 of Vol. III, where it was
signed;
(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. Judge 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”)
SUMMARY
OF ARGUMENT
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
party’s pleadings. Professional Group Travel, Ltd. v.
Professional Seminar Consultants Inc., 136 ILL App 3d 1084, 483 N.E. 2d 1291;
Buzzard v. Bolger, 117 ILL App 3d 887, 453 N.E. 2d 1129 et al.
A- Jan. 8th, 2008,
Cir. Ct. Judge ignored Plaintiff’s wife Amended Petition, another Cir. Ct. Judge
signed off and made reference to an unauthorized Complaint P. L., signed, Ref as
Line 18-24, Page 40, Line 1, of the
Sealed Imp. Record of Vol. IV, as a basis for which she could not grant an
Emergency Order of Protection, that which she Dismissed; Although some trial
judges may not review the orders of other judges, because that would not be
consistent with the orderly administration of justice or with our judicial
system People ex rel. Kelly, Ketting Furth, Lnc. V. Epstein, 61 ILL 2d, 229,
335 N.E. 2d 430 (1974) (Appeal of order as proper remedy); Cruz v.
Columbus-Cuneo-Cabrini Medical Center, 194 ILL App. 3d 1037, 551 N.E. 2d 1345,
141. Dec. 817 (1st Dist. 1990)
B-
Administrative Law
Judge circumvented the legal applications of the law where precedents had
already been established forbidding Judges from engaging in such practices;
C-
That because Circuit
Court Judge having had proper
Jurisdiction over the parties and had a hearing on the Order of Protection
regardless to numerous Civil Rights Violations against Petitioner as noted in the record, Administrative
Law Judge could not assume jurisdiction and rule against the Plaintiff and
against the Circuit Court and Indicate any Findings against him;
D-
That because of the
noted Criminal acts of Conspiracy Fraud in said DCFS matter on all accounts
makes said Administrative Law Judge Order a VOID JUDGEMENT;
ILL. App. (1st
Dist. 2000). A “VOID JUDGEMENT OR ORDER” is one that is entered by a court
lacking jurisdiction over the parties or the subject matter, or lacking the
inherent power to enter the particular order of judgment, or where the order
was procured by FRAUD- in re Adoption of E.L., 248 ILL. Dec. 171, 733 N.E. 2d
846, 315 ILL. App. 3d 137- Judgm 7, 16, 375.
Review of the orders of one judge by another in the same case is not
consistent with effective judicial administration. 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).
Although the chancery division of the
County Department of the Circuit Court and the Municipal Department of the
Circuit Court have concurrent jurisdiction of actions to demolish buildings,
where the municipal department first acquired jurisdiction of the subject
matter and entered an order of demolition, the county department could not
properly assume jurisdiction and enter an order preventing municipal
departments from entering an order of demolition. Pepin v. City of Chicago, 79
ILL. App. 2d 295, 224 N.E. 587 (1st Dist. 1967).
ARGUMENT
STANDARD OF REVIEW LEGAL ANALYSIS
Plaintiff
have presented to this Jurisdiction 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, (35), Ref as C01104 of Sealed Imp. Record of Vol.
IV, Par. 3 Lisa L. Milford, The Development of the ABA Judicial Code 24-25
(1992);
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
officers and attorneys violating the laws they were elected or appointed to
uphold in any office (State City or otherwise).
In
addition, Plaintiffs Brief (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; (22) 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;
Plaintiff’s Brief before the Seventh Cir..has 80 (legal
Citations) footnotes, due to said judges
ethnic make up demonstrates a fraternal unification (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.
That because of the Fraternal Order of Judges who were
incredibly united in numbers, in
how, they were able to manipulate and desecrate any Laws
necessary on any legal level,
so as to uphold, their Racist doctrines;
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.”)
CONCLUSION
For
the foregoing reasons, Plaintiff requests that this Honorable Court of Justices
Impose Unprecedented Sanctions, Dismiss and Expunge all related charges
Indicated against him by the Circuit Court., Reverse and Remand with
instructions the appropriate sanctions for the noted acts recorded within;
A
1928 decision by Supreme Court Justice
Louis Brandeis, that said “if the Government becomes the law breaker, it breeds
Contempt for the Law, it invites everyman to become a law unto himself. It
invites Anarchy”
(17)
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
Attorney Pro Se
APPEAL TO THE ILLINOIS APPELLATE COURT
FIRST DISTRICT
FROM THE CIRCUIT
COURT OF
COOK COUNTY
DOMESTIC RELATIONS DIVISION
________________________________________________________________________
)
Joe Louis
Lawrence
)
) Trial Court No. 09 CH 1773
Plaintiff-Appellant
) General No.
09-2287
) Division No. 2
V. )
)
Erwin McEwen, Dir. of DCFS ) Hon. William O Maki
Et al
)
Defendants- Appellee
)
)
APPENDIX
Order
entered: August 31, 2009
Notice of
Appeal filed: September 1, 2009
Statute:
Unequal Protection of the Laws Violations, Disparate Unequal Protection of the
Laws, Civil Rights Violations, Judicial Errors, Judicial Abuse of Discretion, Perjury, Chicanery, Public, Political,
Fraternal Corruption Conspiracies, and other Un-Constitutional Lawless
Violations, Particularly Section 4 of the Ku Klux Klan Act of 1871 ““Whenever
in any State or part of a State……unlawful combinations……..shall be organized
and armed, and so numerous and powerful as to be able, by violence, to either
overthrow or set at defiance the constituted authorities of such State, or when
the constituted authorities are in complicity with or shall connive at the
unlawful purposes of such powerful and armed combinations; 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 is appealing to the Illinois Appellate Court, for a
reversal and remand with instructions based on the foregoing stated above:
The Illinois
Appellate Court has the Jurisdiction, to correct any error, 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 Illinois
Appellate Court has the Jurisdiction and Wisdom to recognize when an
individual has not been afforded Justice in accordance to the United States
Constitution;
Plaintiff is before the Illinois Appellate Court because as a African American ”Pro Se” certain Circuit Court Judges have allowed attorneys of various backgrounds to commit the
aforementioned criminal acts, ignoring
affidavits, the Laws of the Illinois Civil Code of Civil Procedures, Supreme
Court of Illinois Rules and the Rules of the United States Constitution and Plaintiffs
Civil Rights, in spite of the laws presented in his pleadings said judge due to
Bias and other Irregularities ignored all Civil Rights Violations, in the above cited manner and in the
following, Vaughn 462 S.E. 2d 728 (Ga.
1995), The Supreme Court of Georgia removed a judge from office
for disregarding defendant’s constitutional rights;
Plaintiff is before the Illinois Appellate Court because
as a “Pro Se” litigant the Courts have
corroborated and proved beyond the Preponderance of the evidence a Disparate
application in how laws are dispensated against non-licensed attorneys sharing
a different ethnicity that act alone,
“shall be deemed a rebellion against the Government of the United States…..”
Respectfully Submitted
Joe Louis
Lawrence
Plaintiff-Appellant
APPEAL TO THE ILLINOIS APPELLATE COURT
FIRST DISTRICT
FROM THE CIRCUIT
COURT OF
COOK COUNTY
DOMESTIC
RELATIONS DIVISION
________________________________________________________________________
)
Joe Louis
Lawrence
)
) Trial Court
No. 09 CH 1773
Plaintiff-Appellant
) General No. 09-2287
) Division No. 2
V. )
)
Erwin McEwen, Dir. of DCFS ) Hon. William O Maki
Et al
)
Defendants- Appellee
)
)
CERTIFICATION OF BRIEF COMPLIANCE
I certify that this brief conforms to
the requirements of Rules 341 (a) and (b), the length of the brief, including
the appendix is 40 pages.
____________________________
Joe Louis Lawrence
Attorney Pro Se
Joe Louis
Lawrence
Post Office Box
490075
Chicago,
Illinois 60649-0075
312 927-4210
APPEAL TO THE ILLINOIS APPELLATE COURT
FIRST DISTRICT
FROM THE CIRCUIT
COURT OF
COOK COUNTY
DOMESTIC
RELATIONS DIVISION
________________________________________________________________________
)
Joe Louis
Lawrence
)
) Trial Court
No. 09 CH 1773
Plaintiff-Appellant
) General No. 09-2287
) Division No.
2
V. )
)
Erwin McEwen, Dir. of DCFS ) Hon. William O Maki
Et al
)
Defendants- Appellee
)
)
CERTIFICATE OF SERVICE
I
hereby certify that on February 25,
2009, I served opposing counsel a copy of Plaintiff-Appellant’s Brief
and by depositing/hand delivering it in the United States mail addressed
to:
AAG
Danielle J. Steimel
Said Courtesy Copies will be personally Del.
Child
Welfare Litigation Bureau in a
timely manner:
100
West Randolph
Robert Grant/James Chatto FBI Chicago
Chicago,
Illinois 60601 2111
West Roosevelt Road
Chief Judge Timothy Evans
Chicago, Illinois 60612
Daley Center U.S. Atty. Patrick
Fitzgerald
Suite
2600
219 South Dearborn, Suite 500
Chicago,
Ill. 60604
Appointed
Child Rep. Brian E. Wright
Ruth
B. Watson
5310 North Harlem
1011 Lake #412
Chicago, Ill. 60656
Oak Park, Ill. 60301
Respectfully submitted
Joe Louis Lawrence
_________________________
Plaintiff-Appellant
Pro Se Attorney
APPEAL TO THE ILLINOIS
APPELLATE COURT
FIRST DISTRICT
FROM THE CIRCUIT
COURT OF
COOK COUNTY
DOMESTIC
RELATIONS DIVISION
________________________________________________________________________
)
Joe Louis Lawrence )
) Trial Court No. 09 CH 1773
Plaintiff-Appellant ) General No. 09-2287
) Division No. 2
V. )
)
Erwin McEwen, Dir. of DCFS )
Et al )
Defendants- Appellee
)
)
NOTICE OF MOTION
YOU ARE HEREBY NOTIFIED that Plaintiff-Appellant
Moves to the Illinois Appellate Court, First District for an Order on Motion to
Impose Sanctions on the Attorney General’s Law Department Pursuant to Supreme
Court Rule 137 Instanter.
TO: AAG Paul Racette
Courtesy Copy
Child Welfare Litigation Bureau Chief Judge Timothy C. Evans
100 West Randolph Street Suite 1200 Daley Center, Suite 2610
Chicago, Ill. 60601
PLEASE BE ADVISED that on June 10,
2010 said Notice of Motion was hereby filed with the Motion to Impose Sanctions
et al., with the attachments and mailed/hand delivered to all parties recorded
in said notice via regular mail.
_________________________________
Joe
Louis Lawrence, Atty. Pro Se
Name Joe
Louis Lawrence
Attorney for Pro Se
Address P.O. Box 490075
City, State Chicago, Illinois
60649-0075
Phone
(312) 927-4210
APPEAL TO THE ILLINOIS APPELLATE COURT
FIRST DISTRICT
FROM THE CIRCUIT
COURT OF
COOK COUNTY
DOMESTIC RELATIONS DIVISION
________________________________________________________________________
)
Joe Louis Lawrence )
) Trial Court No. 09 CH 1773
Plaintiff-Appellant ) General No. 09-2287
) Division No. 2
V. )
)
Erwin McEwen, Dir. of DCFS ) Hon. Judge O’Maki
Et al
)
)
Defendants- Appellees
)
)
MOTION TO IMPOSE SANCTIONS ON THE ATTORNEY
GENERAL’S LAW DEPARTMENT PURSUANT TO SUPREME COURT RULE 137 INSTANTER
Now comes Plaintiff-Appellant,
Joe Louis Lawrence respectfully moves this court for an Order on the above
entitled cause.
Reasons in
support of this motion are set forth in the attached affidavit.
Respectfully Submitted,
Joe
Louis Lawrence
By:____________________________
Joe
Louis Lawrence
Attorney Pro Se
STATE OF ILLINOIS
)
)
COUNTY
OF COOK )
AFFIDAVIT
Joe Louis Lawrence being first duly sworn on oath deposes
and state as follows:
1.)
I am Joe Louis Lawrence, Attorney Pro Se.
2.)
That the Asst. Atty. Gen. (Paul Racette) recorded slander and defamation at the
Appellant, recorded on Page 10, Par. 2, “The Dept………. that P.L. had gashes, red marks, and swelling on her neck,
forehead, and face et al;
A- That
nowhere in any report or medical documentation did anyone record vicious slander
“gashes” “swelling on neck face and forehead”
3.) That Asst. Atty. Gen. recorded on Page 9, Par. 1, “in his rambling—and
at points incoherent—opening brief”
A-
That said attorney is demonstrating a “SO WHAT ATTITUDE” !!! To all of
the facts properly recorded by the Appellant in his brief—nowhere in any aspect
of his documentation did he DENY or OBJECT to its VERACITY!
B-
That because said facts recorded in Appellant’s brief
is in fact unimpeachable demonstrates the arrogance and ethnic make-up of the
perpetrators involved;
C-
That because Asst. Atty. Gen. (Paul Racette) is Caucasian
in a powerful position along with other conspirators have elected to
demonstrate how he (they) will falsify, embellish any statement, delete any
documents from court files that incriminates their fraternal order engaging in
a criminal conspiracy, ignore any and all criminal acts perpetrated against a
black man as demonstrated entirely against the Appellant, so as to arrive at
any legal objective necessary to oppress the black man and his family;
4.) That Asst. Atty. Gen. (Paul Racette) failed to
acknowledge and admit in his document, Circuit Court Judge Aurelia Pucinski
had a hearing on the matter where an Order of Protection was filed, she
considered P.L. “moderately unstable”
A- Furthermore,
he failed to acknowledge Carolyn Lawrence admitted under oath, Appellant never
attacked his daughter nor did he choke her;
B-
Judge Pucinski stated, “P.L. never testified about any hitting”
C- He
recoded more slander against Appellant, Page
6, Par 3, he records, “On January 16, 2009, Lawrence filed a
complaint for administrative review of the Department’s decision. (C.
3-10), A “Heinous Fabrication”
Jan. 16, 2009, Appellant filed a Judicial Review/Appeal/ Rule To Show Cause
For “Fraud” “Civil Rights Violations “Contempt Of Court” Perjury &
“Criminal Conspiracy/Cover-Up Conspiracy” “Judicial Impersonation/Corruption”
Other Irregularities & Impose Sanctions with Affidavit;
D- That
Atty Gen. (Paul Racette) recorded another fabrication, “Lawrence that he has a black belt in the martial arts. (C.637)
nowhere in any documentation did Appellant make that statement, he has no black
belt in martial arts;
5.)
That Asst. Atty.
Gen. (Paul Racette) with complete malicious depraved indifference to the law
and demonstrates “Draconian” intimidating
arrogance to this court and specifically to the judges presiding over this
matter;
A-
He records on Page
7, Par. 1, “Accordingly, to the extent of the Lawrence attempts to challenge
matters that occurred while this case was pending before the Circuit Court,
this court need not address those arguments”
B-
Who is he to
lodge blatant overtones of intimidation to a body of Judges? What are the consequences if said Judges
do not take heed to his directive?
C-
He reminds the Judges on Page 11, Par. 1, how
Appellant has been many times DENIED in the legal tribunals and never
tried honorably, they are to follow suit as the others did and do what he says
and as the others did;
D-
He records on Page
9, Par. 1, “and because Lawrence is proceeding pro se.”underlined
with emphasis (a code word to let Judges in the Order Know they need their
help, Appellant experienced Asst. States Atty. Brian Volkman used the word, Pro
Se to Judge Haracz three times and he was placed in Contempt of Court for
allegedly owing child support and the Judge had the audacity to ask, are you
sure you want to go forward on your motions?
That it is no fault of the Appellant
that an Atty. connected to racist, political machine fraternal orders are
intellectually challenged and lack the legal aptitude to interpret and apply
the laws in a legally upright manner, hereto attached, Group Ex. A, Motion before the Illinois Supreme Court, for
Reconsideration et al., rest assured No Supreme Court Justice or true Judge
in the Appellate Division find his legal arguments as rambling or incoherent
“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.
6.)
7.)
Appellant
promised this court that he would submit to this Honorable Court a Brief no
Justice in this State has ever read or expected any pro se litigant to prepare;
He is no Prisoner, or Felon, (a Great Father) He is no Slave and this is not a
Plantation nor is this Germany where Hitler was in control;
FURTHER
AFFIANTH SAYETH NOT
Under penalties as provided by law pursuant to 735 1265 5/1
-109, the undersigned certifies that the statements set forth in this
instrument are true and correct, except as to matters therein stated to be on
information and belief and as to such matters, the undersigned certifies as
aforesaid that he verily believe the same to be true.
Respectfully submitted,
Joe
Louis Lawrence
Attorney Pro Se
APPEAL TO THE ILLINOIS
APPELLATE COURT
FIRST DISTRICT
FROM THE CIRCUIT
COURT OF
COOK COUNTY
DOMESTIC RELATIONS DIVISION
________________________________________________________________________
)
Joe Louis Lawrence )
) Trial Court No. 09 CH 1773
Plaintiff-Appellant
) General No. 09-2287
) Division No. 2
V. )
Erwin McEwen, Dir. of DCFS ) Hon. Judge O’Maki
Et al
)
)
Defendant- Appellee
)
)
DRAFT ORDER
This matter having
come on to be heard on Motion to Impose Sanctions on the Attorney General’s law
Department pursuant to Supreme Court Rule 137, due notice having been given,
the court having jurisdiction over the parties and the subject matter, and
being fully advised in the premises;
It is HEREBY ORDERED that Appellant’s Motion
to Impose Sanctions on the Attorney General’s law Department pursuant to
Supreme Court Rule 137 is GRANTED INSTANTER.
ENTERED:
_________________________________
Justice Joy V. Cunningham
_________________________________
Justice Thomas E. Hoffman
_________________________________
Justice Themeis N. Karnezis
Joe Louis Lawrence
Attorney Pro Se
________________________________
P.O. Box 490075 Justice
Mary Jane Theis
Chicago,
Illinois 60649-0075
(312) 927-4210
APPEAL TO THE ILLINOIS
APPELLATE COURT
FIRST DISTRICT
FROM THE CIRCUIT
COURT OF
COOK COUNTY
DOMESTIC
RELATIONS DIVISION
________________________________________________________________________
)
Joe Louis Lawrence )
) Trial Court No. 09 CH 1773
Plaintiff-Appellant ) General No. 09-2287
) Division No. 2
V. )
)
Erwin McEwen, Dir. of DCFS )
Et al )
Defendants- Appellee
)
)
NOTICE OF MOTION
YOU ARE HEREBY NOTIFIED that Plaintiff-Appellant
Moves to the Illinois Appellate Court, First District for an Order on Motion for
Reconsideration/Vacate Order due to Judges Corroboration in an Organized Chain
Conspiracy “Perjury” “Fraud” Racial Fraternal Civil Rights Violations and other
Irregularities;
Courtesy
copies sent to the following:
TO: U. S. Attorney Patrick Fitzgerald, 219 South Dearborn, Chgo.
Ill. 60604
Dir. of FBI
Robert Grant/Agent Chatto, 2111 West Roosevelt Road, Chg. Il 60612
States
Attorney Anita Alvarez, Daley Center Suite 500, Chgo Ill. 60601
Clerk of
Circuit Court Dorothy Brown, Daley Center, Suite 1001, Chgo. Ill 60601
Presiding
Judge Mosche Jacobius, Daley Center, Suite 1900
AAG Paul Racette
Child Welfare Litigation Bureau Chief Judge Timothy C. Evans
100 West Randolph Street Suite 1200 Daley Center, Suite 2610
Chicago, Ill. 60601
AAG Tyler Roland
100 West Randolph, Suite 1300
Chicago, Ill. 60601
PLEASE
BE ADVISED that on Nov. 22nd , 2010 said Notice of Motion was
hereby filed with the Motion for Reconsideration et al., with the attachments
and mailed/hand delivered to all parties recorded in said notice via regular
mail.
_________________________________
Joe Louis Lawrence, Counsel, Pro Se
Name Joe
Louis Lawrence
Attorney for Pro Se
Address P.O. Box 490075
City, State Chicago, Illinois
60649-0075
Phone
(312) 927-4210
APPEAL TO THE ILLINOIS APPELLATE COURT
FIRST DISTRICT
FROM THE CIRCUIT
COURT OF
COOK COUNTY
DOMESTIC
RELATIONS DIVISION
________________________________________________________________________
)
Joe Louis Lawrence )
) Trial Court
No. 09 CH 1773
Plaintiff-Appellant ) General No. 09-2287
) Division No.
2
V. )
)
Erwin McEwen, Dir. of DCFS ) Hon. Judge O’Maki
Et al
)
)
Defendants- Appellees
)
)
MOTION FOR RECONSIDERATION/VACATE ORDER DUE
TO JUDGES CORROBORATION IN AN ORGANIZED CHAIN CONSPIRACY “PERJURY” “FRAUD”
RACIAL FRATERNAL CIVIL RIGHTS VIOLATIONS & OTHER IRREGULARITIES
Now comes Plaintiff-Appellant,
Joe Louis Lawrence respectfully moves this court for an Order in the above
entitled cause.
Reasons in
support of this motion are set forth in the attached affidavit.
Respectfully Submitted,
Joe Louis Lawrence
By:____________________________
Joe Louis Lawrence
Attorney
Pro Se
STATE OF ILLINOIS
)
)
COUNTY
OF COOK )
AFFIDAVIT
Joe Louis Lawrence being first duly sworn on oath deposes
and state as follows:
1.)
I am Joe Louis Lawrence, Counsel Pro Se.
2.)
That Judges Michael Murphy, John Owen Steele, and
Patrick J. Quinn has legally acknowledged and admitted corroborated every fact
recorded by the Plaintiff-Appellant, hereto attached Group Ex A, (Motion to Disqualify Judge William O’ Maki for Bias
(Corroboration Civil Rights Violations) and or Prejudice pursuant to Canon 3
(c) (1) and to Vacate any Orders where Criminal Conspiracy Civil Rights were
Violated); Judge O’Maki recused himself Instanter he never denied any facts
recorded in said affidavit;
A- That
Judge O’Maki tried to FIX said case in favor of the Attorney General Lisa
Madigan got caught, he DENIED everything Appellant filed with an affidavit;
(Oct. 5, 2010) as Ref in the above Ex B
of Gr. Ex A;
B- That
on Nov. 1, 2010, Judge O’Maki asked Tyler Roland if he had anything he had to
say about Plaintiff’s motion, his reply, “no Judge”
C-
That said case was reassigned to Judge Daniel A.
Riley, Appellant properly Re noticed Motion for Default judgment Remand/Body
attachment w/Affidavit Petition for Rule to Show Cause et al., and Re noticed
Motion to Supplement Petition for Rule to Show Cause et al, hereto attached as Gr. Ex. B;
D- That
on Oct 21, 2010 Appellant tendered courtesy copies to Judge Riley’s clerk
everything unlawfully removed from the court file;
E- That
on Friday Oct. 29, 2010 Judge Daniel A Riley surprisingly retired from the
bench never facing the Appellant;
F- That
on Nov 1, 2010 a Judge was promoted from Juvenille with no ties to the
Political Machine and Terrorist Fraternal network was assigned to the matter;
G- Appellant
argued the legal merits of the case in a concise comprehensible manner, AAG
Diane Moshman (a very nice lady) did not do very well, she told the judge they
were representing all of the defendants, Appellant raised his hand to object,
judge acknowledge, he informed the court, “he
has complied with Judge Riley’s standing order and what counsel is asserting is
not true they are not representing everyone” the court’s reply, “we are not entertaining the substantive
issues today” AAG asked the judge, “if
she could make an ORAL MOTION to
strike all of Appellant’s Motions and Petitions and we present our Motion to
Dismiss”? Everybody looked at this lady astonishingly as if she had lost
her mind, what came out of her mouth was not a reflection of her demeanor, the
judge was very professional told her, NO!
we don’t things like that up here, you are going to respond to the documents he
has filed and he will respond to your motion to dismiss” AAG reminded the
court. she was not coming back on this
case, she was only filling in for her collegue Tyler Roland” hereto
attached, Ex. C court order from the
above;
3.)
That said Judges in the Appellate Court unanimously
demonstrated fixing this matter on appeal (trying to save Judge William O’Maki)
in an attempt to protect and uphold Jim Crowism laws that has been abolished by
the United States Supreme Court so as to protect members of the fraternal order
in this City and State;
4.)
FACT
Pursuant to Sup Ct. Rule 272 “if at the time of announcing final
judgment the judge requires the submission of a form of written judgment to be
signed by the judge et al” the judgment becomes final only when the signed
judgment is filed—There is no signed COURT ORDER from the FINAL
JUDGMENT!
5.) FACT Where the trial court requests
that a written judgment be prepared, and where the attorney who obtains the
judgment prepares it and submits it to the judge for approval and entry, the
judge’s oral announcement of his decision and the reasons thereof have no
effect; the judgment is not the act of the court until it is signed or approved
and entered of record. In re Marriage
of Dwan, App 1st Dist. 1982, 64 Ill. Dec 340, 108 Ill. App 3d 808,
439 N. E. 2d 1005.
6.)
FACT This
case was originally assigned to the second division Judges Joy V. Cunningham,
Thomas E. Hoffman, Themis N. Karnezis and Mary Jane Theis because all of the
judges were not of the consensus FIXING
this case, mainly one of the judges had a father indicted and convicted
in the Greylord Scandal;
7.)
FACT That
Judges Patrick J. Quinn, Michael J. Murphy and John O. Steele unlawfully
assumed jurisdiction of this matter never filing orders with the Appellate
Clerks demonstrating it’s reassignment;
8.)
FACT That
Judge Joy V. Cunningham is a former Asst. AAG
signed numerous court orders granting extensions of time due to a
plethora of obstructive criminal acts in an attempt to prevent this matter
going to the Appellate court;
A-
Pursuant to 735 ILCS 5/2-610 where
allegations of complaint are not denied, there is admission of all facts
well-pleaded by adversary, and such admission, drawn from failure to plead, may
be considered as evidence. Hecht v.
Hecht, App. 1 Dist. 1977, 7 Ill. Dec. 169, 49 Ill. App. 3d 334, 364 N.E. 2d
330.
B-
Pursuant to 735 ILCS 5/2-612 Counsel never
Objected to the sufficiency of Petitioners pleadings, Objections to sufficiency
of pleadings either in form or substance must be made In trial court, and if
not so made, they will be considered waived and cannot be raised for the first
time on appeal. People ex rel. Deynes
v. Harris, App. 1948, 77 N.E. 2d 439, 333 Ill. App. 280.
The Law
is CLEAR: 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 party’s pleadings. Professional Group Travel,
Ltd. v. Professional Seminar Consultants Inc., 136 ILL App 3d 1084, 483 N.E. 2d
1291; Buzzard v. Bolger, 117 ILL App 3d 887, 453 N.E. 2d 1129 et al.
The Law is clear: The purpose
of a Motion to Vacate is to alert the trial court to errors it has made and to
afford an opportunity for their correction. In re Marriage of King, App. 1 Dist. 2002, 270 Ill. Dec. 540, 336 Ill.
App. 3d 83, 783 N.E. 2d 115, rehearing denied pending appeal; et al.
The Law is clear: Motions for Reconsideration are designed to
bring to the court’s attention newly discovered evidence that was unavailable
at time of original hearing, changes in existing law, or errors in court’s
application of law. Continental Cas. Co.
v. Security Ins. Co. of Hartford, App. 1 Dist. 1996, 216 Ill. Dec. 314, 279
Ill. App. 3d 815, 665 N.E. 2d 374, appeal dismissed, et al.;
Supreme
Court Rule [137] provides in pertinent part:
If a pleading, motion, or other
paper is signed in violation of this Rule, the court, upon motion or upon its
own initiative, may impose upon the person who signed it , a represented party,
or both, an appropriate sanction, which may include an order to pay to the
other party or parties the amount of reasonable expenses incurred because of
the filling of the pleading, motion, or other paper, including a reasonable
attorney fee. Not only will the courts consider an award of sanctions for
active false statements: failures to disclose material facts to the court can
also justify an award of sanctions.
BRUBAKKEN
v. Morrison, No. 1-9-1670, 1992 Ill App. LEXIS 2144 (1st Dist. Dec.
30, 1992). Additionally, the fact that a false statement or omission is the
result of an honest mistake is no defense to entry of a sanction. ID. To the
extent that an individual lawyer has engaged in sanction able conduct, that
lawyer’s firm can also be jointly and severally liable with the lawyer.
9.)
FACT Appellant
filed a Motion to Impose Sanctions on the Attorney General’s Law Department Pursuant to Supreme Court Rule 137
Instanter w/Affidavit; (June 10, 2010), said Judges have corroborated
their relationship with said Terrorist Conspirators aided and DENIED said
Motion unchallenged;
A-
Said judges had
knowledge and was aware an attorney impersonated the position and authority of
a Chief Administrative Law judge endorsed subpoenas regarding his daughters
medical records;
B-
Said judges had knowledge of the specific medical
diagnosis of said Appellant’s daughter someone had her therapist to impersonate
the position as a Doctor where she deleted medical records from her file and
made false entries in medical records of daughter’s medical diagnosis;
10.)
That because the judges are exercising laws outside of their immunity and
jurisdiction and in accordance to other Political/Fraternal laws makes the
Court order signed by Judges Patrick J. Quinn, Michael J. Murphy and John Owen
Steele a Void Order Rules of
law Canon Ethics, Code of Judicial Conduct Rule 62 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.
11.)Said judges are of the unified
impression they are hurting the Appellant by constantly DENYING each and every
legally certified document, he has presented before the courts, it is expected
because it corroborates, what the FBI ordered him to obtain, they are the ones
bringing down the entire Political Machine of Terrorists, they don’t care who
“YOU” are “You” break the Law “you” go to jail;
12.)That said judges are no longer
acting against the Plaintiff they are up against the Federal Government and
there is not one judge yet with the legal aptitude in Constitutional Law to
realize this very fact, this is an Equal Opportunity Eradication;
A-
That Appellant’s brief legally surpassed the document
Paul Racette presented to this court as a brief even with the judges colluding
with him in concert, he still was unable to attack legally the meritorious
claims presented in said brief factually due to it’s veracity; The Supreme
Court of Mississippi has taken the position that willful abuse of authority, in
violation of the Code of Judicial conduct, for a justice court Judge to
notarize a deed with a false acknowledgement and to enter orders in cases not
pending before the Judge, Mississippi Commission on Judicial Performance v.
Hartzog, 646 So. 2d 1319, 1321-1322;
That because of the above; Fraud admissibility great latitude is permitted in proving fraud C.J.S. Fraud
104 ET Seg. Fraud 51-57. where a question of fraud and deceit is the issue
involved in a case, great latitude is
ordinarily permitted in the introduction of evidence, and courts allow the
greatest liberality in the method of examination and in the scope of inquiry Vigus
V. O’Bannon, 1886 8 N.E 788, 118 ILL 334. Hazelton V. Carolus, 1907 132 ILL.
App. 512.
INDUCING RELIANCE
To prevail in a cause of action for
fraud, plaintiff must prove that defendant made statement of material nature
which was relied on by victim and was made for purposes of inducing reliance,
and that victim’s reliance led to his injury. Parsons V. Winter, 1986, 1 Dist., 491 N.E.
2d 1236, 96 ILL
Dec. 776, 142 ILL App 3d 354, Appeal Denied.
In Carter V. Mueller 457
N.E. 2d 1335 ILL. App. 1 Dist. 1983 The Supreme
Court has held that: “The elements of a cause of action for fraudulent
misrepresentation (sometimes referred to as “fraud and deceit” or deceit) are:
(1) False statement of material fact; (2) known or believed to be false by the
party making it; (3) intent to induce the other party to act; (4) action by the
other party in reliance on the truth of the statement; and (5) damage to the
other party resulting from such reliance.
13.) That said Judges have
corroborated/admitted beyond all legal standards of the law their universal
collaboration as Racist Terrorists and their ability to recruit the necessary
Justices outside their ethnicity to enforce their doctrines on innocent Black
and Hispanic men like the Appellant as noted throughout all documents;
A-
That every Judge played a significant role
in every layer of this conspiracy ILL. App. (1st Dist. 2000). A “VOID JUDGEMENT
OR ORDER” is one that is entered by a court lacking jurisdiction over the
parties or the subject matter, or lacking the inherent power to enter the
particular order of judgment, or where the order was procured by FRAUD- in re
Adoption of E.L., 248 ILL. Dec. 171, 733 N.E. 2d 846, 315 ILL. App. 3d 137- Judgm
7, 16, 375.
B-
U.S 2003.
Essence of a conspiracy is an agreement to commit an unlawful act.-U.S. v.
Jimenez Recio; 123 SCt. 819, 537 U.S. 270, 154, L. Ed.2d 744, on remand 371
F.3d 1093;
Agreement to commit an unlawful act, which
constitutes the essence of a conspiracy, is a distinct evil that exist and be
punished whether or not the substantive crime ensues,-id.
Conspiracy poses a threat to the public over
and above the threat of the commission of the relevant substantive crime, both
because the combination in crime makes more likely the commission of other
crimes and because it decreases the part from their path of criminality-id;
C 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).
14.)REPORTING JUDICIAL MISCONDUCT
CANON 3D (1)
Under Section 3D (1), a judge who receives
information that indicates “a substantial likelihood that another judge “ has
violated the Code of Judicial “should take appropriate action”. The Canon does
not require the judge to hold a hearing and make a definitive decision that a
violation has occurred before the reporting requirement is triggered and at
least one state’s judicial ethics committee has advised that the reporting
requirement is triggered when the judge has “sufficient information” to conclude
that a “substantial issue” has been raised that a violation has occurred, Mass.
Comm. On Judicial Ethics, Op. 2002-04 (2002)
“Appropriate action” may include direct
communication with the judge who has committed the violation and reporting the
violation to the appropriate or other agency or body. See Commentary to Canon
3D (1). “Appropriate authority” is the authority with responsibility for
initiation of disciplinary proceedings with respect to the violation reported.
Some jurisdictions’ rules specify to whom a judge must report misconduct. For
instance, Massachusetts Rule 3D (1) provides that if a judge becomes aware of
another judge’s unprofessional conduct he must report his knowledge to the
Chief Justice of the Massachusetts Supreme Court and the court of which the
judge in question is a member.
Note that the term “knowledge”, as defined
in the Terminology Section, denotes actual knowledge of the fact in question
and as such, a person’s knowledge may be inferred from circumstances. In
drafting Section 3D (1), the Committee rejected the suggestion that the
criteria of raising substantial question as to honesty or trustworthiness be
applied in the context of reporting judicial misconduct as well, on the grounds
that those criteria are implicit in the present criterion of raising a
substantial question as to a judge’s fitness for office.
Under Section 4 of the Ku Klux
Klan Act of 1871:
The President had additional
power in case of rebellion within a state to suspend the writ of habeas corpus
and to declare and enforce marital law. Cong.
Globe, supra note 1, at 317. With respect to a definition of rebellion,
Section 4 provided;
“Whenever
in any State or part of a State……unlawful combinations……..shall be organized
and armed, and so numerous and powerful as to be able, by violence, to either
overthrow or set at defiance the constituted authorities of such State, or when
the constituted authorities are in complicity with or shall connive at the
unlawful purposes of such powerful and armed combinations; 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….”
FURTHER AFFIANTH SAYETH NOT
Under penalties as provided by law pursuant to 735 1265 5/1
-109, the undersigned certifies that the statements set forth in this instrument
are true and correct, except as to matters therein stated to be on information
and belief and as to such matters, the undersigned certifies as aforesaid that
he verily believe the same to be true.
Respectfully
submitted,
Joe Louis Lawrence
Counsel
Pro Se
APPEAL TO THE ILLINOIS
APPELLATE COURT
FIRST DISTRICT
FROM THE CIRCUIT
COURT OF
COOK COUNTY
DOMESTIC
RELATIONS DIVISION
________________________________________________________________________
)
Joe Louis Lawrence )
) Trial Court
No. 09 CH 1773
Plaintiff-Appellant )
General No. 09-2287
) Division No.
2
V. )
Erwin McEwen, Dir. of DCFS
) Hon. Judge O’Maki
Et al
)
)
Defendant- Appellee
)
)
DRAFT ORDER
This matter having
come on to be heard on Motion for Reconsideration/Vacate Order due to Judges Corroboration
in an Organized Chain Conspiracy “Perjury” “Fraud” Racial Fraternal Civil
Rights Violations and other irregularities, due notice having been given, the
court having jurisdiction over the parties and the subject matter, and being
fully advised in the premises;
It is HEREBY ORDERED that Appellant’s Motion
is GRANTED INSTANTER.
ENTERED:
_________________________________
Judge Patrick J. Quinn
_________________________________
Judge Michael Murphy
_________________________________
Judge
John O. Steele
Joe Louis Lawrence
Counsel Pro Se
________________________________
P.O. Box 490075
Chicago,
Illinois 60649-0075
(312) 927-4210
APPEAL TO THE ILLINOIS
APPELLATE COURT
FIRST DISTRICT
FROM THE CIRCUIT
COURT OF
COOK COUNTY
DOMESTIC
RELATIONS DIVISION
________________________________________________________________________
)
Joe Louis
Lawrence
)
) Trial Court No. 09 CH 1773
Plaintiff-Appellant
) General No. 09-2287
) Division No. 2
V. )
)
Erwin McEwen, Dir. of
DCFS )
Hon. Judge
O’Maki
Et al )
Defendant- Appellee
)
)
Notice of
Motion
for Disqualification of Judge Due to Bias (Civil Rights Violations) and or Prejudice
pursuant to Canon 3(C) (1) and to Vacate Orders where Civil Rights were
Violated
YOU ARE HEREBY NOTIFIED that
Plaintiff-Appellant Moves to the Illinois Appellate Court, First District for
an Order on Motion for Disqualification of Judge Due to Bias (Civil Rights
Violations) and or Prejudice pursuant to Canon 3 (C) (1) and to Vacate Orders
where Civil Rights were Violated.
TO: AAG Paul Racette
FBI Robert Grant (Courtesy Copy)
Child Welfare
Litigation Bureau 2111 West
Roosevelt Road
100 West
Randolph, Suite 1200 Chicago, Ill. 60612
Chicago, Ill.
60601
Chief Judge Timothy Evans U.S. ATTY Patrick
Fitzgerald
Daley
Center
219 South Dearborn Suite 500
Suite
2600
Chicago, Ill. 60604
Hon. Mosche
Jacobius Clerk
of Circuit Court
Daley
Center
Dorothy Brown
Suite
1900
Daley Center, Suite 1001
PLEASE BE ADVISED that on July 14, 2010
said Notice of Motion was hereby filed with the Motion for Disqualification of
Judge Due to Bias (Civil Rights Violations) and or Prejudice pursuant to Canon
3 (C) (1) and to Vacate Orders where Civil Rights were Violated with the
attachments and mailed/hand delivered to all parties recorded in said notice
via regular mail.
Respectfully Submitted
Joe Louis Lawrence
P.O. Box 490075
Chicago, Illinois 60649-0075
(312) 927-4210
APPEAL TO THE ILLINOIS APPELLATE COURT
FIRST DISTRICT
FROM THE CIRCUIT
COURT OF
COOK COUNTY
DOMESTIC
RELATIONS DIVISION
________________________________________________________________________
)
Joe Louis Lawrence )
) Trial Court
No. 09 CH 1773
Plaintiff-Appellant
) General No.
09-2287
) Division No.
2
V. )
)
Erwin McEwen, Dir. of
DCFS ) Hon. Judge O’Maki
Et al
)
Defendant- Appellee
)
)
Motion
for Disqualification of Judge Due to Bias (Civil Rights Violations) and or Prejudice
pursuant to Canon 3(C) (1) and to Vacate Orders where Civil Rights were
Violated
Now comes defendant, Joe Louis
Lawrence, Attorney Pro Se, in this cause, files herewith his affidavit,
factually establishing the Bias (Civil Rights Violations) Prejudice alleged
herein, with exhibits, in accordance to Supreme Court of Illinois and Canon
rules in accordance to the American Jurisprudence and pleadings (rev.) to show
that Justice Patrick J. Quinn, Sharon
Johnson Coleman and John Owen Steele has a personal bias or prejudice against
the Plaintiff-Appellant and has demonstrated such in violating his civil rights
and, they have personal knowledge of undisputed evidentiary facts accompanied
by affidavits concerning the proceeding; they are using their robes in an
attempt to cover up the unprecedented acts of conspiracy fraud perpetrated on
the courts;
Based
thereon defendant respectfully moves that the Justice Patrick J. Quinn, Sharon
Johnson-Coleman and John Owen Steele proceed no further herein, and that the
Honorable Executive Committee who have not been Motioned by the Appellant for Disqualification
assign this matter accordingly.
Appellant has exhausted 18-20 Judges out of 24
in the Appellate Division where there are only six Qualified Judges left with
integrity to preside over this matter;
Respectfully Submitted,
By:
________________________
Attorney Pro Se
STATE OF ILLINOIS )
)
COUNTY OF COOK )
AFFIDAVIT
In support of Motion to Disqualify
Justice Patrick J. Quinn, John Owen Steele and Sharon Johnson-Coleman for Bias Obstruction of Justice “Fraud”
Conflict of Interest (Civil Rights Violations) and or Prejudice pursuant to
Canon 3 (c) (1) and to Vacate any Orders where Civil Rights were Violated:
1.)
I
am Joe Louis Lawrence, Attorney Pro Se, defendant in this cause, being first
duly sworn on oath deposes and states, as follows;
2.)
I am
informed and believe and based on such information and belief, allege that Justices
Patrick J. Quinn, John Owen Steele, Sharon Johnson- Coleman, Joy V. Cunningham,
Thomas E. Hoffman, Themis N. Karnezis,
Mary Jane Theis, Michael J. Murphy, Sheila M. O’Brien whom this cause has
pended before, has demonstrated culpability, Personal Bias and or Prejudice and
has demonstrated beyond the Preponderance of the evidence their conspiratory
participation in an elaborate conspiracy;
A-
Said
Judges had knowledge and was aware of the legal Torture/Lynching lodged at Appellant
and received unabated affidavits, particularly
(Motion For Reconsideration/Vacate Order due to Error, Organized Chain
Conspiracy, “Fraud” Racial Fraternal Civil Rights Violations w/Affidavit )
filed June 23, 2010—detailing “Corruption” “Fraud” “Perjury” and a host of
other Civil Rights Violations;
B-
That
Judge Pat J. Quinn as a former States Atty. used his robe and authority
assisting members of the fraternal order in a corroborating manner
demonstrating himself as a major player/fixer obstructing justice;
C-
That
Appellant filed a motion for Mandatory Injunction Interlocutory Appeal et al
with Affidavit in 2006, detailing Asst. States Attorneys and a number
Judges engaging in a racist criminal conspiracy trying to cover-up for the CTA
and Paternity matter, (case # 06-1061)
D-
That
said case was assigned to the 4th Div. before Judges Hon. Calvin C.
Campbell, Michael J. Murphy, P. Scott Neville, Jr., Sheila O’ Brein;
E- That Judge Patrick J. Quinn was found
not qualified by the Lawyers Council of Chicago, hereto attached, Ex. A, they said, “he is accused by many criminal defense practitioners as having a bias
favoring the prosecution”;
F-
That
said judge demonstrated his racial affiliations with the Ku Klux Klan and other
Fraternal orders while judge in the 3rd Div. with Judge Joy V.
Cunningham, Alan J. Grieman, Mary Jane Theis, he personally denied Appellant’s
motion before the 4th Div. so as to cover-up and uphold his criminal
involvement and protect other members of the fraternal order;
G-
That
Appellant filed a Petition for Writ of Mandamus/Issuance of Supervisory
Order & Rule to Show Cause and Impose Sanctions, hereto attached, Ex. B, court order from the Illinois
Supreme Court where certain judges of the same fraternal order denied said
petition so as to protect all members in the “closet” fraternal order; (July
19, 2006)
H-
That
on July 6, 2010, Judge Patrick J. Quinn violated the immunity provisions of his
robe while in the 3rd Div. recruited the necessary blacks to aid
him, (he was not going down alone on this one) as they Denied his motion for
Reconsideration et al., hereto attached as Ex.
C, handwritten court order with their signatures;
That the Justices erred
considerably when it received notice and knowledge of other Judges complicit in
a Criminal Conspiracy failed to follow Canon Ethics 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.
I- That because of the veracity of all
pleadings and facts presented before this Honorable Appellate Court with
affidavits, no attorney objected to or denied any of the factual claims
presented; and not one attorney would ever deny or object because everything
recorded is the TRUTH;
Pursuant to 735 ILCS 5/2-610 where allegations of complaint are not denied,
there is admission of all facts well-pleaded by adversary, and such admission,
drawn from failure to plead, may be considered as evidence. Hecht v. Hecht,
App. 1 Dist. 1977, 7 Ill. Dec. 169, 49 Ill. App. 3d 334, 364 N.E. 2d 330.
Pursuant to 735 ILCS 5/2-612 Counsel never Objected to the sufficiency of
Petitioners pleadings, Objections to sufficiency of pleadings either in form or
substance must be made In trial court, and if not so made, they will be
considered waived and cannot be raised for the first time on appeal. People
ex rel. Deynes v. Harris, App. 1948, 77 N.E. 2d 439, 333 Ill. App. 280.
Counsel
for Respondent waived any defects against Petitioner in any pleadings by
failing to object, any defects in pleadings, either of form or substance, not
objected to in trial are waived on appeal. Geleto v. Giglietti, 1976, 40
Ill.App 3d 226, 352 N.E. 2d 1; In re Leyden Fire Protection Dist., 1972, 4 Ill.
App. 3d 273, 280 N.E. 2d 744; Lyon v. Metropolitan Life Ins. Co., 1942, 315
Ill. App. 451, 43 N.E. 2d 187.
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
reasonably be questioned …..”Arkansas
Code of Judicial Conduct, Canon 3 (C) (1) 1988.
Where a judge exhibits bias or the
appearance of bias, the court will reverse. Patterson v. R.T., 301 Ark. 400,
784 S.W. 2d 777 (1990); 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.
“Bolden v. State, 262 Ark.
718, 561 S.W. 2d 281 (1978).
3.)
The
facts and reasons for the belief that such Bias and or Prejudice and Civil
Rights Violations exists, are that, the following laws were noticeably maliciously
violated, said Justices having complete knowledge and was aware of all
“fraudulent” acts perpetrated by the Chicago Transit Authority attorneys,
States Attorneys and Asst. Atty. Generals and certain Circuit Court Judges,
hereto attached, Group Ex. D, Petition
for Rule to Show Cause et al (filed Feb 24, 2009) demonstrates how every
judge and a slew of others in the “closet” connected to the fraternal order
involved his children as they tried to cause and incite domestic violence
between his wife and daughter; became intertwined in his divorce, became
intertwined falsified medical documents with daughters medical condition etc.,
aiding DCFS which is the very case before the 2nd Div. that is to be
“FIXED”
A- Due to said Judges Biasness, they have
exercised anarchy and a Disparate application of the laws of everyone involved
who shared a political make up by ignoring every criminal Civil Rights Act
lodged at Appellant;
B-
Said
Judges violated all Rules of law Canon Ethics, Code of Judicial Conduct Rule
62 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.
Said case is likened to legal intercourse,
legal sodomy, legal rape where all judges involved who have engaged in such
acts by ignoring every criminal act perpetrated at Appellant by their
colleagues who closed their eyes to his
cries for help, shut their mouths and remained silent so as to keep their
positions, signed any court orders against him having complete knowledge of all
unlawful criminal acts, is likened to contracting Legal HIV (Aids), for which
there is no cure for this legal virus, one of the premiere symptoms is it’s ability
to ravish away any and all accolades of any attorney or judge accomplished in
the legal venues, like the virus in the body destroying the immune system, only
this legal virus will destroy anybody’s career;
Homosexuals are not the primary victims of
the Aids virus, Heterosexuals have taken over in that area, the only safe legal
sex a judge, States Atty. Asst. Atty. Gen. etc is to protect yourself with
legal abstinence (don’t involve your self with corruption), legal copulation
(protect yourself by abiding by the laws of the United States Constitution) if
not, who ever you are doing it to in the “dark” (corruption etc) or who ever
you do it with in the “dark” (corruption etc.) will truly make it’s way into
the “light” (Justice, etc) “Take a
strong look at this case”
A
judge’s disrespect for the rules of court demonstrates disrespect for the law.
Judges are disciplined under Canon 2A 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”)
C- Said Justices had knowledge the
Chicago Transit Authority under the direction of Kent Stephen Ray (Gen. Counsel
for CTA)) have properly agreed to all facts recorded and corroborated to
participating in Draconian Civil Rights violations against the Appellant and
other noted criminal acts;
Ill.
App. (1st Dist. 2000) “A VOID Judgment or ORDER” is one that is
entered by a court lacking jurisdiction over the parties or the subject matter,
or lacking the inherent power to enter the particular order of judgment or
where the order was procured by FRAUD—in re Adoption of E.L., 248 Ill. Dec.
171, 733 N.E. 2d 846, 315 Ill. App. 3d 137-Judgm 7, 16, 375
Judge Patrick J. Quinn
and many other Judges were aware, Mr. Tom Foley of the Attorney Registration
& Disciplinarian Commission paralegal under the authority of the Honorable
Jodi N. Goode never met Appellant, had the entire paternity matter retrieved
and learned every summons against him was returned not served;
When people ask how and why, did all the judges enter orders against
you and you were never served? They did the same thing YOU did ignored Appellant
and assumed he was a Typical NIGGA, Passive NIGGA, Ignorant NIGGA, while the
laws clearly demonstrate my innocence they say NIGGA you GUILTY, I say I am a
CTA
employee they say NIGGA you
ain’t, I say I work for IBC/Wonder bread they say NIGGA you DISCHARGED, I say I
have a wife and 5 children they say NIGGA you don’t have any dependent’s, I say
I AM that That I AM somebody they say NIGGA you don’t get it, you don’t exist,
I say I am Educated I have spent 12-14 hours a day in the Law Library studying
the law and it’s applications, they laugh at me and say NIGGA it ain’t what you
know, it is who you know, I say I have applied the laws better than some your
best involved in this conspiracy, they say NIGGA you right, because everyone
involved is related to someone who is related to someone no one is listening, I
say I have proof they say NIGGA there is no such thing as proof I say what do
you mean? They say NIGGA we Lie we Destroy we Cheat we Intimidate/Threaten we
Undermine anyone necessary to advance our Doctrines, I say my faith is in GOD,
they Laugh NIGGA where was your GOD all those years when we Economically
Murdered you, NIGGA where was your GOD all those years when we Assassinated
your Character, NIGGA where was your GOD all those years when we Buried your
ASS left you for DEAD, NIGGA you should be on CRACK/HEROIN, NIGGA you ain’t
committed SUICIDE, NIGGA you should’a ROBBED somebody, NIGGA you look GOOD how
come you ain’t PIMPIN? NIGGA with your MIND you can be the best DRUG DEALER,
wait a minute NIGGA who are you? How come nothing seem to have WORKED? First of
All I am no NIGGA the GOD I serve moves me by way of the SPIRIT, When I seek
JUSTICE you reward me INJUSTICE, when I seek HELP, you LAUGH at me, when my
family and I suffer you CELERBRATE.
Psalm 121 Verse1, 2 I will lift up mine eyes unto the hills, from
whence cometh my help. My help cometh from the Lord, which made Heaven and
Earth.
4.)
Said Justices
have demonstrated the same level of Prejudice and Biasness as their colleagues
in the sixth Division, when racism is an issue, they simply recruit the
necessary ethnic individuals that would go along with wrong so as to camouflage
and protect the actual leaders perpetrating said racial acts;
A-) That Patrick J. Quinn because
he is the younger brother of acting Governor Patrick J. Quinn has flexed more
muscle with his authority is responsible for the falsification of records
stating Appellant owes child support of $59, 892.41, hereto attached, Group Ex. E, June 24, 2010 letter from
Child support Team 2;
B-) That Patrick J. Quinn has
corroborated and has established beyond the preponderance of the evidence
standard further conspiratory relations with other judges as he and Asst States
Atty Brian Volkman falsifying court orders where it records, he is Contempt of Court for “allegedly
owing $29,100.00”, hereto attached, Ex. F, April 14, 2004, Court Order, Judge David Haracz;
C-) That due to Judge Patrick J.
Quinn’s criminal involvement and racist fraternal connections, Appellant was
taken into custody where his mother had to post $250.00, hereto attached, Ex. G, because as a Public Aid
recipient they tried to exhaust every tactic necessary to have him incarcerated
and slain, a judge told them he did get on board for this and balked at any
other signing of any documents against the Appellant;
D-) Lastly, Judge Patrick J. Quinn
was aware of the official complaint lodged against Asst States Atty. Brian
Volkman, served upon Richard Devine Oct. 13, 2004, hereto attached, Ex. H, and was Asst States Atty. during the
era of when John Burge was Commander of the Police Department; Now witness
the other type of TORTEOUS HEINOUS acts perpetrated on an innocent black
man and the extent many white men exhausted to DESTROY him causing a Genocidal
effect on the black man and his children and witness the role of the black
women in this mess;
Petitioner submits the Willie
Lynch Letter of 1712
Gentleman:
I greet you here on the bank of the James
River in the year of our Lord, one thousand seven hundred and twelve. First I
shall thank you, the Gentlemen of the Colony of Virginia, for bringing me here.
I am here to help you solve some of your problems with slaves. Your invitation
reached me on my modest plantation in the West Indies where I have experimented
with some of the newest and still the oldest methods for control of slaves.
Ancient Rome would envy us if my program is implemented. As our boat sailed
south on the James River, named for our illustrious King James, whose bible we
cherish, I saw enough to know that your program is not unique. While Rome used
cords of wood as crosses for standing human bodies along the old highways in
great numbers, you are here using the tree and the rope on occasion.
I caught the whiff of a dead slave
hanging from a tree a couple of miles back. You are not only losing valuable
stock by hangings, you are having uprisings, slaves are running away, your
crops are sometimes left in the fields too long for maximum profit, you suffer
occasional fires, your animals are killed, gentlemen...you know what your
problems are; I do not need to elaborate. I am not here to enumerate your
problems; I am here to introduce you to a method of solving them.
In my bag here, I have a fool-proof
method for controlling your black slaves. I guarantee every one of you that if
installed correctly it will control the slaves for at least 300 years. My
method is simple, any member of your family or any overseer can use it.
I have outlined a number of differences
among the slaves, and I take these differences and make them bigger. I use
fear, distrust, and envy for control purposes. These methods have worked on my
modest plantation in the West Indies, and it will work throughout the South.
Take this simple little test of differences and think about them. On the top of
my list is "Age", but it is there because it only starts with an
"A"; the second is "Color" or shade; there is intelligence,
size, sex, size of plantations, attitude of owners, whether the slaves live in
the valley, on a hill, East, West, North, South, have fine or coarse hair, or
is tall or short. Now that you have a list of differences, I shall give you an
outline of action--but before that, I shall assure you that distrust is
stronger than trust, and envy is stronger than adulation, respect, or
admiration.
The Black Slave, after receiving this
indoctrination, shall carry on and will become self refueling and self
generating for hundreds of years, maybe thousands.
Don't forget, you must pitch the old
Black vs. the young Black male, and the young Black male against the old Black
male. You must use the dark skinned slaves vs. the light skinned slaves, and
the light skinned slaves vs. the dark skinned slaves. You must use the female
vs. the male, and the male vs. the female. You must also have your servants and
overseers distrust all Blacks, but it is necessary that your slaves trust and
depend on us. They must love, respect, and trust only us.
Gentlemen, these kits are your keys to
control, use them. Have your wives and children use them. Never miss
opportunity. My plan is guaranteed, and the good thing about this plan is that
if used intensely for one year, the slaves themselves will remain perpetually
distrustful.
That the Willie Lynch Letter is
truly merited in this manner in all facets of this conspiracy, but it is
not applicable to all self respecting black people;
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 the 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.
5.)
That the color or ethnic origin of said Judges in
this manner is of no merit because they all share a philosophical doctrine so
as to keep their jobs “Go along with wrong, see wrong, close eyes to wrong in
order to get along with the wrongdoers”
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.”)
The Miseducation of the Negroe Political
Education Neglected
Carter G. Woodson, 1933
The
opponents of freedom and social justice decided to work out a program which
would enslave the negroes’ mind in as much as the freedom of body had to be
conceded. It was well understood that if by teaching of history the white man
could be further assured of his superiority and the negroe could be made to
feel that he had always been a failure and that the subjection of his will to
some other race is necessary for the freedman, then, would still be a slave. If
you can control a man’s thinking you do not have to worry about his action.
When you determine what a man shall think you do not have to concern yourself
about what he will do. If you make a man feel that he is inferior, you do not
have to compel him to accept an inferior status, for he will seek it himself.
If you make a man think that he is justly an outcast, you do not have to order
him to the back door. He will go without being told; and if there is no back
door, his very nature will demand one.
6.)
Said
Justices are not dispensating the laws in accordance to the laws of the United
States Constitution but in accordance to other Political/Fraternal “closet”
laws outside of the Constitution and Illinois Supreme Court rules;
Under Section 4 of the Ku Klux Klan Act of 1871:
The President had additional
power in case of rebellion within a state to suspend the writ of habeas corpus
and to declare and enforce marital law. Cong.
Globe, supra note 1, at 317. With respect to a definition of rebellion,
Section 4 provided;
“Whenever in any State or part
of a State……unlawful combinations……..shall be organized and armed, and so
numerous and powerful as to be able, by violence, to either overthrow or set at
defiance the constituted authorities of such State, or when the constituted
authorities are in complicity with or shall connive at the unlawful purposes of
such powerful and armed combinations; 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….”
794 S.W. 2d 692 (Mo.
App. 1990) “No system of justice can function at its best or maintain broad
public confidence if a litigant can be compelled to submit his case in a court
where the litigant sincerely believes the judge is incompetent or prejudicial……
{T}hat is the price to be paid for a judicial system that seeks to free a
litigant from a feeling of oppression”. State ex Rel. McNary v. Jones, 472 S.W.
2d. 637, 639-640 (Mo. App. 1971) Indeed, the
right to disqualify a judge is “one of the keystones of our legal
administration edifice“ State ex Rel. Campbell v. Kohn, 606 S.W. 2d 399-401(Mo. App. 1980). It is
vital to public confidence in the legal system that the decisions of the court
are not only fair, but also appear fair. Thus whether the disqualification of a
judge hinges on a statute or rule in favor of the right to disqualify. A
liberal construction is necessary if we wish to promote and maintain public
confidence in the judicial system. Kohn, 606 S.W. 2d at 401; State ex Rel. Ford
Motor Co. v. Hess S.W. 2d 147, 148 (Mo.
App. 1987).
7.)
Said
Justices have truly demonstrated that because of Appellant’s skin color, and he
is prosecuting his claims Pro Se against powerfully connected white men in said
State of Illinois, he will never receive Equal Protection of the Laws as long
as their are Justices beholding to the Political machine, Racist Fraternal
“closet” orders presiding over this matter as demonstrated, by denying every
Motion accompanied by affidavit;
A-) Appellant was never going to file a
Motion Disqualifying Joy V. Cunningham et al judges because it was an
impossibility for him to lose that case because said Judge is a former Asst.
Atty. Gen. and never should have been presiding over this matter making any
type of rulings due to conflict of interest;
B-) That it was necessary to establish
corroboration demonstrating black women on the bench is worst than whites as
they would do anything to uphold their positions in office as demonstrated in
this matter;
Section 1983 of USCS contemplates the
depravation of Civil Rights through the unconstitutional application of a law
by conspiracy or otherwise. Mansell V. Saunders ( CA 5 FLa) 372 F 2d
573,especially if the conspiracy was actually carried into effect and plaintiff
was thereby deprived of any rights privileges, or immunities secured by the
Constitution and laws, the gist of the action may be treated as one for the
depravation of rights under 42 USCS 1983 Lewis V. Brautigam (CA 5 Fla) 227 F 2d
124, 55 Alr 2d 505.
The Judges, Attorneys, clerks involved
have done a wonderful job amplifying their criminal conspiratory relationship
beyond their own imagination this case reminds me of Stone Phillips initiating
a undercover sting capturing pedophiles on Channel 5, those sexual predators are soliciting minors
over the internet for sex knowing their ages, but when they are caught and
notified that they are apart of a sting, they have no defense for their criminal
solicitation, this is you and every
person in position to exercise accountability) You and all of the attorneys
have complete knowledge of the FBI’s involvement, demonstrated draconian
disrespect for the law, used their robes to incite Hate Crimes, Like a police officer planting drugs on an innocent
black man to justify an arrest, or killing them; Like a fireman burning a black
mans home or business, he does not like in his neighborhood; these people are
your next door neighbors, look at this case good it demonstrates how educated Caucasians
feel about people of color;
so what Africans Americans have
top positions in Chicago, or the State of Illinois, when there is a Negroe in
charge to effect a possible change for the better he is prohibited because his
education is almost entirely in the hands of those who have enslaved them and
now segregate them. The Negroes placed in charge would be the products of the
same system and would show no more conception of the task at hand than do the
whites who have educated them shaped their minds as they would have them to
function. Carter G. Woodson 1933
Now everyone
can witness and read first hand on how cases are FIXED here in Illinois
seemingly is the most RACIST
SEGRAGATED legal System in Illinois how judges are recruited their
ethnic profile and what they are willing to do in committing careecide (to
knowingly commit a heinous act against someone via Public, City, Fed.
employment etc. losing that position along with their pension etc) to maintain
their positions as a Judge;
FURTHER AFFIANTH SAYETH NOT
By:____________________ ___
Joe Louis Lawrence
As
penalties as provided by law, pursuant to Section 1-109 of the Code of Civil
Procedures, the undersigned certifies that the statement set forth in this
instrument are true and correct, except as to matters herein stated, the
undersigned certifies as aforesaid that he verily believes the same to be true.
Joe
Louis Lawrence
Attorney
Pro Se
Joe
Louis Lawrence
Atty.
For Pro Se
P.O.Box 490075
Chicago, Illinois
60649
Atty.
Code: 99500
(312)
927-4210
APPEAL TO THE ILLINOIS APPELLATE COURT
FIRST DISTRICT
FROM THE CIRCUIT
COURT OF
COOK COUNTY
DOMESTIC
RELATIONS DIVISION
________________________________________________________________________
)
Joe Louis
Lawrence
)
) Trial Court
No. 09 CH 1773
Plaintiff-Appellant ) General No. 09-2287
) Division No.
2
V. )
)
Erwin McEwen, Dir. of
DCFS ) Hon. Judge O’Maki
Et al
)
Defendant- Appellee )
)
DRAFT ORDER
This matter having
come on to be heard on Motion for Disqualification of Judge Due To Bias (Civil
Rights Violations) and or Prejudice pursuant to Canon 3 (C) (1) and to Vacate
Orders where Civil Rights were Violated due notice having been given, the court
having jurisdiction over the parties and the subject matter, and being fully
advised in the premises;
It is HEREBY ORDERED that Judges Patrick J.
Quinn, Sharon Johnson Coleman, John Owen Steele and any and every Judge
recorded in Appellants Affidavit are Recused
Pursuant To Canon 3 (C) (1) and Orders DENIED with Affidavits are VACATED
INSTANTER;
ENTERED:
_________________________________
Justice
Patrick J. Quinn
_________________________________
Justice Sharon Johnson-Coleman
_________________________________
Justice john Owen Steele
Joe Louis Lawrence
Attorney Pro Se
P.O. Box 490075
Chicago,
Illinois 60649-0075
(312) 927-4210
________________________________________________________________________
IN THE
SUPREME COURT OF ILLINOIS
________________________________________________________________________
)
Joe Louis Lawrence )
Appeal from the Circuit
) Court of Cook
County
Plaintiff-Appellant
) Chancery
Division
) Case No. 09-2287
V.
)____________________________________
)
Erwin McEwen, Dir. of DCFS ) Honorable
Et al
) William O Maki
Defendant- Appellee
) Appellate Judges Joy V.
Cunningham,
) Thomas E. Hoffman, Themis N.
Karnezis
) Michael J. Murphy, Sharon Johnson
C
) Coleman, John O. Steele,
Patrick J. Quinn
) No. 09-2287 2nd&
3rd Division
PETITION FOR WRIT OF
MANDAMUS
FOR MANDATORY INJUNCTION/ISSUANCE OF A
SUPERVISORY ORDER VACATING ORDERS AND ADMONISHING JUDGES for “FRAUD” AND
CONSPIRATORY CIVIL RIGHTS VIOLATIONS AND TO IMPOSE SANCTIONS
_______________________________________________________________________
Now comes Plaintiff-Appellant, Joe Louis Lawrence
respectfully moves this Honorable Court to enter an Order for a Writ of
Mandamus for Mandatory Injunction/Issuance of a Supervisory Order Vacating Order
and Admonishing Judges for “FRAUD” and
Conspiratory Civil Rights Violations and to Impose Sanctions in the above
entitled cause.
Reasons in
support of this motion are set forth in the attached affidavit.
Respectfully
Submitted,
Joe Louis Lawrence
By:____________________________
Joe Louis Lawrence
Attorney Pro Se
STATE OF ILLINOIS
)
)
COUNTY
OF COOK )
AFFIDAVIT
Joe Louis Lawrence being first duly sworn on oath deposes
and states as follows:
1.)
I am Joe Louis Lawrence, Attorney Pro Se.
2.)
Appellant filed an unchallenged Motion accompanied by
an Affidavit Motion for Reconsideration Vacate Order due to Error
“Fraud” Racial Fraternal Civil Rights Violations & other Irregularities
before the 2nd Division (Filed June 24, 2010) said Motion
demonstrated Racist Civil Rights Violations and a plethora of Criminal acts
involving numerous Judges, Justices Patrick J. Quinn, Sharon Johnson Coleman
and John O. Steele of the 3rd Division, DENIED said Motion July 6, 2010, hereto
attached as Ex. A ;
3.) Appellant
filed an unchallenged Motion accompanied by an Affidavit Motion to Impose
Sanctions on the Attorney General’s law department pursuant to Supreme Court
Rule 137 ( Filed June 10, 2010) said Motion
demonstrated an Assistant Atty. Gen. making implied threats to Judges
instructing them on how to rule on said case, said Judges Joy V. Cunningham,
Thomas E. Hoffman and Themis N. Karnezis did what the Asst. Atty. Gen
instructed them to do, they DENIED said Motion, (June 23, 2010) hereto attached
as Ex. B;
4.)
Appellant filed an unchallenged Motion for
Disqualification of Judge Due to Bias (Civil Rights Violations) and or
Prejudice pursuant to Canon 3(C) (1) and to Vacate Orders where Civil Rights
were Violated w/Affidavit, (Filed July. 14, 2010) said Motion demonstrated
Judges engaging in Racist Civil Rights acts as they covered up numerous
criminal acts on the part of CTA attorneys and tried to cover –up Judge Quinn’s
criminal involvement fixing a paternity matter against the Appellant and the
number of corrupt Judges used as he corroborated every fact in said Affidavit;
A-
That on July 16, 2010, said Judges unlawfully presided
over the matter and DENIED said Motion, hereto attached as Gr. Ex. C;
That because said
Justices have acted outside of their immunity provisions of their robes makes
this case criminal and not a Civil matter anymore-- The Appellate Court erred in ignoring his motion for
Disqualification of Judge, Sarah Bush
Lincoln Health Center v. Berlin 268 Ill. App. 4 Dist. 1994, 205 Ill. Dec. 325,
268;When party is entitled to substitution of judges as matter of right .
pursuant to section 2------1001(a)(2) of the Code of Civil Procedure, a party
is entitled to a substitution of judges as a matter of right if the party has
not entered an appearance in the case and has not been found in default, and
rulings on any substantial issue before the party’s appearance shall not be
grounds for denying an otherwise timely application for substitution of judge
as of right.
B-
The Supreme Court of Mississippi has taken the position
that willful abuse of authority, in violation of the Code of Judicial conduct,
for a justice court Judge to notarize a deed with a false acknowledgement and
to enter orders in cases not pending before the Judge, Mississippi Commission
on Judicial Performance v. Hartzog, 646 So. 2d 1319, 1321-1322;
C-
That there are at least 3 Justices in the Illinois
Supreme Court guilty of conspiring and aiding support to the Ku Klux Klan
“closet” fraternally connected Political Machine Justices, one can easily infer
their are only 3 because when Appellant filed a Motion to Disqualify said
Justices May 26, 2010, a Judge Ordered a Illinois Supreme Court clerk to
obstruct justice and not record the legal document in the computer;
D-
That if said Judges were of the majority Denying
anything he filed would have been a consensus because they had enough votes;
That because of the above; Fraud admissibility great latitude is permitted in proving fraud C.J.S. Fraud
104 ET Seg. Fraud 51-57. where a question of fraud and deceit is the issue
involved in a case, great latitude is
ordinarily permitted in the introduction of evidence, and courts allow the
greatest liberality in the method of examination and in the scope of inquiry Vigus
V. O’Bannon, 1886 8 N.E 788, 118 ILL 334. Hazelton V. Carolus, 1907 132 ILL.
App. 512.
INDUCING RELIANCE
To prevail in a cause of action for
fraud, plaintiff must prove that defendant made statement of material nature
which was relied on by victim and was made for purposes of inducing reliance,
and that victim’s reliance led to his injury. Parsons V. Winter, 1986, 1 Dist., 491 N.E.
2d 1236, 96 ILL
Dec. 776, 142 ILL App 3d 354, Appeal Denied.
In Carter V. Mueller 457
N.E. 2d 1335 ILL. App. 1 Dist. 1983 The Supreme
Court has held that: “The elements of a cause of action for fraudulent
misrepresentation (sometimes referred to as “fraud and deceit” or deceit) are:
(1) False statement of material fact; (2) known or believed to be false by the
party making it; (3) intent to induce the other party to act; (4) action by the
other party in reliance on the truth of the statement; and (5) damage to the
other party resulting from such reliance.
5.)
That said
Justices have corroborated/admitted beyond all legal standards of the law their
universal collaboration as Racist Terrorists and their ability to recruit the
necessary Justices outside their ethnicity to enforce their doctrines on
innocent Black and Hispanic men like the Appellant as noted throughout all documents;
A-
That every Justice played a significant role
in every layer of this conspiracy ILL. App. (1st Dist. 2000). A “VOID JUDGEMENT
OR ORDER” is one that is entered by a court lacking jurisdiction over the
parties or the subject matter, or lacking the inherent power to enter the
particular order of judgment, or where the order was procured by FRAUD- in re
Adoption of E.L., 248 ILL. Dec. 171, 733 N.E. 2d 846, 315 ILL. App. 3d 137-
Judgm 7, 16, 375.
B-
U.S 2003.
Essence of a conspiracy is an agreement to commit an unlawful act.-U.S. v.
Jimenez Recio; 123 SCt. 819, 537 U.S. 270, 154, L. Ed.2d 744, on remand 371
F.3d 1093;
Agreement to commit an unlawful act, which
constitutes the essence of a conspiracy, is a distinct evil that exist and be
punished whether or not the substantive crime ensues,-id.
Conspiracy poses a threat to the public over
and above the threat of the commission of the relevant substantive crime, both
because the combination in crime makes more likely the commission of other
crimes and because it decreases the part from their path of criminality-id;
C 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).
FURTHER AFFIANTH SAYETH NOT
Under penalties as provided by law pursuant to 735 1265 5/1
-109, the undersigned certifies that the statements set forth in this
instrument are true and correct, except as to matters therein stated to be on
information and belief and as to such matters, the undersigned certifies as
aforesaid that he verily believe the same to be true.
Respectfully submitted,
Joe Louis Lawrence
Attorney Pro Se
Joe Louis Lawrence
Attorney Pro Se
P.O. Box
490075
Chicago,
Illinois 60649-0075
(312) 927-4210
_______________________________________________________________________
IN THE
SUPREME COURT OF ILLINOIS
________________________________________________________________________
Joe Louis Lawrence ) Appeal from the Circuit
) Court of Cook
County
Plaintiff-Appellant
) Chancery Division
) Case No.
09-2287
V.
)____________________________________
)
Erwin McEwen, Dir. of DCFS ) Honorable
Et al
) William O Maki
Defendant- Appellee ) Appellate Judges Joy V. Cunningham,
) Thomas E. Hoffman, Themis N.
Karnezis
) Michael J. Murphy, Sharon Johnson
C
) Coleman, John O. Steele, Patrick J.
Quinn
) No. 09-2287 2nd&
3rd Division
PETITION
FOR WRIT OF MANDAMUS
FOR MANDATORY INJUNCTION/ISSUANCE OF A
SUPERVISORY ORDER VACATING ORDERS AND ADMONISHING JUDGES for “FRAUD” AND
CONSPIRATORY CIVIL RIGHTS VIOLATIONS AND TO IMPOSE SANCTIONS
To the
Honorable Justices of the Supreme Court of the State of Illinois.
Now comes Plaintiff –Appellant, your petitioner, the
people of the State of Illinois, a citizen, a resident and an Elector of the
City of Chicago, County of Cook, and State of Illinois, respectfully represents
and shows to your Honors the following:
1.) Appellant appeared before this Honorable
Court in and around April 2006, case #102650, this court was unaware that the
Paternity matter they DENIED, the
Supervisory Order was a Bogus case Reliance was Induced on this Court—Patrick
J. Quinn had conspired with certain corrupt Justices in the Illinois Supreme
Court and Plaintiff appealed all the way to the Seventh Circuit;
A- Appellant
was directed from the Seventh Circuit and FBI to go back on the State Level and
acquire the necessary corroboration demonstrating how the Paternity case, CTA
and IBC/wonder bread are all connected and the FBI was going to get everyone
involved;
B- Appellant
was provided unprecedented protection and latitude exhausted various legal
venues demonstrating how cases are “FIXED” in the various courts and have Due-diligently
been trying to get back to this Honorable Supreme Court so that the Federal
Authorities can ascertain other members of the Fraternal Order aiding and
assisting in this Civil Rights Conspiracy;
C- That
the Hightower
V. Lawrence 88 D 79012 was
a Bogus case Appellant was never legally before any court and no Judge
in the State of Illinois ever had Legal Jurisdiction on him—that is why the
enactment of the Ku Klux Klan law was put into place in 1871 Section 1 (42
U.S.C.) 1983 to prohibit any majority from engaging in the very criminal
acts that has become an acceptable norm in these legal tribunals controlled by
the Political Machines and they Blackballed him from working and receiving any
employment forcing him to exist on Welfare living below poverty where he is
unable to pay any bills due to no income only receives food stamps;
D- That
said Judges have all participated in “Treason like Offenses”
E- Appellant
has Due-diligently prepared and perfected all legal documents for the Appeals
Courts, he knew how the “good ol boys”
thought and operated in the courts, no Motion or Petition was ever presented
before the courts Frivolously;
F- FOR THE RECORD: Appellant thanks God for the Wisdom and
fortitude needed enduring the heinous acts perpetrated by many, Patrick
Fitzgerald, Robert Grant, Cook County Sheriff, Police Personnel and a host of
others for granting him the lead in acquiring the needed corroboration and
protection against all parties involved every Indictment had against the
memberships involved in this matter will surely yield successful convictions,
again thank you;
2.) That
due to “Fraud” Systemic Racism and alleged political intimidation, no Circuit Court Judges/Appellate Court Judges/ Supreme
Court Judges will ever enter orders in favor of Appellant, thereby validating the
veracity the Illinois Legal tribunals are under seize by Terrorists violating
all laws of Civil Procedure and Rules in accordance to Illinois Supreme Court
Rules and in accordance to Precedent legal citations; enforcing a Legal Lynching of the Laws against the Appellant;
3.)
That all Judges
have acted as a “Commander Burge” under his command where innocent black
men were tortured, in a Heinous manner (confessing to crimes they did not commit)
had their testicles electrocuted
squeezed and incarcerated for crimes they did not commit, in that said Justices
are of the same profile committing the same Racial Hate Crimes on the academic
side of the law;
4.)
That various clerks under the authority of Dorothy
Brown notified appellant he owed no child support due to the May 1988 Court
Order;
A- He
was instructed to notify the FBI and the Media because someone has a judge in
their back pocket;
B- That
Dorothy Brown’s office is no match to the Ku Klux Klan Political Machine
“Closet” Fraternal Operatives;
5.)
That because no attorney, States
Attorney, Attorney General in said offices etc., were able to litigiously
defeat the Attorney Pro Se, in that, all
Judges acted as renegade corrupt
attorneys, especially a judge was quoted as saying “Yall can’t handle that Pro Se Nigger give the Nigger to me” the case was reassigned from
Honorable Edward Jordan for trial, Judge Jeanne R. Bernstein and R. Morgan
Hamilton were the choices, Appellant ended up with R. Morgan Hamilton, said
judge engaged in a plethora of criminal acts and allowed his minor children to
become affected by said conspiracy;
WHEREAS, your petitioner prays that Writ
of Mandamus for Mandatory Injunction/Issuance of a Supervisory Vacating Orders
Admonishing Judges for “Fraud” and Conspiratory Civil Rights Violations and
Impose Sanctions maybe issued, directed to the Appellate Court Vacating all Orders
where Civil Rights were in Violation, Recuse Justices Patrick J. Quinn, Sharon
Johnson Coleman, John O. Steele & Michael J. Murphy, Joy V. Cunningham,
Thomas E. Hoffman, Themis N. Karnezis; directed to the Appellate Court Issuance
of a Supervisory Order for Sanctions removal from the bench & Order Criminal
Probe Instanter of all Corroborated
Facts; Supervisory Order against all parties associated in said conspiracy for
Rule to Show Cause for “Fraud” against the Appellant and to impose sanctions; and for
this Honorable Court to Invoke it’s authority wherever applicable.
Joe Louis Lawrence
Petitioner
Attorney Pro Se for Petitioner
Joe Louis Lawrence
P.O. Box 490075
Chicago, Illinois 60649-0075
(312) 927-4210
________________________________________________________________________
IN THE
SUPREME
COURT OF ILLINOIS
________________________________________________________________________
)
Joe Louis Lawrence ) Appeal from the Circuit
) Court of Cook
County
Plaintiff-Appellant
) Chancery
Division
) Case No.
09-2287
V. )____________________________________
)
Erwin McEwen, Dir. of DCFS ) Honorable
Et al ) William O Maki
Defendant- Appellee
) Appellate Judges Joy V.
Cunningham,
) Thomas E. Hoffman, Themis N.
Karnezis
) Michael J. Murphy, Sharon
Johnson
C ) Coleman, John O. Steele, Patrick J.
Quinn
) No. 09-2287 2nd&
3rd Division
MOTION FOR LEAVE TO
FILE
PETITION FOR WRIT OF
MANDAMUS
FOR MANDATORY INJUNCTION/ISSUANCE OF A
SUPERVISORY ORDER VACATING ORDERS AND ADMONISHING JUDGES for “FRAUD” AND
CONSPIRATORY CIVIL RIGHTS VIOLATIONS AND TO IMPOSE SANCTIONS
To the Honorable Justices of the Supreme Court
of the State of Illinois:
Now comes Plaintiff-Appellant, your
petitioner, the people of the State of Illinois, by the relator herein
Illinois, a Citizen, a Resident and an elector of the City of Chicago, County
of Cook, and State of Illinois, by and through himself, Attorney Pro Se Joe
Louis Lawrence, respectfully asks leave of this court to file a Petition for
Writ of Mandamus et, al; and that summons issue as provided by law.
Joe Louis Lawrence
Petitioner-Appellant
Attorney for Petitioner
Joe Louis Lawrence
P.O. Box 490075
Chicago, Illinois 60649-0075
(312) 927-4210
________________________________________________________________________
IN THE
SUPREME
COURT OF ILLINOIS
________________________________________________________________________
)
Joe Louis Lawrence ) Appeal from the Circuit
) Court of Cook
County
Plaintiff-Appellant ) Chancery Division
) Case No.
09-2287
V.
)____________________________________
)
Erwin McEwen, Dir. of DCFS ) Honorable
Et al
) William O Maki
Defendant- Appellee
) Appellate Judges Joy V.
Cunningham,
) Thomas E. Hoffman, Themis N.
Karnezis
) Michael J. Murphy, Sharon Johnson
C ) Coleman, John O. Steele, Patrick J.
Quinn
) No. 09-2287 2nd&
3rd Division
SUGGESTIONS IN SUPPORT OF THE PETITION
Along with
MEMORANDUM
OF LAW IN SUPPORT OF THE RELIEF REQUESTED
The petition and the procedure in this case are based upon former
proceedings in which this court granted the writ prayed. People V. Fischer, 303 Ill
430, 135 NE 751 et, al.
The petition proceeds in conformity with the instructions of this court
in People
V. Haas, 239 Ill 320, 87 NE 1111, with respect to the
presentation of original petition for Mandamus et al;
The issue presented in this original petition for Mandamus involves a
matter of great public importance in that it concerns the power conferred upon
county judges by the City Election Act to punish judges and clerks as for
contempt because of misbehavior or misconduct in their respective offices.
Petitioner respectfully submits that the court should grant leave to
file the Petition for Writ of Mandamus et al; duly signed and verified and
herewith presented with a petition, and with these suggestions and Memorandum
of Law in support of the relief requested, and that a summons issue in
conformity with the law, to the respondents returnable within a short time to
be fixed by this court, so that in this proceeding the powers of the County
judges under the City Election Act may be definitely and promptly determined.
REPORTING JUDICIAL MISCONDUCT
CANON 3D (1)
Under Section 3D (1),
a judge who receives information that indicates “a substantial likelihood that
another judge “ has violated the Code of Judicial “should take appropriate
action”. The Canon does not require the judge to hold a hearing and make a
definitive decision that a violation has occurred before the reporting
requirement is triggered and at least one state’s judicial ethics committee has
advised that the reporting requirement is triggered when the judge has
“sufficient information” to conclude that a “substantial issue” has been raised
that a violation has occurred, Mass. Comm. On Judicial Ethics, Op. 2002-04
(2002)
“Appropriate action” may include direct communication with the judge who
has committed the violation and reporting the violation to the appropriate or
other agency or body. See Commentary to Canon 3D (1). “Appropriate authority”
is the authority with responsibility for initiation of disciplinary proceedings
with respect to the violation reported. Some jurisdictions’ rules specify to
whom a judge must report misconduct. For instance, Massachusetts Rule 3D (1)
provides that if a judge becomes aware of another judge’s unprofessional
conduct he must report his knowledge to the Chief Justice of the Massachusetts
Supreme Court and the court of which the judge in question is a member.
Note that the term “knowledge”, as defined in the Terminology Section,
denotes actual knowledge of the fact in question and as such, a person’s
knowledge may be inferred from circumstances. In drafting Section 3D (1), the
Committee rejected the suggestion that the criteria of raising substantial
question as to honesty or trustworthiness be applied in the context of
reporting judicial misconduct as well, on the grounds that those criteria are
implicit in the present criterion of raising a substantial question as to a
judge’s fitness for office.
Joe
Louis Lawrence
Petitioner
Attorney
for the Pro Se Petitioner
Joe
Louis Lawrence
P.O.
Box 490075
Chicago,
Illinois 60649-0075
(312)
927-4210
________________________________________________________________________
IN THE
SUPREME COURT OF ILLINOIS
)
Joe Louis Lawrence ) Appeal from the Circuit
) Court of Cook
County
Plaintiff-Appellant
) Chancery
Division
) Case No. 09-2287
V.
)____________________________________
)
Erwin McEwen, Dir. of DCFS ) Honorable
Et al
) William O Maki
Defendant- Appellee
) Appellate Judges Joy V.
Cunningham,
) Thomas E. Hoffman, Themis N.
Karnezis
) Michael J. Murphy, Sharon
Johnson C
) Coleman, John O. Steele,
Patrick J. Quinn
) No. 09-2287 2nd& 3rd
Division
DRAFT ORDER
This matter having
come on to be heard on Writ of Mandamus for Mandatory Injunction/Issuance of a
Supervisory Order “Fraud” Order for a
Writ of Mandamus for Mandatory Injunction/Issuance of a Supervisory Order
Vacating Order and Admonishing Judges
for “FRAUD” and Conspiratory Civil Rights Violations and to Impose Sanctions and being fully advised in the premises;
It is HEREBY Ordered that Writ of Mandamus for Mandatory Injunction
/Issuance of a Supervisory Order Vacate Orders for “Fraud” Instanter
ENTERED:
_________________________________
Justice
_________________________________
Justice
_________________________________
Justice
Joe Louis Lawrence
________________________________
Attorney Pro Se
Justice
P.O. Box
490075
________________________________
Chicago,
Illinois 60649-0075 Justice
(312) 927-4210 _________________________________
Justice
_______________________________________________________________________
IN THE
SUPREME COURT OF ILLINOIS
________________________________________________________________________
)
Joe Louis Lawrence ) Appeal from the Circuit
) Court of Cook
County
Plaintiff-Appellant ) Chancery Division
) Case No.
09-2287
V. )____________________________________
)
Erwin McEwen, Dir. of DCFS ) Honorable
Et al
) William O Maki
Defendant- Appellee
) Appellate Judges Joy V.
Cunningham,
) Thomas E. Hoffman, Themis N.
Karnezis
) Michael J. Murphy, Sharon Johnson
C ) Coleman, John O. Steele, Patrick J.
Quinn
) No. 09-2287 2nd&
3rd Division
CERTIFICATE OF SERVICE
PETITION FOR WRIT OF
MANDAMUS
FOR MANDATORY INJUNCTION/ISSUANCE OF A
SUPERVISORY ORDER VACATING ORDERS AND ADMONISHING JUDGES for “FRAUD” AND
CONSPIRATORY CIVIL RIGHTS VIOLATIONS AND TO IMPOSE SANCTIONS
YOU ARE HEREBY NOTIFIED that APPELLANT
Appeals to the Illinois Supreme Court, for an Order on Petition for Writ of Mandamus for Mandatory Injunction/Issuance of a
Supervisory Order Vacating Orders & Rule to Show Cause for “Fraud” and To
Impose Sanctions. I Joe Louis Lawrence, Attorney Pro Se, hereby certify
that, I Have caused the following on said service list to receive the Petition
et al., and all of it’s attachments by depositing them in a Post Office via
regular mail, or hand delivery July 8, 2010 to the following:
Service List:
TO:
Asst. Atty.
Gen. Paul Racette
Chief Judge Timothy C. Evans
Civil Appeals
Bureau
Daley Center, Suite 2600
567 West Lake
Street
Chicago, Ill.
60661-1498
Justice Joy V.
Cunningham Clerk
of Circuit Court Dorothy Brown
160 North
LaSalle, Suite 1400
Daley Center, Suite 1000
Chicago, Ill.
60601
Justice Thomas E. Hoffman Justice Themeis N. Karnezis
160 North LaSalle, Suite 1400 160 North
LaSalle, Suite 1400
Chicago, Ill. 60601
Chicago, Ill. 60601
Justice Patrick J.
Quinn Justice
Michael J. Murphy
160 North LaSalle, Suite 1400 160
North LaSalle, Suite 1400
Chicago, Ill. 60601
Chicago, Ill. 60601
Justice Sharon Johnson Coleman Justice John
O. Steele
160 North LaSalle, Suite 1400 160
North LaSalle, Suite 1400
Chicago, Ill. 60601
Courtesy
Copies United
States Attorney
Robert R. Thomas, Chief Justice Patrick
Fitzgerald
1776 South Naperville Rd. 219
South Dearborn, Suite 500
Building A Suite 207
Chicago, Illinois 60604
Wheaton, Illinois
60189
Director
of FBI
Charles E. Freeman, Justice Robert
Grant/Agent Chatto
Ann M. Burke, Justice
2111 West Roosevelt Road
Thomas R. Fitzgerald, Justice Chicago,
Ill. 60612
Thomas L. Kilbribe,
Justice
Rita B. Garman, Justice
1819 4th Ave. 3607 North
Vermillon, Suite 1
Rock Island, Illinois
61201
Danville, Illinois 61832
Lloyd A. Karmeier, Justice
1100 Mills
P.O. Box 266
Nashville, Illinois
62263
Under penalties as provided by law pursuant to 735 1265 5/1
-109, the undersigned certifies that the statements set forth in this
instrument are true and correct, except as to matters therein stated to be on
information and belief and as to such matters, the undersigned certifies as
aforesaid that he verily believe the same to be true.
_________________________________
Joe Louis Lawrence, Pro Se
Name Joe
Louis Lawrence
Attorney for Pro Se
Notary
Address P.O. Box 490075
City, State Chicago, Illinois
60649-0075
Phone
(312) 927-4210
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