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Saturday, April 28, 2012

HOW THE POLITICAL MACHINE (CORRUPT RACIST WHITE MEN"MIGHTY IN POWER") USES THE LAWS AND THE BLACK WOMAN TO KEEP THE BLACK BROWN MAN OPPRESSED USING WELFARE AND CHILD-SUPPORT AS CONTROLLING THIS PARTICULAR CASE THE USED THE DEPARTMENT OF CHILDREN & FAMILY SERVICES (D.C.F.S.)

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),

(30Jennings 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 1866of 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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