CORRUPTION EXPOSED UNDER MAYOR RAHM EMANUEL:
Honorable Franklin U.
Valderrama
2601 Richard J. Daley
Center
Chicago, Illinois 60602
Mar. 23, 2015
Case#
15 CH 01670
Room 2305
COURTESY COPY
A MUST READ
Honorable Judge Valderrama:
Please Find Plaintiff’s
MOTION MOVING FOR DEFAULT & SUMMARY JUDGMENT W/ AFFIDAVIT AND ORDER
Special Note: Please be advised the number of attorneys engaging
in criminal acts upholding Perjury and “fraud”.
Because
of the “Hue” of your skin these attorneys have lied to you turned your court
into a circus as if they have you intimidated they don’t respect you as a Judge
or a person because they are RACIST!!.
Because
certain attorneys with political clout with certain unnamed City Hall officials
have demonstrated “Above the Law”
antics and is quite “Brazen”
Because
many of the parties involved are not able to “Lynch” the Plaintiff with a physical rope “Lynching” is executed in an updated manner on an innocent man
simply for standing up to Racism, Racial Segregation and Racial Injustice in
Chicago and how many closed their eyes to the crimes because Black and Brown
lives don’t matter living in Chicago.
Because
your Honor is up for re appointment for the position of Associate Judge June of
this year maybe the reason why you are hesitant admonishing said attorneys.
If
the Illinois Supreme Court had a position of Judge Pro Se Plaintiff would be
able to fulfill the roles of jurisprudence with integrity before any ethnic
group corruption and racist personnel would settle before coming before me in
any case.
Court Call Mar. , 2015 @ 9:30 am
Let
this communication receive you and your family in good health
Respectfully
Submitted,
________________________
Joe
Louis Lawrence
Movant
Counsel
Pro Se
(312)
927-4210
CC.
Chief Judge Timothy Evans Courtesy
Copy U.S. Atty. Zachary T. Fardon, Judge Mary Mikva, Gordon & Rees,
Cary & Schiff & Assc., Seyfarth & Shaw, CHA, Maria Sewell Joseph, Gov.
Bruce Rauner, Mayor Rahm Emmanuel
---See Certificate of Service of other names.
Presiding Judge Moshe Jacobius, Asst. Gen Counsel, Sec. of State
Terrence McConville, City of Chg
Commission on Human Relations, States
Attorney, Anita Alvarez, Clerk of
Circuit Court Dorothy Brown
Robert
J. Holley, FBI Agent Chicago
Courtesy Copy
IN THE CIRCUIT COURT
OF
CHANCERY DIVISION
In Re Racial Discrimination/Source Income Violations
Housing Matters:
Joe Louis
Lawrence
Case
# 2015 CH 01670
Appellant
HON. F. U. Valderrama
Room 2305
V
420 East Ohio, Chicago Housing Authority
345 East Ohio, City of Chicago, Commission on Human
Relations, K2 Apartments
Respondents
MOTION MOVING FOR DEFAULT & SUMMARY
JUDGMENT W/AFFIDAVIT
Now comes Plaintiff, Joe Louis Lawrence, Counsel
Pro Se, in this cause respectfully represents to this Hon Court the reasons for
a Default & Summary Judgment and files herewith his Affidavit in support
for said Motion Moving for Default et al; Pursuant
to Supreme Court Rules & Civil Procedures.
Respectfully
Submitted,
Joe Louis Lawrence
Plaintiff
Counsel Pro Se
312
927-4210
joelouislaw@yahoo.com
Twitter @joelouis7
AFFIDAVIT
I Joe Louis Lawrence, being duly sworn on
oath states:
1.) CERTIFIED MAIL ISSUED January 30th 2015
2.) SUMMONS ISSUED AND RETURNED SERVED ON
ALL PARTIES
3.) NO DEFENDANT ANSWERED OR FILED AN
APPEARANCE or ANSWER ON OR BEFORE March 9th 2015
4.) That pursuant to 735 ILCS
5/3-101, et seq. 420 East Ohio, ZRS Management, Tracking #7014-0150-0001-5043-5130
was served via certified mail Feb. 6, 2015, 10:57 am, Attorney Anne D. Harris
admitted in open court Feb. 27, 2015 on Petition for Rule to Show Cause et al.
5.)
That pursuant to 735 ILCS 5/3-101, et seq. 345 East Ohio, Village Green
Management same sequence of numbers except for the last four numbers, #5154 was
served via certified mail Feb. 6, 2015, 1:18 pm; Frank Fiorentino.
6.)
That pursuant to 735 ILCS 5/3-101, et seq. City of Chicago, Commission
on Human Relations same sequence of
numbers except for the last four numbers, #5147 was served via certified mail
Feb. 5, 2015, 2:12 pm; Jeffery Wilson.
7.) That pursuant to 735 ILCS
5/3-101, et seq. Chicago Housing Authority
same sequence of numbers except for the last four numbers, #5123 was
served via certified mail Feb. 6, 2015, 12:35 pm; Armstrong C.
8.) Attorney T.B. King of CHA,
Christian Novay of 345 East Ohio perjured themselves before Hon Valderrama that
they were never served!
9.) Judge Valderrama accepted the
perjured testimony of the above and dismissed the Petition for Rule to Show
Cause because he had no jurisdiction, Feb. 27, 2015 all attorneys admitted not
filing an appearance;
10.) That on March 20, 2015 on an
Amended Petition for Rule to Show Cause et al. The City attorney, 345 East Ohio
and CHA again reiterated they were never served any documents;
11.)
Plaintiff handed the Judge (March 20, 2015) copies of services had on
all parties as they continuously denied being served:
That because the defendants/attorneys Induced Reliance on Judge
Valderrama committing Fraud causing him to sign court orders dismissing said
Petition for Rule to Show Cause et al makes both orders VOID, 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.
A.) Sheriff
#01712556 Served CHA via corporation 3-11-2015, 10:17am they served them copies
of the Amended Petition for Rule to Show Cause along with an Amended Request
for Review et al. Counsel never Objected or responded to the $25 Million Dollar
Demand;
B.) Sheriff
#01712558 Served Christian T. Novay 3-9-2015, 11:21am copies of the Amended
Petition for Rule to Show Cause et al along with an Amended Request for Review
et al. Counsel never Objected or responded to the $25 Million Dollar Demand.
C.)
Sheriff #01712557 Served Rahm Emanuel via corporation 3-12-2015, 10:00am
copies of the Amended Petition for Rule to Show Cause et al along with an
Amended Request for Review et al. Counsel never Objected or responded to the
$25 Million Dollar Demand.
D.)
Sheriff #01712560 Served Christopher R. Johnson personal service
3-12-2015, 10:20am, copies of the Amended Petition for Rule to Show Cause et al
along with an Amended Request for Review et al. Counsel never objected or
responded to the $25 Million Dollar Demand K2 has Defaulted twice on a $3
Million Dollar Default before the Human Relations Commission.
E.)
Sheriff #01722070 Served Seyfarth & Shaw via corporation 3-16-2015,
12:30pm copies of the Amended Petition for Rule to Show Cause et al. along with
the Amended Request for Review et al. Counsel never Objected or responded to
the $25 Million Dollar Demand.
12.)
That Defendants with vexatious Contempt for the laws did not request
leave of the court in which to file a late response and has Defaulted whereby
summary judgment is being sought on the claims presented before the court,
defendants have not raised any affirmative defenses or responded to any
documents filed before the courts due to its veracity.
Summary
judgment is appropriate when the pleadings, depositions, admissions and
affidavits, viewed in a light most favorable to the nonmovant, fail to
establish a genuine issue of material fact, thereby entitling the moving party
to judgment as a matter of law. 735 ILCS 5/2-1005; Progressive Universal Ins.
Co. v Liberty Mut. Fire Ins. Co., 215 Ill.2d 121, 127-28 (2005). The purpose of
summary judgment is not to try a question of fact, but simply to determine
whether one exists, Jackson v. TLC Assoc., Inc., 185 Ill. 2d 418, 423 (1998). A
trial court is required to construe the record against the moving party and may
only grant summary judgment if the record shows that the movant’s right to
relief is clear and free from doubt. Id. If disputes as to material facts exist
or if reasonable minds may differ with respect to the inferences drawn from the
evidence, summary judgment may not be granted.
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.
When the party
moving for summary judgment supplies evidentiary facts which, if not
contradicted, would entitle him to judgment, the opposing party cannot rely
upon his complaint or answer alone to raise issues of material fact. Smith v. St. Therese Hospital, 106 Ill. App. 3d 268, 270 (2d Dist. 1982). A counter
affidavit is necessary to refute evidentiary facts properly asserted by
affidavit supporting the motion or else the facts are deemed admitted. Barber-Colman Co. A And K Midwest Insulation
Co. 236 Ill. App. 3d 1065, 1078 (5th
Dist. 1992).
FURTHER AFFIANTH SAYETH NAUGHT
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 believes the same to be true.
Joe Louis Lawrence
Plaintiff/Counsel Pro Se
WHEREFORE the aforementioned
reasons Plaintiff respectfully Prays for the Relief
1.) For an Order Defaulting the Defendants Granting Summary Judgment Instanter;
That
because of the heinous acts Plaintiff have been harmed by said Civil Rights
Violations and no one objected to said assertions put before any tribunal, and
the number of City personnel and plethora of other conspirators making sure he
did move where he desired and numerous Civil Rights Violations, Plaintiff is
seeking Summary Judgment $25 Million Dollars as punitive damages; 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}”
2.) For the entry of an Order awarding to the Plaintiff for such other relief and any other
relief necessary as equity may require of which this court may deem
overwhelmingly just;
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 believes the same to be
true.
Respectfully Submitted
Joe Louis Lawrence
Plaintiff
Counsel Pro se
CERTIFICATE OF SERVICE
Commander & Chief Attorney General of United States
President Barack
Obama
Eric Holder
The White House U.S. Department of Justice
1600 Pennsylvania Avenue NW 950 Pennsylvania Avenue, NW
Washington, DC 20500 Washington, DC 20530-0001
1600 Pennsylvania Avenue NW 950 Pennsylvania Avenue, NW
Washington, DC 20500 Washington, DC 20530-0001
Chicago Housing
Authority Wilson Elser
Moskowitz Edelman & Dicker LLP
Office of the General Counsel Christian T. Novay
Asst Gen Counsel 55 West
Monroe, Street, Suite 3800
Maria Sewell Joseph Chicago, Il
60603
60 East Van Buren
Chicago, Ill 60605 Seyfarth & Shaw
Jeffrey K. Ross, Kyle A. Petersen & Anne Harris
131 S. Dearborn
Street, Suite 2400
Chicago, Ill. 60603
TO AAG Tyler
Roland Chief Judge Timothy Evans, Daley Center, Chg., Ill. 60601
General Law
Bureau Presiding Judge Jacobius, Daley Center, Chg. Ill. 60601
100 West
Randolph Street Suite 1300
Chicago, Ill.
60601 Clerk of Circuit Court Dorothy Brown, Suite 1001, Chg. Ill.
States Attorney, Anita Alvarez,
Daley Center, Chg. Ill. 60601
Atty Gen Lisa Madigan, 100 West
Randolph, Suite 1300 Chg. Ill. 60601
Sec of State
Asst Deputy Dir Candace Cheffin
Asst Gen Counsel
Terrence McConville 60 East Van
Buren, 8th floor
100 West Randolph, Suite 500 Chicago, Ill. 60601
Chicago, Ill. 60601
CHA Mobility
CHA Mobility, HCP Counselors
Chris Klepper, Executive Dir Tracey Robinson/Joann
Harris
28 East Jackson Blvd. 4859 S.
Wabash, Suite 2nd Floor
Chicago, Ill 60604
Chicago, Ill. 60615
CHA Mobility, Real
Estate Specialist Recorder
of Deeds
Jessie McDaniel Karen Yarbrough
4859 S. Wabash
118 N. Clark,
Room 120
Chicago, Ill. 60615 Chicago, Ill.
60602
City of Chicago,
Department of Buildings Sabre
Investments
Christopher
Lynch 120 West Madison Street
121 North LaSalle, Room 900 Chicago, Ill
60601
Chicago, Ill. 60601
Cary G. Schiff &
Associates
Yuleidy Joa Gordon & Rees LLP
Christopher R. Johnson Lindsay Watson,
Christian T. Novay
134 N. LaSalle Street, Suite 1720 1 North Franklin, Suite 800
Chicago, Ill. 60602 Chicago,
Illinois 60606
Courtesy Copies:
US Attorney FBI Robert J. Holley
Zachary T. Fardon 2111 West Roosevelt Road
219 S. Dearborn, 5th floor Chicago, Ill. 60612
Chicago, Ill. 60604
Governor
Bruce Rauner
100 West Randolph
Chicago, Ill. 60601
Mayor
Deputy Regional Adm., Field Office Dir.
Rahm Emanuel Beverly
E. Bishop
City Hall 77 West Jackson Boulevard
Chicago, Ill. 60601 Chicago, Ill.
60604
Cook County
President
Cook County Sheriff
Toni Preckwinkle
Thomas J. Dart
118 N. Clark, Room 517 Richard J. Daley
Center, Room 701
Chicago, Ill. 60602
Chicago, Ill. 60602
Hearing Officer CHA
Frederick Bates
60 East Van Buren, Suite 900
Chicago, Il 60605
PLEASE BE ADVISED that on March 23, 2015, A Motion Defaulting the Defendants with Summary Judgment has
been filed with the Circuit Court of Cook County and said copy have been
delivered or emailed to the applicable parties;
Respectfully Submitted
Joe Louis Lawrence Counsel Pro Se
PO Box 490075
Chicago,
Ill. 60649-0075
312 927-4210
@joelouis7
IN THE CIRCUIT COURT
OF
CHANCERY DIVISION
In Re Racial Discrimination/Source Income Violations
Housing Matters:
Joe Louis
Lawrence
Case # 2015 CH 01670
Appellant
HON. F. U. Valderrama
Room 2305
V
420 East Ohio, Chicago Housing Authority
345 East Ohio, City of Chicago, Commission on Human Relations,
K2 Apartments
Respondents
ORDER
This case is before the Court on the Plaintiff Joe Louis
Lawrence’s Motion for Summary Judgment against Defendants 420 East Ohio,
Chicago Housing Authority, 345 East Ohio, City of Chicago, Commission on Human
Relations pursuant to 735 ILCS 5/2-1005.
Plaintiff is a United States Citizen born and Raised a
Freeman and Plaintiff alleges that the Defendants have defaulted on their
obligation to respond to the summons or any motions accompanied by affidavits.
That said Request for Review et al and Petition for Rule to
Show Cause was filed to recover damages and bring to the courts attention the
“fraudulent” acts perpetrated by attorneys “sandbagging” the courts violating
individuals “Civil Rights” just to obtain an advantage before any judge, Defendants
have not raised any affirmative defenses or counterclaims.
Summary
judgment is appropriate when the pleadings, depositions, admissions and
affidavits, viewed in a light most favorable to the nonmovant, fail to establish
a genuine issue of material fact, thereby entitling the moving party to
judgment as a matter of law. 735 ILCS 5/2-1005; Progressive Universal Ins. Co.
v Liberty Mut. Fire Ins. Co., 215 Ill.2d 121, 127-28 (2005). The purpose of
summary judgment is not to try a question of fact, but simply to determine
whether one exists, Jackson v. TLC Assoc., Inc., 185 Ill. 2d 418, 423 (1998).
A trial court
is required to construe the record against the moving party and may only grant
summary judgment if the record shows that the movant’s right to relief is clear
and free from doubt. Id. If disputes as to material facts exist or if
reasonable minds may differ with respect to the inferences drawn from the
evidence, summary judgment may not be granted. Assoc. Underwriters of Am.
Agency, Inc. v. McCarthy, 356 Ill. App. 3d 1010, 1016-17 (1st Dist.
2005).
When the party
moving for summary judgment supplies evidentiary facts which, if not
contradicted, would entitle him to judgment, the opposing party cannot rely upon
his complaint or answer alone to raise issues of material fact. Smith v. St. Therese Hospital, 106 Ill. App. 3d 268, 270 (2d Dist. 1982). A counter
affidavit is necessary to refute evidentiary facts properly asserted by
affidavit supporting the motion or else the facts are deemed admitted. Barber-Colman Co. A And K Midwest Insulation
Co. 236 Ill. App. 3d 1065, 1078 (5th
Dist. 1992).
Here, Plaintiff
has supplied Affidavits and other evidentiary material that establishes all of
the elements necessary to entitle it to recovery under the parties’ agreements,
including the amount of damages. Defendants have failed to submit any evidence
in opposition to the Motion in order to raise any genuine issues of material
fact. Thus, summary judgment is proper.
Based on the
foregoing, it is hereby ORDERED:
1.) Plaintiff’ Joe Louis Lawrence’s Motion for
Summary Judgment is GRANTED.
Judgment
is entered in favor of Plaintiff and against Defendants 420 East Ohio, Chicago
Housing Authority, 345 East Ohio, City of Chicago, Commission on Human
Relations severally and jointly of $25 Million Dollars Pursuant to Smith V. Wade, 461 U.S. 30,
35. 103 S. Ct. 1625, 1629 75 L Ed 2d 632 (1983) that because of the noted
depraved acts of all parties pay punitive damages, of $25 Million Dollars
Plaintiff has endured in these matters;
2.)
For an Order Recommending a Special Prosecutor
outside of States Attorney Anita Alvarez, Attorney General Lisa Madigan’s
jurisdiction due to the political influence involved and them ignoring the
criminal acts perpetrated by “Powerful” White Men in authority;
3.)
For an Order REVERSING the Commission’s order for
failing to follow Supreme Court rules and procedures;
4.)
For an Order Imposing Sanctions Fining CHA and all
attorneys and law firms $20,000.00 - $30, 000.00 a day to the City of Chicago
until Appellant is expeditiously housed;
5.)
Prohibit
any Attorney from delaying prosecution of this matter with frivolous
continuances due to Appellant and family suffering behind said acts;
6.)
For an Order Remanding every Party and
attorneys disbarring them complicit in said Criminal acts ignoring and
covering-up said unlawful acts of all parties;
7.)
For an Order Compelling all Parties to appear before a Court or Grand
Jury to determine who should be INDICTED
for their part in said Conspiracy;
8.)
For an Order
Appointing an Independent Examiner
to ascertain all persons removed from the CHA section 8 program in the last 4
years where the City of Chicago, Human Relations Commission and Hearing
Officers under CHA’s authority dismissed their complaints unlawfully;
_____________________________
ENTERED
____________________________
JUDGE 
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