JUDGE VALDERRAMA HAD TO #TRESPASS UPON THE LAWS VIOLATED HIS OATH AS A JUDGE AND BECAME A PRIVATE CITIZEN "FIXING" THIS CASE COMMITTING TREASON IN AN ATTEMPT TO PROTECT THE MEMBERS OF THE POLITICAL DEMOCRATIC MACHINE.
BULLYING DONE THE LEGAL WAY AS 12 ATTORNEYS, CITY ATTORNEYS STEPHEN R. PATTON, CORPORATION COUNSEL CITY OF CHICAGO, REY A. PHILLIPS SANTOS, ASSISTANT CORPORATION COUNSEL CITY OF CHICAGO, CHICAGO HOUSING AUTHORITY OFFICE OF THE GENERAL COUNSEL, ASSISTANT GENERAL COUNSEL MARIA SEWELL JOSEPH AND TOM B. KING, FORTUNE 500 INTERNATIONAL LAW FIRM, SEYFARTH & SHAW, ANNE D. HARRIS, KYLE A. PETERSEN AND JEFFREY K. ROSS, FORMER ASSISTANT DISTRICT ATTORNEY FROM NEW YORK, CHRISTIAN NOVAY WHO WAS FORMERLY WITH THE LAW FIRM WILSON ELSER MOSKOWITZ EDELMAN & DICKER LLP NOW WITH GORDON & REES, LLP WITH LINDSAY WATSON, CARY G. SCHIFF & ASSOCIATES, CHRISTOPHER R. JOHNSON, YULEIDA JOY
Cary G. Schiff is a regular speaker and author on the subject of Property Management Law and those issues that are ancillary to property management practice, such as landlord rights and eviction practices. Cary G. Schiff & Associates is one of the largest firms in Illinois as measured by volume of Forcible Entry and Detainer Actions filed. Over the last twenty years, the firm has initiated and prosecuted some of Greater Chicago’s most publicized and controversial eviction battles with a heavy focus on preserving landlord rights.
THERE WAS A TIME WHEN WHITE MEN WERE COVERED WITH WHITE SHEETS OVER THEIR FACES CONCEALING THEIR IDENTITIES AS THEY "LYNCHED" INNOCENT MEN OF COLOR."LYNCHING" IS DONE DIFFERENTLY AS IN THIS CASE!
________________________________________________________________________
IN THE
CIRCUIT COURT
OF
COOK
COUNTY, ILLNOIS
CHANCERY
DIVISION
)
In Re Racial Discrimination ) 2015 CH 01670
/Source Income Violations )
Housing Matters:
) Hon. F. U. Valderrama
Joe Louis Lawrence ) Room 2305
Plaintiff )
)
V
)
420 East Ohio, Chicago Housing Authority )
345 East Ohio, City of Chicago,Commission)
On Human
Relations
)
Defendants )
________________________________________________________________________
MOTON
FOR RECONSIDERATION VACATE MARCH 30, 2015 DEFAULT ORDER DUE TO “ERROR” w/AFFIDAVIT
Now comes Petitioner, Joe Louis Lawrence,
Attorney Pro Se, in this cause respectfully represents to this court the
reasons and files herewith his Affidavit in support for said Motion for
Reconsideration Vacate Order due to “Error” with Affidavit, pursuant to Supreme Court Rules and
Illinois Rules of Civil Procedure , 3D (2) Reporting Lawyer Misconduct
Respectfully
Submitted,
Joe Louis Lawrence
Petitioner
312 927-4210
joelouislaw@yahoo.com
Twitter @joelouis7
AFFIDAVIT
I Joe Louis Lawrence, being duly sworn on
oath states:
1.)
That
Judge Franklin Ulysses Valderrama erred in the application of the laws, and the
attorneys representing the Defendants did not exhaust due-diligence in
requesting from the court an extension of time in which to respond or leave of
the court in which to answer.
A- 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.;
B-
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.
C- 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.
2.) Pursuant to court
transcript presented at hearing before Honorable Neil H. Cohen Friday April 17,
2015 referenced as Group Exhibit A, Page 4 line 23-24, Page 5 1-6 Judge Valderamma stated “No. The clerk’s office doesn’t serve anybody by certified mail. Let me back up.” “When I say service, I don’t mean mailing anything. When I say service
I mean providing a copy of the complaint and summons on the entity that you
have named in your complaint, 420 East Ohio, the housing authority, 345 East
Ohio, and it looks like the City of Chicago and Commission on Human Relations”.
A- It was at this
Hearing where Judge Cohen shared words of Wisdom in his deliberation, he
expressed empathy and transparency as he apologized for the Racial Injustice
Plaintiff endured as 21 judges in the County presided over a Bogus paternity
matter where he lost his job in the Cook County Sheriff Department, wasn’t
reinstated back to the CTA and had him locked up five times for allegedly owing
child support to a woman who never had any children for him.
B- Because the man was
a Police Officer with incredible connections to City Hall he was never charged
with impregnating his minor daughters but was arrested for impregnating one of
his daughters but was reinstated back to the police department, Richard Daley
was the former States Attorney didn’t want any part of the mess DISMISSED the
paternity suit September 17, 1987 which is the only time there were paternity
tests which were in fact altered but demonstrated exclusion of paternity.
C- Because Judge
Valderrama may have made errors in the laws don’t make him a racist but the
judge was clear on the mindset of the Plaintiff as he testified to the many
denials he has experienced in the courts; For
the Record: because Judge Valderrama expressed in his own words, Page 4, Line 23, 24 “The
clerk’s office doesn’t serve anybody certified mail.” Because he was not aware that the Clerk of
the Circuit Court do in fact issue summons in certified mail in Administrative
cases, Plaintiff apologizes for filing the aforementioned Motion for
Disqualification et al against judge Valderrama for Racial implications.
Pursuant to Vigus v. O’Bannon
D- Petitioner Appealed to the Appellate
Court where Honorable Rodolfo Garcia, Thomas Hoffman, John Owen Steele, Patrick
J. Quinn former Governor Pat Quinn’s brother, Themesis Karnezis, Mary K.
Rochford, Warren D. Wolfson who is related to Loretta Higgins- Wolfson, Mathias
W. Delort, Bertina Lampkin, Sebastian Patti, Shelvin Louise Marie Hall, Joy
Cunningham, Mary Jane Theis, who had a father convicted in the Greylord sting
as a judge, Michael Murphy all were complicit in covering-up criminal Civil
Rights violations of a “Bogus” paternity case 88 D 079012, said judges ignored
every unchallenged affidavit issued orders outside of their provisions of
judicial immunity;
3.)
Pursuant to 735 ILCS 5/3-105 quote “service of summons, summons issued in
any action to review the final administrative decision of any administrative
agency shall be served by registered or certified mail on the administrative
agency and on each of the other defendants except in the case of a review of a final administrative decision of
the regional board of school trustees, regional superintendent of schools, or
state superintendent of education et al”.
4.) Service on the administrative agency shall be made by
the clerk of the court by sending a copy of the summons addressed to the agency
at its main office in the state. The clerk of the court shall also mail
a copy of the summons to each of the other defendants, addressed to the last
known place of residence or principal place of business of each defendant.
5.) That a decision is
considered served which requires that every action to review a final
administrative decision shall be commenced by defiling of a complaint and the
issuance of summons within 35 days from the date that a copy of the decision
sought to be reviewed was served upon the party affected by the decision when
it is deposited in the U.S. mail. Nudell vs. Forest Preserve dist. Of Cook
County, App. 1 Dist. 2002, 267 Ill. Dec. 343, 333 Ill. App. 3d 518, 776 N. E.
2d 715, appeal allowed 272 Ill. Dec. 343, 202 Ill. 2d 614, 787 N. E. 2d 158.
6.) For purposes of
statute provided that action to review final administrative decision shall be
commenced by filing of complaint within 35 days from date copy of decision was
served upon party, decision is considered served when it is deposited in the
U.S. mail. Lutheran General healthcare system vs. Department of Revenue, App. 1 Dist.
1992, 172 Ill. Dec. 544, 231 Ill. App. 3d 652, 595 N. E. 1214, appealed denied
176 Ill. Dec. 802, 146 Ill. 2d 631, 602 N. E. 2d 456.
7.) That Line 7-14, Page 5, Plaintiff informed
the court, “No, sir, I didn’t do that. I
followed the rules of what the clerk had me to do downstairs. Filled out the
green card for the certified mail. And I have that information here in the
affidavit. I did not have the sheriff to in fact serve none of the parties in
that normal manner. I only followed the procedures of what they told me to do
down there”.
A- Furthermore, in
referenced to the aforementioned, Page 8,
Lines 1-5, Judge stated, “So if I understand you correctly, you are
not quite saying but maybe implicitly what you are saying is you may have
received some bad information from the clerk’s office is what I’m really
hearing”
8.) That the Clerk of
the Circuit Court certified a computer printout, Ref as Gr Ex B, validating the
veracity of the CHA, 345 East Ohio, 420 East Ohio and City of Chicago,
Department of Human Relations;
A- 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.
B- 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., Hereto attached, Gr Ex C;
C- 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, Hereto attached,
Gr Ex E;
D-
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, Hereto attached, Gr Ex D;
E-
That
pursuant to the Cook County Sheriff effecting service on the Defendants, Hereto
attached, Gr Ex F, CHA, 345 East Ohio, Comm. On Human Relations, City of
Chicago, k2, 420 East Ohio Amended Petition for Rule to Show Cause,
Amended Request for Review et al;
F-
For the Record: K2 Defaulted in the Commission like
the Defendants did in Circuit Court but a person acting in a Fraudulent
capacity was mailing court orders without signatures was seeking their response
where motions for Default and objections were in fact filed timely and never
responded to seeking $3 Million Dollars in damages.
G-
For the Record: This is a case about Racial
Discrimination in Housing where allegedly whites are allowed to use vouchers to
live in what is described as opportunity areas and make over $70,000.00 but
because of Plaintiff’s skin color and allegedly he did not have a sponsor and
did not purchase his voucher was prohibited from moving in any of these
buildings despite having credit scores of 716, CHA has exhausted all types of
political muscle and intimidation at the Plaintiff because he refused to move
to Englewood or Auburn Gresham with his 3 bedroom voucher.
9.) Judge Valderrama asked Anne Harris of 420 East
Ohio, Page 8, Lines 18-24, “Defendant 420
what do you want to do? Ms. Harris, “Your
Honor, I would ask for an oral request to dismiss whatever has been filed.
Quite frankly what has been filed is gibberish in terms of the petition for
Rule to Show Cause which quite frankly I don’t understand, but as well as that request for review, I mean we simply can’t answer
it, and you know so I would make an oral motion to dismiss”
A- Judge Valderrama,
stated, “Page 10 Lines 11-16, “I, admittedly, could not quite follow what
it is that you were getting at. So to the extent that counsel for East Ohio is
arguing that she cannot respond to it because she doesn’t quite know what it is
that you are getting at, I agree with that as I read it”
B- Furthermore, Lines 19-23, Judge stated, “Unless I am mistaken, and feel free to let
me know that I am wrong, you did not cite an order that had been previously
entered by a court that had been violated. Am I correct?
C-
Plaintiff responded,
Page 10, Line 24, Page 11, Lines 1-8
“No sir, you are incorrect. There were
two orders without signatures. And without signatures or a stamped seal
validating the veracity pursuant to Supreme
Court Rule 272, that is the basis of why this matter is brought before
this court. And I had challenged the validity of that with the commission. No
one signed any orders. As a matter of fact, they sent me an order with the
wrong date and wrong year”
D- Like
the Bogus paternity case absent court signatures which ruined Plaintiff’s life
and his children, now in 2015 the same example of “FRAUD” is presented and the
judge didn’t understand his jurisdiction in this matter,
E- Hereto attached, Gr Ex K, Investigative Order demonstrates a Prima Facie showing
of Directed Evidence of “Fraud” where Reliance has been Induced on all parties
associated in these matters.
10.) Hereto attached, Gr Ex H, I lacking jurisdiction of authority causing it to be Void,
Judge Valderrama acknowledged receiving orders, Page 12, Lines 10-13, “Thank
you. I do have---- I have seen this, this order denying request for review. And
I have read it. Thank you, I am not sure how that ties in though. I’ve read
that document”
11.) That Hon. Neil H. Cohen articulated an
understanding of what Plaintiff was saying in his pleadings, Judge Mikva
understood what Plaintiff was saying in his pleadings when the Secretary of
State was seeking to suspend his drivers license, she stood above the fray and
ruled according to the laws in the Plaintiff’s favor.
The Miseducation of the Negroe Political
Education Neglected
Carter
G. Woodson, 1933
The opponents of freedom and social
injustice 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 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.
D- Court order of
September 17, 1987, case #85 D 068184 properly signed and dismissed by former
Mayor Richard J. Daley, States Attorney, Hereto attached, Ex L;
E- Plaintiff has never
been served via personally or by publication in the 88 D 079012 case and never
were there any paternity tests.
F- That every Judge
affiliated with the Democratic Political Machine never at any time read Plaintiff’s
affidavit demonstrating case# 88 D 079012 was not only a Bogus case but was
absent a judges signature and attorney information, -Illinois Supreme Court
Rule That 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!
G- That
every judge issued rulings against the manifest weight of the evidence
primarily because of what Plaintiff felt was due to his skin color but because
the case is in fact “FRAUDULENT” makes every court order a “VOID JUDGMENT” in the paternity case.
H- That
Appellant has filed an Emergency Petition for Rule to Show Cause et al. before
the City of Chicago, Commission on Human Relations, Dec. 18, 2013, Chicago
Housing Authority via assistant General Counsel (Maria Joseph Sewell) did not
deny any of the charges of discrimination and source income violations, 420
East Ohio hired a top international law firm Seyfarth & Shaw (Jeffrey K.
Ross, Kyle A. Petersen, Anne D. Harris) as they subordinated perjury and fraud,
Wilson, Elser, Moskowitz, Edelman & Dicker LLP, (Christian T.Novay) former
District attorney from NewYork , who made a slew of misrepresentations of the
facts in an attempt to finagle themselves from the admissions and
corroborations of CHA’s responses;
12.)
Pursuant
to Vigus v. O’Bannon, that
Judge Leonard Murray aided and assisted Craig Fulton and other Section 8 Officials
in an elaborate criminal conspiracy stealing from Federal Government and Plaintiff’s
ordered the Cook County Sheriff to break into home which was an abandoned
building Section 8 placed Plaintiff and his family in.
A-
Plaintiff
complied with the Police Desk Sargent directive of informing the court of
Police Report being filed via Motion (June 12, 2013);
B-
That
Craig Fulton was in fact properly served via certified mail with his signature
recorded but the court never invoked jurisdiction on him nor did they find him
frivolous;
C-
Craig
Fulton never owned the property never objected to any of the legal documents put
before any courts Judges ignored the fact none of them had jurisdiction
and Court order signed in favor of Petitioner VACATING ORDER OF POSSESION
was never vacated;
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).”
Conspirators
to be guilty of offense need not have entered into conspiracy at same time or
have taken part in all its actions.
People
V. Hardison, 1985, 911 Dec. 162, 108. Requisite mens rea elements of
conspiracy are satisfied upon showings of agreement of offense with intent that
offense be committed; Actus reas element is satisfied of act in furtherance of
agreement People V. Mordick, 1981, 50 ILL, Dec. 63
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.
13.)
In Plaintiff’s cases it appears justice lies
within the judge who beholds the law and not in accordance to laws of the
United States Constitution and depending on the mood of the court is how
justice or a decision is rendered.
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.
Pursuant to Vigus v. O’bannon
14.)
That
Craig Fulton with vexatious “Contempt”
for the laws never owned the property, in that
A-
Recorder of Deeds have him purchasing the property July
27, 2006- Sept. 14, 2006 from Brandon C. Davis, Derrick Davis for $105,000.00;
B-
Recorder of Deeds have Craig Fulton, listing U.S. Bank
as the bank who has the MORTGAGE, account #0625740137;
C-
That US Bank was notified and informed said numbers
were invalid, Craig Fulton did not have any Mortgage with them or any
accounts;
D-
Tax bills (Pin Index 25-10-401-037-0000) being sent to
163 Raye Drive, Chicago, Heights, Illinois 60411;
E-
That when Defendant moved into the home for almost a
year and a half States Attorney investigators were trying to apprehend Brandon
Davis under the authority of states Attorney Anita Alvarez, he allegedly
carjacked someone;
F-
Cook County Treasury, stated the property owner has not
payed taxes on said property since 2009, 2010, and 2011 and the County sold the
taxes to SABRE INVESTMENTS, 120 West Madison, Chicago, Ill. 60601;
G-
Craig Fulton has alleged incredible “Shady” “”Fraudulent” City Hall et al.,
connections never paid the water bill of 10058 South Vernon for 4 years it is
still in the DECEASED person’s (Linda Davis, mother of named subjects in
question) name service was never disconnected, but Respondent’s gas service is
disconnected light bill pending disconnection neither bill is near the
thousands of dollars owed to the City;
H- Craig
Fulton successfully master minded receiving FEDERAL SECTION 8 MONIES with incredible support with these noted
unlawful documents, said judges have selectively ignored in attempt to uphold
and protect other conspirators involved in said HOUSING SCAM DEFRAUDING the FEDERAL
GOVERNMENT out of what appears to be a MULTI-MILLION
DOLLAR OPERATION involving numerous Public Officials;
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.
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 SCt. 819, 537
U.S. 270, 154 L.Ed.2d 744, on remand 371F.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.
CONSPIRACY
Fraud maybe
inferred from nature of acts complained of, individual and collective interest
of alleged conspirators, situation, intimacy, and relation of parties at time
of commission of acts, and generally all circumstances preceding and attending
culmination of claimed conspiracy Illinois Rockford Corp. V. Kulp, 1968, 242
N.E. 2d 228, 41 ILL. 2d 215.
7.
The Chicago Daily
Law Bulletin, Wednesday April 26, 2006, Page
1, Illinois Political Machines help breed corruption, Associated Press
writer Deanna Bellandi states, “Illinois
is apparently a Petri dish for corruption. It is a real breeding ground”.
That Chicago is the
most Corrupt City in America, Huffington Post, Internet
Newspaper, February 23, 2012; University of Illinois Professor Dick Simpson, “The two worst crime zones in Illinois are
the governor’s mansion…..and the City Council Chambers in Chicago.” Simpson a
former Chicago Alderman told the AP “no other State can match us.”
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 Movant respectfully Prays for the Relief
1.) For an Order Vacating the March 30,
2015 Court Order Instanter;
2.) For an Order Vacating the March 30, 2015 Default Order and Summary judgment
due to Error.
3.) For an Order summoning Federal Authorities to ascertain the criminal
allegations noted in affidavits to determine what prosecutorial remedies are
afforded Instanter:
4.) For the entry of an Order awarding to your Plaintiff for
such other relief and any other relief necessary as equity may require of which
this court may deem overwhelmingly just;
Respectfully
Submitted
Joe
Louis Lawrence
Plaintiff
Counsel Pro se
________________________________________________________________________
IN THE
CIRCUIT COURT
OF
COOK
COUNTY, ILLNOIS
CHANCERY
DIVISION
)
In Re Racial Discrimination ) 2015 CH 01670
/Source Income Violations )
Housing Matters:
) Hon. F. U. Valderrama
Joe Louis Lawrence ) Room 2305
Petitioner )
)
V
)
420 East Ohio, Chicago Housing Authority )
345 East Ohio, City of Chicago,Commission)
On Human
Relations
)
Respondents )
________________________________________________________________________
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
Chief Judge Timothy Evans Judge Moshe Jacobius
50 West
Washington, Suite 2600
50 West Washington, Suite 2403
Chicago,
Illinois 60601
Chicago, Ill. 60601
Judge
Mary Lane Mikva Clerk of Circuit Court, Dorothy Brown
50 West
Washington, Suite 50 West Washington, Suite 1000
Chicago, Ill
60601
Chicago, Ill. 60601
Atty. Gen, Lisa Madigan Asst. Atty. Gen
Tyler Roland
100 West
Randolph, Suite 1200 100 West Randolph, Suite 1200
Chicago, Ill.
60601
Chicago, 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 Gordon & Rees LLP
Christopher R. Johnson, Yuleida Joy Lindsay Watson, Christian T. Novay
134 N. LaSalle Street, Suite 1720 1 North Franklin, Suite 800
Chicago, Ill. 60602 Chicago,
Illinois 60606
Jessica Mallon, Gen Counsel CHA Roy Martinez Manager 420 East Ohio
60 East Van
Buren 420 East Ohio
Chicago, Ill
60601
Chicago, Ill. 60611
Eve Aywaz,
Sales Consultant Sarah
Aredia, Leasing Consultant
345 East
Ohio 420
East Ohio
Chicago, Ill.
60611
Chicago, Ill. 60611
John-Paul
Loseto, Executive Manager
345 East Ohio
Chicago, Ill.
60611
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
Hon Judge Neil Cohen
50 West
Washington, Suite 2308
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
Governor Hon Mark Kirk
525 South 8th St. 607 East
Adams, Suite 1520
Springfield, Ill. 62703 Springfield, Ill. 62701
Bruce Rauner
100 West Randolph
Chicago, Ill. 60601
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
Chicago Housing Authority Seyfarth & Shaw
Office of the General Counsel Jeffrey K. Ross, Kyle A. Petersen, Anne D.
Harris
Asst. Gen
Counsel, Maria Sewell Joseph 131 South
Dearborn Street, Suite 2400
60 East Van
Buren
Chicago, Ill 60603
Chicago, Ill.
60605
Wilson Elser Moskowitz Edelman &
Dicker LLP
Christian Novay
55 West Monroe,
Street, Suite 3800
Chicago, Ill.
60603
Hon Dick Durbin Hearing
Officer CHA
525 South 8th St.
Frederick Bates
Springfield, Ill. 62703 60 East Van Buren, Suite 900
Chicago, Ill. 60605
CERTIFICATE OF
SERVICE
The undersigned hereby certifies that the above notice and
all attachments were caused to be personally delivered, emailed or via
facsimile or deposited in the U.S. mail to the above parties at the addresses
provided before 5:00 pm on April 21, 2015.
________________________
Joe Louis
Lawrence
Plaintiff/Counsel
Pro Se
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