THIS IS A CLEAR CASE OF JIM CROW BEING EXERCISED IN THE COURTS PEOPLE OF COLOR AND LIBERAL WHITES WHO OPPOSES RACIAL INJUSTICE ARE BEING VICTIMIZED THE SAME LEVEL OF OPPRESSIVE TERRORISM WHO OPPOSES THE CORRUPT WHITE MEN IN POWER.
THE WORSE INSULT IS THAT A NEGROE JUDGE STATED THAT THE ISSUES PRESENTED WERE IN FACT FACTUAL AND THAT, I COULD NOT HAVE MADE IT THIS FAR WITHOUT THEM THE CITY IS NOT ARGUING YOUR FACTS!!!
Pursuant to the following statement from a legal brief “The
promise of equality has been the cornerstone of the American government, from
the Declaration of Independence’s pronouncement that “all men are created
equal”, to President Abraham Lincoln’s restatement of the promise in his
Gettysburg Address, to the ultimate incorporation of the right to equal
protection of the laws in the United States and Illinois Constitutions.
President Barack Obama recently invoked this promise of
equality when he stated, “Every single
American –gay, straight, lesbian, bisexual, transgender—every single American
deserves to be treated equally in the eyes of the law and the eyes of our
society”. It’s a simple proposition. “Barack Obama, Remarks by the
President of the United States at the Human Rights campaign’s Annual National
Dinner (Oct. 1, 2011) http://www.whitehouse.gov/thepress-office/2011/10/01/remarks-president-human-rights-campaigns-annual-national-dinner.
IN CHICAGO RACIST WHITE MEN CONTROLLING AND INFILTRATING THE DEMOCRATIC PARTY HATE PEOPLE OUTSIDE THEIR ETHNICITY AND ONLY RECRUIT AND APPOINT PEOPLE OF COLOR OR OTHERWISE WHO WILL TAKE PART IN DOMESTIC TERRORISM PROTECTING THEIR IDENTITIES.
_______________________________________________________
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 K2
Apt )
Respondents )
________________________________________________________________________
PETITION FOR RULE TO SHOW CAUSE DUE TO CORROBBORATION of FRAUD PERJURY
CIVIL RIGHTS VIOLATIONS VACATE NOV 2, ORDER REMAND/BODY
ATTACHMENT INSTANTER
IMPOSE SANCTIONS
w/AFFIDAVIT
Now comes Petitioner, Joe Louis Lawrence, Counsel
Pro Se, in this cause respectfully represents to this court the reasons and
files herewith his Affidavit in support for said Petition for Rule to Show
Cause for Willful Misrepresentations to Court et al… Remand/Body Attachment
Instanter Impose Sanctions, pursuant to
the Ku Klux Klan Act of 1871, Section
1983 of U.S.C.S., S.H.A. Criminal Ch. 38, 33-3, Civil Rights Act of 1964, 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 pursuant to Supreme Court Rule 272 and Violation of Supreme Court Rule 137 the following orders entered by the
Defendant City of Chicago, Commission on Human Relations and Judge Valderrama
is deemed VOID, due to no signature or certification and FRAUD, Adoption
of E.L., .. “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”.
248
Ill. Dec. 171, 733 N.E. 2d 846, 315 Ill. App. 3d 137- Judgm 7, 16, 375, Amended Request for Review et al
(March 2, 2015); Petitioner having complied with the courts directive in
amending the complaint because it was without the orders from the Commission
but was attached with the Petition for Rule to Show Cause et al.
2.) That because the Respondents are
experts violating and undermining the laws engaging in Diabolical Terrorist
Acts violating Petitioners Civil Rights have thereby reopened every motion
denied by the Judge mainly, motion Objecting any Dismissal due to Fraud and
Alleged Murder of his brother (Timothy D. Lawrence) et al., That even as the
attorneys Lied in court nobody ever submitted a counter-affidavit attesting to
their own fraudulent admissions made in court pursuant to all rules of Civil
Procedures because they didn’t fear the judges authority or directives because
of his skin color no man of color have any authority over white men, that is
why many of them in authority who have read the atrocities perpetrated at the
Petitioner closed their eyes and turned their backs on him seeking help;
3.) That because so many closed their
eyes to the Petitioners plight due to his skin color said Terrorist have taken
their acts to another level judges are now being threatened Cook County judges
sent threats: 'You're on a kill...
http://unlawful1.blogspot.com/2015/11/cook-county-judges-sent-threats-youre.html?spref=tw
A-
Petitioners
brother a city employee with a great record no drug or related issues of abuse
was shot in the head and allegedly other parts of the body but was set on fire
so as to conceal his identity but the murders don’t know is that they were
under surveillance captured everything but no one is in custody;
4.) That pursuant to 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., the attorneys for the
Defendants satisfied this requirement by committing PERJURY and engaging in a
plethora of other Terrorists Acts when they informed the court they were never
served, See Gr. Ex I, J, K, and L; of
the Motion for Disqualification et al. (filed April 2, 2015)
5.)
That
because Defendant City of Chicago, Commission on Human Relations has
demonstrated beyond the Preponderance of Standards as participants in said
conspiracy upholding criminal terrorists acts, K2 Apartments have legally
defaulted on responding to the complaint and charges and has DEFAULTED, Appellant in his
Default prayer for relief sought $3 Million dollars no one objected or
responded;
6.)
That
on November 2, 2015 Line 8 on the 10:00am call, Judge Varderrama
acknowledged receiving Plaintiff’s complaint from someone else but did not
receive the city’s response only after city attorney Philip Santos attempted to
tender a white envelope to the judge;
7.)
The
judge asked counsel Santos where was 420 and CHA? His reply was that this was
only a clerk status appearance, the judge looked stun at counsel’s reply told
him we are having the hearing today;
8.) Counsel stated “that plaintiff had not plead in any areas by the Commission or any
cause of action or facts that would support the complaint”
9.)
Plaintiff
respectfully objected and referred the court to Ex D, E (Orders purportedly from the Commission, Pursuant to
Supreme Court Rule 272 both order were absent a signature which is the basis
how this matter ended up in Circuit Court because this is fraud; furthermore, Ex I, CHA Tenancy Approval Packet #4 Determining the rent CHA will call the
owner with a rent offer based on other comparable unassisted units within 1
year, within 1 mile et al.,
A-
Plaintiff
informed the court that white families were living in the units using their
Section 8 vouchers but because of my skin color CHA and building managers had
someone to hack into my credit report unbeknown to them, I have fraud alert
which lets me know when someone is tampering with my credit, see Ex L someone went into my credit report
45 times and deleted all of my good scores and added negative entries making
sure, I did not get into the buildings and putting child support on there that,
I don’t owe, when in fact, I was qualified to move into the particular
buildings but because of my skin color, I was discriminated against; moreover, Ex J Crain’s business report
talks about poor families using super vouchers to rent when in fact the very
buildings that are subject of the complaint accepted white families but denied
me this is a fact, Judge Valderramma stated,
“that I have facts that is clear, you would have not made it this far without
them” this is not an evidentiary
hearing the city is not arguing your facts that is another matter”
B-
The
Judge asked Counsel to respond, Santos stated, that the Supreme Court Rule 272 does not apply to the city it is
governed under a different municipality, and they are not required to his
understanding to have a signature” the judge looked at him in shock asked
him if there is a page missing with a signature his reply, “he did not know” Plaintiff interjected
“no your honor that is everything which is why and how this matter got before
this court”;
C-
The
Judge granted the City’s Motion to Dismiss told the Plaintiff to “re plead his case explain how the
Commission discriminated or committed fraud so that they can respond”
10.)
That
said attorneys and all participants have
satisfied the legal standard of the preponderance of the evidence taking part
in an “Organized Conspiracy” engaging
in Terrorist activities likened to the Ku Klux Klan fraternal order;
11.)
That
pursuant to CCHR Reg.
Rule 240.349
of the City of Chicago Human Relations Commission Motions, Objections, and Orders (a)
Pre-Hearing and Post-Hearing Motions Unless otherwise specified in these
regulations or ordered by the hearing officer, all pre-hearing and post-hearing
motions must be in writing and must be filed with the Commission and served on
all other parties and the hearing officer.
(d) Hearing
Officer Orders All pre-hearing and post-hearing orders shall be issued by the
hearing officer in writing. Oral motions or objections may be heard at a
pre-hearing conference if the hearing officer either
(1) Requires
the party to file and serve the motion or objection in writing before issuing a
decision or
(2) Issues a
written order after the pre-hearing conference which describes the motion or
objection and sets forth the decision.
12.)
FACTS That because the City of Chicago
attorneys Stephen R. Patton, Rey A. Phillips Santos, CHA Attorney T. B. King,
Christian Novay et al have been able to Induce Reliance on the court claiming
not to have been served and the court having excepted their oral testimony
instead of ascertaining veracity makes the court orders signed November 1,
2015, (Motion Objecting any Dismissal due to Fraud et al), March 30, 2015,
(Motion for Reconsideration Vacate March 30, 2015 Order et al) March 23, 2015
(Motion moving for Default et al)
13.)
FACTS Petitioner appeared before Hon Mary
Lane Mikva case #10 CH 23588 Secretary of state was trying to have Petitioners
license suspended Assistant Attorney General Diane Moshman tried to orally get
the judge to dismiss Petitioners case properly plead, she denied the States
oral motion, so another attorney got on the case Tyler Roland filed a motion
trying to get the case dismissed saying that it was not properly plead, Hon.
Mikva spoke up adamantly said that because you went to school and learned how
to plead a certain way does not make the style in how said pleadings are
presented to this court any less plead, he has met his burden in pleading this
case and ordered the Attorney to respond;
A-
The
judge was astounded at the fact that no court orders or court file was
presented mainly a May 18, 1988 court order with no signatures or attorney
information;
B-
Because
of the Petitioners due-diligence and the judges integrity within the laws,
Petitioners license was never suspended because he never owed any child support
despite all of the fraudulent civil rights acts perpetrated at him;
C- Petitioner filed Motion for
Disqualification of Judge et al., Ex A
Court transcript Page 11 Lines 1-8,
Petitioner stated, “There were two orders
without signatures. And without 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 and no signature”
D-
The
court asked the Petitioner, “Do you
attach that as part of your petition? It was tendered again to the judge,
he stated, Lines 7-13, “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 quite sure how that ties in though. I’ve read that
document”.
14.)
FACT Orders from the City of Chicago,
Commission on Human Relations Case #(12-H-19)
signed by Mona Noriega, Chair and Commissioner (Housing Choice Voucher matter),
signed validating the veracity City attorneys Perjured themselves in court;
A- Hereto attached, (12-E-04) Orders from Chair
and Commissioner Mona Noriega signed validating the veracity counsel perjured
himself in court;
B- Hereto attached, (09-P-10) Order from the Chair and Commissioner Mona Noriega signed
validating the veracity counsel with vexatious contempt for the laws perjured
himself in court;
C- Hereto attached, (13-E-56) Order from the chair and Commissioner Mona Noriega signed
validating the veracity counsel with vexatious contempt for the laws perjured
himself in court;
D- Hereto attached, (14-P-18) Order from the Commissioner signed in a consistent manner
demonstrating Corruption and Fraud in the City of Chicago Commission on Human
Relations by Mona Noriega;
E- Hereto attached, (13-P-83) Order from the Commissioner signed by Mona Noriega
demonstrating Counsel perjured himself in court;
F- Hereto attached, (13-E-60), Order from the Commissioner signed validating the
attorneys who have committed fraud and made perjured testimony to the judge;
15.)
That
the CHA and other Terrorist Operatives with vexation for the laws deliberately made
perjured testimony to Hon. Valderrama Feb 27, 2015, claiming they were never
served, so as to prolong this matter further;
A-
That
because of the “Organized Conspiracy” perpetrated at Petitioner by
Respondents at the CHA and Commission on Human Relations, as they colluded
mailing out “Fraudulent” court orders absent certification with a seal or
signature;
B-
That because of Petitioners ethnicity non-white
many in the City of Chicago Commission on Human Relations, CHA have
corroborated their roles in this active chain conspiracy by disseminating false
documents to whomever is necessary to Induce Reliance on the agency or judge
hearing the matter, as demonstrated in this case;
That the
Request for Review et al filed ( March 3, 2015) unequivocally demonstrate the
mayhem and Terrorist Acts many racist individuals were willing to exhaust
covering up-crimes that should have been reported and addressed but was ignored
because Petitioner’s life did not matter; Canon
3D
(1) Reporting Judicial Misconduct
A-
Mass.
Comm. On Judicial Ethics, Op. 2002-04 (2002)……………………………………
B-
That
in addition to the Organized Conspiracy, Respondents continued to violate Petitioners
Civil Rights as they colluded with alleged members of the City of Chicago by accessing
personal credit information where there was a “freeze” on said report while said matter was under
investigation. See Par. 15 of Dec.
10, response;
C-
Pursuant
to Vigus V. O’Bannon, 1886 N.E 788, 188 Ill 334 Hazelton V. Carolus,
1907 132 Ill. App. 512, hereto attached,
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;
Cannon v. Commission on Judicial
Qualifications,
14 Cal. 3d 678, 537 P. 2d 898,
122 Cal. Rptr. 778 (1975)……………………
E-
That Respondents are anticipating any judge
recorded within the aforementioned, who is corrupt and willing to step outside
of their immunity provisions and commit the following “Terrorist Crimes” by
dismissing said “Request for Review et al” simply because ethnic groups Black
and Brown don’t matter; Judges erred in abusing the adversarial process, a
fundamental aspect of the adversarial system is that proceedings are to be
conducted in open court. Judges have been disciplined for disposing of cases
without an adversarial proceeding, In re Fitzgerald, Unreported Determination
(Ky. Comm’n 1986); Holder, 74 N.J. 581, 379 A. 2d 220 (1977……………………….
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.
Vaughn 462 S.E. 2d 728 (Ga. 1995), The Supreme
Court of Georgia removed a judge from office for disregarding defendant’s
constitutional rights
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.
16.)
That
many blacks along with obvious whites working for Edward Burke see him as a
Messiah an untouchable God in that, they have forsaken the integrity of their
careers by participating in said Terrorists Acts, so as to maintain their
positions of authority and titles oppressing individuals like the Petitioner
and said Blacks, Latinos are only figureheads and will not enforce the laws on
the perpetrators who’s ethnicity is white and is a part of the “Organized Conspiracy”;
A-
That
Judge Moche Jacobius before being appointed judge of the circuit court had
assisted Petitioner on another case as Assistant Attorney General he was aware
of the corruption and mayhem Petitioner had experienced in the courts is the only
Judge to appoint him legal representation when locked up 5 times for allegedly
owing child support on a “Bogus” paternity case that had no judges signatures
which is the modis operandi of
the perpetrators involved engaging in this “Terrorist Organized Conspiracy”;
B-
That
Judge Timothy P. Murphy said “today is
your lucky day” and was upset he could not remand Petitioner back into
custody because his attorney Gerald Nordgren informed him he was on Public Aid;
That
Under Section 4 of the Ku Klux Klan
Act of 1871: the law is clear, “Whenever in any State or part of a
State………unlawful combinations…….shall be organized and armed, and so numerous
and powerful et al…………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…..”
17.)
Said Respondent Terrorists impersonating
attorneys and private citizens thought they were in fact denying the Petitioner
in their plethora of unlawful acts were really demonstrating their might
against the Federal Government;
A-
That
because the conspirators have demonstrated their rebellion against the federal
government, it is necessary to ascertain how many are willing to spend the rest
of their lives in a Maximum Federal Penitentiary or face execution working for
the King of Terrorism;
B-
That
because this matter is now before a judge with “Contempt Power” it is necessary
to establish a precedent in the laws imposing applicable laws that would
discourage and prohibit this area of Racial Genocide, Racial Apartheid ethnic
cleansing of persons of color from Equal access to the laws and Public Housing,
unlawful incarcerations by a racial majority seizing a City and legal system is
why Remands are necessary with Body attachments;
C-
Petitioner
served Rahm Emmanuel via Police Personnel, he ignored the issues simply because
Black and Brown people lives simply don’t matter where racial Discrimination or
Segregation is concerned, Chicago
Reader, Feb. 5, 2015, Steve Bogira and Mike Dumke, The Chicago agency charged with investigating complaints of housing
discrimination is the Commission on Human Relations. In recent years, it has
seldom punished landlords for discriminating racially. The commission's modest
$1.9 million budget has grown yet more modest since Rahm Emanuel became mayor:
he's cut it to $1.1 million. It's one of the things we would have liked to have
discussed with him, but he declined to talk with us about segregation.
D-
That
the Mayor’s true color on how he feels about people of color is indicative to
how policies are enforced under his jurisdiction Racism and Racial Hatred is
how Chicago is presently governed ;
The
Mis education of the Negroe, Carter G. Woodson 1933
“History shows that it does not matter who is in power or what revolutionary
forces take over the government, those who have not learned to do for
themselves and have to depend solely on others never obtain any more rights or
privileges in the end than they had in the beginning.”
“When you control a man's thinking you do not have to worry
about his actions. You do not have to tell him not to stand here or go yonder.
He will find his 'proper place' and will stay in it. You do not need to send
him to the back door. He will go without being told. In fact, if there is no
back door, he will cut one for his special benefit. His education makes it
necessary.”
18.)
That many Respondents white and
Hispanic not racist and not a part of the political machine tried to help Petitioner,
stated “he needed a court order from a
judge not connected because there are too many judges Burke owns and is
involved and nobody wants to lose their job doing what is right to help you”
A-) That because Ed Burke is the
Finance Chairman and responsible who receives payment from the City, allegedly
stated “As long as he is Chairman the Nigger referencing Petitioner
will never be reinstated to CTA and receive his back wages” To this date no
one has ever objected to the veracity of said assertions recorded in said
affidavits.
B-) That Petitioner
under the FBI’s directorship ascertained the necessary corroboration from every
legal tribunal and State Agencies demonstrating and recording it in all
affidavits how cases are fixed and judges are used as weapons of “Mass
Destruction” against citizens of color as demonstrated in this matter;
C-) That all parties were properly
noticed that the FBI was in fact receiving courtesy copies basically presented
a middle finger to the Feds and every respected legal representative of the
laws challenging them to exercise their authority and necessary force removing
them from office, the FBI will not get involved directly until the case is
disposed of because it is still a private civil matter;
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.”)
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
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.
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
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.
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
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 sanctionable conduct, that
lawyer’s firm can also be jointly and severally liable with the lawyer.
19.)
That
because of the Directed Evidence and admissions in the aforementioned recorded
within Complainant is seeking all parties be REMANDED into CUSTODY Instanter regardless to their
Racial Political Fraternal Affiliations for their respective roles in said
Criminal Housing Conspiracies;
A- That all parties
have demonstrated in their respective roles that they are not capable of
DISCHARGING their duties in accordance to the Laws of Professional Ethics,
Rules of Illinois Supreme Court or United States Constitution with any
integrity; therefore, a COURT’S ORDER is needed to MANDATE THE PARTIES TO act
within their obligations;
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
Petitioner/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 2601
Petitioner )
)
V
420 East Ohio, Chicago Housing Authority
345 East Ohio, City of Chicago, Commission on Human
Relations,
K2 Apartments
Respondents
________________________________________________________________________
In
Accordance to all of The Cook County Circuit Court Rules
MEMORANDUM OF LAW IN SUPPORT OF THE
RELIEF REQUESTED
The
canons of ethic in the Rules of Professional Conduct constitute a safe guide
for professional conduct, and attorneys may be disciplined for not observing
them. In re Himmel, 125 Ill.2d 531,
533 N.E.2d 790, 127 Ill. Ill. App. 3d 999, 697 N.E.2d 820, 232 Ill. Ill.
App.3d 485, 654 N.E.2d 232, 210 Ill. Dec. 933
(2d Dist.), appeal denied, 164 Ill.
Ethics
All Illinois
RPC
3.3, entitled “Conduct Before a Tribunal,” sets forth the
standards to be followed by the trial lawyer during “battle.” Section (a) of
that rule states:
(a) In appearing in a professional capacity before a tribunal, a
lawyer shall not:
(1) make a statement of
material fact or law to a tribunal which the lawyer knows or reasonably should
know is false;
(2) fail to disclose to a
tribunal a material fact known to the lawyer when disclosure is necessary to
avoid assisting a criminal or fraudulent act by the client;
(3) fail to disclose to the
tribunal legal authority in the controlling jurisdiction known to the lawyer to
be directly adverse to the position of the client and not disclosed by opposing
counsel;
(4) Offer evidence that the
lawyer knows to be false. If a lawyer has offered material evidence and comes
to know of its falsity, the lawyer shall take reasonable remedial measures;
(5) participate in the
creation or preservation of evidence when the lawyer knows or reasonably should
know the evidence is false ;
(6) counsel or assist the
client in conduct the lawyer knows to be illegal of fraudulent;
(7) engage in other illegal
conduct or conduct in violation of these Rules;
(8) fail to disclose the
identities of the clients represented and of the persons who employed the
lawyer unless such information is privileged or irrelevant;
(9) intentionally degrade a
witness or other person by stating or alluding to personal facts concerning
that person which are not relevant to the case;
(10) in trial, allude to any matter that the lawyer does not
reasonably believe is relevant or that will not be supported by admissible
evidence, assert personal knowledge of facts in issue except when testifying as
a witness, or state a personal opinion as to the justness of a cause, the credibility
of a witness, the culpability of a civil litigant or the guilt or innocence of
and accused, but a lawyer may argue, on analysis of evidence, for any position
or conclusion with respect to the matter stated herein;
Acts constituting direct, criminal
contempt
A wide variety of acts may constitute a direct, criminal
contempt. And act may be criminal contempt even though it is also an indictable
crime. Beattie v. People, 33 Ill. Ill. Ill.
Official
misconduct is a criminal offense; and a public officer or employee commits
misconduct, punishable by fine, imprisonment, or both, when, in his official
capacity, he intentionally or recklessly fails to perform any mandatory duty as
required by law; or knowingly performs an act which he knows he is forbidden by
law to perform; or with intent to obtain a personal advantage for himself or
another, he performs an act in excess of his lawful authority ….S.H.A. Ch 38
33-3.
False statements
Censure was recommended sanction for
attorney who engaged in conduct involving dishonesty, made statement of
material fact or law to tribunal which she knew or reasonably should have known
to be false, and failed to disclose to tribunal a material fact known to her
when disclosure was necessary to avoid assisting criminal or fraudulent at by
client, given that attorney’s misconduct was not result of dishonest or corrupt
motive, but of misguided attempt to accommodate clients. 99 Ill.Atty.Reg. & Disc.Comm. SH11
Three-year suspension was
recommended sanction for attorney who engaged in conduct involving dishonesty
and fraud, made statement of material fact to tribunal which he knew or
reasonably should have known was false, and offered evidence that he knew to be
false and failed to take reasonable remedial measures. 96 Ill.Atty.Reg. &
Disc.Comm. SH 358.
Disbarment was recommended sanction
for attorney who engaged in conduct involving dishonesty, made false statements
of material fact or law to tribunal which she knew were false and engaged in
conduct which tended to defeat administration of justice. 95 Ill Atty.Reg. & Disc.Comm. CH 877.
Censure was recommended sanction for
attorney who made statements of material fact or law known was false, and
engaged in conduct which was prejudicial to the administration of justice. 95
Ill Atty.Reg. & Disc.Comm. CH 504
One-year suspension was recommended sanction for attorney who made
statement of material fact which he knew was false in appearing in professional
capacity before tribunal, made a statement of material fact which he knew to be
false in course of representing client, and engaged in conduct involving
dishonesty. 95 Ill Atty.Reg. &
Disc.Comm. CH 191.
Disbarment was recommended sanction
for attorney who engaged in serious misconduct by making misrepresentation
during his divorce proceedings and who was a recidivist. 94 Ill.Atty.Reg. & Disc.Comm. SH469
Fraud on court
Two-year suspension, retroactive to beginning of interim
suspension, was recommended sanction for attorney who made statement of
material fact or law to tribunal which lawyer knew or reasonably should have
known to be false, instituted criminal charges as prosecutor when he knew or
reasonably should have known that charges were not supported by probable cause,
committed criminal act that reflected adversely upon lawyer ‘s honesty,
trustworthiness, or fitness as lawyer, engaged in conduct involving dishonesty,
fraud, deceit, or misrepresentation, engaged in conduct prejudicial to
administration of justice, and engaged in conduct which tended to bring courts
or legal profession into disrepute. 96 Ill.
WHEREFORE the
aforementioned reasons Respondent respectfully Prays for the Relief
1.) For an Order Remanding all attorneys related Respondents found in Contempt who
did not report any improprieties to proper authorities demonstrating their non-
involvement in Civil Rights Violations, Terrorist Acts et al.
2.) 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 For an Order to pay PUNITIVE damages of $25
Million Dollars to the Petitioner and bond be set for all parties from the
above demand;
3.) For an Order Recommending a Special Prosecutor outside of States
Attorney Anita Alvarez, Attorney General Lisa Madigan jurisdiction (more
importantly attorney Kent Stephan Ray who committed numerous Civil Rights
violations as General attorney of the CTA is now a States Attorney; Attorney
General Lisa Madigan, when confronted with numerous documents alleging “FRAUD
on numerous Judges and States Attorneys her reply, “The Civil Rights Bureau of the Attorney General is in receipt of the
correspondence you delivered to our offices on 10/26/06. Unfortunately, your
file was closed because we do not have jurisdiction over child support related
matters”);
4.) For an Order Compelling Respondents to provide documentation of all
persons living in the named units that excluded the Petitioner a 3 bedroom
voucher;
5.) For
an Order issuing an Injunction against
the City of Chicago, Commission on Human Relations to ascertain the number of
cases “Fixed” that were disposed of without signatures or dismissed;
6.) For
an Order seeking Federal
Jurisdiction in the applicable statutes prohibiting the Respondent CHA from
removing any families from the Voucher program and reinstate all families who
were removed during the last years Petitioner complained of Racial
Discrimination that went ignored;
7.) For
an Order Imposing Sanctions against
all attorneys and law firms to absorb any and all attorney fees and costs for
the prosecution and enforcement of these matters;
8.) Prohibit any Attorney from delaying
prosecution of this matter with frivolous continuances due to Petitioner and
family suffering behind said acts;
9.) For an Order auditing all tenants for ZRS Management, Riverstone
Management and K2 Management and the Streeter to determine the ethnicity of all
tenants with vouchers and income criteria with said vouchers;
10.)
For
an Order Remanding every Party
complicit in said Criminal Conspiratory acts ignoring and covering-up said
unlawful acts of all parties and participants at the City of Chicago,
Commission on Human Relations responsible for mailing fraudulent documents to
Petitioner ;
11.)
For
an Order Compelling all Parties to appear before a Court with
jurisdiction to determine who should be REMANDED
into Custody for their part in said Terrorist Conspiracies;
12.)
For
the entry of an Order awarding to
your Respondent 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
Complainant
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
Petitioner )
)
V
)
420 East Ohio, Chicago Housing Authority )
345 East Ohio, City of Chicago,Commission)
on Human Relations K2
Apt )
Respondents )
________________________________________________________________________
CERTIFICATE OF SERVICE
Commander
& Chief
Attorney General of United States
President Barack
Obama
Loretta Lynch
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
States Attorney,
Anita Alvarez, Daley Center, 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
Seyfarth & Shaw
Anne D. Harris,
Jeffrey K. Ross, Kyle A. Petersen, Suite 2400
131 South
Dearborn
Chicago, IL.
60603
Chicago Housing Authority
Office of the
General Counsel, Maria Sewell Joseph, Thomas B. King
60 East Van
Buren
Chicago, IL.
60605
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
Stephan R.
Patton, Mary E. Reuther, Rey A. Phillip Santos
Corp Counsel, Deputy Corp. Counsel, Asst
Corp Counsel
30 N. LaSalle
Street, Suite 800
Chicago, Ill
60602
Wilson Elser Moskowitz Edelman &
Dicker LLP
Christian Novay
55 West Monroe,
Street, Suite 3800
Chicago, Ill.
60603
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
Media Personnel
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
Superintendent of Police
Garry F. McCarthy
Garry F. McCarthy
Hon Judge Neil Cohen 3510 S. Michigan
50 West
Washington, Suite 2308
Chicago, Ill 60653
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
Hon Dick Durbin Hearing Officer CHA
525 South 8th St.
Frederick Bates
Springfield, Ill. 62703 60 East Van Buren,
Suite 900
Chicago, Ill. 60605
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 Nov. 5, 2015.
PLEASE BE ADVISED that on Nov. 5, 2015 said motion with the
attachments was mailed, emailed 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
Email joelouislaw@yahoo.com
Twitter @joelouis7
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