THE MOST RACIST HATED WHITE MEN NOT IN ALABAMA OR MISSISSIPPI HAVE ADMITTED TO ALL OF THE PLEADINGS OF RACIAL HATRED SURPASSING HUMAN IMAGINATION FROM THE DECEMBER 1, 2015 POSTS.
AFRICAN AMERICAN IN POWER ARE RECRUITED AS FOOT SOLDIERS FOR THE DEMOCRATIC MACHINE TO DESTROY THEIR ON RACE OF PEOPLE THEY ARE APPOINTED TO JUDGE POSITIONS TO UPHOLD EVERYTHING DR MARTIN LUTHER KING STOOD FOR AND DIED FOR.
________________________________________________________________________
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 )
________________________________________________________________________
NOTICE OF FILING
YOU ARE HEREBY NOTIFIED that on Jan 21,
2016 Plaintiff has filed a Motion Objecting Extension of Time due to “Fraud”
& a plethora of other Civil Rights Violations w/Affidavit.
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, Sara Eber
Fowler 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
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
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 Jan.
21, 2016.
PLEASE BE ADVISED that on Jan 21, 2016
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
________________________________________________________________________
IN THE
CIRCUIT COURT
OF
COOK
COUNTY, ILLNOIS
CHANCERY
DIVISION
)
In Re Racial Discrimination ) Case # 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 )
________________________________________________________________________
MOTION OBJECTING ANY EXTENSION OF TIME DUE TO
FRAUD & A PLETHORA OF OTHER CIVIL RIGHTS VIOLATIONS W/AFFIDAVIT
Now comes
Plaintiff Counsel Pro Se, Joe Louis Lawrence respectfully moves this court on Plaintiff’s
Motion Objecting any Extension of Time due to “Fraud” & a plethora of other
Civil Rights violations with affidavit in the above entitled cause.
Reasons in
support of this motion are set forth in the attached affidavit.
Respectfully Submitted,
Joe Louis Lawrence
By:____________________________
Counsel Pro Se
Post
Office Box 490075
Chicago, Ill. 60649
(312) 927-4210
Twitter @joelouis7
STATE OF ILLINOIS
)
)
COUNTY OF COOK
)
AFFIDAVIT
Joe Louis Lawrence being first duly sworn on oath deposes
and states as follows:
1 I
am Joe Louis Lawrence, Counsel Pro Se.
2 Pursuant to Illinois Civil Procedure Rules,
failure to file an answer, where an answer is required, results in the
admission of the allegations of the complaint, Ill. S. Ct. R. 286 (a) Pinnacle Corp. v. Village of Lake in the Hills,
258 Ill. App 3d 205, 196 Ill. Dec 567, 630 N.E. 2d 502 (2d Dist. 1994)
3 That
because Plaintiff properly plead all facts correctly in said complaint negates
any extension of time for the Defendant to respond, due to there not being “Good Cause Shown” Bright v. Dicke, 166 Ill. 2d 204, 209 Ill.
Dec. 735 652 N.E. 2d 275 (1995)
Justice Harrison delivered the opinion of the
court:
The
issue in this case is whether a circuit court may permit a party to respond to
a request for the admission of facts or the genuineness of documents once the
28 day time limit specified by Rule
216 (c) (134 Ill. 2d R. 216 (c) has
expired. For the reasons that follow, we hold that the court may allow an
untimely response where the delinquent party has shown good cause for the delay
in accordance with Rule 183 (134
Ill. 2d R. 183) Because No Good Cause
was shown here, permission to make a late response was properly denied. The
circuit court’s order denying such permission and the judgment of the appellate
court affirming the circuit court’s order are therefore affirmed.
4 FACTS: That Defendants having been
properly served by the Clerk of the Circuit Court of Cook County via certified
mail with summons, and Cook County Sheriff and Plaintiff personally and hand
delivered;
5 FACTS: That the representing law firms
and attorneys were in receipt of all documents Motions, Petitions for Rule to
Show Cause, 2nd Amended Complaints et al. Seyfarth & Shaw, Anne D. Harris, Jeffrey K. Ross, Kyle A.
Petersen and Sara Eber Fowler; Gordon
& Rees, Christian Novay, Lindsay Watson; Cary G. Schiff, Christopher R. Johnson, Yuleida Joy; City of Chicago, Rey A. Phillips
Santos, Stephan R. Patton, Mary E. Reuther; Chicago Housing Authority, General Counsels Thomas B. King, Maria
Sewell Joseph, Jessica Mallon;
6 Plaintiff
Amended and filed a Second Amended Complaint pursuant to the courts directive
(court order) never once did he request an extension of time with the murder of
his brother (City employee Timothy D. Lawrence), Defendants never responded to
the court order, despite the court granting the Defendants overwhelming
latitude to answer the Plaintiffs complaint who have defaulted but held the
Plaintiff at a higher legal standard, in that, said attorneys made a mockery
out of the court for reasons requesting an Extension of Time in which to answer
the complaint, but is saying to the court in the properly plead admissions a SO WHAT
attitude!
A-
That attorney Kyle Petersen having already admitted to
all Facts of the 2nd Amended Complaint, she presented to the court
falsified documents purportedly, to be the 2nd Amended Complaint not
legible as the basis for an extension of time to answer the complaint;
B-
Plaintiff personally hand delivered the same document
in the judges’ possession on the bench and in CHA’s T. B. King’s possession
said Complaint was in excess of 200 pages, but Kyle stated she was never served
a copy or received a copy but presented a 58 page document copied on both sides’
pages deliberately skewed and pages incomprehensible.
C-
Plaintiff notified the court “this is not what was
served on the law firm” T. B. King interjected said he scanned Kyle the
documents perhaps during the transmission that caused the papers to become bad or
not readable!
D-
CHA attorney having already admitted to all facts
properly plead in Plaintiffs 2nd Amended Complaint stated the
reasons for an extension of time is that the Complaint was complicated, (WOW!)
E-
The City of Chicago like the other Defendants never
presented an affidavit with their defective motions having already admitted to
all facts properly plead in Plaintiff’s 2nd Amended Complaint it is a general rule that a failure to deny an
allegation results in it being admitted, in addition to this legal precedent
and because they have failed to articulate
sufficient cause pursuant to In Re
Estate of Michalak, 404 Ill. App3d 75; 343 Ill. Dec 373, 934 N.E. 2d 697 (1st
Dist. 2010), appeal pending, (Jan. 1, 2011), makes it impossible for any
court to apply discretion allowing an extension of time;
Pursuant to Roth v Roth, 45 Ill. 2d 19, 256 N.E.838 (1970), Pleading—Failure to respond to adversary
pleading may constitute admission of all facts well pleaded. As a purpose
of pleading is to develop the issues to be determined, a failure to respond to
an adversary pleading may constitute an admission of all facts well pleaded by
the adversary, and admissions thus drawn from failure to plead may be
considered as evidence. (See Mooney v.
Underwriters at Lloyd’s London, 33 Ill. 2d 566. People ex rel. Lacanski v.
Backes, 19 Ill. 2d 541, 543; see also, Ill. Rev Stat. 1967, ch 110 par. 40(2);
Nichols, Illinois Civil Practice, 1960, sec 1233.
7 Defendant City of Chicago, having admitted to
the facts recorded Page 6, Par 3 and 5, 8B is expecting the court
to ignore these admissions and continue to deny Plaintiffs 2nd
Amended Complaint because as Page 28,
Par 47 A-B is clear without a scintilla of falsity articulates the
contemptuous arrogance perpetrated upon this court knowing said acts are in
fact unlawful, but because of Plaintiffs skin color Defendants are expecting
the Judge who supports their racist agenda within the Democratic Machine to
continue to ignore the laws and deny anything Plaintiff files and grant the
Defendants anything they put before the courts as demonstrated in all prior
rulings;
8
Defendants having admitted to all pleadings
properly plead corroborates the systematic fraudulent acts, in that men of
color like the Plaintiff is not supposed to work in providing for his family,
he is not supposed to be educated, not supposed to stand up to racist corrupt
white Democrats in the Political Machine, he is not to have good credit scores
to live “Freely” as he desires within the city of Chicago, he is to accept a
lifestyle of inferiority, maintain a lifestyle of criminal employment and be a
member of the penal institution existing on welfare, to attempt to rise above
the racist atrocities is not tolerated by the Democratic Machine operatives; in
that, any man like the Plaintiff who attempts to rise above racial oppression
or racial terrorism, they are met with all of the facts within the 2nd
Amended Complaint and the aforementioned;
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.
To further amplify the veracity and credence
of the above, Plaintiff having appeared before Judge William Maddux (93 L
10772) in relation to Page 28 Par. C, Joe Louis Lawrence v Chicago
Transit Authority Wrongful Discharge, Ken Stephen Ray falsified all types of
documents, as we stood before Judge Patrick McGann he was very angry and in a
rage, Plaintiff lodged allegations of wrong doing by the CTA administrators
because he would falsify how his injury was sustained and apply for Public Aid
use the medical card to absorb the medical costs, Ken stood before the judge
licking his lips inciting the judge to become even more irate as he called the
plaintiffs filings garbage, said who do he think he is saying this garbage?
The Judge stood up as if he was
going to come down off the bench, the deputy starred at him, the judge sat back
down, Ken told the judge, “he thinks
there is a great big grand conspiracy against him” wailing his hands all
over the place like a female, he told the judge, he has no proof of any
discharge and don’t belong here judge, Plaintiff respectfully objected to the
judges behavior and admitted he never received any documents of a discharge but
CTA said, that, I was discharged terminating my medical benefits for sick
daughter with an ear infection while off work due to a work related injury, the
judge berated the Plaintiff with insults saying you don’t come to court on
hearsay! This Judge replaced Judge Willard K. Lassers who said he was going to
help (me) the Plaintiff, he told Ken S. Ray “he
better wipe that smirk off his face and when we returned back to court this
matter better be straighten out” somebody, had the judge removed from the
case
Plaintiff filed a Motion for
Disqualification of Judge and appeared before Judge Maddux he had the demeanor
of a powerful person surpassing judicial authority, said that what the
Plaintiff was asserting was in fact true, “but
up here things are done differently, you need a sponsor (Plaintiff ‘s
interpretation a white man) to represent
your issues because you are out of your league on this one you are a bright
kid, “I commend you, but the union is supposed to handle this matter, it
was explained to the judge nobody will talk to me or address this matter,” he
said, “go back to the union, they will
talk to you, I will not entertain this Motion for the reasons, I have explained
to you”
The Cook County Sheriff stated
this have to be reported Judge McGann was later transferred from the Law Division
to traffic court 312 N. LaSalle, the CTA did in fact forward documents of
status as a certified Bus Operator to the union but was never reinstated because
the CTA did not have the money in the budget because someone stole all of Plaintiff’s
back wages while off injured on duty according to Vice President of Operations
Hilcox and if anyone reinstated Badge 26115 they would have been terminated!
That allegedly due to Judge
Maddux influence and authority the Chicago
Transit Authority released employment records pursuant to Gr Ex A, Vol. II, Nov. 23, 1994 letter
from Michael Cook Manager Personnel, and the above information is furnished
in reply to your request for verification of employment from the CTA. He was
never DISCHARGED. AND Oct 20, 1994 Printout from database where someone tried
to erase Plaintiff from the database to prevent anyone’s knowledge he was an
employee but was unsuccessful along with medical statement finding him fit to
return to regular duty 12-1-1994 along with emails and letters grievances to
the ATU 241 that went ignored;
That Chairman Valerie Jarrett
tried having the Plaintiff reinstated and was met with some serious
oppositions.
That because Chicago is so
racist and segregated they attack the young boys exercising genocide likened to
the Laquan McDonald case where police shot him 16 times as officers of color
stood by and watched, in this case Plaintiff’s son on the Honor Roll at Leo
kicked out of School because administrators falsified records saying a debt was
owed when grants scholarships and sponsors cleared all debts due to Plaintiff
living on welfare, See Nov. 20, 2015
Notarized Affidavit;
That despite Gr Ex B, Judicial Complaint of Vol. II of the 2nd
Amended Complaint clearly demonstrate how the attorneys properly plead to
the facts of Chicago Public School officials corroborated their roles in
engaging in Terrorist Acts against son a talented hard hitting football player
denied the opportunity to pursue his passion to continue playing as Coach
McAlister and Principal Matthew Sullivan of Phillips High School engaged in
Racist Conspiracies keeping said son from receiving recognition in order to
receive a scholarship at prominent Universities but students living with the
white teachers of the school were given priority and scholarships not the
Plaintiffs son because of his skin color and father standing up to racial
injustice, “Jim Crow” .
9 The
Defendants must assert some independent ground as to why their untimely
response should be allowed. Hernandez,
73 Ill. 2d at 96; Greene, 73 Ill. 2d at 107.
10 That
Rule 183 does give judges discretion
to allow responses to be served beyond the 28 day limit, that discretion does
not come into play under the rule unless the responding party can first show
good cause for the extension. Hernandez
v. Power Construction Co. (1978) 73 Ill. 2d 90, 95-97).
A city’s
top attorney (Jordan Marsh) resigned Monday (Jan.4, 2016) after a federal judge
said he intentionally hid evidence while defending two Chicago police officers
in a wrongful-death lawsuit.
The judge
Edmond Chang has now ordered a new trial and is forcing the city to pay
attorney’s fees.
This
revolves around a wrongful death lawsuit filed by the family of Darius Pinex
against the city.
“He said the attorney for the city had intentionally
hidden evidence, which is very troubling,” says Steve Greenberg, the attorney
for Pinex’s family.
“It shows
that this culture of indifference to finding out the truth, to holding people
accountable, goes up to the highest levels,” Greenberg adds.
Chicago
police shot Pinex on a South Side street in January 2011, saying the car he was
in matched the description of a vehicle wanted in a shooting.
U.S.
District Judge Edmond Chang on Monday said city attorney Jordan Marsh
withheld information that may have cast doubt on those claims.
Marsh resigned
Monday, the city’s Department of Law said. “The conduct outlined by the
court in today’s decision is unacceptable,” the department said in a prepared
statement.
Greenberg says Pinex’s mother is “ecstatic” about the federal
judge’s ruling.
As for Marsh, he said, “I haven’t run into anything like
what Mr. Marsh did in this case.”
Marsh, who handled civil rights cases for the city, knew
about the recording before the lawsuit went to trial in March 2015, Chang said
in a 72-page opinion.
Jordan Marsh |
Facebook photo
“The court has no choice but to conclude, based on the
record evidence, that Marsh intentionally withheld this information from the
court,” the judge wrote.
Another city attorney, Thomas Aumann, “failed to make a
reasonable inquiry, as required by the discovery rules, to search for the
recording,” Chang added.
Aumann resigned on Aug. 31, city officials say.
The conduct by Marsh and Aumann thwarted the ability of
lawyers for Pinex’s family to prepare for trial, Chang said.
Attorneys for Pinex asked the city for the recording so
they could show the officers were not acting on information that would have
justified an aggressive traffic stop resulting in Pinex’s death.
Mosqueda had initially claimed he stopped the Oldsmobile
Aurora that Pinex was driving based on an Englewood District police radio
broadcast that warned the car might have been involved in a shooting in a
different police district about three hours earlier.
Because
people of color lives are of no merit the Mayor and many others within the
political system continue to engage in heinous lynching acts perpetrating
criminal acts within the legal system or violating the Civil Rights of the
Plaintiff because Chicago is still of the Confederate Democracy engaging in Jim
Crow practices.
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 believe the same to be true.
Respectfully
submitted,
Joe Louis Lawrence
Counsel
Pro Se
WHEREFORE the aforementioned reasons Plaintiff
respectfully Prays for the Relief of Denying
all Motions by the Defendants requesting an Extension of Time & Enforce Remands Body Attachments in accordance
to $25 Million Dollar sought as Bond and Sanctions pursuant to Supreme
Court 137 Instanter;
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 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
believe the same to be true.
Respectfully submitted,
Joe Louis Lawrence
Counsel Pro Se
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