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IN THE CIRCUIT COURT
OF
CHANCERY DIVISION
In Re Racial Discrimination/Source Income Violations
Housing Matters:
Joe Louis
Lawrence
Case
# 2015 CH 01670
Appellant
HON. F. U. Valderrama
Room 2305
V
420 East Ohio, Chicago Housing Authority
345 East Ohio, City of Chicago, Commission on Human
Relations, K2 Apartments
Respondents
MOTION MOVING FOR PROVE-UP ENTERING DEFAULT
JUDGMENT & SUMMARY JUDGMENT W/AFFIDAVIT
Now comes Plaintiff, Joe Louis Lawrence, Counsel
Pro Se, in this cause respectfully represents to this Hon Court the reasons for
a Prove-up Entering Default judgment & Summary Judgment and files herewith
his Affidavit in support for said Motion Moving for Prove-up entering Default
et al; Pursuant to Supreme Court Rules
& Civil Procedures.
Respectfully Submitted,
Joe Louis Lawrence
Plaintiff
Counsel Pro Se
312 927-4210
joelouislaw@yahoo.com
Twitter @joelouis7
AFFIDAVIT
I Joe Louis Lawrence, being duly sworn on
oath states:
1.) CERTIFIED MAIL ISSUED January 30th 2015
2.) SUMMONS ISSUED AND RETURNED SERVED ON
ALL PARTIES
3.) NO DEFENDANT ANSWERED OR FILED AN
APPEARANCE or ANSWER ON OR BEFORE March 9th 2015;
4.)
That
pursuant to 735 ILCS 5/3-101, et seq. 420 East Ohio, ZRS Management,
Tracking #7014-0150-0001-5043-5130 was served via certified mail Feb. 6, 2015,
10:57 am, Attorney Anne D. Harris admitted in open court Feb. 27, 2015 on
Petition for Rule to Show Cause et al. They were in fact served.
A-) Law firm Seyfarth
& Shaw filed an appearance timely never answered, or responded to the Nov
2, 2015 court order pursuant to 735 5/2
1301 (d) “if he or she fails to appear after being properly served or,
having once appeared, fails to file a timely answer, S.H.A. 735 ILCS 5/2-1301 (d), provides that “{j}udgment by default
may be entered for want of an appearance or for failure to plead, but the court
may, in either case, require proof of the allegations of the pleadings upon
which relief is sought .” In Ameritech
Pub. Of Illinois, Inc. v. Hadyeh, 362 Ill. App. 3d56, 298 Ill. Dec 302, 839
N.E. 2d 625 (1st Dist. 2005), a default was entered for failure
to answer although an appearance had been filed;
5.) That pursuant to 735 ILCS 5/3-101,
et seq. 345 East Ohio, Village Green Management same sequence of numbers
except for the last four numbers, #5154 was served via certified mail Feb. 6,
2015, 1:18 pm; Frank Fiorentino.
6.)
A-) Law firm Gordon & Rees never filed an
appearance or answered, or responded to Nov. 2, 2015 court order pursuant to 735 5/2 1301 (d) “if he or she fails to
appear after being properly served or, having once appeared, fails to file a
timely answer, S.H.A. 735 ILCS 5/2-1301
(d), provides that “{j}udgment by default may be entered for want of an
appearance or for failure to plead, but the court may, in either case, require
proof of the allegations of the pleadings upon which relief is sought .” In Ameritech Pub. Of Illinois, Inc. v.
Hadyeh, 362 Ill. App. 3d56, 298 Ill. Dec 302, 839 N.E. 2d 625 (1st
Dist. 2005), a default was entered for failure to answer although an appearance
had been filed;
B-)
7.) 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.
A-)
Law firm City of Chicago,
Corporation Counsels never filed an appearance or answered summons
complaint served in a timely manner or responded to court order of Nov. 2, 2015
pursuant to 735 5/2 1301 (d) “if he or
she fails to appear after being properly served or, having once appeared, fails
to file a timely answer, S.H.A. 735
ILCS 5/2-1301 (d), provides that “{j}udgment by default may be entered for
want of an appearance or for failure to plead, but the court may, in either
case, require proof of the allegations of the pleadings upon which relief is
sought .” In Ameritech Pub. Of Illinois,
Inc. v. Hadyeh, 362 Ill. App. 3d56, 298 Ill. Dec 302, 839 N.E. 2d 625 (1st
Dist. 2005), a default was entered for failure to answer although an
appearance had been filed;
7.) That pursuant to 735 ILCS
5/3-101, et seq. Chicago Housing
Authority same sequence of numbers
except for the last four numbers, #5123 was served via certified mail Feb. 6,
2015, 12:35 pm; Armstrong C., they informed the court that they were never
served;
A-
Law firm Chicago
Housing Authority General Counsels never filed an appearance or answered
summons complaint served in a timely manner or responded to court order of Nov.
2, 2015, pursuant to 735 5/2 1301 (d)
“if he or she fails to appear after being
properly served or, having once appeared, fails to file a timely answer, S.H.A. 735 ILCS 5/2-1301 (d), provides
that “{j}udgment by default may be entered for want of an appearance or for
failure to plead, but the court may, in either case, require proof of the
allegations of the pleadings upon which relief is sought .” In Ameritech Pub. Of Illinois , Inc. v.
Hadyeh, 362 Ill. App. 3d 56, 298
Ill. Dec 302, 839 N.E. 2d 625 (1st Dist. 2005), a default was
entered for failure to answer although an appearance had been filed;
8.) Attorney T.B. King of CHA,
Christian Novay of 345 East Ohio perjured themselves before Hon Valderrama said
that they were never served!
9.) That pursuant to K2 Management being
represented by Cary G. Schiff,
attorneys Yuleida Joy, Christopher R. Johnson received Notice and Knowledge of
the 2nd Amended Complaint November 30, 2015 and other subsequent
Notices of said matter being before the court where Cook County Sheriff served
the law firm via Christopher R. Johnson personally;
A-) Law firm Cary G. Schiff never filed an appearance or answered, but made
numerous court appearances after receiving notice informing the court that they
were observers because they had not been served pursuant to 735 5/2 1301 (d) “if he or she fails to appear after being properly served or, having
once appeared, fails to file a timely answer, S.H.A. 735 ILCS 5/2-1301 (d), provides
that “{j}judgment by default may be entered for want of an appearance or for
failure to plead, but the court may, in either case, require proof of the
allegations of the pleadings upon which relief is sought .” In Ameritech Pub. Of Illinois, Inc. v.
Hadyeh, 362 Ill. App. 3d56, 298 Ill. Dec 302, 839 N.E. 2d 625 (1st
Dist. 2005), a default was entered
for failure to answer although an appearance had been filed;
B-
That Group Ex E from the 2nd Amended Complaint an Order from
the Defendant City of Chicago, Comm. On Human Relations, states “ORDER
TO RESPOND AND NOTICE OF POTENTIAL DEFAULT” K2 was to have responded on
or before December 29, 2015, said order was absent a signature;
C-
That
Defendants having admitted to all facts properly plead in Gr Ex G and H validates the
veracity of the aforementioned recorded above and within;
10.) That Defendants having no respect
for the court or its authority because of the judge’s skin color continued
their mayhem on the Plaintiff and family (son in High School kicked out of Leo
transferred to Phillips) because he had no authority over white men complicit
in said “Terrorist Acts”, in
that, their expectation was that he was going to continue to berate the
Plaintiff unjustly and continuously deny anything he presented to the court as
demonstrated openly and in prior matters before the court;
11.)
Plaintiff anticipating the Racist white men fraternally connected in
this matter were going to attempt a frivolous delay seeking continuances noted
on Page 41, Par. 21 from the Relief Prayed for states, “Prohibit any attorney from delaying prosecution of this matter with
frivolous continuances due to Plaintiff and family suffering behind said acts”.
12.)
That because Defendants were not able to “Lynch” the Plaintiff in a celebratory manner using Ropes
have engaged in depraved racist acts against the Plaintiff violating his Civil
Rights surpassing human imagination because his life didn’t matter simply
because of the color of his skin;
A.) Sheriff #01712556 Served CHA via
corporation 3-11-2015, 10:17am they served them copies of the Amended
Petition for Rule to Show Cause along with an Amended Request for Review et al.
Counsel never Objected or responded to the $25 Million Dollar Demand;
B.) Sheriff #01712558 Served Christian
T. Novay via corporation 3-9-2015, 11:21am copies of the Amended Petition
for Rule to Show Cause et al along with an Amended Request for Review et al.
Counsel never Objected or responded to the $25 Million Dollar Demand.
C.) Sheriff #01712557 Served Rahm
Emanuel via corporation 3-12-2015, 10:00am copies of the Amended Petition
for Rule to Show Cause et al along with an Amended Request for Review et al.
Counsel never Objected or responded to the $25 Million Dollar Demand.
D.) Sheriff #01712560 Served Christopher
R. Johnson personal service 3-12-2015, 10:20am, copies of the Amended
Petition for Rule to Show Cause et al along with an Amended Request for Review
et al. Counsel never objected or responded to the $25 Million Dollar Demand K2
has Defaulted twice on a $3 Million Dollar Default before the Human Relations
Commission.
E.) Sheriff #01722070 Served Seyfarth
& Shaw via corporation 3-16-2015, 12:30pm copies of the Amended
Petition for Rule to Show Cause et al. along with the Amended Request for
Review et al. Counsel never Objected or responded to the $25 Million Dollar
Demand.
12.)
That Defendants with vexatious Contempt for the laws did not request
leave of the court in which to file a late response and has Defaulted whereby, Summary Judgment is being sought on the
claims presented before the court, defendants have not raised any affirmative
defenses or responded to any documents filed before the courts due to its
veracity.
Summary Judgment is appropriate when the pleadings,
depositions, admissions and affidavits, viewed in a light most favorable to the
nonmovant, fail to establish a genuine issue of material fact, thereby
entitling the moving party to judgment as a matter of law. 735 ILCS 5/2-1005; Progressive
Universal Ins. Co. v Liberty Mut. Fire Ins. Co., 215 Ill.2d 121, 127-28 (2005).
The purpose of summary judgment is not to try a question of fact, but simply to
determine whether one exists, Jackson v.
TLC Assoc., Inc., 185 Ill. 2d 418, 423 (1998).
A trial court is required to construe the record against the moving party and
may only grant summary judgment if the record shows that the movant’s right to
relief is clear and free from doubt. Id. If disputes as to material facts exist
or if reasonable minds may differ with respect to the inferences drawn from the
evidence, summary judgment may not be granted.
Properly
alleged facts within an affidavit that are not contradicted by counter
affidavit are taken as true, despite the existence of contrary averments in the adverse party’s pleadings. Professional
Group Travel, Ltd. v. Professional Seminar Consultants Inc., 136 ILL App 3d
1084, 483 N.E. 2d 1291; Buzzard v. Bolger, 117 ILL App 3d 887, 453 N.E. 2d 1129
et al.
When the
party moving for summary judgment supplies evidentiary facts which, if not contradicted,
would entitle him to judgment, the opposing party cannot rely upon his
complaint or answer alone to raise issues of material fact. Smith
v. St. Therese Hospital, 106 Ill. App. 3d 268, 270 (2d Dist. 1982). A
counter affidavit is necessary to refute evidentiary facts properly asserted by
affidavit supporting the motion or else the facts are deemed admitted. Barber-Colman
Co. A And K Midwest Insulation Co. 236 Ill. App. 3d 1065, 1078 (5th Dist.
1992).
FURTHER AFFIANTH SAYETH NAUGHT
Under penalties as provided by law pursuant to 735 1265
5\1-109, the undersigned certifies that the statements set forth in this
instrument are true and correct, except as to matters therein stated to be on
information and belief and as to such matters, the undersigned certifies as
aforesaid that he verily believes the same to be true.
Joe Louis Lawrence
Plaintiff/Counsel Pro Se
WHEREFORE the
aforementioned reasons Plaintiff respectfully Prays for the Relief
1.) For an Order Entering Judgment Prove-up Defaulting the Defendants Granting
Summary Judgment Instanter;
That
because of the heinous acts Plaintiff have been harmed by said Civil Rights
Violations and no one objected to said assertions put before any tribunal, and
the number of City personnel and plethora of other conspirators making sure he
did move where he desired and numerous Civil Rights Violations, Plaintiff is
seeking Summary Judgment $25 Million Dollars as punitive damages; Smith
v. Wade,
461 U.S. 30, 35, 103 S. Ct. 1625, 1629, 75 L Ed 2d 632 (1983) Justice Brennen “The threshold standard for
allowing punitive damages for reckless or callous indifference applies even in
a case, such as here, where the underlying standard of liability for
compensatory damages because is also one of recklessness. There is no merit to
petitioner’s contention that actual malicious intent should be the standard for
punitive damages because the deterrent purposes of such damages would be served
only if the threshold for those damages is higher in every case than the
underlying standard for liability in the first instance. The common-law rule is
otherwise, and there is no reason to depart from the common-law rule in the
context of {1983}”
2.) For the entry of an Order awarding to the Plaintiff for
such other relief and any other relief necessary as equity may require of which
this court may deem overwhelmingly just;
Under penalties as
provided by law pursuant to 735 1265 5\1-109, the undersigned certifies that
the statements set forth in this instrument are true and correct, except as to
matters therein stated to be on information and belief and as to such matters,
the undersigned certifies as aforesaid that he verily believes the same to be
true.
Respectfully Submitted
Joe Louis Lawrence
Plaintiff
Counsel Pro se
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