DEPARTMENT OF JUSTICE NEED TO INVESTIGATE HOW JUDGES ARE APPOINTED TO THE BENCH BECAUSE THE SAD REALITY JUDGES APPOINTED AS ASSOCIATED  JUDGES TO THE BENCH ARE EITHER BIAS RACIST OR INCOMPETENT.

https://www.pinterest.com/pin/315252042647146763/ JIM CROW LAWS WERE ENFORCED AND CREATED BY THE DEMOCRATS;

OTIS LOVE IS BEING PUNISHED BY HATEFUL RACIST INDIVIDUALS IN THE DEMOCRATIC MACHINE FOR STANDING UP SPEAKING UP AGAINST RACISM AND INJUSTICE TRYING TO SEE AND HAVE CUSTODY OF HIS NATURAL BORN DAUGHTER SO THEY ARE TRYING TO LYNCH HIM UNJUSTLY USING INJUSTICE.

FACT; JUDGES OF IRISH OR POLISH ETHNICITY DO NOT RULE IN FAVOR OF PERSONS OF COLOR WHERE CONNECTED WHITE MEN ARE THE PERPETRATORS OF CRIMES AGAINST PEOPLE OF COLOR AND CERTAIN FOREIGNERS OR LIBERAL WHITES.

FACT; AFRICAN AMERICAN MEN & WOMEN SADLY FOR THE MOST PART RULE AGAINST PERSONS OF COLOR AND FAVOR THE OPPRESSOR IN THEIR RULINGS SO AS TO SECURE BEING APPOINTED FOR ANOTHER 4 YEAR TERM;

FACT; IT HAS BEEN ALLEGED JUDGES WHO ARE APPOINTED AS ASSOCIATE JUDGES HAVE TO PAY $10,000.00 INTO THE CAMPAIGN OR WHOMEVER SO AS TO DISGUISE PURCHASING A JUDGESHIP POSITION THAT IS WHY COMPLAINING ON A JUDGE OR FILING COMPLAINTS FALLS ON DEAF EARS!

GREAT JUDGES WHO ARE ON THE BENCH ALONG WITH GOOD ATTORNEYS ARE INTIMIDATED BY THE POLITICAL MACHINE SOME JUDGES IGNORE THEM AND RULE IN ACCORDANCE TO THE LAWS AS FOR THE ATTORNEYS THE MACHINE USES THE A.R.D.C. ATTORNEY REGISTRATION & DISCIPLINARIAN COMMISSION TO GO AFTER THOSE ATTORNEYS WITH FALSE CHARGES THEY HAVE TO ANSWER TO AND SETTLE FOR 6 MONTH SUSPENSION TO KEEP THEM OFF OF CASES THEY MAY PROPOSE A PROBLEM ON.

THE FOLLOWING MOTION GIVES AN ACCURATE DEPICTION ON THE AFOREMENTIONED VALDERRAMA IS A NEGRO BLACK AFRO AMERICAN JUDGE WHO WORKED AS AN ATTORNEY FOR THE LAW FIRM OF Sanchez & Daniels, 333 West Wacker Drive, Suite 500, Chicago, Illinois 60606  Admitted to the Bar: November 1988. College: University of Illinois, Chicago, Illinois - B.A. 1985. Law School: DePaul University College of Law, Chicago, Illinois - J.D. 1988. Current Affiliation:

HE WAS FIRST APPOINTED AS AN ASSOCIATE JUDGE:

SUBJECT: APPOINTMENT OF ASSOCIATE JUDGES

Upon receipt of a letter dated March 5, 2007, in which the Director of the Administrative Office of the Illinois Courts has certified the thirty-one (31) persons receiving the highest number of votes in the election for thirty-one (31) associate judges of the Circuit Court of Cook County, conducted pursuant to a notice published August 31, 2005, and on which the ballots were mailed February 16, 2007, and returned to the Director on or before March 2, 2007.

I hereby declare the following thirty-one (31) certified persons to be appointed as Associate Judges of the Circuit Court of Cook County effective April 11, 2007, their terms to expire on June 30, 2007.

David B. Atkins	Stuart Paul Katz
Callie Lynn Baird	Patricia Marian Logue
Yolande M. Bourgeois	Martin Paul Moltz
Darron Edward Bowden	Leonard Murray
Anthony John Calabrese	Joseph D. Panarese
John Thomas Carr	Kathleen Ann Panozzo
Peggy Chiampas	Angela Munari Petrone
Maria Kuriakos Ciesil	Marguerite Anne Quinn
Lisa R. Curcio	Jeanne Marie Reynolds
Mathias William Delort	Naomi Hornick Schuster
Sheila King Devane	David A. Skryd
Lauren Gottainer Edidin	Domenica A. Stephenson
Pamela Hughes Gillespie	Franklin Ulyses Valderrama
Steven J. Goebel	Neera Lall Walsh
Joel Leslie Greenblatt
Bridget Jane Hughes
Timothy Joseph Joyce

Dated this 8th day of March, 2007. This order shall be spread upon the records of this Court and published.

ENTER:

Timothy C. Evans
Chief Judge

Circuit Court of Cook County 

BECAUSE MY ETHNICITY IS THAT OF A PERSON OF COLOR THE DRACONIAN ACTS PERPETRATED BY THIS JUDGE IS DEEMED EXCEPTIONABLE AND IS TOLERATED BY THE CHIEF JUDGE BECAUSE THEY ARE ONLY FIGUREHEADS IN AUTHORITY RACIST WHITE MEN IN AUTHORITY ARE ABLE TO INCITE NUMEROUS CRIMINAL ACTS FROM ALL VENUES BECAUSE THEY KNOW AND HAVE MANY OF THE BLACKS IN POWER IN CHECK AS PUPPETEERS:

LET ME ADD ON THURSDAY FEB. 25, ON THE 9:30 CALL, THIS CASE WAS WRONGFULLY UP ON THE CITY'S MOTION TO DISMISS MY COMPLAINT THEY FAILED TO PROVIDE ME NOTICE AND HAD TO HAND ME A COPY IN COURT WHICH LEAVES THE CHA AND 420 EAST OHIO FILING MOTIONS TO DISMISS 345 EAST OHIO DID'NT SHOW UP TO COURT; LET ME PROVIDE SOME HISTORY SO THAT EVERYONE READING THIS CAN UNDERSTAND WHAT IS GOING ON ON THIS CASE!

JUDGE VALDERRAMA ON THE POST OF JAN 30, 2016 COURT ORDER, THE JUDGE GAVE THE DEFAULT DEFENDANTS WHO HAVE BEEN IN DEFAULT EVER SINCE MARCH 9TH 2015 7 DAYS TO ANSWER, THEY ARE COGNIZANT TO THE TYPE OF NEGROE HE IS ON THE BENCH DID NOT RESPOND TO HIS COURT ORDER; NEVERTHELESS, THE JUDGE ENTERED AN ORDER FOR THE MATTER TO BE CONTINUED UNTIL MARCH 10, AT 10:30, I DIDN'T LIKE THE FACT THE JUDGE ALLOWING SO MUCH TIME TO ELAPSE INSTEAD OF ADJUDICATING THE CASE ON THE MERITS (KEEP IN MIND BLACK JUDGES ARE SUPPOSED TO DO WHAT WHITE MEN IN POWER TELL THEM TO DO AND NOT WHAT THE LAW SAYS) THE JUDGE TOLD THE ATTORNEY FOR 345 EAST OHIO THEY WERE NOT A PART OF THIS ORDER WHEN I INFORMED HIM THEY HAVE NOT RESPONDED, HE SAID FOR ME TO FILE THE APPROPRIATE MOTION;

WHICH IS EXACTLY WHAT I DID, SO I FILED A MOTION FOR PROVE-UP LIKE THE ONE BELOW AGAINST 345 AND K2 MANAGEMENT WE APPEARED ON THE 9:30 CALL FEB. 5, 2016, THE JUDGE TREATED THE MOTION CALL AS A HEARING, I WAS PREPARED CHA, CITY ATTORNEY AND 420 EAST OHIO ONE OF THEIR ATTORNEYS WAS IN ATTENDANCE NOT K2, THE JUDGE ASKED ME TO RESPOND TO MY MOTION, I PRESENTED TO HIM AN AFFIDAVIT FROM DOROTHY BROWN CLERK OF THE CIRCUIT COURT SHOWING SUMMONS AND COMPLAINT HAD BEEN SERVED ON THE ENTITY 345 EAST OHIO AND RETURN RECEIPT WHERE  certified mail Feb. 6, 2015, 1:18 pm; Frank Fiorentino. SIGNED IT.

THE JUDGE TOLD COUNSEL TO REPLY Counsel (GOLI RAHIMI) informed the court that they thought this was a Civil matter and not an Administrative Review case and that they appeared in court not as being served but as a strategy to learn or stay abreast of what the court was doing so that they could have an effective defense for their client because documents were being served on the law firm not their client and they were not accepting service on behalf of their client and nowhere in any of the documents is 345 East Ohio mentioned, THEY JUDGE HAD A STRANGE LOOK ON HIS FACE;

SO THE JUDGE TURNED TO ME   asked, ME a series of questions seeking to ascertain MY legal understanding as to why and how 345 is named in the suit;

       I responded reminding the court of a plethora of “Fraudulent Acts” the City’s Commission on Human Relations have engaged in upholding housing and source income discrimination where whites with vouchers were allowed to use their Section 8 vouchers to live in the buildings but when the building managers learned of my ethnicity they denied me access to move into the units, took my money never returning it someone on the city level without authority mailed to my attention orders claiming the complaints were in fact dismissed absent any authorized signatures, which enabled them  to Induce Reliance upon everyone which is the basis how the review ended up in Chancery because the proper motions addressing the “Fraudulent Acts” and Conspiracies went ignored because the City Commission on Human Relations is absent Contempt Power to address the irregularities is how this matter ended up in Chancery on Administrative Review, the judge nodded as if he was understanding what was articulated by the Plaintiff, he has a habit of pretending to gesture in Plaintiff’s behalf but then DENY every Motion or Petition that is presented before him;  

      YOU COULD HEAR A RAT PISS ON COTTON NOBODY OBJECTED OR INTERRUPTED MY ARGUMENT WHEN JUDGES ASK THE ATTORNEYS IF THEY WANT TO REBUT WHAT I SAY THEY SAY NO! OR REPLY THEY SAY NO!

A-    The judge surprisingly asked Counsel for 345 East Ohio “so what are you going to do counsel”? he appeared agitated, he said, “I am about to grant his Motion”! The attorney became nervous as Hell, he repeated himself and said angrily, I am not going to tell you what to do! Then she said can I have 28 days? The judge immediately said GRANTED! I’m like what the Hell!

B-    That if that is not clear enough the court heard testimony of how K2 was served did not grant Plaintiff any relief on that motion said he would continue that matter until March 17, 2016;

     NOW WE ARE UP TO SPEED FEB. 25, THE ATTORNEYS THOMAS B. KING OF CHA, REY A. PHILLIP SANTOS OF THE CITY OF CHICAGO AND SARA EBER OF 420 E OHIO SEEMS TO HAVE ENTERED INTO SOME TYPE OF ALLEGED UNLAWFUL ACT WITH THE COURT BUT THERE WAS  A COURT REPORTER PRESENT CAPTURING EVERYTHING;

I PROPERLY OBJECTED TO ANY DISMISSALS AND REMINDED THE COURT MY MOTION MOVING FOR PROVE-UP ENTERING DEFAULT JUDGMENT ALONG WITH SUMMARY JUDGMENT AND THAT DEFENDANTS FAILED TO RESPOND TO YOUR COURT ORDER IN WHICH THEY WERE TO ANSWER IN 7 DAYS THEY FILED A MOTION TO DISMISS WHICH IS NOT A RESPONSE PURSUANT TO ILLINOIS SUPREME COURT RULE 286 (a) I READ THE LAW TO HIM VERBATIM, THE FAILURE TO RESPOND TO AN ADVERSARY PLEADINGS BY STANDING ON A MOTION TO DISMISS RATHER THAN FILING AN ANSWER, CONSTITUTES AN ADMISSION OF ALL WELL PLEADED FACTS, PINNACLE CORP. V. VILLAGE OF LAKE IN THE HILLS 258 ILL. APP 3D 205;

THE JUDGE SAID I MAY OR MAY NOT BE RIGHT BECAUSE THE DEFENDANTS DID IN FACT ANSWER WITH A MOTION, I REMINDED THE COURT HE ALREADY ORDERED MARCH 10 AS THE DATE IN WHICH TO HEAR THIS CASE MAKES SENSE AND IS GERMANE TO MY DEFENSE BECAUSE MARCH 4TH RESPONSE OR NO REPLY FROM 345 EAST OHIO WITH HAVE RELATIONSHIP ON THE OUTCOME OF THIS CASE BECAUSE THE SAME INFORMATION IN WHICH YOU ALLOWED 345 EAST OHIO 28 DAYS TO RESPOND  IS THE SAME INFORMATION WHERE CHA 420 EAST OHIO AND THE CITY OF CHICAGO IS IN DEFAULT, HE SAID THAT HAS NO BEARING ON THIS CASE LAWYERS ARE NOT SAYING ANYTHING;

THEN THE JUDGE TRIED TO PUNK ME BY ASKING ME NOW WHAT ARE YOU GOING TO DO? I HAVE 3 MOTIONS BEFORE ME DISMISSING YOUR COMPLAINT!

I SAID GIVE ME 14 DAYS HIS REPLY THAT'S ALL YOU NEED? MY REPLY YEP! WHICH PUTS AT THE VERY DATE EVERYONE WAS TRYING TO AVOID MARCH 10TH THEN THE JUDGE ASKED THE CITY ATTORNEY CAN THEY REPLY IN 3 DAYS ( IMPLYING MY OPINION) HE WAS GOING TO DISMISS THE CASE IN THEIR FAVOR VIOLATING ANY AND EVERY LAW NECESSARY TO HELP THE DEFENDANTS.

IN THE CIRCUIT COURT

OF

COOK COUNTY, ILLINOIS

CHANCERY DIVISION

In Re Racial Discrimination/Source Income Violations

Housing Matters:                                                               

Joe Louis Lawrence                                                               Case # 2015 CH 01670

            Petitioner                                                                  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                                                                            

                                                              P.O. Box 490075

                                                                  Chicago, Illinois 60649-0075

                                                            312 927-4210

                                                                      joelouislaw@yahoo.com

                                                                                    Twitter @joelouis7

                                         AFFIDAVIT

  

I Joe Louis Lawrence, being duly sworn on oath states:

                     1.) CERTIFIED MAIL ISSUED January 30^th 2015

2.)  SUMMONS ISSUED AND RETURNED SERVED ON ALL PARTIES

3.)  NO DEFENDANT ANSWERED OR FILED AN APPEARANCE ON OR BEFORE March 9^th 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.

5.)   That the Jan. 28, 2016 court order went against the manifest weight of the evidence cited in Plaintiff’s Affidavit Objecting Extension of Time et al.;

6.)   That the Defendant’s having no respect for the Judge mainly because of his skin color; despite, the court bending over backwards operating outside of judicial discretion and judicial immunity provisions allowing them extra time to answer the complaint never complied with his directive;

7.)   That despite the court repeatedly asking the Defendant’s attorneys to answer the 2^nd Amended Complaint, they have demonstrated a SO WHAT ATTITUDE to every Fact properly plead;

  

                      A-) That Page 10 Par. 12 & 13 validates the veracity to the aforementioned;

                      B-) That Page 15 Par. 13 & 14, Defendants have properly plead to all facts recorded in said 2^nd Amended Complaint;

                      C-) Page 20 Par. 27 & Vol 1 of Group Ex A, B, C, D and E, Vol. II of Gr. Ex D and E all absent signatures proving “Fraud” and Terrorist Conspiracy which said attorneys have properly plead to the veracity of Plaintiff’s pleadings as being factual;

8.)   That the Defendants having full cognizance of what was being asserted as being factual in Plaintiff’s complaint was relying on their racist brethren in the Democratic Machine or any judge that they controlled and dictated to making sure that judge “FIXED” the case by whatever means necessary irrespective to the fact over 15 of the top attorneys money can buy was deployed attempting to "Lynch” the Plaintiff with “Jim Crow” Civil Rights Violations in the courts—to the judges surprise and the attorneys involved none of them expected Plaintiff to have responded with counter-moves to every deceptive act exercised at him in the courts;

9.)    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)

A-    The failure to respond to an adversary pleadings by standing on a Motion to Dismiss rather than filing an answer, constitutes an admission of all well pleaded facts;

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.

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 (1^st Dist. 2005), a default was entered for failure to answer although an appearance had been filed;

10.)    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.

                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 (1^st Dist. 2005), a default was entered for failure to answer although an appearance had been filed;

                   

11.)    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 (1^st 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 (1^st 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 2^nd 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 (1^st Dist. 2005), a default was entered for failure to answer although an appearance had been filed;

B-    That Group Ex E from the 2^nd 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, and 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 (5^th 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

                                      ________________________________________________________________________

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                                        )                                                        

________________________________________________________________________

                                                    RE NOTICE OF FILING                                

    YOU ARE HEREBY NOTIFIED that on Feb. 12, 2016 Plaintiff has filed a ReNotice Motion Moving for Prove-Up Entering Default Judgment & Summary Judgment 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

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, 8^th 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 2^nd 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                                                         Father Michael Pfleger

Chicago, Ill. 60611                                                      St. Sabina

                                                                                   1210 West 78^th Pl.                                                                                                                

Courtesy Copies:                                           Chg. Il 60620

 US Attorney                                            FBI Robert J. Holley

 Zachary T. Fardon                                2111 West Roosevelt Road

219 S. Dearborn, 5^th floor                         Chicago, Ill. 60612

Chicago, Ill 60604

                                                          Leo High School

Hon Judge Neil Cohen                             7901 S. Sangamon

50 West Washington, Suite 2308                  Chicago, Il 60620

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 8^th St.                                       607 East Adams, Suite 1520

Springfield, Ill. 62703                               Springfield, Ill. 62701

                                                                    

Bruce Rauner                                             Alderman David Moore

100 West Randolph                                      Alderman Ed Burke 

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 8^th St.                                       Frederick Bates

Springfield, Ill. 62703                           60 East Van Buren, Suite 900

                                                                Chicago, Ill. 60605

                PLEASE BE ADVISED that on February 12, 2016, A Motion Moving for Prove-Up Defaulting the Defendants with Summary Judgment has been filed with the Circuit Court of Cook County and said copy have been delivered or emailed to the applicable parties;

Plaintiff will present the above captioned Motion at the Hearing of March 10, 2016 at 10:30 before Judge Valderrama in room 2305.

                                                             Respectfully Submitted

                                                                 Joe Louis Lawrence Counsel Pro Se

                                                                           PO Box 490075

                                                                      Chicago, Ill. 60649-0075

                                                                          312 927-4210

                                                                      joelouislaw@yahoo.com

                                                                         @joelouis7      

   

IN THE CIRCUIT COURT

OF

COOK COUNTY, ILLNOIS

CHANCERY DIVISION

In Re Racial Discrimination/Source Income Violations

Housing Matters:                                                               

Joe Louis Lawrence                                                               Case # 2015 CH 01670

            Plaintiff                                                                  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                                                                                             

           Defendants 

                                                                                               

                                                                   ORDER 

THIS CAUSE COMING TO BE HEARD on PROVE-UP Entering Judgment Prove-up Defaulting the Defendants Granting Summary Judgment Instanter case is before the Court on the Plaintiff Joe Louis Lawrence’s being present, the Defendants being served and in Default, the court being fully advised in the premises and having heard the testimony and considering all facts as evidence.

IT IS HEREBY ORDERED THAT THIS COURT finds the issues in favor of the Plaintiff on all issues pursuant to the testimonies and affidavits presented before this court:

IT IS FURTHER ORDERED THAT THE COURT ENTERS JUDGMENT on the findings against the Defendants for the Relief Prayed for against 420 East Ohio, Chicago Housing Authority, 345 East Ohio, City of Chicago, Commission on Human Relations and K2 Management pursuant to 735 ILCS 5/2-1005, Punitive Damages to the City that will be determined at a later Hearing and JUDGMENT OF $25 MILLION DOLLARS plus costs;

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).

Plaintiff is Born and Raised a Heterosexual United States Citizen a Freeman and he alleges that the Defendants have defaulted on their obligation to respond to the summons or any motions accompanied by affidavits.

A trial court is required to construe the record against the moving party and may only grant summary judgment if the record shows that the movant’s right to relief is clear and free from doubt. Id. If disputes as to material facts exist or if reasonable minds may differ with respect to the inferences drawn from the evidence, summary judgment may not be granted. Assoc. Underwriters of Am. Agency, Inc. v. McCarthy, 356 Ill. App. 3d 1010, 1016-17 (1^st Dist. 2005).   

When the party moving for summary judgment supplies evidentiary facts which, if not contradicted, would entitle him to judgment, the opposing party cannot rely upon his complaint or answer alone to raise issues of material fact. Smith v. St. Therese Hospital, 106 Ill.  App. 3d 268, 270 (2d Dist. 1982). A counter affidavit is necessary to refute evidentiary facts properly asserted by affidavit supporting the motion or else the facts are deemed admitted. Barber-Colman Co. A And K Midwest Insulation Co. 236 Ill.  App. 3d 1065, 1078 (5^th Dist. 1992). 

That said  2^nd Amended Complaint was filed to recover damages and bring to the courts attention the “fraudulent” acts perpetrated by attorneys “sandbagging” the courts violating individuals “Civil Rights” just to obtain an advantage before any judge, Defendants have not raised any affirmative defenses or counterclaims.

Here, Plaintiff has supplied Affidavits and other evidentiary material that establishes all of the elements necessary to entitle it to recovery under the parties’ agreements, including the amount of damages. Defendants have failed to submit any evidence in opposition to the Motion in order to raise any genuine issues of material fact. Thus, summary judgment is proper.

Based on the foregoing, it is FURTHER ORDERED:

1.)    Plaintiff’ Joe Louis Lawrence’s Motion for Summary Judgment is GRANTED.

Judgment is entered in favor of Plaintiff and against Defendants 420 East Ohio, Chicago Housing Authority, 345 East Ohio, City of Chicago, Commission on Human Relations severally and jointly of $25 Million Dollars Pursuant to Smith V. Wade, 461 U.S. 30, 35. 103 S. Ct. 1625, 1629 75 L Ed 2d 632 (1983) that because of the noted depraved acts of all parties pay punitive damages, of $25 Million Dollars Plaintiff has endured in these matters;

2.)    For an Order Recommending a Special Prosecutor outside of States Attorney Anita Alvarez, Attorney General Lisa Madigan’s jurisdiction due to the political influence involved and them ignoring the criminal acts perpetrated by “Powerful” White Men in authority;

  

3.)    For an Order REVERSING the Commission’s order for failing to follow Supreme Court rules and procedures;

4.)    For an Order Imposing Sanctions Fining CHA, City personnel and all attorneys and law firms $20,000.00 - $30, 000.00 a day to the appropriate entity until Plaintiff is expeditiously housed with a CHA voucher;

5.)    Prohibit any Attorney from delaying prosecution of this matter with frivolous continuances due to Plaintiff and family suffering behind said acts being Homeless;

6.)    For an Order Remanding every Party and attorneys disbarring them complicit in said Criminal acts ignoring and covering-up said unlawful acts of all parties;

7.)    For an Order Compelling  all Parties to appear before a Court or Grand Jury to determine who should be INDICTED for their part in said Conspiracy;

8.)    For an Order Appointing an Independent Examiner to ascertain all persons removed from the CHA section 8 program in the last 4 years where the City of Chicago, Human Relations Commission and Hearing Officers under CHA’s authority dismissed their complaints unlawfully;

                                                           _____________________________

                                                            ENTERED

                                                             

                                                             ____________________________