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Sunday, February 14, 2016


Dr Martin Luther King, Jr.'s struggles and death in vain for People of Color, Racism in Chicago has undermined the very policies of the Civil Rights struggles:

   1.)   This document shows America how the Democrats of the Political Machine have been able to recruit and appoint the necessary Blacks described as African Americans in various positions as Judges Aldermen etc. who has a self-hatred for themselves who would use their positions and authority to destroy people of color upholding racism and racial injustice.

   2.)   Black on Black crimes in Chicago is horrific but is worse in the political structure not one Black in Power stepped up to discuss the outrage perpetrated in this case because they have no real authority over white people corrupt in political power.

   3.)   So in actuality many see that the Blacks in power have either no backbone or integrity for themselves or their on constituents who voted them into office believing they have a voice in areas of racial injustice, discrimination or housing discrimination with certain persons of color are Bamboozled so other ethnic groups the Latinos some come along and BULLY SLAIN OR VIOLATE PERSONS OF COLOR CIVIL RIGHTS because they see the colored people don't say anything or speak up because they don't care so apathy sets in and nobody cares because #BlackandBrownlivesdontmatter.

WHY CONTINUE TO VOTE FOR PEOPLE THAT MAY LOOK LIKE YOU BUT DON'T REPRESENT YOU?



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 Feb. 12, 2016 Plaintiff has filed his Reply 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


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 March 17, 2016, Plaintiff will appear before Judge Valderrama at 10:00 am in room 2305 and present said reply motion.

                                                                        _________________________________
                                                                               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                                         )                                                         
________________________________________________________________________


                                                         PLAINTIFF’S REPLY
                     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 his Reply 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
                                                                                         joelouislaw@yahoo.com
                                                                                          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.


  1. Plaintiff’s Reply is Due March 11, 2016 but don’t need to wait because there is not a judge in this state or Country that will be able to “FIX” this case. Dr. Martin Luther King, Jr. said “Injustice Anywhere Is A Threat To Justice Everywhere” #BLACKANDBROWNLIVESMATTER #BLACKHISTORYMONTH


  1. 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)
  1. 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.  


  1. 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;


  1. 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;


  1. That on Feb. 5, counsel 345 East Ohio appeared before the court without filing an appearance where the judge had an impromptu Hearing on a Motion Call where the judge received and accepted an Affidavit Printout from Dorothy Brown, Clerk of the Circuit Court and green card receipt establishing the veracity a person from 345 East Ohio accepted the summons and complaint;


  1. Counsel 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;    
  1. That the judge asked, the Plaintiff a series of questions seeking to ascertain his legal understanding as to why and how 345 is named in the suit;


  1. Plaintiff  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;  


  1. 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!


  1. 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;


  1. That Plaintiff filed a Petition for Rule To Show Cause et al. (Nov. 5, 2015) Vacating the Nov. 2, 2015 Court Order et al. unequivocally demonstrating brazen contempt and “Fraud” by City attorneys, Page 7 Par. 14 pursuant to CCHR Reg. Rule 240.349 of the City of Chicago Human Relations Commission (2) Issues a written order after the pre-hearing conference which describes the motion or objection and sets forth the decision.


  1. That pursuant to a Motion for Disqualification et al. filed (April 2, 2015) Par 8, 9, Page 9 the judge ignored the service had on 345 East Ohio; Par. 10 of Page 10 validates the veracity of Judge Valderrama engaging in an Organized Conspiracy;


  1. That pursuant to the same Motion Par. 10, Page 6 Judge acknowledged receiving the very court orders he kept asking the Plaintiff about how this court have jurisdiction, said, “I have read it but I am not sure how that ties in though”


  1. That pursuant to Page 2, Par. 2 of Affidavit Motion for Reconsideration Vacate Order et al. filed (April 21, 2015) and Page 3 Par C Judge Valderrama stated, “The clerks office doesn’t serve anybody certified mail et al”
  2. Said judge and Defendant’s attorneys deliberately violated Plaintiff’s Civil Rights because he stood up to Racial Injustice, the court having cognizance of the FBI’s involvement and has received notice of said facts didn’t care  Jennings v. Patterson, 488 F. 2d 442, equal access to public facilities. The court found that the plaintiffs had been “denied the right to hold and enjoy their property on the same basis as white citizens.” Jennings suggests the potential usefulness of the equal benefit clause in guaranteeing full and equal enjoyment of public property and public services.” Developments  in the Law section 1981, 15 Harv. Civ. Rts. ---- Civ. Lib. L. Rev 29, 133 (1980). Said judge and the attorneys have demonstrated no regard for the FBI or Plaintiff’s Civil Liberties in his attempt to obtain Equal Access to the Courts (58)  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.


  1. That Judge Valderrama have DENIED every legally certified document filed and presented before this court, due to Plaintiff’s skin color never opposed and has GRANTED every and any “FRAUDULENT” document any white attorney absent affidavits or legal precedents which corroborates  Directed evidence of his role in said conspiracy;

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.        


  1. That 345 East Ohio (Village Green management) never filed an Appearance  and 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.   


A judge’s disrespect for the rules of court demonstrates disrespect for the law. Judges are disciplined under Canon 2 A for violating court rules and procedures. Judged ignored mandated witness order in attempt to accommodate witnesses’ schedules; Citing Canon 2A the court noted, “[a] court’s indifference to clearly stated rules breeds disrespect for and discontent with our justice system. Government cannot demand respect of the laws by its citizens when its tribunals ignore those very same laws”)
(14) Crawford v. State, 770 N.E. 2d 775 (Ind.)    
(15) Dash, 564 S.E. 2d 672 (S.C. 2002).


            
   8      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;


  1. 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” .


  1. 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.


  1. That Rule 183 does give judge’s 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).  


  1. That Plaintiff having been informed by his white colleagues that Irish or Polish judges would never rule in a brothers favor against their own referring to said ethnicity and furthermore, he was to forget about the so called Afro American Brother on the bench they have to do what they are told none of them will stand up to the white man, they are worse on your people that is how and why they were selected.


From the above tutor ledge Plaintiff had to develop pleadings that would enable “Corrupt Racist White men” to trap themselves and everybody regardless to their skin color was able to legally snitch on one another through Plaintiff’s pleadings.


So the old adage it’s who you know don’t fair in this case because it is what you should know that will determine many outcomes a real judge with integrity can now rule from the bench without political retaliation or oppression in the end Justice wins!      


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
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 any Motions or Responses 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;


3.)  For the reimbursement of all fees and costs associated in this matter.


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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