HOW A JUDGE IS BLATANTLY EXERCISING RACIAL DISCRIMINATION VIOLATING EQUAL PROTECTION OF THE LAWS UNDER THE DEPARTMENT OF JUSTICE & FBI NOSE:
The Judge outright DENIED every unopposed Motions with Affidavits where all of the attorneys admitted to my pleadings proving Racial Discrimination, Housing Discrimination and Source Income Violations.
The judge proved his inferior position as a Negroe by helping the whites by lying and helping the white attorneys in granting them extensions of time, ignoring "FRAUD" "PERJURY" and never questioning the unsigned documents (court orders) that was put in front of his face demonstrating racial conspiracies attorneys helping the building managers uphold all type of criminal acts with the judges support!
Negroe judges or police and especially those in political power do not have jurisdiction over whites committing crimes on persons of color, they only enforce laws unlawfully on their own race, THEY ARE ONLY FIGUREHEADS-----THIS IS WHY CHICAGO IS CORRUPT RACIST AND VIOLENT BLACK IRISH OR POLISH ESPECIALLY DO NOT RULE IN FAVOR OF ANY PERSON OF COLOR WHERE CRIMES ARE COMMITTED, THERE ARE SOME LATINOS AND OTHER JUDGES WHO SOMETIMES FIT THE ABOVE CRITERIA.
BLACK JUDGES ARE WORSE THAN ANY RACIST JUDGE ON THE BENCH AND WILL DO ANYTHING FOR THEM TO BE ACCEPTED!
Civil Rights
civil rights: an overview
A civil right is an enforceable right or privilege, which if interfered with by another gives rise to an action for injury. Examples of civil rights are freedom of speech, press, and assembly; the right to vote; freedom from involuntary servitude; and the right to equality in public places. Discrimination occurs when the civil rights of an individual are denied or interfered with because of their membership in a particular group or class. Various jurisdictions have enacted statutes to prevent discrimination based on a person's race, sex, religion, age, previous condition of servitude, physical limitation, national origin, and in some instances sexual orientation.
The most important expansions of civil rights in the United States occurred as a result of the enactment of the Thirteenth and Fourteenth Amendments of the U.S. Constitution. The Thirteenth Amendment abolished slavery throughout the United States. See U.S. Const. amend. XIII. In response to the Thirteenth Amendment, various states enacted "black codes" that were intended to limit the civil rights of the newly free slaves. In 1868 the Fourteenth Amendment countered these "black codes" by stating that no state "shall make or enforce any law which shall abridge the privileges or immunities of the citizens of the United States... [or] deprive any person of life, liberty, or property without due process of law, [or] deny to any person within its jurisdiction the equal protection of the laws." See U.S. Const. amend. XIV. Section Five of the Fourteenth Amendment gave Congress the power by section five of the Fourteenth Amendment to pass any laws needed to enforce the Amendment.
During the reconstruction era that followed, Congress enacted numerous civil rights statutes. Many of these are still in force today and protect individuals from discrimination and from the deprivation of their civil rights. Section 1981 of Title 42 (Equal Rights Under the Law) protects individuals from discrimination based on race in making and enforcing contracts, participating in lawsuits, and giving evidence. See 42 U.S.C. § 1981. Other statutes, derived from acts of the reconstruction era, that protect against discrimination include: Civil Action for Deprivation of Rights (See 42 U.S.C. § 1983); Conspiracies to Interfere With Civil Rights (See 42 U.S.C. § 1985); Conspiracy Against Rights of Citizens (See 18 U.S.C. § 241); Deprivation of Rights Under Color of Law, (See 18 U.S.C. § 242); The Jurisdictional Statue for Civil Rights Cases (See 28 U.S.C. § 1443); and Peonage Abolished (See 42 U.S.C. § 1994).
The most prominent civil rights legislation since reconstruction is the Civil Rights Act of 1964. Decisions of the Supreme Court at the time limited Congressional enforcement of the 14th Amendment to state, rather than individual, action. (Since 1964 the Supreme Court has expanded the reach of the 14th Amendment in some situations to individuals discriminating on their own). Therefore, in order to reach the actions of individuals, Congress, using its power to regulate interstate commerce, enacted the Civil Rights Act of 1964 under Title 42, Chapter 21 of the United States Code. Discrimination based on "race, color, religion, or national origin" in public establishments that have a connection to interstate commerce or are supported by the state is prohibited. See 42 U.S.C. § 2000a. Public establishments include places of public accommodation (e.g., hotels, motels, and trailer parks), restaurants, gas stations, bars, taverns, and places of entertainment in general. The Civil Rights Act of 1964 and subsequent legislation also declared a strong legislative policy against discrimination in public schools and colleges which aided in desegregation. Title VI of the Civil Rights Act prohibits discrimination in federally funded programs. Title VII of the Civil Rights Act prohibits employment discrimination where the employer is engaged in interstate commerce. Congress has passed numerous other laws dealing with employment discrimination. See Employment Discrimination.
The judiciary, most notably the Supreme Court, plays a crucial role in interpreting the extent of the civil rights, as a single Supreme Court ruling can alter the recognition of a right throughout the nation. Supreme Court decisions can also affect the manner in which Congress enacts civil rights legislation, an occurence that occurred with the Civil Rights Act of 1964. The federal courts have been crucial in mandating and supervising school desegregation programs and other programs established to rectify state or local discrimination.
1.) On today's Motion call the judge heard evidence where 345 East Ohio and K2 had been served properly and were in Default, I presented an Affidavit from Dorothy Brown showing 345 East Ohio, CHA, 420 East Ohio and City of Chicago, Commission on Human Relations were served summons personally.
2.) He also had the green receipt showing Frank Fiorentino signed for the summons at 345 East Ohio the attorney told the judge they thought this was a Civil Suit and not an Administrative Hearing Case------The judge asked me to explain how is it 345 East Ohio was a part of this suit?
I explained to him 345 East Ohio like 420 East Ohio and K2 management were the subject of Housing Discrimination Complaints filed by the Department of Human Rights Commission of Chicago, there were two other buildings 175 North Wacker and Trio.
Trio and 345 are part of Village Green management the City had evidence of the units not allowing me to move into the buildings because of my skin color where I had credit scores of 716, they went against the Manifest Weight of the Evidence and presented me a court order with no signature which is the subject of "Fraud" somebody from the City had someone to mail to me that the cases against all these parties were Dismissed, trying to cover up the criminal acts lodged in my complaints where CHA was involved as well; however, when I challenged the veracity of the order purportedly sent by an alleged Human Rights Commissioner it went ignored because they are without Contempt Power to act on the allegation is how this matter made it here before Chancery as an Administrative Matter, furthermore, you are aware just last week an attorney Ms Heinz or Hemp was here last week from 345 and you informed her, she was not a part of this extension and Yuleda Joy representing K2 have always been here claiming they were not served.
This court has the jurisdiction act on the issues presented in the complaint that the City Commission had no jurisdiction on---The City attorney Santos was present and CHA Gen Counsel TB King and 420 had an attorney were in attendance not one person opened their mouths to Object or deny anything, I said in that court, (You could hear a Rat piss on cotton)
The Judge gestured with an understanding but became noticeably agitated with my response asked the attorney Ms Rahimi how did she know to come to court today since her contention was that they were not served and counsel here, I mean Mr Lawrence has presented me evidence you were in fact served?
Ms. Rahami said she was not familiar with the name mentioned and that the law firm was receiving service not the building in question we were only coming to court as observers so as to have a legal strategy protecting our clients (This was the worse crock of Shit, I ever heard of), The judge became more agitated said he was about to grant me my motion to her emphatically, asked her in a coaching like manner, "what are you going to do"? she was nervous as HELL! Her reply, can I have 28 days Judge immediately said granted never looking at me asked me how much time do I need to respond? I said 7 days. I'M LIKE WHAT THE FUCK!
The the judge said he had 3 Motions which, I had no knowledge of and told the judge I was at the mailbox yesterday and there was nothing there from anyone filing anything in the courts, it was a freaking mess nothing happened but it is my understanding, CHA, 420 East Ohio and the City of Chicago Bullshitted the judge did not respond to the 2nd Amended Complaint; thereby again admitting to all facts placing the in DEFAULT---I WONDER HOW MUCH MONEY IS ALLEGEDLY BEING PAID FOR THIS JUDGE TO FIX THIS CASE?
3.) Last Year, I filed a Motion for Reconsideration (April 21, 2015) with an Affidavit reiterating all of the aforementioned, the judge ignored everything, I said and DENIED my Motion only because of my skin color, for example, Page 6, Par C, Plaintiff responded Page 10, Line 24, Page 11, Lines 1-8 from a court transcript, "No sir, you are incorrect. There were two orders without signatures and without signatures or a stamped seal validating the veracity pursuant to Supreme Court Rule 272, that is the basis of why this matter is brought before this court. And I had challenged the validity of that with the commission. No one signed any orders. As a matter of fact they sent me an order with the wrong date and year.
4.) Judge Valderrama acknowledged receiving orders,, Page 12, Lines 10-13 Thank You, I do have----I have seen this, this order denying request for review. And I have read it. Thank You, I am not sure how it ties in though. I've read that document.
5.) This judge is demonstrating to everyone how and what he is willing to do to protect and uphold criminal acts in his courtroom not caring who is watching because as a Machine Democrat they are untouchable!
CHICAGO NEEDS MILITARY SUPPORT TO ROOT OUT THIS LEVEL OF TERRORISM IN THE COURTS!
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. 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 (1st
Dist. 2005), a default was entered for failure to answer although an
appearance had been filed;
B-) That on Jan. 28, 2015 an attorney appeared
in court on behalf of 345 East Ohio and was informed by the court she was not a
part of the orders parties seeking an extension of time.
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;
A-
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;
B-
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;
A.) 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.
B.) 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.
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 $10 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
CERTIFICATE OF SERVICE
Commander & Chief Attorney
General of United States
President Barack
Obama
Eric Holder
The White House U.S. Department of Justice
1600 Pennsylvania Avenue NW 950 Pennsylvania Avenue, NW
Washington, DC 20500 Washington, DC 20530-0001
1600 Pennsylvania Avenue NW 950 Pennsylvania Avenue, NW
Washington, DC 20500 Washington, DC 20530-0001
Chicago Housing
Authority Wilson Elser
Moskowitz Edelman & Dicker LLP
Office of the General Counsel Christian T. Novay
Asst Gen Counsel 55 West
Monroe, Street, Suite 3800
Maria Sewell Joseph Chicago, Il
60603
60 East Van Buren
Chicago, Ill 60605
TO AAG Tyler
Roland Chief Judge Timothy Evans, Daley Center, Chg., Ill. 60601
General Law
Bureau Presiding Judge Jacobius, Daley Center, Chg. Ill. 60601
100 West
Randolph Street Suite 1300
Chicago, Ill.
60601 Clerk of Circuit Court Dorothy Brown, Suite 1001, Chg. Ill.
States Attorney, Anita Alvarez,
Daley Center, Chg. Ill. 60601
Atty Gen Lisa Madigan, 100 West
Randolph, Suite 1300 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
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
Governor
Bruce Rauner Media
Personnel
100 West Randolph
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
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
Hearing Officer CHA
Frederick Bates
60 East Van Buren, Suite 900
Chicago, Il 60605
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
Leo High School Terra London
Chicago, Ill.
60611
7901 S. Sangamon
Chicago,
Ill. 60620
Hon Dick Durbin Hearing
Officer CHA
525 South 8th St.
Springfield, Ill. 62703 60 East Van Buren,
Suite 900
Chicago, Ill. 60605
Father Pfleger Alderman David Moore 17th ward
St. Sabina
Chicago, IL. 60620
1210 West 78th Pl.
Chicago, IL. 60620
Alderman Ed Burke
2650
West 51st Street 302
Chicago,
Il 60632
PLEASE BE ADVISED that on January 29th, 2015, 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;
Respectfully Submitted
Joe Louis Lawrence Counsel Pro Se
PO Box 490075
Chicago, Ill. 60649-0075
312 927-4210
@joelouis7
IN THE CIRCUIT COURT
OF
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 345 East Ohio, K2 Management pursuant to 735 ILCS
5/2-1005, Punitive Damages to the Plaintiff and JUDGMENT OF $10 MILLION DOLLARS plus costs
for the enforcement of this matter;
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 a United States Citizen born and Raised a
Freeman and Plaintiff 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 (1st 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 (5th Dist.
1992).
That said 2nd
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 345 East Ohio, and K2 management severally and jointly of $10
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 $10
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.)
4.)
For an Order Imposing Sanctions Fining CHA and all
attorneys and law firms $20,000.00 - $30, 000.00 a day to the City of Chicago
until Plaintiff is expeditiously housed until said matters are appropriately
resolved in the courts voucher was the
issue;
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;
_____________________________
ENTERED
____________________________
JUDGE
No comments:
Post a Comment