1.) IN THIS CASE IF A JUDGE ALLEGEDLY PAID $10,000.00 FOR THE POSITION OF APPOINTMENT OF ASSOCIATE JUDGE IT IS KINDA RISKY FLEXING ON THAT JUDGE BECAUSE THEY CAN HURT THE PARTY AND POWERFUL PEOPLE RECEIVING KICKBACKS SELLING JUDGESHIPS.
2.) IF A COMPLAINT HAS BEEN FILED AGAINST THESE TYPE OF JUDGES TO THE JUDICIAL INQUIRY BOARD THEY WON'T DO ANYTHING BECAUSE OF THE JUDGES CONNECTIONS UNLESS THEY ARE BLACK OR BROWN OR INDEPENDENT WHITES:
3.) THE PRESENT ADMINISTRATION OF APPOINTED JUDGES BLACK MALES DAVID B. ATKINS, LEONARD MURRAY FRANKLIN U. VALDERRAMA ARE SELLOUTS THEY HAVE BEEN APPOINTED TO DO WHAT THE POWERFUL WHITE MEN IN CITY HALL TELLS THEM TO DO THEY ARE PUPPETS "HOUSE NIGGERS"
4.) MANY INDEPENDENT WHITES AND PEOPLE WHO HAVE MIGRATED TO THIS CITY FROM OTHER COUNTRIES ARE OUTRAGED AT THE TYPE OF BLACK MEN ON THE BENCH NOT STANDING UP AGAINST RACISM OR ADDRESSING IT IN THEIR RULINGS IN COURT:
5.) THE CAVEAT TO THIS CERTAIN BLACK MEN WHO HAVE BEEN APPOINTED AS ASSOCIATE JUDGE IS ALLEGEDLY DATING CERTAIN IRISH MEN IN POWER OR OTHER WHITE MEN IN POWER, THIS IS AMERICA PEOPLE HAVE A RIGHT TO BE WITH WHOM EVER THEY WANT BUT WHEN WHO YOU ARE DATING INFRINGES ON THE CIVIL LIBERTIES OF INNOCENT PEOPLES LIVES YOU ARE NO BETTER THAN THE KU KLUX KLAN.
THIS IS NOT AN INDICTMENT AGAINST THE LGBT COMMUNITY BUT ENLIGHTENMENT TO SHED LIGHT AND KNOWLEDGE TO THE PUBLIC EVERY WALK OF LIFE IS INVOLVED IN THIS MATTER.
IT IS THE CONSENSUS OF MANY KEEPING WITH THIS CASE AND CLERKS UNDER DOROTHY BROWN JUDGE VALDERRAMA IS A TICKING TIME BOMB, HE IS COGNIZANT OF WHAT THE WHITE JUDGES DID TO ME WHERE RACIAL INJUSTICE IS CONCERNED DARE ANYONE TO ADDRESS HIM ON WHAT HE HAS DONE TO ME IN COURT OR ANYONE ELSE, HE WANTS TO BE TREATED LIKE THE WHITE MEN WHO GOT AWAY WITH THEIR CRIMES NOT CARING ABOUT ANYBODY!!!!
HIS ACTIONS ON THIS CASE IS HOW WHITE RACIST MEN ACTUALLY RULE AGAINST PEOPLE OF COLOR FROM THE BENCH AS DEMOCRATS, TIMOTHY EVANS AS THE CHIEF JUDGE WON'T SAY NOTHING BECAUSE HE IS ONLY A FIGUREHEAD!
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
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
MOTON
FOR RECONSIDERATION VACATE (MARCH 10) ORDER DUE TO CIVIL RIGHTS VIOLATIONS,
TERRORISTS ACTS, BIAS, PREJUDICE CONDUCT pursuant to S.H.A. 735 ILCS 5/2—1001
(a) (2,3) CORROBORATION OF FRAUD,
PERJURY, CONSPIRACY
REMAND/BODY
ATTACHMENT INSTANTER
IMPOSE SANCTIONS
w/AFFIDAVIT
Now comes Petitioner, Joe Louis Lawrence,
Attorney Pro Se, in this cause respectfully represents to this court the
reasons and files herewith his Affidavit in support for said Motion for
Reconsideration Vacate Order (March 10th) Due to Civil Rights Violations,
Terrorists Acts, Bias, and or Prejudice Corroboration of Fraud, Perjury,
Conspiracy Misrepresentations To Court Remand/Body Attachment Instanter Impose
Sanctions, pursuant to the Ku Klux Klan
Act of 1871, Section 1983 of
U.S.C.S., S.H.A. Criminal Ch. 38, 33-3, Civil Rights Act of 1964, Canon 3D (1)
Reporting Judicial Misconduct, 3D (2) Reporting Lawyer Misconduct (as a Pro Se Counsel);
Respectfully Submitted,
Joe Louis Lawrence
Petitioner
312 927-4210
joelouislaw@yahoo.com
Twitter @joelouis7
AFFIDAVIT
I Joe Louis Lawrence, being duly sworn on
oath states:
1.)
That
Judge Franklin U. Valderrama knowingly with malicious intentions committed Fraud /Erred demonstrated Bias and
or Prejudice conduct in said March 10th court order, in Denying/Quashing Subpoena
saying, “The subpoena served upon Leo High School is quashed as the
subject-matter of the subpoena is not related to the Complaint presently before
the court ;
A- Motions for Reconsideration are
designed to bring to the court’s attention newly discovered evidence that was
unavailable at time of original hearing, changes in existing law, or errors in
court’s application of law. Continental
Cas. Co. v. Security Ins. Co. of Hartford, App. 1 Dist. 1996, 216 Ill. Dec.
314, 279 Ill. App. 3d 815, 665 N.E. 2d 374, appeal dismissed, et al.;
B-
The purpose of a Motion to Vacate is to alert
the trial court to errors it has made and to afford an opportunity for their
correction. In re Marriage of King, App.
1 Dist. 2002, 270 Ill. Dec. 540, 336 Ill. App. 3d 83, 783 N.E. 2d 115,
rehearing denied pending appeal; et al.
C- 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.
D-
The above
is Basic State Law—certain Judges and attorneys do not seem to have a comprehensible understanding
of the legal procedures in how laws are
to be enforced; thereby, engaging in a plethora of corrupt legal practices
violating petitioner’s Civil Rights.
2.)
That Judge Valderrama continued to exercise Bias and or Prejudice conduct continued to ignore all legal aspects
demonstrating that said subpoena had a prima facie cause for this court to
enforce “Contempt Power” that Group
Ex B of the 2nd Amended Complaint, Petitioner filed a
Judicial Complaint with the Judicial Inquiry Board, Page 2 Par. 8, Gr Ex ‘s B and C totaling more than 25 pages of retaliatory discrimination
on the part of Leo High school and Phillips High School;
A-
Judge Valderrama acknowledged receiving the Motion for
Disqualification of judge for Cause due to Bias (Civil Rights Violations) et
al. ignored the Motion because the other attorneys were not present in court
and ruled in favor of Leo High School, Principal Philip Messina who was without
an attorney did not object or Deny any of the assertions petitioner testified
to in court not owing the school any money; thereby, admitting being complicit
in said Terrorist Acts against Petitioners son
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.
INDUCING RELIANCE
To prevail in a cause of action for fraud,
plaintiff must prove that defendant made statement of material nature which was
relied on by victim and was made for purposes of inducing reliance, and that
victim’s reliance led to his injury.
Parsons
V. Winter, 1986, 1 Dist., 491 N.E. 2d 1236, 96 ILL Dec. 776, 142 ILL App 3d
354, Appeal Denied.
In Carter V. Mueller 457 N.E. 2d 1335
ILL. App. 1 Dist. 1983 The Supreme Court has held that: “The elements of a
cause of action for fraudulent misrepresentation (sometimes referred to as
“fraud and deceit” or deceit) are: (1) False statement of material fact; (2)
known or believed to be false by the party making it; (3) intent to induce the
other party to act; (4) action by the other party in reliance on the truth of
the statement; and (5) damage to the other party resulting from such reliance.
3.)
FOR THE RECORD: There was a court reporter present and said
Judge acted as if he didn’t care said what he wanted did whatever he wanted
maintaining “untouchable arrogance” pursuant to the very Motion requesting Disqualification for Cause,
rather than continue the matter to the 17th of March he ruled
against the legally prepared and properly served Subpoena by Cook County
Sheriffs;
735
ILCS 5/2—1001(a)(3) (West 2006). Although the statute does not define
“cause”, Illinois courts have held that in such circumstances, actual prejudice
has been required to FORCE REMOVAL of a judge from a case, that is , either
prejudicial trial conduct or personal bias. Rosewood Corp. n Transamerica Insurance Co., 57 Ill 2d 247, 311 N.E. 2d
673 (1974; In re Marriage of Kozloff, 101 Ill 2d 526, 532, 79 Ill. Dec 165 463
N.E. 2d 719 (1984); see also People v. Vance, 76 Ill. 2d 171, 181, 28 Ill. Dec.
508, 390 N.E. 2d 867 (1979). Moreover, in construing the term “cause” for
purposes of a substitution once a substantial ruling has been made in a case,
4.)
That Judge
Valderrama with vexatious “Contempt”
for the laws due to Bias and or Prejudice conduct became a law unto himself is further demonstrating as long
as he is wearing a robe nobody can tell him what to do or how to enforce the
laws, if racist judges can all get away with criminal acts fixing a paternity
case where the petitioner is concerned, it’s as if he is daring anyone to say
anything to him at how this case is being “FIXED”,
pursuant to Sup Ct. Rule 71, Sufficient for Removal, conduct which
does not constitute a criminal offense may be sufficiently violative of the
Judicial canons to warrant removal for cause. Napolitano v. Ward, 457 F 2d 279 (7th Cir.), cert denied,
409 U.S. 1037, 93 S. Ct. 512, 34 L. Ed. 2d 486 (1972).
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.
U. S Sup Court Digest 24(1) General Conspiracy
U.S. 2003. Essence of a conspiracy is an
agreement to commit an unlawful act.—U.S. v. Jimenez Recio, 123 SCt. 819, 537
U.S. 270, 154 L.Ed.2d 744, on remand 371F.3d 1093
Agreement
to commit an unlawful act, which constitutes the essence of a conspiracy, is a
distinct evil that exist and be punished whether or not the substantive crime
ensues.-Id.
Conspiracy
poses a threat to the public over and above the threat of the commission of the
relevant substantive crime, both because the combination in crime makes more
likely the commission of other crimes and because it decreases the part from
their path of criminality.-Id.
CONSPIRACY
Fraud maybe
inferred from nature of acts complained of, individual and collective interest
of alleged conspirators, situation, intimacy, and relation of parties at time
of commission of acts, and generally all circumstances preceding and attending
culmination of claimed conspiracy Illinois Rockford Corp. V. Kulp, 1968, 242
N.E. 2d 228, 41 ILL. 2d 215.
Conspirators to be guilty of offense
need not have entered into conspiracy at same time or have taken part in all
its actions. People V. Hardison, 1985, 911 Dec. 162, 108.
Requisite mens rea elements of conspiracy are satisfied upon showings of agreement of offense
with intent that offense be
committed; Actus reas
element is satisfied of act in furtherance of agreement People
V. Mordick, 1981, 50 ILL, Dec. 63
Supreme Court Rule [137] provides in
pertinent part:
If a pleading, motion, or other paper is signed in
violation of this Rule, the court, upon motion or upon its own initiative, may
impose upon the person who signed it , a represented party, or both, an
appropriate sanction, which may include an order to pay to the other party or
parties the amount of reasonable expenses incurred because of the filling of
the pleading, motion, or other paper, including a reasonable attorney fee. Not
only will the courts consider an award of sanctions for active false
statements: failures to disclose material facts to the court can also justify
an award of sanctions.
BRUBAKKEN v. Morrison,
No. 1-9-1670, 1992 Ill App. LEXIS 2144 (1st Dist. Dec. 30, 1992).
Additionally, the fact that a false statement or omission is the result of an
honest mistake is no defense to entry of a sanction. ID. To the extent that an
individual lawyer has engaged in sanctionable conduct, that lawyer’s firm can
also be jointly and severally liable with the lawyer.
A- 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.
B- Said judge have demonstrated he is “Above the Law” and has employed
tactics validating the veracity of said assertions in the aforementioned acts Vaughn 462 S.E. 2d 728 (Ga. 1995), The
Supreme Court of Georgia removed a judge from office for disregarding
defendant’s constitutional rights.
5.) Said judges have
failed to follow the laws under Canon 2A and the failure to apply the laws to
matters that come before them, 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”)
The Chicago Daily
Law Bulletin, Wednesday April 26, 2006, Page
1, Illinois Political Machines help breed corruption, Associated Press
writer Deanna Bellandi states, “Illinois
is apparently a Petri dish for corruption. It is a real breeding ground”.
That Chicago is the
most Corrupt City in America, Huffington Post, Internet
Newspaper, February 23, 2012; University of Illinois Professor Dick Simpson, “The two worst crime zones in Illinois are
the governor’s mansion…..and the City Council Chambers in Chicago.” Simpson a
former Chicago Alderman told the AP “no other State can match us.”
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
Petitioner/Counsel
Pro Se
WHEREFORE the
aforementioned reasons Petitioner respectfully Prays for the Relief
1.) For an Order REMANDING ALL parties
complicit in said ORGANIZED CRIMINAL CONSPIRACY RETALIATING and OPPRESSING
him and family EXHAUSTING TERRORISTS TACTICS PLACING HIM IN THAT STATE for
standing up to the Democratic Political Machine and Racial Injustice in the
courts, and Leo High School, Phillips High School;
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 for all damages, for the
enforcement of expenses delaying son from registering in the NCAA College
Recruitment process entering a University of merit;
2.) For an Order Vacating the March 10th, 2016 Court Order;
3.) For an Order Compelling all responsible PARTIES with NOTICE and KNOWLEDGE of
the aforementioned CRIMINAL ACTS who did nothing make them pay/absorb
Petitioners son’s costs training getting him into the University of his choice
as punitive Damages not excluding any costs;
4.) For the entry of an Order awarding to your Petitioner 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
Petitioner
Counsel Pro se
Certificate
of Service
Commander & Chief Attorney General of United States
President Barack
Obama
Loretta Lynch
The White House U.S. Department of Justice
1600 Pennsylvania Avenue NW 950 Pennsylvania Avenue, NW
Washington, DC 20500 Washington, DC 20530-0001
1600 Pennsylvania Avenue NW 950 Pennsylvania Avenue, NW
Washington, DC 20500 Washington, DC 20530-0001
Chief Judge Timothy Evans Judge Moshe
Jacobius
50 West
Washington, Suite 2600
50 West Washington, Suite 2403
Chicago,
Illinois 60601
Chicago, Ill. 60601
Judge
Mary Lane Mikva Clerk of
Circuit Court, Dorothy Brown
50 West
Washington, Suite 50 West
Washington, Suite 1000
Chicago, Ill
60601
Chicago, Ill. 60601
Atty. Gen, Lisa Madigan Asst. Atty. Gen
Tyler Roland
100 West
Randolph, Suite 1200 100
West Randolph, Suite 1200
Chicago, Ill.
60601
Chicago, Ill. 60601
States Attorney,
Anita Alvarez, Daley Center, Chg. Ill. 60601
Sec of State
Asst Deputy Dir. Candace Cheffin
Asst Gen Counsel Terrence McConville
60 East Van Buren, 8th floor
100 West
Randolph, Suite 500 Chicago, Ill. 60601
Chicago, Ill.
60601
CHA Mobility
CHA Mobility, HCP Counselors
Chris Klepper, Executive
Dir. Tracey Robinson/Joann
Harris
28 East Jackson
Blvd.
4859 S. Wabash, Suite 2nd Floor
Chicago, Ill
60604
Chicago, Ill. 60615
CHA Mobility, Real Estate Specialist Recorder of Deeds
Jessie McDaniel
Karen Yarbrough
4859 S.
Wabash
118 N. Clark, Room 120
Chicago, Ill.
60615 Chicago, Ill. 60602
City of Chicago, Department of
Buildings Sabre Investments
Christopher Lynch
120 West Madison Street
121 North
LaSalle, Room 900
Chicago, Ill 60601
Chicago, Ill.
60601
Seyfarth & Shaw
Anne D. Harris,
Jeffrey K. Ross, Kyle A. Petersen, Sara Eber Fowler Suite 2400
131 South
Dearborn
Chicago, IL.
60603
Chicago Housing Authority
Office of the
General Counsel, Maria Sewell Joseph, Thomas B. King
60 East Van
Buren
Chicago, IL.
60605
Cary G. Schiff &
Associates Gordon & Rees LLP
Christopher R. Johnson, Yuleida Joy Lindsay Watson, Christian T. Novay
134 N. LaSalle Street, Suite 1720 1 North Franklin, Suite 800
Chicago, Ill. 60602 Chicago,
Illinois 60606
Stephan R.
Patton, Mary E. Reuther, Rey A. Phillip Santos
Corp Counsel, Deputy Corp. Counsel, Asst
Corp Counsel
30 N. LaSalle
Street, Suite 800
Chicago, Ill
60602
Wilson Elser Moskowitz Edelman &
Dicker LLP
Christian Novay
55 West Monroe,
Street, Suite 3800
Chicago, Ill.
60603
Jessica Mallon, Gen Counsel CHA Roy Martinez Manager 420
East Ohio
60 East Van
Buren 420 East Ohio
Chicago, Ill
60601
Chicago, Ill. 60611
Eve Aywaz,
Sales Consultant Sarah
Aredia, Leasing Consultant
345 East Ohio 420 East Ohio
Chicago, Ill.
60611
Chicago, Ill. 60611
John-Paul
Loseto, Executive Manager
345 East Ohio
Father Michael Pfleger
Chicago, Ill.
60611
St. Sabina
1210 West 78th Pl.
Courtesy Copies: Chg.
Il 60620
US Attorney FBI
Dir. Michael J. Anderson
Zachary T. Fardon 2111 West Roosevelt Road
219 S. Dearborn, 5th floor Chicago, Ill. 60612
Chicago,
Ill 60604
Leo High School Principal Philip Messina
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 8th 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 Judge
525 South 8th St.
Frederick Bates
Springfield, Ill. 62703 50 West Washington
Chicago, Ill. 60601
Please be advised that on March 11, 2016, Petitioner has filed before this Circuit Court,
Motion for Reconsideration et al; and will present said legally sufficient
instrument before Judge Valderrama or any Judge in his stead March 17, at 9:30 am in room 2305.
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 Mar. 11, 2016.
________________________
Joe Louis
Lawrence
Counsel Pro Se
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