HERE IS A CASE AN ELDERLY COUPLE BEING REPRESENTED BY AN ATTORNEY WITH OVER 40 YEARS EXPERIENCE OF LAW WHO IS ELDERLY HIMSELF MEANS NOTHING TO JUDGES AS THEY HAVE COLLUDED WITH BANK ATTORNEYS SIGNING BLANK COURT ORDERS WHILE THE APPELLATE COURT JUDGES IN THE SECOND DIVISION IS PROTECTING CIRCUIT COURT JUDGE MICHAEL OTTO.
THEY HAVE SOLD THE BISHOP'S HOME HER HUSBAND A DOCTOR MIGRATED FROM AFRICA (GHANA) TO THE UNITED STATES HAVE EXPERIENCED MORE RACISM AND RACIAL INJUSTICE IN AMERICA HAS REALLY ASTOUNDED HIM TO LIFE IN AMERICA.
WHILE AMERICA IS SIDETRACKED ON THE ISSUES OF TRANSGENDER BATHROOMS IN NORTH CAROLINA AND ACROSS THE UNITED STATES.
WASHINGTON — President Obama on Monday made an impassioned argument for his administration’s decision to instruct public schools to allow transgender students to use the bathroom that matches their gender identity, saying that society must protect the dignity and safety of vulnerable children.
The remarks were the president’s first public comments on a directive released Friday that has added fuel to a searing national debate over transgender rights. Mr. Obama said the guidance, issued by the Education and Justice Departments, represented “our best judgment” on how to help schools wrestling with the issue.
“We’re talking about kids, and anybody who’s been in school, been in high school, who’s been a parent, I think should realize that kids who are sometimes in the minority — kids who have a different sexual orientation or are transgender — are subject to a lot of bullying, potentially they are vulnerable,” Mr. Obama said in an interview with BuzzFeed News. “I think that it is part of our obligation as a society to make sure that everybody is treated fairly, and our kids are all loved, and that they’re protected and that their dignity is affirmed.”
NOBODY IS TALKING ABOUT THE APARTHEID RACIAL CONDITIONS IN CHICAGO COURTS OR VIOLENT TERROR IN THE STREETS;
AN ELDERLY COUPLE WHO HAVE EARNED RECOGNIZABLE ACCOMPLISHMENTS IS SUBJECT TO TERRORIST ACTS OF JUDGES AND BANK ATTORNEYS STEALING HER HOME AND HAS SOLD IT IN THE NAME OF FORECLOSURE BECAUSE THESE ARE RACIST WHITE DEMOCRATS AND INFERIOR NEGROES WEARING ROBES THIS IS NOT A PRIORITY OR A CONCERN.
THEY ARE NOW WITHOUT GAS AND THEIR LIGHTS AND WATER IS PENDING DISCONNECTION AND THEY ARE NOW RECEIVING TICKETS AT THEIR HOME FOR NUMEROUS UNWARRANTED REASONS BECAUSE THE ATTORNEYS WANT THEIR PROPERTY.
THIS DOCUMENT WAS FILED IN THE ILLINOIS SUPREME COURT MAY 19, 2016.
JUDGES ARE DOING WHAT THEY WANT VIOLATING EVERY LAW NECESSARY AS THE DEMOCRATS OF THE OLD WHO WERE KU KLUX KLANS MEN AND THE SAD REALITY IS THAT BECAUSE SO MANY BLACK MEN ARE IN IDENTITY SITUATIONS OR ARE INFERIOR TO THESE MEN WON'T OPEN THEIR MOUTHS AGAINST THE MAYHEM INFLICTED ON PEOPLE OF COLOR OR LIBERAL WHITES WHEN IN FACT EVERYBODY IS AFFECTED BY THESE TERRORIST ACTS.
IT'S APPARENT UNDER THE DEMOCRATIC SYSTEM OF GOVERNMENT IN CHICAGO JUSTICE IS NOT AFFORDED TO PEOPLE OF COLOR, LIBERAL WHITES, HETEROSEXUALS, OR INDEPENDENT GAYS OR LESBIANS AND DEFINITELY NOT THE ELDERLY!!!!!!!!!!!!!!!
MANY OF YOU HAVE READ WHAT OTIS LOVE HAS ENDURED BY RACIST SEXIST CORRUPT JUDGES HE IS NOT ABLE TO SEE HIS DAUGHTER AND IT HAS BEEN 2 YEARS HE IS BROKE MUSTERING UP MONEY FOR LEGAL REPRSENTATION IT'S 2 YEARS HE HAS NOT SEEN HIS DAUGHTER BECAUSE HIS CHILD'S MOTHER LIED.
THE BANSA'S HAVE AN ATTORNEY AND JUDGES DON'T CARE THEY ARE NOT FOLLOWING ANY LAWS AND DON'T SEEM TO FEAR ANY AUTHORITY NOT THE FBI AND SURELY NOT PRESIDENT OBAMA BECAUSE MEN LIKE THIS DON'T RESPECT MEN OF COLOR.
I HAVE HAD ABOUT NINE ATTORNEYS TRYING TO REPRESENT ME NOBODY WAS ABLE TO DO WHAT, I HAVE DONE.
I WOULD LIKE TO THANK MY NEW VIEWERS TUNING IN TO MY BLOG FROM CURACAO AND BAHRAIN TOTALING 75 COUNTRIES AND MANY THANKS TO ALL OF MY TWITTER FOLLOWERS FOR ALL OF THEIR SUPPORT AND RETWEETS.
________________________________________________________________________
IN THE
SUPREME COURT OF ILLINOIS
________________________________________________________________________
HSBC BANK USA, NATL.
ASSOC. ) Appeal from
the Circuit Court of Cook County
) Chancery Division
Plaintiff-Appellee
) Gen No. 15-2393
) Division No. 2
) Hon Michael Otto
Hon’s Michael B. Hyman, Michael Otto )
P. Scott Neville, Daniel J. Pierce )
John B. Simon
)
V. ) Trial Court No. 12 CH 24000
DR. EMMANUEL BANSA AND )
BISHOP CONNIE
BANSA )
Defendant- Appellant
)
)
________________________________________________________________________
MOTION FOR WRIT OF MANDAMUS
FOR ISSUANCE OF A SUPERVISORY ORDER VACATING
ORDERS DUE TO CRIMINAL ACTS UNLAWFULLY SELLING HOME AND RECUSING JUDGES for “CAUSE”
DUE TO BIAS AND OR PREJUDICE CONDUCT PURSUANT TO S.H.A. 735 ILCS 5/2—1001 (a) (2,3)
(WEST 2006) TO IMPOSE SANCTIONS/REMANDS PURSUANT TO SUPREME COURT RULE 137 S.H.A.
CRIMINAL CH. 38, 33-3 W/AFFIDAVIT
_______________________________________________________________________
Now comes Plaintiff-Appellant, Dr
Emmanuel Bansa, Connie Bansa, a United States Citizen through their attorney
Joseph P. Harris respectfully moves this Honorable Court to enter an Order for
a Writ of Mandamus /Issuance of a Supervisory Order Vacating Orders due to
Criminal Acts Unlawfully Selling Home and Recusing Judges for “Cause” due to Bias and or Prejudice
Conduct Pursuant to S.H.A. 735 ILCS
5/2—1001 (a) (2,3) (West 2006) Impose
Sanctions/Remands Pursuant to Supreme
Court Rule 137 S.H.A. Criminal CH. 38, 33-3 with affidavit in the above entitled cause.
Reasons in
support of this motion are set forth in the attached affidavit.
Respectfully Submitted,
By: ____________________________
Joseph
P. Harris, Counsel For
Defendant /Appellants
STATE OF ILLINOIS )
)
COUNTY OF COOK )
AFFIDAVIT
I Attorney Joseph P.
Harris being first duly sworn on oath depose and states as follows:
1.)
Counsel filed an
Appearance in Cir. Ct. ref as Ex A, explaining all “Fraudulent Acts” where said
attorneys have Induced Reliance upon the courts for a favorable verdict;
2.)
That the Cir.
Ct. acted outside of its judicial discretion no attorney denied or Objected
to any of the merits of the motion, the court struck the very defenses
demonstrating “Fraud” against the Plaintiffs,
hereto attached, Ex B;
3.) Pursuant
to Supreme Court Rule 71, Sufficient
for Removal, conduct which does not constitute a criminal offense maybe
sufficiently violative of the Judicial Canons to warrant removal for cause. Napolitano v. Ward, 457 F 2d 279 (7th
Cir)
4.)
In furtherance to Par.
3, Motion for Reconsideration was filed and the judge ignored the errors
which have now culminated into an “Organized Criminal Conspiracy”, the
court entering an order Denying the Motion as Ex C outside of its jurisdiction and based upon “Fraud” making it a
Void Order ILL.
App. (1st Dist. 2000). A “VOID JUDGEMENT OR ORDER” is one that is
entered by a court lacking jurisdiction over the parties or the subject matter,
or lacking the inherent power to enter the particular order of judgment, or
where the order was procured by FRAUD- in re Adoption of E.L., 248 ILL. Dec.
171, 733 N.E. 2d 846, 315 ILL. App. 3d 137- Judgm 7, 16, 375. hereto attached, Gr Ex D;
5.)
Counsel Due-Diligently filed a Notice of Appeal,
hereto attached, Ex E;
6.)
Counsel
Due-Diligently filed an Emergency Motion to Stay the Sale Scheduled for April
8, 2016, until the Appellate Court rulings have been entered, hereto attached, Gr Ex F (filed April 5, 2015);
7.)
The Appellate Court acted in collusion to the Cir Ct
expeditiously denied said Motion April 6, 2016, hereto attached Ex G, no attorney denied or objected to
any of the Motions Counsel has respectively put before the courts;
A- The court stated, “The Certificate of Service does not indicate the manner of service,
whether personal delivery or, email, via facsimile et al”
B- That
Gr Ex G did in fact state the manner
in how service was had the only error was in fact the month but the April 5th
Court Stamp demonstrated said veracity;
8.)
That the Plaintiffs
filed a Motion Dismissing said Appeal for want of jurisdiction, hereto
attached, Gr Ex H;
9.)
Counsel due-diligently filed a Motion Objecting
Dismissal et al. (April 13, 2016), hereto attached, Gr Ex I,
10.)
That the Appellate Court immediately denied said Motion, April 14, 2016,
hereto attached, Ex J;
11.)Counsel due-diligently filed an
Amended Motion Objecting to Dismissal of Appeal for Want of Jurisdiction,
hereto attached, Gr Ex K, making
sure the “Fraudulent Orders” were attached, ( April 15, 2016);
A-
The Appellate Court ignored said Affidavit, Supreme
Court Rules violated Canon Ethics engaged in an “Organized Conspiracy” closed their eyes to both court orders
demonstrating the Cir. Ct. never had jurisdiction;
B-
The Appellate Court by ignoring the legal areas of law
have now condoned and is complicit in criminal acts;
C-
12.)Counsel due-diligently filed a
Motion for Reconsideration & Vacate (April 14, 2016) Order due to Error,
hereto attached, Gr Ex L;
13.)The Appellate Court judges due to
Bias, Prejudice Conduct towards Counsel pursuant to S.H.A. 735 ILCS 5/2—1001 (a) (2,3) engaged in a diabolical
conspiracy by denying every legally certified motion accompanied by an
affidavit;
A- Hereto
attached, Ex M,(April 14th court order) Appellate Court Judge Daniel
J. Pierce acknowledged the April 15th Motion stated, “the objection is noted and Denied” back
dated the court order to April 14th, 2016;
B- Hereto
attached, Ex N, (April 14th
court order) Appellate Court judges Daniel J. Pierce, Michael B. Hyman and P.
Scott Neville underlined Petition for a Stay of the sale of the Elderly
Defendants and Denied said motion;
C- Hereto
attached, Ex O (April 14th
court order) Appellate Court Judges Daniel J. Pierce, P. Scott Neville and
Michael B. Hyman, Granted Plaintiff’s Motion to Dismiss said Appeal and
Dismissed it for want of jurisdiction;
14.) That
because of the judges active participation in an “Organized Conspiracy”
Denied the Motion noted in Par 12, Gr Ex L, (April 28, 2016), hereto
attached, Ex P;
15.)Hereto attached, Ex Q (April 18, 2016) court order
judges found said “Fraudulent Court Orders as being Moot Denied said Motion;
A-
Pursuant to 735 ILCS 5/2-612 Counsel never
Objected to the sufficiency of Petitioners pleadings, Objections to sufficiency
of pleadings either in form or substance must be made In trial court, and if
not so made, they will be considered waived and cannot be raised for the first
time on appeal. People ex rel. Deynes v. Harris, App. 1948, 77 N.E. 2d
439, 333 Ill. App. 280.
B-
Counsel for defendants
waived any defects against Petitioner in any pleadings by failing to object,
any defects in pleadings, either of form or substance, not objected to in trial
are waived on appeal. Geleto v. Giglietti, 1976, 40 Ill.App 3d 226, 352 N.E.
2d 1; In re Leyden Fire Protection Dist., 1972, 4 Ill. App. 3d 273, 280 N.E. 2d
744; Lyon v. Metropolitan Life Ins. Co., 1942, 315 Ill. App. 451, 43 N.E. 2d
187.
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.
16.)In that pursuant to Vigus v. O’Bannon 1886 8 N.E 788, 118 ILL 334. Hazelton V.
Carolus, 1907 132 ILL. App. 512
A-
In ref to Case# 15
CH 01670 Chancery Judge Franklin U. Valderrama used his robe and authority
to deny a young man Equal Protection of the Laws denied everything he filed in
a Housing Discrimination Source Income Discrimination matter clear with racist
acts;
B-
That man is legally homeless because the courts closed
their eyes to the horrific acts he experienced in the courts upholding
Terrorist Acts;
C-
That the judges found said exhibits in this matter
corroborating “Fraud” moot (May 4th)
when the Motion was in fact filed timely curing said defects April 15, Amending
the Motion.
D-
That said judges ignored the fact a court order was in
fact tendered absent a judges signature violating Supreme Court Rule 272 which was Ex A;
That because of the above; 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
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.
17.) That many Judges are collectively
acting outside of their discretion and is undermining the very laws installed
to make the jurisprudence of the courts operate with integrity and in an
unbiased manner, justice seems to lie in the court of the beholder not in
accordance to any rules or civil procedure.
18.)
That said judges demonstrated racial hatred and elderly hatred made it clear in
Ex N underlining “Petition for a Stay of the sale of the
Elderly Defendants” was Denied with emphasis;
A-
That because certain judges are entering
orders outside of their discretion and judicial immunity provisions of the laws
where “Fraud” is apparent, the law is clear ILL. App. (1st Dist. 2000). A “VOID JUDGEMENT
OR ORDER” is one that is entered by a court lacking jurisdiction over the
parties or the subject matter, or lacking the inherent power to enter the
particular order of judgment, or where the order was procured by FRAUD- in re
Adoption of E.L., 248 ILL. Dec. 171, 733 N.E. 2d 846, 315 ILL. App. 3d 137-
Judgm 7, 16, 375.
19.)That the App. Ct. judgs acted outside of judicial
discretion and judicial immunity provisions collectively denied everything
Counsel presented with affidavits and because of this Defendants are now being
harassed physically and intimidated their gas has been cut off and their water
and electricity is pending disconnection this month and are receiving
unwarranted tickets at their home for violations they have not experienced
since living there.
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.
B-
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 371
F.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;
C-
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.
D-
Section
1983 of U.S.C.S. contemplates the depravation of Civil Rights through the
Unconstitutional Application of a Law by conspiracy or otherwise. Mansell v.
Saunders (CA 5 F 1A) 372 F 573, especially if the conspiracy was actually
carried into effect, where an action is for a conspiracy to interfere with
Civil Rights under 42 U.S.C.S. 1985 (3), or for the depravation of such rights
under 42 U.S.C.S. 1983, if the conspiracy was actually carried into effect and
plaintiff was thereby deprived of any rights, privileges, or immunities secured
by the United States Constitution and Laws, the gist of the action maybe
treated as one for the depravation of rights under 42 U.S.C.S. 1983, Lewis
v. Brautigam (CA 5 F 1a) 227 F 2d 124, 55 Alr 2d 505, John W.
Strong, 185, 777-78 (4 th ed. 1992).
Finally, this document is best closed by a jurist who has stated”;
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”)
Most recently stated in Federal Court FEDERAL JUDGE GETTLEMAN:
stated, Tuesday March 10, 2009, where he found Superintendent of police Jody
Weiss in Contempt of Court and Ordered the City to Pay $100,000.00, “No
one is above the Law”, he cited a 1928 decision by Supreme Court
Justice Louis Brandeis, that said, “If the Government becomes the law
breaker, it breeds Contempt for the Law, It invites everyman to become a law unto
himself. It invites Anarchy.”
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 NOT
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,
Joseph P. Harris
____________________________
Counsel for Petitioner Appellant
Counsel for Petitioner
28618
417 South Des Plaines, St. 165
Forest Park, Illinois 60130
312 608-2494
NOTARY
________________________________________________________________________
IN THE
SUPREME COURT OF ILLINOIS
________________________________________________________________________
HSBC BANK USA, NATL.
ASSOC. ) Appeal from
the Circuit Court of Cook County
) Chancery Division
Plaintiff-Appellee
) Gen No. 15-2393
) Division No. 2
) Hon Michael Otto
Hon’s Michael B. Hyman, Michael Otto )
P. Scott Neville, Daniel J. Pierce )
John B. Simon )
V. ) Trial Court No. 12 CH 24000
DR. EMMANUEL BANSA AND )
BISHOP CONNIE
BANSA )
Defendant- Appellant
)
)
________________________________________________________________________
PETITION FOR
WRIT OF MANDAMUS
FOR ISSUANCE OF A SUPERVISORY ORDER VACATING
ORDERS DUE TO CRIMINAL ACTS UNLAWFULLY SELLING HOME AND RECUSING JUDGES for
“CAUSE” DUE TO BIAS AND OR PREJUDICE CONDUCT PURSUANT TO S.H.A. 735 ILCS
5/2—1001 (a) (2,3) (WEST 2006) TO IMPOSE SANCTIONS/REMANDS PURSUANT TO SUPREME
CT. RULE 137 S.H.A. CRIMINAL CH. 38, 33-3 W/AFFIDAVIT
To the Honorable Justices of the Supreme
Court of the State of Illinois.
Now comes Plaintiff –Appellant, Dr Emmanuel Bansa,
Connie Bansa, a United States Citizen through their attorney Joseph P. Harris
your Petitioner, the people of the State of Illinois, a citizen, a resident and
an Elector of the City of Chicago, County of Cook, and State of Illinois,
respectfully represents and shows to your Honors the following:
1.)
That Counsel nor the Defendants have Never received any
Notices of a Sale date or Hearing before the Cir Ct May 10, 2016, ref as Ex
T and Ex U nor have Counsel or the Defendants received any of the Orders
from the Court granting the aforementioned
and that the parties have become a law unto themselves, judges ignored the
laws, became a law unto themselves, acted outside of their discretion and
judicial immunity provisions violating Canon Ethics and all of the Supreme
Court Rules;
2.)
That Ex S
unequivocally demonstrate how Defendant’s home was stolen in an elaborate
scheme with judicial support, file stamped April 25, 2016 and May 2, 2016 for
court appearance May 10, 2016;
A-
That a Clerk in
Dorothy Browns office of Chancery provided a printout, last page of Ex S, 5-10-2016 judge Otto unlawfully
Approved Sale and Order of Possession no signed Court Order was filed, he had
no jurisdiction, engaged in an “Organized Conspiracy” colluding with the
attorneys using his robe stealing Defendant’s home;
B-
That Ex T
and Ex U was absent a certified
signature violating Sup. Ct. Rule 272 but was mailed allegedly; thereby
violating other laws because said order is not in fact LEGAL;
3.)
That said Plaintiffs
have engaged in an elaborate “Organized Conspiracy” so as to steal Defendants
home taking advantage of the fact they were indigent and elderly, hereto
attached Gr Ex Motion filed in the Cir Ct before Judge Otto validating the
verity of judge colluding in a Criminal Corruption scheme;
4.) That
Gr. Ex H demonstrates how the attorneys
all have violated Ethics
All Illinois
RPC
3.3, entitled “Conduct Before a Tribunal,” sets forth the
standards to be followed by the trial lawyer during “battle.” Section (a) of
that rule states:
(a) In appearing in a professional capacity before a tribunal, a
lawyer shall not:
(1) make a statement of
material fact or law to a tribunal which the lawyer knows or reasonably should
know is false;
(2) fail to disclose to a
tribunal a material fact know to the lawyer when disclosure is necessary to
avoid assisting a criminal or fraudulent act by the client;
(3) fail to disclose to the
tribunal legal authority in the controlling jurisdiction known to the lawyer to
be directly adverse to the position of the client and not disclosed by opposing
counsel;
(4) Offer evidence that the
lawyer knows to be false. If a lawyer has offered material evidence and comes
to know of its falsity, the lawyer shall take reasonable remedial measures;
(5) participate in the
creation or preservation of evidence when the lawyer knows or reasonably should
know the evidence is false ;
(6) counsel or assist the
client in conduct the lawyer knows to be illegal of fraudulent;
(7) engage in other illegal
conduct or conduct in violation of these Rules;
(8) fail to disclose the
identities of the clients represented and of the persons who employed the
lawyer unless such information is privileged or irrelevant;
(9) intentionally degrade a
witness or other person by stating or alluding to personal facts concerning
that person which are not relevant to the case;
(10) in trial, allude to any
matter that the lawyer does not reasonably believe is relevant or that will not
be supported by admissible evidence, assert personal knowledge of facts in
issue except when testifying as a witness, or state a personal opinion as to
the justness of a cause, the credibility of a witness, the culpability of a
civil litigant or the guilt or innocence of and accused, but a lawyer may
argue, on analysis of evidence, for any position or conclusion with respect to
the matter stated herein;
5.)
That said judges and attorneys have satisfied the legal
standard Preponderance of the Evidence have exhausted a plethora of unlawful
acts using their robes upholding criminal acts being a part of an “Organized Conspiracy” trying to
steal Defendant’s home;
6.) That
due to “Fraud” Systemic Racism and alleged Political Terrorist Intimidation, Supreme Court Rule 383 is necessary because the Affidavits and Exhibits
attached demonstrates the need for this court to tear down the walls of Injustice,
Corruption and Racism in that those Judges and lawyers who cannot uphold the
integrity of their duties and oath as an attorney and judge need to seek
employment in another profession; alternatively, be remanded into custody.
7.) Where
applicable judges and lawyers who ignore the laws and act outside of the laws
don’t belong in the profession 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.
Vaughn 462 S.E. 2d 728 (Ga. 1995), The Supreme Court of Georgia
removed a judge from office for disregarding defendant’s constitutional rights.
8.) In
the wake of extensive investigations by Federal Law enforcement authorities
revealing widespread corruption in the Illinois court system (“Operation
Greylord”) and elsewhere, indicating not only that significant professional
misconduct was occurring but also that the requirement to report misconduct was
frequently ignored, particularly in the cases of judges with regard to the
conduct of other judges.
Lisa L. Milord, The Development of the
ABA,
Judicial
Code 24-25 (1992)
9.) Furthermore,
when testing for the “appearance of impropriety” the Court has a criteria that must be met, Commentary
Canon 2, 2A 2C, this Commentary
in Canon 2C clearly and unequivocally demonstrate the Court’s posture towards
the membership no judge in any of the lower courts were able to lawfully
Dismiss or Deny any of the, Motions presented in a Legally upright manner, in
that, they had to act outside of judicial discretion, and outside of the
judicial immunity provisions afforded to them denying the Defendants claims;
WHEREAS, your petitioner
prays that Writ of Mandamus /Issuance
of a Supervisory Order Vacating Orders due to Criminal Acts Unlawfully
Selling home and Recusing judges for “Cause” due to Bias and or Prejudice
Conduct Pursuant to S.H.A. 735 ILCS
5/2—1001 (a) (2,3) (West 2006)
due to another judge making deliberate Errors not wanting to Recuse said Judge
and Impose Sanctions/Remands Pursuant to Supreme
Court Rule 137 S.H.A. Criminal Ch. 38, 33-3 and a Rule to Show Cause be issued
on all attorneys and judges complicit in these acts in the above entitled cause.
Respectfully submitted,
Joseph P. Harris
____________________________
Counsel for Petitioner Appellant
Counsel for Petitioner
28618
417 South Des Plaines, St. 165
Forest Park, Illinois 60130
312 608-2494
________________________________________________________________________
IN THE
SUPREME COURT OF ILLINOIS
________________________________________________________________________
HSBC BANK USA, NATL.
ASSOC. ) Appeal from
the Circuit Court of Cook County
) Chancery Division
Plaintiff-Appellee
) Gen No. 15-2393
) Division No.
2
) Hon Michael Otto
Hon’s Michael B. Hyman, Michael Otto )
P. Scott Neville, Daniel J. Pierce )
John B. Simon )
V. ) Trial Court No. 12 CH 24000
DR. EMMANUEL BANSA AND )
BISHOP CONNIE
BANSA )
Defendant- Appellant
)
)
________________________________________________________________________
MOTION
FOR LEAVE TO FILE
PETITION FOR WRIT OF MANDAMUS
FOR ISSUANCE OF A SUPERVISORY ORDER VACATING
ORDERS DUE TO CRIMINAL ACTS UNLAWFULLY SELLING HOME AND RECUSING JUDGES for
“CAUSE” DUE TO BIAS AND OR PREJUDICE CONDUCT PURSUANT TO S.H.A. 735 ILCS
5/2—1001 (a) (2,3) (WEST 2006) TO IMPOSE SANCTIONS/REMANDS PURSUANT TO SUPREME
CT. RULE 137 S.H.A. CRIMINAL CH. 38, 33-3 W/AFFIDAVIT
To the Honorable Justices of the Supreme
Court of the State of Illinois:
Now
comes Defendant-Appellant, Dr. Emmanuel Bansa, Connie Bansa your Petitioners,
being represented by Joseph P. Harris, the people of the State of Illinois, by
the relator herein Illinois, a Citizen, a Resident and an elector of the City
of Chicago, County of Cook, and State of Illinois, by Attorney Joseph P. Harris,
respectfully asks leave of this court to file a Petition for Writ of Mandamus
et, al; and that summons issue as provided by law.
Respectfully submitted,
28618
417 South Des Plaines, St. 165
Forest Park, Illinois 60130
312 608-2494 Joseph
P. Harris
____________________________
Counsel for Movant Appellant
________________________________________________________________________
IN THE
SUPREME COURT OF ILLINOIS
________________________________________________________________________
HSBC BANK USA, NATL.
ASSOC. ) Appeal from the Circuit Court of Cook County
) Chancery Division
Plaintiff-Appellee
) Gen No. 15-2393
) Division No. 2
) Hon Michael Otto
Hon’s Michael B. Hyman, Michael Otto )
P. Scott Neville, Daniel J. Pierce )
John B. Simon )
V. ) Trial Court No. 12 CH 24000
DR. EMMANUEL BANSA AND )
BISHOP CONNIE
BANSA )
Defendant- Appellant
)
)
________________________________________________________________________
SUGGESTIONS IN SUPPORT OF THE PETITION
Along with
MEMORANDUM
OF LAW IN SUPPORT OF THE RELIEF REQUESTED
The petition and the procedure in this case are based upon former
proceedings in which this court granted the writ prayed. People V. Fischer, 303 Ill
430, 135 NE 751 et, al.
The supervisory authority of the
Supreme Court of Illinois: A powerful tool for the court and practitioner
alike. April 2012 Vol. 57, No. 9, Ill State Bar Ass.
In Philip Morris, USA, Inc. v. Byron, 226 Ill.2d 416 (2007), albeit in
dissent, Justice Freeman, joined by now Chief Justice Kilbride, stated that
“[g]enerally this court will not issue a supervisory order absent a finding
that (i) the normal appellate process will not afford adequate relief, (ii) the
dispute involves a matter important to the administration of justice, or (iii)
our intervention is necessary in order to prevent an inferior tribunal from
acting beyond the scope of its authority.” 226
Ill.2d at 422 (citation omitted)
Justice Freeman and Chief Justice
Kilbride thus appear to have treated the lack of adequate appellate relief
situation as an alternative basis for granting a supervisory order rather than
simply a factor modifying the other two bases for granting such an order. This
expanded formulation of the supervisory order standard is a logical extension
given the Rule’s constitutional underpinnings. After all, as noted above, the
Illinois Constitution states that “supervisory authority over all courts is
vested in the Supreme Court” without any reference to the normal appellate
process. Ill. Const. 1970, art. VI, Sec.
16
Mandamus is an appropriate remedy
to compel compliance with mandatory legal standards. People ex rel. Birkett v. Konetski, 233 Ill.2d 185, 192-93 (2009)
(“Mandamus relief will not be granted unless the petitioner shows a clear right
to the requested relief, a clear duty of the public officer to act, and clear
authority of the public officer to comply with the order.” (Emphasis in
original).
Rule 383 and the
Standards the Court Utilizes in Considering Motions for Supervisory Order:
Rule 383
provides, at its most basic, that “[a] motion requesting the exercise of the
Supreme Court’s supervisory authority shall be supported by explanatory
suggestions and shall contain or have attached to it the lower court records or
other pertinent material that will fully present the issues.”Rule 383(a) After stating the
requirements for service, the Rule provides a relatively expedited period for
objection— seven days when service of the motion is made by facsimile or 14
days when service is accomplished by mail or commercial carrier. Rule
383(c) Additionally, the Rule allows oral argument at the discretion of the
court. Rule 383(d)
The formulation of the standard for supervisory orders in
Suria is very broad. Suria provides that a supervisory order may be granted in
any situation where a trial or appellate court acted in excess of its authority
or abused its discretionary authority. Suria,
112 Ill. 2d at 38.
Justice Freeman and former Chief Justice Kilbride thus
appear to have treated the lack of adequate appellate relief situation as an
alternative basis for granting a supervisory order rather than simply a factor
modifying the other two bases for granting such an order. This expanded
formulation of the supervisory order standard is a logical extension given the
Rule’s constitutional underpinnings. After all, as noted above, the Illinois
Constitution states that “supervisory authority over all courts is vested in
the Supreme Court” without any reference to the normal appellate process. Ill. Const. 1970, art. VI, Sec. 16.
The supervisory authority of the Supreme Court of Illinois:
A powerful tool for the court and practitioner alike By Matthew R. Carter,
Winston & Strawn LLP 2 Trial Briefs | April
2012, Vol. 57, No. 9
As the foregoing analysis reveals,
the court has absolute authority to act when it feels so compelled. Moreover,
the instances where the Supreme Court has issued supervisory orders are so
eclectic that diligent litigators should consider it a tool to achieve timely
relief in critical situations
The petition proceeds in conformity with the instructions of this court
in People
V. Haas, 239 Ill 320, 87 NE 1111, with respect to the
presentation of original petition for Mandamus et al;
The issue presented in this original petition for Mandamus involves a
matter of great public importance in that it concerns the power conferred upon
county judges by the City Election Act to punish judges and clerks as for
contempt because of misbehavior or misconduct in their respective offices.
Petitioner respectfully submits that the court should grant leave to
file the Petition for Writ of Mandamus et al; duly signed and verified and
herewith presented with a petition, and with these suggestions and Memorandum
of Law in support of the relief requested, and that a summons issue in
conformity with the law, to the respondents returnable within a short time to
be fixed by this court, so that in this proceeding the powers of the County
judges under the City Election Act may be definitely and promptly determined.
REPORTING JUDICIAL MISCONDUCT
I.
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).
Sup Ct. Rule 63 (C) (1). S.H.A. 735 ILCS
5/2-----1001 (a) (3);
In Re Marriage of O’Brien 912 N.E. 2d 729 (Ill App. 2 Dist.
2009),
When a party moves for substitution of the trial judge for cause
based upon an alleged violation of rule setting forth mandatory bases for
recusal, the movant need only show the existence of that factor and that an
objective, reasonable person would conclude that the judge’s impartiality might
reasonably be questioned, and need not show actual prejudice.
Canon
3
D (2) Reporting Lawyer Misconduct
Fravel
v. Haughey, 727 So. 2d 1033 (Fla. App. Ct.Illinois
Acts constituting direct, criminal
contempt
A wide variety of acts may constitute a direct, criminal
contempt. And act may be criminal contempt even though it is also an indictable
crime. Beattie v. People, 33 Ill. Ill. Ill.
Official
misconduct is a criminal offense; and a public officer or employee commits
misconduct, punishable by fine, imprisonment, or both, when, in his official
capacity, he intentionally or recklessly fails to perform any mandatory duty as
required by law; or knowingly performs an act which he knows he is forbidden by
law to perform; or with intent to obtain a personal advantage for himself or
another, he performs an act in excess of his lawful authority ….S.H.A. Ch 38
33-3.
False statements
Censure was recommended sanction for
attorney who engaged in conduct involving dishonesty, made statement of
material fact or law to tribunal which she knew or reasonably should have known
to be false, and failed to disclose to tribunal a material fact known to her
when disclosure was necessary to avoid assisting criminal or fraudulent at by
client, given that attorney’s misconduct was not result of dishonest or corrupt
motive, but of misguided attempt to accommodate clients. 99 Ill.Atty.Reg. & Disc.Comm. SH11
Three-year suspension was
recommended sanction for attorney who engaged in conduct involving dishonesty
and fraud, made statement of material fact to tribunal which he knew or
reasonably should have known was false, and offered evidence that he knew to be
false and failed to take reasonable remedial measures. 96 Ill.Atty.Reg. &
Disc.Comm. SH 358.
Disbarment was recommended sanction
for attorney who engaged in conduct involving dishonesty, made false statements
of material fact or law to tribunal which she knew were false and engaged in
conduct which tended to defeat administration of justice. 95 Ill Atty.Reg. & Disc.Comm. CH 877.
Censure was recommended sanction for
attorney who made statements of material fact or law known was false, and
engaged in conduct which was prejudicial to the administration of justice. 95
Ill Atty.Reg. & Disc.Comm. CH 504
One-year suspension was recommended sanction for attorney who made
statement of material fact which he knew was false in appearing in professional
capacity before tribunal, made a statement of material fact which he knew to be
false in course of representing client, and engaged in conduct involving
dishonesty. 95 Ill Atty.Reg. &
Disc.Comm. CH 191.
Disbarment was recommended sanction
for attorney who engaged in serious misconduct by making misrepresentation
during his divorce proceedings and who was a recidivist. 94
Ill.Atty.Reg. & Disc.Comm. SH469
Fraud on court
Two-year suspension, retroactive to beginning of interim
suspension, was recommended sanction for attorney who made statement of
material fact or law to tribunal which lawyer knew or reasonably should have
known to be false, instituted criminal charges as prosecutor when he knew or
reasonably should have known that charges were not supported by probable cause,
committed criminal act that reflected adversely upon lawyer ‘s honesty,
trustworthiness, or fitness as lawyer, engaged in conduct involving dishonesty,
fraud, deceit, or misrepresentation, engaged in conduct prejudicial to
administration of justice, and engaged in conduct which tended to bring courts
or legal profession into disrepute. 96 Ill.
Jim Crow Laws are still
being enacted and enforced in Chicago, Illinois Courts Black and Brown lives
simply don’t matter and it is clear now in these proceedings being elderly is
worse because the laws are used against said parties to destroy or displaced
them in society unless you are in a position to pay off certain politicians or
abide by their rules and doctrines of Corrupt politicians or Terrorists
operating behind the scenes making sure the events recorded never come to “Light” exposing the truth how
the courts are under siege by so many judges closing their eyes to the
realities of injustice, being perpetrated on the innocent and indigent.
In the 20th century,
the Supreme Court began to overturn Jim Crow laws on constitutional grounds. In
Buchanan v. Warley 245 US 60 (1917), the court held that a Kentucky law could not require residential
segregation. The Supreme Court in 1946, in Irene Morgan v. Virginia ruled segregation in interstate transportation to be unconstitutional,
in an application of the commerce clause of the Constitution. It was not until 1954 in Brown v.
Board of Education of Topeka 347 US 483 that the court held that separate
facilities were inherently unequal in the area of public schools, effectively
overturning Plessy v. Ferguson, and outlawing Jim Crow in other areas of
society as well. This landmark case consisted of complaints filed in the states
of Delaware (Gebhart v. Belton); South Carolina (Briggs
v. Elliott); Virginia (Davis v. County School Board of Prince Edward County); and Washington, D.C. (Spottswode Bolling v.
C. Melvin Sharpe). These decisions, along
with other cases such as McLaurin v.
Oklahoma State Board of Regents 339 US 637
(1950), NAACP v. Alabama 357 US 449 (1958), and Boynton
v. Virginia 364 US 454 (1960), slowly
dismantled the state-sponsored segregation imposed by Jim Crow laws.
Respectfully
submitted,
Joseph P. Harris
____________________________
Counsel for Petitioner Appellant
Counsel for Petitioner
28618
417 South Des Plaines, St. 165
Forest Park, Illinois 60130
312 608-2494
________________________________________________________________________
IN THE
SUPREME COURT OF ILLINOIS
________________________________________________________________________
HSBC BANK USA, NATL.
ASSOC. ) Appeal from
the Circuit Court of Cook County
) Chancery Division
Plaintiff-Appellee
) Gen No. 15-2393
) Division No. 2
) Hon Michael Otto
Hon’s Michael B. Hyman, Michael Otto )
P. Scott Neville, Daniel J. Pierce )
John B. Simon )
v )
Trial Court No. 12 CH 24000
DR. EMMANUEL BANSA AND )
BISHOP CONNIE
BANSA )
Defendant- Appellant
)
)
MOTION FOR WRIT OF MANDAMUS
FOR ISSUANCE OF A SUPERVISORY ORDER VACATING
ORDERS (May 10, 2016) DUE TO CRIMINAL ACTS UNLAWFULLY SELLING HOME AND RECUSING
JUDGES for “CAUSE” DUE TO BIAS AND OR PREJUDICE CONDUCT PURSUANT TO S.H.A. 735
ILCS 5/2—1001 (a) (2,3) (WEST 2006) TO IMPOSE SANCTIONS/REMAND PURSUANT TO
SUPREME CT. RULE 137 S.H.A. CRIMINAL CH. 38, 33-3 W/AFFIDAVIT
DRAFT ORDER
This matter having
come on to be heard on Writ of Mandamus /Issuance of a Supervisory Order
Vacating Orders due to Criminal Acts unlawfully Selling home and Recusing
Judges for “Cause” due to Bias and or Prejudice Conduct Pursuant to S.H.A. 735 ILCS 5/2—1001 (a) (2,3) (West
2006) due to another judge making deliberate Errors not wanting to Recuse
said Judge and Impose Sanctions/Remands Pursuant to Supreme Court Rule 137 S.H.A. Criminal Ch. 38, 33-3 and Court being
fully advised in the premises;
It is HEREBY Ordered that Writ of Mandamus /Issuance of a
Supervisory Order Vacating Orders (May 10, 2016) and Recusing Judge for Cause et al is Granted/ Denied
Joseph P. Harris ________________________________
417 South Des Plaines, St. 165 Justice
Forest Park, Illinois 60130 ________________________________
Justice
(312) 608-2494
_________________________________
Justice
________________________________________________________________________
IN THE
SUPREME COURT OF ILLINOIS
________________________________________________________________________
HSBC BANK USA, NATL.
ASSOC. ) Appeal from the Circuit Court of Cook County
) Chancery
Division
Plaintiff-Appellee
) Gen No. 15-2393
) Division No. 2
) Hon Michael Otto
Hon’s Michael B. Hyman, Michael Otto )
P. Scott Neville, Daniel J. Pierce )
John B. Simon )
V. ) Trial Court No. 12 CH 24000
DR. EMMANUEL BANSA AND )
BISHOP CONNIE
BANSA )
Defendant- Appellant
)
)
________________________________________________________________________
CERTIFICATE OF SERVICE
PETITION FOR WRIT OF MANDAMUS
FOR ISSUANCE OF A SUPERVISORY ORDER VACATING
ORDERS (May 10, 2016) DUE TO CRIMINAL ACTS UNLAWFULLY SELLING HOME AND RECUSING
JUDGES for “CAUSE” DUE TO BIAS AND OR PREJUDICE CONDUCT PURSUANT TO S.H.A. 735
ILCS 5/2—1001 (a) (2,3) (WEST 2006) TO IMPOSE SANCTIONS/REMAND PURSUANT TO
SUPREME CT. RULE 137 S.H.A. CRIMINAL CH. 38, 33-3 W/AFFIDAVIT
YOU ARE HEREBY NOTIFIED that Petitioner
Appeals to the Illinois Supreme Court, for an Order on Petition for Writ of Mandamus for Mandatory Injunction/Issuance of a
Supervisory Order Vacating Orders due to Criminal Acts “Fraud” and To Impose
Sanctions et al. , I Joseph P. Harris, Attorney in this cause hereby
certify that, I Have caused the following on said service list to receive the
Petition et al., and all of it’s attachments by depositing them in a Post
Office via regular mail, or hand delivery May 19th , 2016 to the
following:
Service List: Courtesy
Copies
TO: THE following
By
Mail
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
All Parties via hand
delivery:
Judge Daniel J.
Pierce Judge
Michael B. Hyman
160 N LaSalle 2nd Div. 160 N LaSalle 2nd Div.
Chg. Il 60601 Chg. Il 60601
Judge P. Scott
Neville Judge John B. Simon
160 N. LaSalle 2nd
Div. 160 N LaSalle 2nd Div.
Chg. Il 60601 Chg.
Il 60601
Judge Michael Otto Pierce & Associates, P.C.
50 West Washington Sid Klemm, ARDC
# 6300227
Chg. Il 60601 1 N.
Dearborn, Suite 1300
Chg.
Il 60602
Atty. Gen, Lisa Madigan
100 West Randolph, Suite 1200
Mayor
.
Chg. IL 60601 Rahm Emanuel
City Hall
Chicago, Ill. 60601
Courtesy Copies:
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
States Attorney,
Anita Alvarez, Suite 500
Daley Center, Chg. Ill. 60601
Gov. Bruce
Rauner
Mayer
Brown, LLP
100 West
Randolph
Lucia
Nale, Michelle V. Dohra, Charles Woodworth
Chicago,
Ill. 60601
71 S. Wacker Drive
Chg. Il 60606
Cook County President
Cook
County Sheriff
Toni Preckwinkle Thomas
J. Dart
118 N. Clark, Room 517
Richard
J. Daley Center, Room 701
Chicago, Ill. 60601
Chicago,
Ill. 60601
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.
_________________________________
28618
Joseph P.
Harris
417
S. Des Plaines, St. 165
Forrest Park, Il 60130
312 608-2494
Notary
________________________________________________________________________
IN THE
SUPREME COURT OF ILLINOIS
________________________________________________________________________
HSBC BANK USA, NATL.
ASSOC. ) Appeal from
the Circuit Court of Cook County
) Chancery Division
Plaintiff-Appellee
) Gen No. 15-2393
) Division No.
2
V. ) Hon Michael Otto
Hon’s Michael B. Hyman, Michael Otto )
P. Scott Neville, Daniel J. Pierce )
John B. Simon ) Trial Court No. 12 CH 24000
DR. EMMANUEL BANSA AND )
BISHOP CONNIE
BANSA )
Defendant- Appellant
)
)
________________________________________________________________________
EXHIBIT LIST
1.)
Gr. Ex. A,
Motion filed in Cir Ct judge Otto
2.)
Ex. B, Court
Order Striking Defendant’s defenses
3.)
Gr. Ex. C
Motion for Reconsideration in Cir. Ct.
4.)
Gr. Ex D
Court Order Denying, Ex C;
5.)
Ex. E, Notice of Appeal filed;
6.)
Gr. Ex F,
Emergency Motion to Stay et al.
7.)
Ex G. Court
Order Denying the Motion (April 6, 2016);
8.)
Gr. Ex. H,
Def’s Motion Dismissing said Appeal et al.
9.)
Gr Ex. I,
Motion Objecting Dismissal (filed April 13, 2016);
10.)
Ex J,
Appellate Court Denying said Motion;
11.)
Gr. Ex K,
Amended Motion Objecting to Dismissal et al.
12.)
Gr. Ex L,
Motion for Reconsideration et al. (April 21, 2016);
13.)
Ex. M, April
14th Court Order, App. Ct. Hon Daniel J. Pierce;
14.)
Ex. N, April
14th Court Order, App. Ct. Hons Daniel J. Pierce, Michael B. Hyman
and P. Scott Neville;
15.)
Ex. O, April
14th Court Order, App. Ct. Hon Daniel J. Pierce, P. Scott Neville
and Michael B. Hyman;
16.)
Ex. P, April
28th Court Order, App. Ct.
17.)
Ex. Q, Emergency
Motion for 14 Day Extension of time to submit Brief;
18.)
Ex. R, App.
Ct. Denying Ex Q (May 4th,
2016);
19.)
Ex. S, May
2, 2016 Motion filed in Cir. Ct. Defendant nor Counsel never received Notice of
any court date;
20.)
Ex. T, Order
Approving Report of Sale et al.
21.)
Ex U, Notice
of Mailing of Order Approving Sale (May 12th, 2016) in violation Sup Ct. Rule 272 no signature.
Respectfully
submitted,
Joseph P. Harris
____________________________
Counsel for Petitioner Appellant
Counsel for Petitioner
28618
417 South Des Plaines, St. 165
Forest Park, Illinois 60130
312 608-2494
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