PART 1 OF 3 HOW RACIST DEMOCRATS IN THE CHICAGO LEGAL SYSTEM HAS SEIZED THE COURTS IN A TERRORIST MANNER AND IS STEALING HOMES FROM ELDERLY RETIRED WOMEN OF COLOR:
#JIMCROW IS REAL! YOU HAVE READ THE VICIOUS ACCOUNTS ON @REDBILLA AND @JOELOUIS7 DEMOCRATS IN CHICAGO CAN BEST DEAL WITH PERSONS OF COLOR IF YOU ARE AN EX CON, INFERIOR, OR GAY TRANSGENDER OR LESBIAN ONLY WITH LIMITATIONS SEE THE AUGUST 10, 2016 POST WHY A LESBIAN JUDGE IS LEAVING THE BENCH.
THESE ELDERLY WOMEN ARE PROFESSIONAL WOMEN A RETIRED POLICE OFFICER AND RETIRED CHICAGO PUBLIC SCHOOL TEACHER.
THIS IS WHAT HAPPENS WHEN PEOPLE OF COLOR VOTE DEMOCRATIC!
IN THE CIRCUIT COURT OF COOK
COUNTY, ILLINOIS
COUNTY
DEPARTMENT--CHANCERY DIVISION
U.S. Bank
National Association, As Trustee Under)
Pooling
and Servicing Agreement Dated as of )
December
1, 2006 Mastr Asset–Backed Securities )
Trust
2006-NC3 Mortgage Pass-Through
) Case # 2008 CH 33616
Certificates,
Series 2006-NC3
) Petitioner
)
)
V. )
)
)
Monzella
Y. Johnson, A/K/A Monzella
)
Johnson; Marcia E. Johnson A/K/A Marcia )
Johnson: Mortgage Electronic Registration )
Systems,
Inc. As Nominee for New Century
)
Mortgage
Corporation; Monzella Y. Johnson )
( C )
Cestui Que Trust; Discover Bank; )
Unknown
Owners and Non-Record Claimants, )
)
Respondents
)
RESPONDENT’S
RESPONSE MOTION FOR
RECONSIDERATION VACATE (May 25, July 26, 2016) ORDER DUE TO ERROR LACK OF
JURISDICTION & “FRAUD” w/AFFIDAVIT
Now
comes Petitioner, Monzella Y. Johnson et al. being represented Pro Se in this
cause respectfully represents to this court the reasons and files herewith her
Affidavit in support of Respondent’s Response Motion for Reconsideration et al;
1.
That Plaintiffs having admitted to all facts
recorded in said Respondent’s Objection to the Order entered May 25 via
affidavit;
A-
Court having no jurisdiction ignored Defendants Motion
demonstrating Prejudice and Bias behavior pursuant to S.H.A. 735 ILCS
5/2-----1001 (a) (3); Sup. Ct. Rule 63 (C) (1).
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
2.
Chronology of
Facts: Complaint was filed Sept. 11, 2008 by Barbara J. Dutton, 10325 West
Lincoln Hwy. Frankfort Il. 60423—Not Pierce & Assc. 1 North Dearborn, Chg
Il. NO RECORD OF AN APPEARANCE BEING
FILED;
A- That
on Oct. 31, 2008, Larson & Assc. 230 West Monroe, Suite 2200, Chg. Il.
60606, filed an Appearance and the 1st
Amended Pleadings and no record of the aforementioned attorneys
withdrawing from the case;
B- That
on April 7, 2009, Robert Wutscher, LLP, 10 South LaSalle, Chg. Il. 60603, filed
an Appearance;
C- That
on June 8, 2009, Pierce & Assc. Filed an Appearance and paid the fee;
D- That
on July 30, 2010, Ciesla & Ciesla, 836 Skokie Blvd. Northbrook Il. 60062,
did not file an Appearance but filed a Memorandum of Law;
E- That
on Aug. 17, 2010, Arendt Richard J. Law office, 640 North LaSalle, Suite 680,
Chg. Il. 60654, filed a Certificate of Service but no Appearance;
F- That
on June 28, 2011, Barbara J. Dutton filed a Motion withdrawing from the case before
Judge Liu, Laura Cha-Yu;
3.
That Defendants filed their Appearance and
paid the fee June 22, 2009;
A- Pursuant
to Vigus v. O’Bannon, 1886 8 N.E 788, 118 ILL 334. Hazelton V. Carolus, 1907 132 ILL.
App. 512. Pursuant to
this precedent, hereto attached Gr Ex A, Motion for Leave to File a
Petition for Writ of Mandamus for Issuance of a Supervisory Order et al. before
the Supreme Court of Illinois by our attorney who is now suspended because he
addressed the very issues we as Defendant’s are having to fiend for to keep our
house but because so many of the attorneys are politically connected, they are
able to do what they want to whomever and nothing is being done to them, but a
great man in Attorney Harris has to suffer for speaking up helping us and
others;
B- Hereto attached, Gr Ex B a Motion to
Supplement the aforementioned Motion above;
C- Hereto
attached, Ex C an Affidavit from Joe
Louis Lawrence where he was representing his Godparents, case #2009 CH 47930 Barbara Dutton was the attorney they
stole their home falsifying documents when the debt was discharged in Bankruptcy
Federal Court;
D- Hereto
attached Gr Ex D, Supreme Court
motion for Reconsideration detailing “Fraud”
4.
That Par. 13, 14 of Respondent’s
Objection et al. is clear within the Preponderance of evidence legal
standard demonstrating how attorneys are trying to steal the Defendants homes
in the guise of “Foreclosure” hereto
attached;
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-
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.
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,
Monzella Y. Johnson, Pro Se
Chicago, Il 60615
WHEREFORE the aforementioned
reasons Defendant respectfully Prays for the Relief
1.
For an Order Vacating the May 25, and July 26, 2016 Court Orders;
2.
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;
IN THE
CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY
DEPARTMENT--CHANCERY DIVISION
U.S. Bank
National Association, As Trustee Under)
Pooling
and Servicing Agreement Dated as of )
December
1, 2006 Mastr Asset–Backed Securities )
Trust
2006-NC3 Mortgage Pass-Through
) Case # 2008 CH 33616
Certificates,
Series 2006-NC3
) Petitioner
)
)
V. )
)
)
Monzella
Y. Johnson, A/K/A Monzella
)
Johnson; Marcia E. Johnson A/K/A Marcia )
Johnson: Mortgage Electronic Registration )
Systems,
Inc. As Nominee for New Century
)
Mortgage
Corporation; Monzella Y. Johnson )
( C )
Cestui Que Trust; Discover Bank; )
Unknown
Owners and Non-Record Claimants, )
)
Respondents
)
NOTICE OF
RESPONDENT’S
RESPONSE MOTION FOR RECONSIDERATION VACATE (May 25, July 26, 2016) ORDER DUE TO
ERROR LACK OF JURISDICTION & “FRAUD” w/AFFIDAVIT
Please be
advised that on August 10, 2016, Defendant has filed before this Circuit
Court, Motion for Reconsideration et al; and will present said legally
sufficient instrument before Judge Myerson or any Judge in her stead August 12,
at 10:30 am in room 2808.
Potestivo & Ass., PC F.B.I Dir. Michael J. Anderson
223 West Jackson, Blvd, Suite
610 2111 West Roosevelt Road
Chicago, IL. 60606 Chicago, Il 60612
Chicago, IL. 60606 Chicago, Il 60612
CERTIFICATE
OF SERVICE
The
undersigned hereby certifies that the above notice and all attachments were
caused to be personally delivered, to the above parties at the addresses
provided before 5:00 pm on August 8, 2016.
________________________
Respectfully Submitted, Monzella Y. Johnson
IN THE CIRCUIT COURT OF COOK
COUNTY, ILLINOIS
COUNTY
DEPARTMENT--CHANCERY DIVISION
U.S. Bank
National Association, As Trustee Under)
Pooling
and Servicing Agreement Dated as of )
December
1, 2006 Mastr Asset–Backed Securities )
Trust
2006-NC3 Mortgage Pass-Through
) Case # 2008 CH 33616
Certificates,
Series 2006-NC3
) Petitioner
)
)
V. )
)
)
Monzella
Y. Johnson, A/K/A Monzella
)
Johnson; Marcia E. Johnson A/K/A Marcia )
Johnson: Mortgage Electronic Registration )
Systems,
Inc. As Nominee for New Century
)
Mortgage
Corporation; Monzella Y. Johnson )
( C )
Cestui Que Trust; Discover Bank; )
Unknown
Owners and Non-Record Claimants, )
)
Respondents
)
AFFIDAVIT
STATE OF ILLINOIS )
)
COUNTY OF COOK )
I Monzella Y. Johnson Pro Se being duly sworn
on oath states the aforementioned pleadings enumerated within said motion
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
Notary
____________________
Monzella Y. Johnson
Chicago, Il 60615
AFFIDAVIT
STATE OF ILLINOIS )
)
COUNTY OF COOK )
I Joe
Louis Lawrence, Counsel Pro Se being duly sworn on oath states.
1.)
That during the year of 2009 and 2011, I was representing
the interests of my Godparents Mr Bogus Knight (deceased) and Alwanna Knight;
2.)
Judge David B. Atkins allowed me the opportunity to
represent my families interest none of the attorneys in Barbara Dutton’s firm
was able to articulate any issues of fact or impeach anything argued in court;
3.)
That judge Atkins did not admonish any of the attorneys
when it was made clear in said affidavits they were trying to steal said home
and that all debt was discharged in Federal Bankruptcy Court;
4.)
That judge Atkins allowed me to argue but ignored everything
I said in the same manner Judge Valderrama did to me on case #2015 CH 01670
heard the truth but denied everything stated because of my skin color;
5.)
It was argued that the court did not have jurisdiction the
attorneys were committing “Fraud” judge Atkins asked the attorneys if they had
a response, the case was continued but he denied every motion that was filed in
his court;
6.)
That Barbara Dutton appeared in court where judge Atkins
was not on the bench Judge Jeanne Prendergast Rooney was the judge she knew me said
“I understand you are trying to help your mom, but you don’t have your law
license yet” I was shocked because she knew me and I never seen her before;
7.)
I tried to explain to her that there are a plethora of
irregularities surrounding this matter, she interjected respectfully said she
fully understands said there would be issues on the Appellate level again
because you do not have your law license yet;
8.)
My Godmother Alwanna Knight was deeply dejected because
there was no attorney she trusted could represent her interests, Judge Rooney
seemed greatly (pissed) perturbed at the position she was in knowing “Fraud”
was taken place but the fact, I had no license gave Barbara who appeared to
have had clout from City Hall to do as she pleased in the courts.
9.)
That Barbara Dutton caused my family to be homeless and the
building 5721 S. Justine is to this day abandoned, Alwanna Knight had to move
in with her daughter.
10.)
That the modis operandi is that The Dutton’s law firm would
falsify whatever documents Inducing Reliance upon the courts and Postivo & Associates
would come in afterwards and finish up their part corroborating their role in
this criminal conspiracy;
FURTHER AFFIANT SAYETH NOT
Respectfully Submitted
Notary
____________________
Joe Louis Lawrence
P. O. Box 490075
Chicago, Il. 60649-0075
Twitter @joelouis7
Email joelouislaw@yahoo.com
No comments:
Post a Comment