Cook County Board of Ethics 69 W. Washington St. Ste. 3040 Chicago IL 60602-3007	Hon. Senator Richard Durbin 230 S. Dearborn Street Suite 3892 Chicago, IL 60604	Hon. Toni Preckwinkle, President 118 N. Clark St. Room 537 Chicago, IL 60602
Hon. Chief Justice  Lloyd Karmeier 161 N. LaSalle 20th Fl Chicago IL 60601	Honorable Michael W. Frierichs 100 W Randolph St, Suite 15-600 Chicago, Il 60601	Hon. Kenneth A. Gunn Commission On Human Relations 740 N Sedgwick St Ste 400  Chicago, IL 60654-8488
Hon. Katherine Rochford, Chair Comm. on Equal Access  on Justice 160 N. LaSalle St. 14th Fl Chicago IL 60601	Hon. Daniel J. Pierce, Co-Chair Comm.  on Equal Access  on Justice 160 N. LaSalle St. 14th Fl Chicago IL 60601	IL Judicial Inquiry Board 100 W. Washington , Ste 1400 Chicago IL 60601
Chief Judge Timothy Evans 50 W. Washington St., Rm. 1703 Chicago, Illinois 60602	Presiding Judge James P. Flannery 50 W. Washington Room 2005 Chicago IL 60602	Judge John C. Griffin 50 W. Washington Room 2303 Chicago IL 60602

I hereby give my permission to post this Complaint against Judge John C. Griffin on anti-corruption blogs. 

CC: CBA, ISBA, other authorities. 

Re: Complaint and Request to investigate Law Division Judge John C. Griffin for corruption, conspiracy with certain lawyers, particularly Hinshaw &Culbertson LLP Senior partner Peter Sullivan (brother of Judge Sharon Sullivan and son of Judge Harold Sullivan);  bribery scheme and/or other undue influence; obstruction justice with intent to defraud; and other misconduct. 

Dear Honorable Committee on Ethics and other Honorable Law enforcement and Human Rights Authorities:

Please find this Notice pursuant to 18 U.S.C. §4 and my demand to investigate and remove from the bench corrupt public Officer, Law Division Judge John C. Griffin for his willful misconduct in office and other conduct that was prejudicial to the administration of justice and brought the Judicial Office into disrepute.

I allege that Judge John C. Griffin, a public Officer on $214,000.00 annual taxpayers payroll, intentionally breached his professional duties and Oath to the Office  to act honestly and apply law equally to all parties, regardless of representation. 

To the contrary, Judge John C. Griffin  entered into a conspiracy Agreement with certain lawyers who represented Defendants in my case 14-L-3632: Chicagoland Community Management, Inc, (“CCM”) Carl Sandburg Village Condo Association #1; Kovitz Shifrin Nesbit P.C.; CNA/Continental Casualty, et.al: (1) Hinshaw &Culbertson LLP well-connected partner Peter Sullivan, brother of Judge Sharon Sullivan and son of Judge Harold Sullivan) and Associate Leigh Bonsall; (2) Sanchez Daniels & Hoffman, LLP, and its partner Michael Franz; (3) Karball Cohen, Economou, Silk and Dunne, LLC, partner Newton Marshall and Associate Blum;  (4) Elenius Frost &Walsh, partner Paul Sheldon (CNA/Continental Casualty) Kovitz Shifrin Nesbit, partner Christopher Ralph, ect.,; and fixed my case in their favor.

I assert impropriety and have evidence that Defendants in my Case 14-L-3632 Fedorova v. CCM. et.al and Plaintiffs in case 14-CH-11573, CCM v. Fedorova entered into a corruption scheme with judges who handled both cases: John C. Griffin, Thomas L. Hogan and James P. Flannery, Jr. with intent to obstruct justice and defraud me  from honest services and equal protection while acted under Color of Law;  and concealed their personal connections with said above law firms; as well as substantial amounts of moneyofficially  received by Judge Thomas L. Hogan from Hinshaw &Culbertson lawyers, at least $4,550.00. 

I strongly believe that a favorable verdict entered by Judge John C. Griffin was procured by undue influence, commonly known as bribery and/or other influence.

Judge John C. Griffin, who acted in excess of ALL jurisdiction while Cases 14-L-3632 and 14-CH-11573 were both in Appeal Court from  November 17, 2014 to July 1, 2015, in October 2014 denied my demand for disclosures of connections between lawyers and other judges, particularly Judge Hogan; and concealed his own family relationship with at least two Firms in my case: Hinshaw&Culbertson LLP, where his relative Joseph Griffin was a Partner;  while his father James Griffin was likely connected with Judge Harold Sullivan;  and he is related  to Ferrell Griffin, who  was a partner with Justice Daniel J. Pierce, Judge Griffin's donor. I also have reasons to believe  that Judge John C. Griffin has certain undisclosed to me connections with Sanchez Daniels &Hoffman, LLP. 

Judge John C. Griffin repeatedly made false statements from the bench that he does “not remember” or “does not know” who are his donors, while concealed his personal connections with Justice Daniel J. Pierce, Griffin’s benefactor, who originally handled my case 12-L-7111 (renumbered as 14-L-3632) and  acted extremely one-sided in favor of my Defendants’ lawyers from day one. I believe that Judge Pierce’s former partner in Pierce Webb Lydon &Griffin was Judge Griffin’s relative Ferrell Griffin, who probably is his uncle.

I respectfully request to investigate staggering corruption in Judge Griffin’s court;  and report Judges John C. Griffin, Thomas Hogan and James Flannery to disciplinary authorities, including but not limited to US Senate; FBI, DOJ; US and IL Offices of Attorney General.

Rule 63 Canon 3 B(3)(a) requires a judge who having knowledge of a violation of these canons on the part of a judge or a  violation of Rule 8.4 of the Rules of Professional Conduct on the part of a lawyer shall take or  initiate appropriate disciplinary measures. Duty of Judge to Report Misconduct A judge who has knowledge that another judge has committed a violation  of the Code of Judicial Conduct that raises a question regarding the judge’s honesty,  trustworthiness, or fitness as a judge in other respects is required to report it to the  Appropriate disciplinary authority. Likewise, a judge who has knowledge of a lawyer’s violation of the Rules of Professional Conduct has an ethical  duty to report it to the disciplinary counsel or a local certified grievance committee.

Please review detailed explanation as well as facts and evidence in support that Judges John C. Griffin, Thomas L. Hogan and James P. Flannery, Jr. intentionally concealed material information about their  personal connections with lawyers who represented parties in cases 14-L-3632 and 14-CH-11573; and provided  a favorable verdict for their parties of interest  through a scheme of deception, corruption and bribery while violated all applicable Laws and rules of this Court, including but not limited to Judge Flannery (who passed his seat to Judge Hogan on October 1, 2014 to consolidate frivolous defamation case 14-CH-11573 filed by CCM into my legit action in case 14-L-3632) Standing Order which requires an official re-assignment of cases after Appeal Court. I complied with this Rule when I filed a Motion asking Judge Flannery to reassign case 12-L-7111, Fedorova v. CCM on April 1, 2014; and renumber is as 14-L-3632.  

The same requirements are apparently not applicable to well-connected lawyers in Judge Flannery’s Court since he never required the same Motion from my opponents after  Cases 14-L-3632 (Appeal No. 1-14-3489, filed on November 17, 2014, concluded on July 1, 2015 ) and 14-CH-11573, CCM v. Fedorova (Appeal No. 1-14-3494, filed on November 17, 2014, concluded on July 1, 2015) were returned back to Cook County Court, while between October 2014 to July 2015 Judge John C. Griffin enthusiastically operated  in both cases without jurisdiction and fixed my case 14-L-3632 in favor of his parties of interest, in the most corrupt manner.   

Moreover, on July 1, 2015  Case 14-CH-11573 was returned back to Chancery Division docket, where lawyer Michael Franz in August-September 2015 repeatedly filed frivolous Motions in CHANCERY DIVISION which he presented to Law Division Judge John C. Griffin, all  favorably accepted by Griffin , in access of ALL jurisdiction and without any questions asked.

I filed a Petition to vacate Judge John C. Griffin’s VOID Orders since it was entered without jurisdiction and  procured by corruption and undue influence commonly known as a bribe. I have also provide a review of similar case, Hessler v. Riviera HOA, Kovitz Shifrin Nesbit PC and compare to  Judge Griffin's ruling  in my case.

I also believe that Judge John C. Griffin acted corrupt and put the Judiciary in disrepute  because he is  absolutely confident  that he can defraud me from the bench and obstruct justice without any consequences since he expects  powerful support from his well-connected friends, Justice Daniel J. Pierce and his and Dan Webb, former US Attorney General, now top white collar crime defender  at Winston &Strawn, former partner at Pierce Webb Lydon &Griffin.

I am sending my Petition to IL Supreme Court Commission on Assess to Justice where one of Judge Griffin’s main donors, lawyer Michael Demetrio’s wife Justice Katherine Rochford is a Chair ; as well as to all other authorities, including IL Board of Elections. 

I will also send it to other Judge Griffin’s donors whom I respectfully invite to attend the hearing on June 28, 2017 at 9:00. If Judge Griffin will suffer from another episode of amnesia about his donors, they can remind him about themselves by holding placards with amounts contributed. 

While I do not donate to judges to obtain positions of public Trust, I fund their $214,000.00 annual paycheck, and cover for judges’ medical bills. So, I demand Judge John C. Griffin to see a doctor to check his episodes of amnesia immediately. Maybe it will help him to recall not only his donors, but also family members, friends, laws and Rules of Professional Ethics, which Griffin also forgot.

I want to remind Judge Griffin that corruption is a crime; and it is absolutely NOT legit to fix cases in favor of his parties of interest and  allow CNA/ Continental Casualty Insurance lawyer Paul Sheldon, who ALSO has fatal conflict of interests to represent anyone else except his clients,  to appear on behalf of ALL parties in case 14--3632 (whose legal bills paid by CNA) as he did with Judge Griffin's approval,  to cover for Judge Griffin and his co-conspirators corrupt Court practices.  Each Defendant has its own set lawyer; and they must respond to my Petition personally. 

Below is a brief review of FACTS in my case and how Judge Griffin ruled on it; and compare it to certain US Supreme Court cases as well as Judge Griffin verdicts in very similar cases which involved same parties.  IL is a FACT pleadings jurisdiction where motion should be liberally constructed. So, regardless if my complaint is nearly typed by a licensed lawyer or handwritten by a ProSe litigant – the same principle of law must apply.

Judges must NOT be one-sided in favor of  their favorite parties (who are usually better-funded lawyers) but discharge their duties impartially and in accordance with law. None of it was present in  Judge Griffin’s court who in my case acted as a zealous lawyer for my Defendants.  When reviewing a motion to dismiss on the pleadings, courts "accept all factual allegations as true, construe the complaint in the light most favorable to the plaintiff, and determine whether, under any reasonable reading of the complaint, the plaintiff may be entitled to relief." Phillips v. Cnty. of Allegheny, 515 F.3d 224. In Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), the Supreme Court clarified the 12(b)(6) standard. The Court held that the factual allegations set forth in a complaint "must be enough to raise a right to relief above the speculative level." Id. at 555. Ultimately, "a complaint must do more than allege the plaintiff's entitlement to relief. A complaint has to `show' such an entitlement with its facts." Fowler v. UPMC Shadyside, 578 F.3d 203, 211 (3d Cir. 2009). Moreover, in deciding a motion to dismiss, "a court may consider the allegations in the complaint, exhibits attached to the complaint, matters of public record, and documents that form the basis of Plaintiffs' claim." Lum v. Bank of Am., 361 F.3d 217, 222 (3d Cir. 2004).

FACTS: Case 14-L-3632 was filed on May 25, 2012 as 12-L-7111, against a predatory HOA, its management Company and their lawyer, where  I am a Pro Se plaintiff.  In 2006, I fell two month behind on my assessments because I was misled about the terms of my mortgage, which put me under financial stress. To compensate the HOA for their loss, I offered to repay my dues through a payment plan. They refused. In a malicious act against a vulnerable homeowner, the HOA promptly used my personal burden for their advantage by swamping me with bogus fees, including an extra month for assessments prior to my ownership of the unit. (I purchased the unit on January 31, 2006 and got actual possession on Feb. 1, 2006, but the HOA charged me starting from Jan 1, 2006, which was an entire month of assessments $282.04.

On May 1, 2006, the HOA claimed that I owed them $1,481.12 in "debt." I contested this amount but was ignored by the HOA. My monthly assessments were always $282.04. With the exception of the two months, I made all payments. So there was no possible way that I could owe more than $714.00, which also takes into consideration the $75.00 in late fees.  In a case contesting these charges, the HOA was able to obtain a favorable judgment and took possession of the unit.  My unit was then rented from Dec. 1, 2006 to a bona fide tenant for $900.00 a month. At all times throughout the rental period the assessments remained $282.04. At this time, the HOA Board and its managers were advised by their lawyers to avoid all communication with me, which made it impossible for me to respond to their hostilities. HOA lawyers Kovitz Shifrin Nesbit said that “the Association is under NO obligation to explain how they ARRIVED at fees as they did”

 On October 23, 2007, the HOA filed a second collection case, in which they claimed that I "owe" then $7,442.00 as of Jan. 1, 2006 and that any payments made for the unit were credit. It was a blatant  lie, perjury and obstruction of justice. At the time of this case, the unit was in possession of the HOA and gainfully rented for $900.00. To hide the rental income, the HOA, its managers, and their lawyers applied all possible fees to swamp me in debt.  Some creative charges even included a “holiday party” and non-existing “parking”  which I never had. By October 1, 2011, after 5 years of consecutive rent, my fabricated in 2006 $1,481.12 debt to HOA was calculated as $3,614.35. HOA refused to return me possession of the premises until the full amount was extorted under their lawyers  and managers guidance. KSN Associate Shrivastava repeatedly appeared before the Court and lied to judge Hambright that I still “owe” . I observe the same racketeering activity against other owners at Carl Sandburg HOA and other HOAs specially advised by KSN lawyers and managed by CCM as well as an avalanche of legal cases for wrongful collections and personal injuries against KSN and CCM (at least one is currently in Judge Griffin’s Court where CCM is represented by Hinshaw &Culbertson lawyers.

I put all these facts in my complaint, along with plentiful evidence in support. Judge Griffin, who had several identical cases pending in his Court, is apparently selectively familiar with the principals of the law and his duty to review Complaints in the most favorable for Plaintiff light, as he did in other cases. 

Here are some examples how Griffin ruled, comparable to my case:

In 14-L12093 Hesser v. Riviera HOA, Kovitz Shifrin Nesbit P.C., a similar case  filed by three licensed lawyers, Judge Griffin applied the same law absolutely differently. In the case filed by lawyers, Griffin immediately recalled that section 2-603 (c) that requires pleadings to be liberally construed to do substantial justice between the parties. In 14-L-3632 case filed by a ProSe, Griffin solely relied on 2-603 (a) and (b) in which he applied the most adverse options for my pleadings. For the lawyers Judge Griffin also recalled that §2-615 standard for review must be done in the light most favorable for the plaintiff. See also Chicago Association of Realtors[1]and Virginia Downs v. Geller[2], Case 12-L-10003[3]

In my case Judge Griffin did nothing but turn a blind to the lawyers’ malpractices. Lawyers  have filed void appearances, obtained Ex Parte judgements, demanded baseless Orders of protection (at least  12 TROs, all favorably granted by Law Division Judges)  on Emergency basis, (my single request for TRO to stop legal harassment was denied since according to judge Brennan,  I am not entitled to such extreme remedy. All lawyers demands were granted, without questions asked), created a frivolous case that resulted a senseless consolidation, filed a frivolous eviction case to harass my  family; lied to judges, given conflicting testimonies, and lack any affirmative matters in defenses. But this was totally ignored by Judge Griffin.  

Instead, all of judge Griffin’s energy went into squashing the entirety of my case. His attempts to humiliate me  by instructing  how to hire a lawyer are especially offensive.

While as a Judge he has the duty to inform litigants of available legal resources, he has absolutely no right to enter an Orderdirecting  me to use these resources when I previously refused to do so. This is an abuse of power and a gross violation of plaintiff’s rights under 18 U.S.C 242 to appear in this Court as Pro Se. I doubts if Chancery judges Flynn and Kinnaird in Cable Am. case, on which judge Griffin relied, humiliated plaintiff’s lawyers in the same way by entering an Order to direct Kindwail Law Offices, P.C. to take MCLE classes after they failed to fix their Complaint in Case 2003-CH-12160 after six attempts in 5 years.

I also doubts that a low-cost lawyer would force Judge Griffin to comply with his duties when he refused to apply the law equally and arbitrarily antagonize  my  filings while concealed his personal interests with my defendants lawyers. Examples are included but not limited to:

Judge Griffin blamed me for attaching too much evidence to the complaint, such as correspondences, motions, bills, ect. Then on the next page he blamed me for NOT attaching enough evidence, claiming that I excluded a copy of the Declaration, which was “a fatal error.” But 5/2-606 does not state any limits on attaching or not attaching exhibits. Moreover, the plaintiff is not required to set forth evidence in the complaint. Section 2/5-606(b) provides that a copy of a contract “must be attached to the pleading as an exhibit or recited therein.” Although English is not my native language the word “recited” means “mentioned,” which was done in the body of the complaint many times.

Then Judge Griffin also argued that I cannot sue for theft and embezzlement in civil Court, but there have been a number of cases involving embezzlement claims heard in all Divisions of Cook County Court including but not limited to Continental Casualty v Hoffman, 2008-CH-03280. Griffin  failed to provide any explanation for why a corporation can sue for embezzlement in civil court and I as Prose  prohibited from the same cause of action.

Judge Griffin  also argued that I  “failed to state a claim or identify a cause of action” but then proceeded to analyze each of my claims, which would de facto mean the judge actually were able to identify all claims.  But no matter - his misinterpretation of the laws which would favor defendants vis-à-vis the claims was the most criminal of his actions. Judge Griffin’s decisions were clearly corrupt, enabled fraud, and invited anarchy.

For instance, he said that I was not able to prove breach of fiduciary duty because defendants acted in accordance with the “business judgement rule” when they fabricated non-exiting debts, rented my property for personal gain, swamped me with bogus fees to keep possession as long as possible, and evaded taxes from profits.

Furthermore, Judge Griffin’s argument that the HOA, whose damages were ultimately resolved, can now breach the Declaration indefinitely due to my  one-time failure to pay two months of assessments in 2006, is also incorrect. By the same logic, if the HOA breached its duty once, which it has many times, then I, too, can refuse to comply with my duties forever.

Judge Griffin’s decision to disregard ALL of the wrongdoings of the HOA and their lawyers is not simply corrupt and blatantly unethical but a danger to all Americans who struggle with greedy HOAs and their predatory lawyers.  Examples are plentiful.

I demand Judge Griffin to STOP his corrupt Court practices  which he repeatedly uses to defraud me from the bench.  If Griffin wants to serve his parties of interests – he should return to the private practice  to work  as an advocate for his clients.  Moreover, Judge Griffin’s demand to hire a lawyer to be “fairly heard” was another deception solely with intent to cause me more harm.

Even if I hired a lawyer who is not as well-connected as Hinshaw &Culbertson lawyers, my legal fees would easily exceed $100,000.00 with the same result since I regularly observe how Griffin rules in favor of the better funded parties. 

 I demand to reverse all void Orders and proceed with my case in accordance with the law and binding precedents.

I respectfully demand Committee on Ethics and other Honorable Law enforcement and Human Rights Authorities to investigate corruption and bribery scheme in Judge John C. Griffin’s Court and remove him from the bench.

Best regards,

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