To show fraud upon the court, the complaining party must establish that the alleged misconduct affected the integrity of the judicial process, either because the court itself was defrauded or because the misconduct was perpetrated by officers of the court. Alexander v. Robertson, 882 F.2d 421,424 (9th Cir. 1989).

A void judgment does not create any binding obligation. Kalb v, Feuerstein (1940) 308 US 433, 60 S Ct 343, 84 L, Ed.370.

DEMOCRATIC JUDGES IN ILLINOIS TRESPASSING UPON THE LAWS COMMITTING TREASON AT WILL NOT FEARING THE TRUMP ADMINISTRATION OR ANY LAWS DEMONSTRATING THEY ARE UNTOUCHABLE DOMESTIC TERRORISTS.

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS.

                                                      COUNTY DEPARTMENT, LAW DIVISION ;

"Elena Fedorova, ProSe ) FILED MAY 24, 2017

Plaintiff Defendant in 14-CH-11573 )                        Case 14-L-3632 ,'ذرہ

                                                                             (ConsolidatedCase 14-CH-11573).

vs

Chicagoland Community Management, Inc. et al

Defendant/Plaintiff in 14-CH-11573

ELENA FEDOROVA’S PETITION TO VACATE VOID JUDGEMENT

PURSUANT TO 735 ILCS 5/2 - 1401(f); FEDERAL RULE 60(B); and 42 U.S.C. 1983 DUE TO NEWLY DISCOVERED EVIDENCE OF JUDGE JOHN C. GRIFFIN CORRUPTION: UNDISCLOSED PERSONAL RELATIONSHIP WITH FEDOROVAS DEFENDANTS LAWYERS AKA CRIMINAL CONCELAMENT AND CONSPIRACY TO DEFRAUD; PERJURY AND OBSTRUCTION OF JUSTICE, DEMAND TO INVESTIGATE JUDGES JAMES P. FLANNERY, JR. JOHN C. GRIFFIN AND THOMAL L.HOGAN FOR BRIBERY SCHEME

1. NOW COMES the Plaintiff Fedorova, and petitions this Court pursuant to Section 735 ILCS 5/2-1401, Fed. R 60(B), applicable to all States; and 42 U.S.C. 1983' for relief from the void orders and void judgements of Judge Griffin entered in purportedly consolidated cases 14 L-3632 and 14-CH-11573, including but not limited to void orders entered on July 17, 2015 and

November 5, 2015. Motion to vacate an order as void may be brought at any time and is not subject to the two-year limitations period imposed under section 2-1401. People v. Harvey, 196 Ill. 2d 444, 447, 753 N.E.2d 293,295 (2001). Petition to vacate under 5/2-1401 must be filed in the same proceeding in which the order or the iudgement being attacked is entered.

2.    Fedorova property filed her Petition in case 14-L-3632 to vacate void orders and void judgements entered in case 14-L-3632 after it was corruptly consolidated with case 14-CH 11573, or from October 1, 2014 to present time. Case 14-L-3632 must be reviewed de novo by an independent and non-bias judge due to this Court's lack of jurisdiction; Fedorova's Appeals in

Petition under Sec. 5/2-1401(a) provides relief from final orders and judgments, after 30 days from the entry is applicable of all voidjudgements.

42 U.S.C. S.1983. Deprivation of Civil Rights. Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, ...or other proper proceeding for redress,

1.

consolidated cases 14-CH-11573 (Appeal 14-3494), Chicagoland Community Management Inc. ("CCM") v. Fedorova and 14-L-3632 (Appeal 14-3489) Fedorova v. CCM which were returned to Cook County Court on July 1, 2015 (Ex. 1) but never reassigned to Law Division as required by Law Division Standing Order; and the criminal concealment of Judge John Griffin's personal relationship with at least two law Firms who represented CCM in the case.

3.             On October 16, 2014, Judge John C. Griffin entered into a conspiracy agreement with Fedorova's opponents when he denied Fedorova's Motion for disclosures of her defendants’ lawyers' relationships with the judges in her case (Ex. 2). Judge Griffin in fact had two close connections to the defendants' lawyers. (1) Hinshaw & Culbertson, LLP ("H&C)where Judge Griffin's relative, lawyer Joseph Griffin', was a senior partner. Fedorova believes that Judge Griffin's father, James Griffin, was closely connected with CCM's leading lawyer Peter Sullivan's father, Judge Harold Sullivan and his sister, Judge Sharon Sullivan who since 1992 works in Cook County Court; (2) Sanchez Daniels & Hoffman LLP whose senior partner Jurgens between 1991-96 worked for Griffin & Associates; and in 1996-2001 was employed by H&C.

4. Judge John C. Griffin also failed to disclose his personal relationship with the original judge in Fedorova's case, Justice Daniel J. Pierce, who was extremely prejudiced against her. Judge Pierce is the former partner of Pierce, Webb, Lydon & Griffin, where Judge Griffin's relative was also a partner.S. Lawyers from H&C and Sanchez Daniels & Hoffman LLP's also entered into a conspiracy agreement with Judge Thomas L. Hogan, whom Judge James P. Flannery, Jr. passed

Hinshaw &Culberton LLP has at least 5 (five) judges sitting in various Divisions of Cook County Court who have family connections with top level partners: Law Division Judges Thomas R. Mulroy, Jr. (father of partner Thomas R. Mulroy III); James Snyder (brother of partner Gregory Snyder and father or uncle to Associate Matthew Snyder); John C. Griffin (relative (probably a Grandson) to Joseph Griffin, former partner); Sharon Sullivan (sister of partner Peter Sullivan, whose father, well-connected judge Harold Sullivan was known by most judges in this Court and highly recognized as a zealous fighter for judicial benefits); and a long-time partner Cecilia Horan, who is currently sitting in Municipal Division. "Lawyer Joseph Griffin was also a Secretary Treasurer for International Association of Insurance Counsel. One of Defendants in Fedorova's case is CNAF Continental Casualty

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his seat on October 1, 2014. Hogan granted bogus consolidation, without disclosing $4,550.00 he officially received from Hinshaw & Culbertson lawyers (Ex. 2 p.2-4).

6.       Moreover, the letter dated September 30, 2014 where lawyer Franz informed Fedorova about Judge Hogan's favorable verdict on October 1, 2014 was on top of Hogan's documents when Fedorova approached the bench. Flannery, whom Fedorova several times petitioned to vacate this corrupt judgement, refused to deconsolidate.

7.       Judge Griffin obstructed justice when he not only refused to investigate Judge Hogan's collusion with Fedorova's opponents, but intentionally concealed essential information about his own conflict of interests with Fedorova's defendants'; violated all applicable laws and Rules of this Court; and acted without any jurisdiction; and refused to resign from Fedorova's case.

8.       Judge Griffin corrupt practices were aided and abetted by Presiding Judge James P. Flannery, Jr. who repeatedly denied Fedorova's Motions to recuse Griffin; and always ruled in favor of her opponents, in violation of all applicable laws and Rules of the Court.

9.       Judge John C. Griffin obstructed justice and committed perjury when he repeatedly made false statements regarding his lack of knowledge about his election donors in order to defraud Fedorova. The largest donor for Judge Griffin's election campaign was himself (he “donated” $31,695.98 on January 26, 2010 but seemed to have forgotten this when Fedorova asked);

Griffin & Gallagher law Firm where he and his father James Griffin were partners; well connected lawyer Michael DeMetrio (whose wife Katherine Rochford and Associate Terrance Lavin are Appeal Court Justices); Corboy & DeMetrio senior partner Robert J. Bingle; and well connected lawyer Joseph A. Power, Jr, a generous donor for many judicial and political elections and son of a well-connected Judge Joseph Power (Mayor Daley's,closest political aide (Daley brother was main supporter for judge Flannery); previously mentioned Justice Daniel J.

Joseph A. Power, Jr. gave many thousands of dollars to Mr. Madigan, who regularly stack IL benches with his cronies and political donors.

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Pierce; and a long list of real estate companies, insurance companies, and lawyers. Each of Fedorova's Defendants are in the same professional field as Judge Griffin's donors and parties of interests, making it impossible for Fedorova to receive an impartial hearing from Griffin.

10. Judge John C. Griffin, who perfectly knew that he will rule in favor of his parties of interests-Fedorova's well-connected Defendants, humiliated and discriminated against Fedorova solely due to her ProSe status when in the Opinions entered on July 17, 2015, Judge Griffin advised Fedorova that she cannot expect equal treatment under the law in his Court because

she does not have a lawyer. He said:

"In its ruling of December 19, 2014, the Court (.1 DIRECTED the Plaintiff to the Circuit Court County's website entitled "For People Without Lawyers”. [...] The "options located to the right contain detailed information regarding Attorney Referral Services, free/low cost legal services (...). In addition December 19, 2014 ORDER stated as follows: 1.7 Therefore, a self-represented individual MAY HIRE AN ATTORNEY to assist them for limited purposes such as drafting and/or reviewing pleadings. The foregoing is part of the Court's attempt to make reasonable efforts, I ...J TO FACILITATE THE ABILITY OF THE PLAINTIFF TO BE FAIRLY HEARD,'

11.     In other words, Judge Griffin informed Fedorova that if her pleadings had been drafted by a lawyer the SAME LAW would have been applied DIFFERENTLY, which was exactly how Judge Griffin ruled in the case. Verdicts entered by Judge Griffin violated 18 U.S.C. 1346 and IL Constitution Article I, Sec 2&12 creating a culture of deliberate indifference causing foreseeable constitutional injury to Pro Se Plaintiff under 18 U.S.C $242 and 42 U.S.C S1985 (3)(b). A judge does not have the discretion on whether or not to follow Supreme Ct. Rules, but a duty to follow. People v. Gersh, 135 Ill. 2d 384 (1990).

12.     Moreover, Judge Griffin's demand to hire a low-budget lawyer was another deception and unjustified attempt to extort from Fedorova payments of legal fees for a lawyer to cause her additional financial burden. Griffin knew in advance that he will rule in favor of her Defendants, who are all closely connected to Judge Griffin's inner circle.

13.     Judge John C. Griffin stole Honest Services from Fedorova and committed conspiracy; Intrinsic and Extrinsic Fraud Upon the Court committed by Officers of the Court; (2) Court's lack of subject-matter jurisdiction to make binding decisions on purportedly consolidated cases

while case 14-CH-11573 was in Appeal Court from November 17, 2014 until July 1, 2015"; (3) corruption and fraudulent concealment; (4) judicial trespasses of the law and double standards for review; (5) theft of honest services (6) violations of Canons of Judicial Ethics; and (7) violations of ABA Rules of Conduct. Fedorova has meritorious claim, supported by material evidence, public records, applicable laws, binding precedents and extensive due diligence.

14.    Fraud upon the court is a basis for equitable relief. Luttrell v. United States, 644 F.2d 1274, 1276 (9th Cir. 1980); see Abatti v. C.I.R.,859 F.2d 115, 118 (9th Cir. 1988) "it is beyond

question that a . court may investigate a question as to whether there was fraud in the procurement of a judgment'. Universal Oil Products Co. v. Root Refining Co., 328 U.S. 575, 66 S.Ct. 1176, 90 L.Ed. 1447. The power of the Court) to unearth such a fraud is the power to unearth it effectively. See Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238, 64 S.Ct. 997, 88 L.Ed. 1250; Sprague v. Ticonic National Bank, 307 U.S. 161, 59 S.Ct. 777, 83 L.Ed.

1184; and United States v. Throckmorton, 98 U.S. (8 Otto) 61, 25 L.Ed. 93.

6 ،،A judge is an officer of the court, as are all members of the Bar. A judge is a judicial officer, paid by the Government to act inpartially and lawfully'. People v. Zajic, 88 ill.App.3d 477,410 N.E.2d626.1980 ' A void judgment is regarded as a nullity, and the situation is the same as it would be if there were no judgment. It has no legal or binding force or efficacy for any purpose or at any place. ... It is not entitled to enforcement. 30A Am Judgments" 43, 44,45. Henderson v. Henderson, 232NC 380, 100 SE2d227. See Restatement, Judgments, '8. Avoid Judgment is one which has no legal force or effect. Its invalidity may be asserted by any person whose rights are affected at any time and at any place directly or collaterally, Long v.Shorebank Development Corp., 182 F.3d 548 (C.A. 7 Ill. 1999). Void Judgment from its inception is and forever continues to be absolutely null, without legal efficacy, ineffectual to bind parties or support a right, of no legal force and effect whatever, and incapable of confirmation, ratification, or enforcement in any manner or to any degree. "Avoid judgment, order or decree may be attacked at any time or in any court, either directly or collaterally"Oak Park Nat. Bank v. Peoples Gas Light & Coke Col, 46 Ill.App.2d 385, 197N.E.2d 73, 77 (1st Dist. 1964). A court "cannot confer jurisdiction where none existed and cannot make a void proceeding valid." People ex rel, Gowdy v Baltimore & Ohio R.R. Co., 385 fl. 86,92, 52 N.E.2d 255 (1943).

To show fraud upon the court, the complaining party must establish that the alleged misconduct affected the integrity of the judicial process, either because the court itself was defrauded or because the misconduct was perpetrated by officers of the court Alexander v. Robertson, 882 F.2d 421,424 (9th Cir. 1989).

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15.    Rule 5/2-1401 and 60(b) do not limit a court's power to redress fraud on the court. The term "fraud on the court" is a nebulous concept. A clear example is the corruption of iudicial officers. Root Refining Co. v. Universal Oil Pros Co., 3 Cir., 169 F.2d 514, 534, cert. denied sub nom. Universal Oil Pros ү, William Whitman Co., 335 U.S. 912, 69 S.Ct. 481,93 L.Ed. 444.'

16.     All orders rendered on the basis of those void orders also must be declared void.

17.    Judge Griffin committed fraud upon the Court, acted corrupt and in excess of his subject/matter jurisdiction when he (1) deprived ProSe Fedorova from Due Process and Equal Protection rights"; (2) accepted and favorably ruled on defendants' legally insufficient as a matter of law Motions filed by licensed lawyers without Sworn Affidavits, in violation of 5/1-

109; 5/2-605; 5/2-615; 5/2-619; L S. Ct.R. 191; and F.R. 47'; (3) ruled on purportedly consolidated cases 14-CH-11573 and 14-L-3632, while case 14-CH-11573 was in Appeal Court'; (4) acted partially in favor of his parties of interests; (5) applied double standards of review on ProSe Fedorova vis-a-vis licensed lawyers, for the identical claims; (6) mislead Fedorova about his election donors and his personal interests in defendants and their lawyers; (7)

refused to reverse his Opinions and disqualify himself. When a judge acts as a trespasser of the

In Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238,64 S.Ct. 997, 88 L.Ed. 1250, the Supreme Court extended the concept to a situation where a bogus scientific article was published to affect the outcome of patent litigation. The fabricated article was relied on, at least in part, by the court of appeals in its decision. Hazel-Atlas is an example of fraud which so defiles the court "that the judicial machinery cannot (sic) perform in the usual manner its impartial task of adjudging cases that are presented for adjudication." Mariina Theatre Corp. v. Schine Chain Theatres, Inc., 2 Cir., 278 F.2d 798, 801, quoting 7 Moore, Fed. P. 60.33, at 512 "Due Process is a requirement of the U.S. Constitution. Violation of the United States Constitution by a judge deprives that person from acting as a judge under the law. He/She is acting as a private person, and not in the capacity of being a judge (and, therefore, has no jurisdiction). "The Court in Yates v. Village of Hoffman Estates, 209 F.Supp. 757 (N.D., Ill. 1962) held that “It is not a judicial function for a judge to commit an intentional tort even though the tort occurs in the courthouse." "To compare: Law Division Judge Brennan refused to hear any Motions in case 12-L-7111 (renumbered as 14-L- 3632) when Fedorova filed interlocutory appeal on Judge Brennan's Ex Parte Order to Quash Service, Brennan also ordered Fedorova to comply with Law Division Standing Order and reassign case 12-L-711 after Appeal Court issued a Mandate. Judge Griffin trespassed the law and acted in excess of his jurisdiction when continued to operate in Case 14-CH-11573 during pending appeal; and never requested proper reassignment of case 14-CH-11573 from Chancery Division, where the Appeal Court Mandate was recorded, to Law Division, as required under Rule 1.3d and Law Division Standing Order.

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law or does not follow the law, the judge loses subject-matter jurisdiction and the judges' orders are void, of no legal force or effect.

18.    The trial court's discretion is not unlimited. “Abuse occurs when a material factor deserving significant weight is ignored, when an improper factor is relied upon, or when all

proper and no improper factors are assessed, but the court makes a serious mistake in weighing them.” Independent Oil and Chemical Workers of Quincy, Inc. v. Procter & Gamble Mfg. Co., 864 F.2d 927,929 (1st Cir. 1988); see also Anderson v. Cryovac, Inc., 862 F.2d 910, 923 (1st Cir. 1988) (to warrant reversal for abuse of discretion, it must "plainly appear that the court below committed a meaningful error in judgment”). A judge receiving a bribe from an interested party over which he is presiding, does not give the appearance of iustice.

19.    Fedorova has proper material evidence that Judges Flannery and Griffin, with aid from ex-Judge Thomas L. Hogan, fixed cases 14-L-3632 Fedorova vs. CCM, etal and 14-CH-11573 CCM v. Fedorova in favor of corporate defendants, all of whom belong to the sphere of these judges' personal interests. Fedorova strongly believes that Judges Flannery, Griffin, and Hogan received indirect (election donations or promises for donations) and direct compensation for their

favorable decisions for defendants in my case. In other words: they accepted bribes. A breadth of evidence backs Fedorova's suspicions: public election records; the judge's incessant deception; unjustified leniency to the defendants' lawyers; acceptance of legally insufficient motions from defendants' lawyers; extreme bias against Fedorova as ProSe'; the defendants' own claims that they have spent a "substantial amounts of money” to dismiss Fedorova's case; and judge Hogan's rapid retirement from the bench after Fedorova's complaint to FBI.

"In Pfizer Inc. v. Lord, 456 F.2d 532 (8th Cir. 1972), the Court stated that "It is important that the litigant not only actually receive justice, but that he believes that he has received justice." The Supreme Court has ruled and has reaffirmed the principle that "justice must satisfy the appearance of justice", Levine v. United States, 362 U.S. 610, 80 S.Ct. 1038 (1960), citing Offitt v. United States, 348 U.S. 1, 14, 75 S.Ct. 11, 13 (1954).

14 Judge Griffin systemically apply double standards in his courts, which are always favorable for the parties of his interests, like licensed lawyers and the corporate defendants in Fedorova's case,

20.    Fedorova diligently pursued her legal options of vacate void order on consolidation of cases 14-CH-11573 with 14-L-3632 and void judgement entered by Judge Griffin on July 17, 2015 and November 5, 2015, in violation of all applicable laws, including $2-615 and $2-619,

21.     Judges Flannery and Griffin acted from their position of power, repeatedly abused their discretion, acted corrupt and bias against Fedorova, applied double standards; refused to comply with the law or follow due process and equal protection clauses; deprived Fedorova from honest judicial services; fraudulently concealed and/or misled Fedorova about their personal conflicts of interests with defendants; readily accepted legally deficient motions filed by licensed lawyers; and customary ruled in favor of their preferred parties, in disregard of lawyers' fatal deficiencies in pleadings and defendants’ false and contradicting statements.

22.     Judge Griffin refused to recuse himself despite his flagrant conflicts of interests with Fedorova; and continued to rule in favor of defendants, in the most corrupt and prejudice manner. Defendants were perfectly aware of his decision on November 5, 2015 and came to the hearing with a fully pre printed favorable verdict,

23.    In 1994, the U.S. Supreme Court held that “Disqualification is required if an objective observer would entertain reasonable questions about the judge's impartiality. If a judge's attitude or state of mind leads a detached observer to conclude that a fair and impartial hearing is unlikely, the judge must be disqualified.” Emphasis added). Liteky v. U.S., 114 S.Ct. 1147,

"Her attempts included but not limited to(1) Motion for Rehearing on consolidation (denied by Judge Flannery on October 20, 2014); (2) Motion to Deconsolidate (Sever) case 14-CH-11573 and request for Judicial Opinion (denied by Judge Solganick without explanations on November 3, 2014); (3) Notice of Appeal final Order on Consolidation of case 14-CH-11573, filed on November 17, 2014); (4) Motion for Reconsideration (denied by Judge Griffin on November 5, 2015); (5) Petition to Substitute Judge Griffin for Cause (denied by Judge Sherlock on August 17, 2015); (6) Rehearing on Petition to vacate (denied by Judge Flannery on October 9, 2015); (7) Complaint for Mandamus (filed on October 13, 2015, case 15-CH-15013); (7) Petition to Vacate Void Order on Consolidation in case 14-CH-11573 (Judge Flannery refused to hear on January 26, 2016, unlawfully consolidated case 14-CH-11573 with 15-CH-11727 and passed Fedorova's Motion to prove jurisdiction to Chancery Judge Cohen). ,

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1162 (1994).' That Court also stated that Section 455(a) “requires a judge to recuse himself in any proceeding in which her impartiality might reasonably be questioned." Judges do not have discretion not to disqualify themselves. By law, they are bound to follow the law. Should a

judge not disqualify himself as required by law,then the judge has given another example of his “appearance of partiality” which further disqualifies the judge. Should another judge not accept the disqualification of the judge, then the second judge has evidenced an "appearance of partiality” and has possibly disqualified himself herself.

24.      None of the orders issued by any iudge who has been disqualified by law would appear to be valid. It would appear that they are void as a matter of law, and are of no legal force or effect.

25.      Should a judge not disqualify himself, then the judge is in violation of the Due Process Clause of the U.S. Constitution. U.S. v. Sciuto, 521 F.2d 842, 845 (7th Cir. 1996) (“The right to a tribunal fee from bias or prejudice is based, not on Sec. 144, but on the Due Process Clause.”).

26.    The Court specifically emphasized that when litigants rights under the due process clause of both the Illinois and United States Constitutions (US Const, amend. XIV; III. Const. 1970, art. I, S 2) were violated by the trial court's actions and”where an error that occurs during a J trial impinges upon the integrity of our judicial system, reversal is required "regardless of the weight

of the other evidence.” People v. Thomas, 123 Ill.App.3d 857, 867,79 Ill.Dec. 278, 463 N.E.2d 832 (1984); People v. Baynes, 88 Ill.2d 225,244, 58 Ill.Dec. 819,430 N.E.2d 1070 (1981).

"Courts have repeatedly held that positive proof of the partiality of a judge is not a requirement, only the appearance of partiality. Liljeberg v. Health Services Acquisition Corp., 486 U.S. 847, 108 S.Ct. 2194 (1988) (what matters is not the reality of bias or prejudice but itsappearance); US v. Balistrieri, 779 F.2d 1191 (7th Cir. 1985) (Section 455(a) 'is directed against the appearance of partiality, whether or not the judge is actually biased.”) ("Section 455(a) of the Judicial Code, 28 U.S.C. S455(a), is not intended to protectilitigants from actual bias in their judge but rather to promote public confidence in the impartiality of the judicial process.”). 'Taylor v. O'Grady, 888 F2d 1189 (7th Cir. 1989). Further, the judge has a legal duty to disqualify himself even if there is no motion asking for his disqualification. The Seventh Circuit Court of Appeals stated that “We think that this language (455(a)) imposes a duty on the judge to act sua sponte, even if no motion or affidavit is filed.” US v. Balistrieri, 779 F.2d 1191 (7th Cir. 1985) at 1202.

27.    Judge Griffin's repetitive refusals to recuse himself from case 14-L-3632 after he had been automatically disqualified by law due to his bias and partiality, constitute judge Griffin's lack of subject/matterjurisdiction, war against the Constitution, treason and anarchy.

28.    It supports Fedorova's argument that judge Griffin's favorable verdicts were procured by fraud upon the Court, corruption and undue influence, commonly known as a bribe. 29, Fedorova was out of remedy and her only choice was to proceed with Sec. 5/2-1401 Petition to vacate voidjudgements; and remove bias judge Griffin from case 14-L-3632.

30.    Double standards in the court for judges' Flannery and Griffin favored litigants are the

norm in Fedorova's case. As mentioned before, Judge Griffin applied the same law differently to

the two parties before him when presiding over her case.

31. After 75 days of intensive search, on July 17, 2015, Griffin dismissed with prejudice

Fedorova's Complaint in case 14-L-3632 (consolidated with 14-CH-11573, both were in Appeal

during all this time), in the most bias and discriminatory manner. Judge Griffin advised Fedorova

that she cannot expect equal treatment under the law and be fairly heard in his Court because she

does not have a lawyer. In other words, Judge Griffin informed Fedorova that if her pleadings

had been drafted by a lawyer, the same lap would have been applied differently,

32. Fedorova's case is not a fluke. Judge Griffin regularly applies the law with double standards'. In case 14-L12093 Hesser v. Riviera HOA, Kovitz Shifrin Nesbit P.C., a case similar to Fedorova, but 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

"In 2009 Judge Griffin was a defendant in case 09CV5243, Gregory v. Judge Griffin, etal. for his bias practices in a foreclosure case. Plaintiffs challenged court jurisdiction and alleged violations of Due Process and Equal Protection rights. Plaintiff contended that Defendant judges are involved in conspiracy in violation of 42 USC 1985, are legislating from the bench, are blatantly disregarding the law.

O

the most adverse options for Fedorova's pleadings. For the lawyers Judge Griffin also recalled that S2-615 standard for review must be done in the light most favorable for the paintiff. See also Chicago Association of Realtors' and Virginia Downs v. Geller', Case 12-L-10003’ CAR filed a questionable defamation case, similar to 14-CH-11573 CCM v. Fedorova, which supports Fedorova's argument that Judge Griffin's assignment was not an accidental.

33.    Griffin's standard for review in ProSe Fedorova case was totally opposite. According to Griffin, Fedorova was unable to prove any sets of facts that on October 2011 defendants conspired to collect unlawful debt of $3,614.35 originally fabricated in 2006 at the amount $1,481.12, after the HOA collected $900.00 in consecutive monthly rent for 5 years. In Hesser, Griffin found that the KSN lawyers owed duties to the plaintiff and breached their HOA's declaration when they engaged in conspiracy with the Board to commit fraud against Hesser.

Identical claims in Fedorova's case were dismissed by Griffin with prejudice in a corrupt manner. Fedorova's FDCPA claim against KSN was ignored in its entirety.

34.      Clearly, Griffin acts with extreme bias against ProSe litigants, with whom he prefers to act under the color of the law; and favors pleadings prepared by politically connected lawyers'.

35.     Courts have repeatedly held that positive proof of the partiality of a judge is not a requirement, only the appearance of partiality.' Fedorova states that Judge Griffin's decision

Represented by Holland & Knight LLP, a global law firm with more than 1,100 lawyers in 24 U.S. offices. o Represented by solo-practitioner Donald C. Battaglia, 5543 W. Diversey Ave. Chicago, IL 60639 'Judge Griffin ruled: "Plaintiffs are NOT required to prove their case in the pleading stage. They merely are required to ALLEGE sufficient facts to state all the elements which are necessary to constitute each cause of action in their complaint". A 2-615 Motion to dismiss should not be granted unless no sets of facts could be proven that would entitled the plaintiff to relief.”

22 "The Chicago Association of Realtors ("CAR”) and its CEO have settled (read: dropped) a defamation suit against Geller, under very questionable circumstances. Apparently, CAR lawyers were not able to prove any sets of facts against Geller, despite Judge Griffin's favorable findings. Geller's lawyer Battaglia said CAR had agreed to dismiss its case against Geller as part of a settlement, but declined to discuss the terms of the settlement.

Lijeberg v. Health Services Acquisition Corp., 486 U.S. 847, 108 S.Ct. 2194 (1988) (what matters is not the reality of bias or prejudice but its appearance); United States v. Balistrieri, 779 F.2d 1191 (7th Cir. 1985) (Section 455(a) “is directed against the appearance of partiality, whether or not the judge is actually biased”) ("Section 455(a) of the Judicial Code, 28 U.S.C. S455(a), is not intended to protect litigants from actual bias in their judge but rather to promote public confidence in the impartiality of the judicial process."),

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must be reversed as originally void due to his partiality, trespasses of the law and application of double standards for review.” When a judge acts as a trespasser of the law or does not follow the law, the judge loses subject-matter jurisdiction and the judges' orders are void, of no legal

force or effect. Judge Griffin committed intentional tort against Fedorova and intended to culpably oppress and deprive Fedorova from her rights, due administration of justice and equal protection under the law guaranteed by U.S. and Ill. Constitution Art. I, S 12.

36.     Griffin committed unmitigated crimes punishable under Federal Criminal Code of Conduct 18 U.S.C. 242, deprivation of civil rights acting under colors of law; engaged into a Conspiracy to Interfere with Civil Rights under 42 U.S.C. 1985(3). Griffin violated 42 U.S.C. 1986, when he neglected to prevent the wrongs conspired to be done by defendants and its lawyers, as mentioned in section 1983 and 85 of this title, and having power to prevent or aid in preventing the commission of the same, neglected or refuses so to do.

37.     In Fedorova's case, the trial court abdicated its role when it favorably ruled on legally insufficient Motion; and entered adverse decisions in purportedly consolidated cases 14-CH 11573 and 14-L-3632 in violation of the law and without subject matter jurisdiction. The job of the trial court is to rule on questions of law, not to grant absolution to attorneys to disregard rules of evidence and civil procedure. "Fraud upon the court” makes Void the orders and judgments

of that court. It is also clear and well-settled Illinois law that any attempt to commit "fraud upon the court”vitiates the entire proceeding.”

24 People V. Gersch, 135 Ill.2d 384, 553 N.E.2d 281 (1990); Agricultural Transp Asson v Carpentier,2 Ill.2d 19, 116N.E.863 (1963). Any act contrary to the above would be an action without lawful authority, a violation of the constitution and the judge's oath. Ajudge has no discretion to engage in a war against the Constitution. Cooper v. Aaron, 358 U.S. 1, 78 S. Ct. 1401 (1958). The iudge would be acting without subject-matter jurisdiction, and as stated below, would be engaged in an act of treason. USy. Will, 449 US 200,216, 101 S. ct. 471, 66 L.Ed.2d 392, 406 (1980); Cohens v. Virginia, 19 U.S. (6 Wheat) 264, 404, 5L. Ed. 257 (1821). In People v. Lambert, Case 294-1326 the Appellate Court of IL, (1997, 2"Dist) held: a judge's "failure to enforce the law invites anarchy."

The People of the State of Illinois v. Fred E. Sterling,357 Ill.354; 192 N.E.229 (1934) ("The maxim that fraud vitiates every transaction into which it enters applies to judgments as well as to contracts and other transactions."); Allen F. Moore v. Stanley F. Sievers, 336 Ill. 316; 168 N.E. 259 (1929) ("The maxim that fraud vitiates every

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38.    The Order to Consolidate case 14-CH-11573 with case 14-L-3632 was obtained in corrupt manner, in violation of applicable laws and perpetrated by fraud, thus a complete nullity and without effect. Herring v. U.S., 424 F.3d 384, at 386." In Bulloch v. United States, 763 F.2d 1115, 1121 (10th Cir. 1985), the court stated “Fraud upon the court is fraud which is directed to the iudicial machinery itself and is not fraud between the parties or fraudulent documents, false statements or perjury. It is where the court or a member is corrupted or influenced or influence is attempted or where the judge has not performed his judicial function - thus where the impartial functions of the court have been directly corrupted.” The 7th Circuit stated "a decision

produced by fraud upon the court is not in essence a decision at all, and never becomes final."

39.    Therefore, all Orders entered by Judge John C. Griffin in consolidated cases 14-L-3632 and 14-CH-11573 from October 2014 until present time must be vacated as void, and case 14-L- 3632 must be reviewed de novo, in accordance with the law and Due Process. A court does not need subject-matter jurisdiction to vacate a void order; it only needs the inherent power of the court, which every court has, to vacate the void orders issued. Since this court was without subject matter jurisdiction, this court only had the inherent power to vacate the void orders and judgment entered on July 17, 2015 and November 5, 2015 as originally void.

40.    A void Judgment is one which has no legal force or effect. Its invalidity may be asserted by any person whose rights are affected at any time and at any place directly or collaterally. Long v. Shorebank Development Corp., 182 F.3d 548 (C.A. 7 Ill. 1999). 'Fedorova posts that

transaction into which it enters..."); In re Village of Willowbrook, 37 IlI. App.2d 393 (1962) ("It is axiomatic that fraud vitiates everything"); Dunham v. Dunham, 57 Ill.App. 475 (1894), affirmed 162 Ill. 589 (1896); Skelly Oil Co. v. Universal Oil Products Co., 338 Ill.App. 79, 86 N.E.2d 875, 883-4 (1949); Thomas Stasel v. The American Home Security Corporation, 362 111.350; 199N.E. 798 (1935). * "This rule does not limit the power of a court to entertain an independent action to relieve a party from a judgment, order, or proceeding, or to grant relief to a defendant not actually personally notified as provided in Title 28, U.S.C., S1655, or to set aside a judgment for fraud upon the court." Rule 60(b). 'Void Judgment from its inception is and forever continues to be absolutely null, without legal efficacy, ineffectual to bind parties or support a right, of no legal force and effect whatever, and incapable of confirmation, ratification, or enforcement in any manner or to any degree. A judgment is a "void judgment" if the court that rendered judgment

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Judge Griffin acted with malice, actual bias and with intent to defraud Fedorova the judge has expressed an "appearance of partiality” and, under the law, it would seem that he has disqualified himself, yet continued to act without subject matter jurisdiction. Id." Here is no doubt that all orders rendered by Judge Griffin must be declared void. Where the relief is sought from a void order pursuant to section 2-1401(f), the court does not exercise its discretion or apply equitable principles in determining whether to grant relief. See People v. Hubbard, 2012 IL App (2d) 101158, S14. The only questions presented are issues of law, and the de novo standard of review applies. An order that exceeds the jurisdiction of the court is Void, and can be attacked in any proceeding in any court where the validity of the judgment comes into issue.”

             CONCLUSION.

43.    Void Judgement is one which has no legal force or effect, invalidity of which may be asserted by any person whose rights are affected at any time and at any place directly or collaterally. Fedorova properly petitions this Honorable Court and Judge Griffin to vacate his Decision entered on July 17, 2015, approved on November 5, 2015 as void.

44.      Grant Fedorova's request for Leave to File Amended Complaint in case 14-L-3632; to be reviewed de novo by a non-biased judge, who does not have a conflict of interest, and a judge who will act impartially who has enough professional pride to not accept bribes from litigants in his or her courtroom. Any other relief.

Respectfully submitted

Elena Fedorova, ProSe. May 24, 2017

To show fraud upon the court, the complaining party must establish that the alleged misconduct affected the integrity of the judicial process, either because the court itself was defrauded or because the misconduct was perpetrated by officers of the court. Alexander v. Robertson, 882 F.2d 421,424 (9th Cir. 1989).

A void judgment does not create any binding obligation. Kalb v, Feuerstein (1940) 308 US 433, 60 S Ct 343, 84 L, Ed.370.