CHICAGO DEMOCRATS DON'T WON'T PRESIDENT TRUMP TO SEE HOW THE DIXIECRATS AKA DEMOCRATS ARE WORSE NOW THAN WHEN THEY OWNED SLAVES
BLACK HISTORY FACT
READ HOW BLACK AND BROWN JUDGES HAVE SOLD OUT THEIR ETHNIC GROUPS ACTING AS POST ERA SLAVES AIDING AND ASSISTING WHITE NATIONALIST DEMOCRATS IN THE COURTS AND CITY HALL TERRORIZING THEIR OWN PEOPLE SO AS TO BE ACCEPTED WITH A PAT ON THE BACK BEING A GOOD HOUSE NIGGER.
DEMOCRATS ARE LYNCHING PEOPLE OF COLOR USING PERSONS OF COLOR FROM ALLEGED HOMOSEXUAL AND BISEXUAL ARENAS PERPETRATING HATE CRIMES ON HETEROSEXUALS SURPASSING HUMAN IMAGINATION.
NOT ONE BLACK OR BROWN DEMOCRAT IN ANY AREA OF AUTHORITY WHO RECEIVED NOTICE AND KNOWLEDGE OF THE AFOREMENTIONED CRIMINAL ACTS PERPETRATED AGAINST THESE ELDERLY SENIOR CITIZENS WHERE JUDGES CONSPIRED WITH ATTORNEYS TO STEAL THESE WOMEN'S HOMES.
PRESIDENT TRUMP IS NOT RESPONSIBLE FOR ANY OF THESE ATROCIOUS CRIMES JIM CROW LAWS ARE BEING ENFORCED IN CHICAGO, ILLINOIS COURTS BECAUSE NIGGRO DEMOCRAT BLACKS HAVE ACCEPTED ROLES AS INFERIOR SUBMISSIVE BEINGS OR DOCILE COWARDS .
THE SAD REALITY MEN ARE NOT MEN ANYMORE, THEY DON'T TEND TO THE ELDERLY, THEY ARE NOT PROVIDERS, DUE TO THEIR SEXUAL IDENTITY MANY OF THEM HAVE ELECTED TO PLEASE THEIR RACIST MASTERS IN THE DEMOCRATIC MACHINE BY BUCK BREAKING ANY COLORED PERSON THAT STANDS UP TO THE DEMOCRATIC POLITICAL MACHINE.
“Buck Breaking” Breakdown
The scattered pieces of “buck breaking” is plaguing our community through prison culture. Prison culture and the structure is identical to the design of a plantation. The intense environment is the same as well. “Buck Breaking” is a method that was used by slave owners to strike fear in the witnessing slaves. This same procedure is used today. It is the process of brutally beating an individual in front of a group of people to incite fear and a sense of dominance. There is a hidden part of buck breaking. During slavery, after the male was beaten, the slave master would rape him in front of a group of people — including the black mans wife and children. After the individual was raped, he was forced to wear his clothes below his waist as a signal to other slave owners that he was already broken. This same signal is a huge part of prison culture.
IN THE CIRCUIT COURT OF COOK
COUNTY, ILLINOIS
COUNTY
DEPARTMENT--CHANCERY DIVISION
Feb.
10, 2020
COURTESY
COPY
PART II
HEARING 11:30AM March 10, 2020 Judge Lyle
1.) Pursuant to the original
court order by Judge Lyle (Dec. 9, 2019) Plaintiff’s requested 28 days to
respond but demonstrated disrespect and racist animus behavior by circumventing
the judges’ directive by failing to respond to Defendant’s Motions accompanied with
Affidavits.
2.) Pursuant to Jan. 8, 2020 Court
Order by Judge Lyle Plaintiff’s requested 28 days again to respond to all 4
Motions Defendant’s filed in Circuit Court totaling 56 days.
Please find: Postestivo Law firm bypassed responding
to said court order pitched the documents to Lord & Locke Law firm P.
Russel Perdew, Trustee’s Opposition to Johnson’s Cross-Motion for Summary
Judgment and Trustee’s Opposition to Johnson’s Motion for Sanctions.
3.) Most importantly, Plaintiff
stated Page 2 from their Opposition Cross Motion for Summary Judgment,
“Johnson mentions events that purportedly took place in Federal Court. She
also makes unsubstantiated claims that banks, attorneys, law firms, and judges
are engaged in a conspiracy against her. Johnson’s allegations are so vague
that the Trustee cannot present any evidence in response”.
4.) FACT: Plaintiff’s in their ranting rage to
insult and disparage pleadings presented by Pro Se litigants not with law
licenses seems to have affected the Democratic attorneys involved because said
actions perpetrated by Anglo Saxon men are a norm in Chicago and is not a crime
in their eyes, in that, Plaintiff never DENIED or OBJECTED to any
of Defendant’s Pleadings in their response.
5.) FACT: Plaintiff’s received Defendant’s Reply
Motion filed Jan. 22, 2020 did not dare impeach any of the Pleadings due to its
veracity attached with an Affidavit, Plaintiff’s did not dare impeach Defendant’s
Motion Striking & Objecting Petitioners’ Motion et al. due to its
veracity attached with an Affidavit, Plaintiff’s did not dare impeach Defendant’s
Motion Striking and Objecting Petitioners’ Motion for Extension of Time et al.
due to its veracity attached with an Affidavit.
6.) A Racist or Terrorist person within the Democratic Party will
never denounce their disposition
to any person of color, but expects Black and Brown Judges or Politicians to do
what they are told as Democrats in that said attorney with no respect for Judge
Lyle or any other person of color in authority figured, he can say and do
whatever, he felt because of the color of his skin knowing that Black and Brown
Democrats have no authority over men like himself!
7.)
Corrupt
Judges or attorneys don’t follow the rules in any court or simply don’t know
them because many are not fit to be judges in the first place. The rule is
very clear that "all material facts set forth in the statement required of
the moving party will be deemed admitted unless controverted by the statement
of the opposing party." Local Rule 56.1(b)(3)(B).
“No one is above the Law”, citing a 1928
decision by Supreme Court Justice Louis Brandeis Olmstead v. United States, 277 U.S. 438 (1928),
“We must subject government officials to the
same rules of conduct that we expect of the citizen. The very existence of the
government is imperiled if it fails to observe the law scrupulously. As
Brandeis puts it, "if the government becomes a lawbreaker, it breeds
contempt for law; it invites every man to become a law unto himself; it invites
anarchy. To declare that in the administration of the criminal law the end
justifies the means—to declare that the government may commit crimes in order
to secure the conviction of a private criminal—would bring terrible
retribution. Against that pernicious doctrine this court should resolutely set
its face."
8.) Plaintiff’s attorneys would never have filed
such insulting pleadings before Caucasian Judges, the sad reality is that so many
Black and Brown judges going along with said criminal acts so as to be accepted
by alleged members of the Democratic Party for favors or appointments.
This is all the reasons why the FBI and U.S. Attorneys need to be
on board ERADICATING every person COMPLICIT in these CRIMES
because they are worse than criminals on the streets stealing homes, destroying
peoples lives simply because they have the power.
Respectfully Submitted,
By: _________________
Monzella Johnson, Marcia Johnson
Counsel
Pro Se
CC FBI, (Buie) US Atty, (Lausch), Hon Mayor Lightfoot, Potestivo, S.
Atty, (Foxx) C.J. (Evans) P.J. (Jacobius)
Lord & Locke (Perdew) Atty Gen(Raoul) l
Media
R82175381v. 1
Return Date: No return date scheduled
Hearing Date: No hearing scheduled
Courtroom Number: No hearing scheduled
Location: No hearing scheduled FILED
2/5/2020 3:34 PM
DOROTHY BROWN
CIRCUIT CLERK COOK COUNTY, IL
2008CH33616
8366611
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 CERTIFICATES, SERIES 2006-NC3, )
Plaintiff,
) Case No. 2008 CH 33616
MONZELLA Y. JOHNSON, et. al,
Defendants.
TRUSTEE'S OPPOSITION TO JOHNSON'S CROSS-MOTION FOR SUMMARY JUDGMENT
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 Certificates, Series 2006-NC3 (the "Trustee”) opposes Monzella Johnson's cross-motion for summary judgment. Johnson's motion is rambling and often unintelligible. While styled as a motion for summary judgment, it is not a summary judgment motion at all. Johnson fails to meet the legal standard for summary judgment, and the Court should deny the motion as a result.
Summary judgment is proper where the pleadings, depositions, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” 735 ILCS 5/2-1005(c). “By filing cross-motions for summary judgment, the parties invite the court to determine the issues as a matter of law and posit that judgment in favor of one of the parties is proper.” Wolfram Partnership v. LaSalle Nat. Bank, 328 III. App. 3d 207, 215 (2001). A party cannot rely on mere allegations at the summary judgment stage; the movant “must present evidence through
82216621v.2
depositions, affidavits and admissions to support the allegations.” Richter v. Burton Inv. Properties, Inc., 240 111. App. 3d 998, 1002 (1993).
2008CH33616 Johnson's motion does not analyze any of the pleadings or evidence to show that no genuine issue of fact exists and that she is entitled to summary judgment. Instead, the motion makes allegations that are irrelevant to the Trustee's foreclosure action against Johnson. For example, Johnson mentions events that purportedly took place in federal court. She also makes unsubstantiated claims that banks, attorneys, law firms, and judges are engaged in a conspiracy against her. Johnson's allegations are so vague that the Trustee cannot present any evidence in response. Such baseless claims do not satisfy the summary judgment standard and the Court should deny Johnson's motion as a result. In re Estate of Hoover, 155 III. 2d 402, 410 (1993) ("Summary judgment is, therefore, proper only when the resolution of a case hinges on a question of law and the moving party's right to judgment is clear and free from doubt.").
CONCLUSION
For these reasons, the Trustee respectfully requests that this Court deny Johnson's cross motion for summary judgment and for any other relief this Court deems fair and just.
Dated: February 5, 2020
Respectfully submitted,
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 Certificates, Series 2006-NC3
By: /s/ P. Russell Perdew
One of Its Attorneys
P. Russell Perdew
rperdew@lockelord.com
Locke Lord LLP
111 South Wacker Drive
Chicago, Illinois 60606
Telephone: 312-443-0700 Firm ID No. 44058
82216621v.2
CERTIFICATE OF SERVICE
I, P. Russell Perdew, an attorney, certify that I caused the foregoing Trustee's Opposition to Johnson's Motion for Sanctions to be e-filed and served upon:
2008CH33616
Monzella Y. Johnson
5217 S. Ingleside Avenue
Chicago, Illinois 60615
FILED DATE: 2/5/2020 3:34 PM
Mr. Art Sriratana
Potestivo & Associates, P.C.
223 West Jackson Boulevard, Suite 610
Chicago, Illinois 60606
by placing a copy of said document into a properly addressed envelope, first class postage prepaid, and placing said envelope into the U.S. Mail depository located at 111 South Wacker Drive, Chicago, Illinois 60606 on February 5, 2020 on or before the hour of 5:00 p.m.
/s/ P. Russell Perdew
82216621v.2
Return Date: No return date scheduled
Hearing Date: No hearing scheduled
Courtroom Number: No hearing scheduled
Location: No hearing scheduled FILED
2/5/2020 3:34 PM
DOROTHY BROWN
CIRCUIT CLERK COOK COUNTY, IL
2008CH33616
8366611
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 CERTIFICATES, SERIES 2006-NC3, )
Plaintiff,
) Case No. 2008 CH 33616
MONZELLA Y. JOHNSON, et. al,
Defendants.
TRUSTEE'S OPPOSITION TO JOHNSON'S MOTION FOR SANCTIONS
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 Certificates, Series 2006-NC3 (the "Trustee”) opposes Monzella Johnson's motion for sanctions. Johnson's sanctions motion is another meritless filing brought by her in this foreclosure case. The motion is based entirely on unsubstantiated claims that banks, attorneys, law firms, and judges are engaged in conspiracy against her. Although the motion is 19-pages long, it fails to meet the legal requirements for a motion for sanctions. “It is well settled that a motion for sanctions must meet minimum requirements of specificity so that a responding party has an opportunity to challenge and defend against the allegations made and so that fees and costs may be fairly apportioned.” Whitmer v. Munson, 335 Ill. App. 3d 501, 512 (2002) (citation omitted).
Other than a vague claim that there is a conspiracy formed against her, Johnson fails to articulate with specificity the alleged sanctionable conduct. Not only is the motion devoid of any specific acts of misconduct, Johnson also fails to provide the legal basis for her motion. Instead,
82175381v. 1
she cites to irrelevant and inapposite portions the Illinois Supreme Court Rules, Illinois Rules of Professional Conduct, state law, and federal law. And most critically, Johnson provides no evidence to support any of her vague allegations of misconduct. Simply put, the motion lacks factual, legal, and evidentiary support. Accordingly, this Court should deny Johnson's motion for sanctions.
CONCLUSION
For these reasons, the Trustee respectfully requests that this Court deny Johnson's motion
for sanctions and for any other relief this Court deems fair and just.
Dated: February 5, 2020
Respectfully submitted,
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 Certificates, Series 2006-NC3
By: /s/ P. Russell Perdew
One of Its Attorneys
P. Russell Perdew
rperdew@lockelord.com
Simon M. Feng simon.feng@lockelord.com
LOCKE LORD LLP
111 South Wacker Drive
Chicago, Illinois 60606
Telephone: (312) 443-0700
Firm ID No. 44058
82175381v. 1
CERTIFICATE OF SERVICE
I, P. Russell Perdew, an attorney, certify that I caused the foregoing Trustee's Opposition to Johnson's Motion for Sanctions to be e-filed and served upon:
Monzella Y. Johnson
5217 S. Ingleside Avenue
Chicago, Illinois 60615
FILED DATE: 2/5/2020 3:34 PM 2008CH33616
Mr. Art Sriratana
Potestivo & Associates, P.C.
223 West Jackson Boulevard, Suite 610
Chicago, Illinois 60606
by placing a copy of said document into a properly addressed envelope, first class postage prepaid, and placing said envelope into the U.S. Mail depository located at 111 South Wacker Drive, Chicago, Illinois 60606 on February 5, 2020 on or before the hour of 5:00 p.m.
/s/ P. Russell Perdew
No comments:
Post a Comment