BLACK HISTORY FACT! MOST BLACK PROMINENT LEADERS IN AUTHORITY OR JUDGES DO NOT HAVE JURISDICTION OVER ANGLO SAXON PERSONS ONLY THEIR ETHNICITY.
BLACK LIVES DON'T MATTER LIVING IN CHICAGO, ILLINOIS BECAUSE THE VERY LEADERS MANY LOOK UP TO HAVE SOLD OUT TO RACISM.
NOT ONE BLACK PERSON DENOUNCED THE RACIST EGREGIOUS ACTS PERPETRATED ON THESE WOMEN, THEY KEPT THEIR MOUTHS SHUT!!!
THE SAD REALITY IS THAT THEIR ARE SO MANY BLACKS STILL TO THIS DAY CONSIDER THEMSELVES AS HOUSE NIGGERS OR MODERN DAY SLAVES SO AS TO BE ACCEPTED BY ANGLO SAXONS CONTROLLING THE POLITICAL MACHINE.
READ WHAT A COLORED NEGROE JUDGE DID FREDRENNA LYLE DID IN HELPING U.S. BANK ATTTORNEYS TRY AND UNLAWFULLY STEAL THE HOME OF RETIRED CIVIL SERVANTS.
THE MENTALITY HERE IN CHICAGO SO MANY INFERIOR MINDED NEGROES HAVE IS THAT AS LONG AS THEIR CRIMES ARE PERPETRATED ON THEIR ETHNIC GROUP, ANGLO SAXONS CONTROLLING THE LEGAL SYSTEM WILL PROTECT THEM BECAUSE THEY DID NOT HURT OR OFFEND THEIR ETHNIC GROUPS.
To:
COURTESY COPY
HEARING 11:30AM March 10, 2020 Judge Lyle
1.) RESPONDENT’S REPLY MOTION TO ANYTHING AND EVERYTHING PLAINTIFF FILES ET al.
2.) RESPONDENT’S MOTION STRIKING & OBJECTING PETITIONER’S MOTION et al.
3.) RESPONDENT’S MOTION FOR SUMMARY JUDGMENT et al.
4.) RESPONDENT’S MOTION FOR SANCTIONS & RULE TO SHOW CAUSE REMANDING ALEXANDER B. POTESTIVO & ASSOC. et al.
5.) RESPONDENT’S MOTION STRIKING AND OBJECTING PETITIONER’S MOTION FOR EXTENSION OF TIME AS FRIVOLOUS et al.
SPECIAL NOTE: That Gr Ex A, from the Summary Judgment is the same document the Seventh Circuit Judges ordered Postestivo, law firm, Hinshaw & Culbertson, LLP, Locke Lord, LLP all received Notice and knowledge failed to respond to the court order; thereby, admitting to every pleading once said Summary Judgment was filed June 24, 2019.
Petitioner’s thought they were able to get away with filing defective documents as a legitimate Summary Judgment the Reply Motion have Plaintiff’s Summary Judgment Motion as Page 39 Exhibit D.
6.) 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).
In the matter of Raymond, 442 F. 3d at 606. (7th Cir. 2013) ) The Court, nevertheless, is concerned and considers the prejudice to Plaintiff for Plaintiff’s counsel’s failure, particularly because cases should be decided on their merits. Certainly, the failure to file a response to a summary judgment motion can be fatal. See, e.g., id at 611.
7.) As a retired Police Officer, it is clear from the actions of this law firm and any judge who aids and assist them in these crimes, trying to steal our home when the law is clear is pure corroboration in the parties being complicit in Criminal Terrorist Acts in said Criminal Enterprise in Cook County courts.
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.
Pursuant to Supreme Court Rule 137 states If a pleading, motion, or other paper is signed in violation of this Rule, the court, upon motion or upon its own initiative, may impose upon the person who signed it , a represented party, or both, an appropriate sanction, which may include an order to pay to the other party or parties the amount of reasonable expenses incurred because of the filling of the pleading, motion, or other paper, including a reasonable attorney fee. Not only will the courts consider an award of sanctions for active false statements: failures to disclose material facts to the court can also justify an award of sanctions.
BRUBAKKEN v. Morrison, No. 1-9-1670, 1992 Ill App. LEXIS 2144 (1st Dist. Dec. 30, 1992). Additionally, the fact that a false statement or omission is the result of an honest mistake is no defense to entry of a sanction. ID. To the extent that an individual lawyer has engaged in sanction able conduct, that lawyer’s firm can also be jointly and severally liable with the lawyer.
1. The Local Rules provide detailed instructions as to how litigants should approach their summary judgment motions and responses. Local Rule 56.1(a) provides that a motion for summary must include a "statement of material facts as to which the moving party contends there is no genuine issue and that entitle the moving party to a judgment as a matter of law."
This statement of material facts "shall consist of short numbered paragraphs, including within each paragraph specific references to the affidavits, parts of the record, and other supporting materials relied upon to support the facts set forth in that paragraph." Part (b) of Local Rule 56.1 requires a party opposing summary for judgment to file a concise response to the movant's statement of material facts. That statement is required to include a response to each numbered paragraph in the moving party's statement, including in the case of any disagreement, "specific references to the affidavits, parts of the record, and other supporting materials relied upon." 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).
In the matter of Raymond, 442 F. 3d at 606. (7th Cir. 2013) ) The Court, nevertheless, is concerned and considers the prejudice to Plaintiff for Plaintiff’s counsel’s failure, particularly because cases should be decided on their merits. Certainly, the failure to file a response to a summary judgment motion can be fatal. See, e.g., id at 611.
- That Pursuant to the aforementioned, Plaintiff has admitted and was served Gr Ex A via receptionist Cassandra Summary Judgment July 18, 2019, by Joe Louis Lawrence, hereto attached as Gr Ex B, Affidavit around 2:35 pm.
A- Plaintiff’s admitted pursuant to Gr Ex A Pages 11, 12 demonstrates how Judge Lyle taking part in helping a bank steal the home of a retired Chicago Board of Education teacher and Retired Police Officer and other judges in the Domestic Relations Division unlawfully taking children from mothers helping child rep attorneys accrue fees in this extortion operation.
First of all, I OBJECT to anything COUNSEL attempts to assert in this court due to the admissions already made in the Seventh Circuit when they failed to respond to the court’s order causing a summary judgment to be filed.
That Gr Ex A is the same document the Seventh Circuit Judges ordered Postestivo, law firm, Hinshaw & Culbertson, LLP, Locke Lord, LLP all received Notice and knowledge failed to respond to the court order; thereby, admitting to every pleading once said Summary Judgment was filed June 24, 2019.
3. For the record your Honor Plaintiff has not presented nothing before you timely or defensive refuting our Summary Judgment.
For Example, Nov. 19, 2019 Plaintiff filed purportedly what they thought was a Motion but it was a CERTIFICATION OF SERVICE ON DEFENDANTS if your Honor like have your Clerk to pull it up on the computer and see for yourself.
4. On Nov. 26, 2019, we received our Notice from the Plaintiff mailed from Rochester Michigan Friday or Saturday of that week where they filed a MOTION FOR SUMMARY JUDGMENT et al.
5. THE FACT THAT THIS LAW FIRM IS STANDING BEFORE YOU WHO HAVE NOT FILED ANYTHING REFUTING NOTHING WE HAVE PROPERLY ASSERTED IN OUR PLEADINGS THEY ARE NOT ONLY ADMITTING TO EVERYTHING BUT IS EXPECTING YOU TO “Trespass upon the Laws, continuously violate your OATH by becoming a “Private Citizen” and do whatever they tell you to aid and assist in stealing our home.
6. Your Court Order requiring a Briefing schedule violates our Civil Rights as Citizens and demonstrates you as the judge colluding with the Plaintiffs, the fact that you have signed a court order Dec. 9, 2019 and for some reason has not made into the computer is no surprise it appears to be a deliberate act to further stall give the Plaintiff as much time necessary further harassing us for fighting back in court stopping them from stealing our home unlawfully with your help.
7. For an Order Pursuant to Smith v. Wade, 461 U.S. 30, 35 103 S. Ct. 1625, 1629, 75 L Ed 2d 632 (1983) Justice Brennen “The threshold standard for allowing punitive damages for reckless or callous indifference applies even in a case, such as here, where the underlying standard of liability for compensatory damages because is also one of recklessness. There is no merit to petitioner’s contention that actual malicious intent should be the standard for punitive damages because the deterrent purposes of such damages would be served only if the threshold for those damages is higher in every case than the underlying standard for liability in the first instance. The common-law rule is otherwise, and there is no reason to depart from the common-law rule in the context of {1983} of $13 Million Dollars for the number of years they have had to endure the Terrorist Mayhem inflicted via stress and anxiety upon them by this Organized Terrorist Criminal Enterprise;
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