EVERY IRISH, SCOTTISH, POLISH ETHNIC JUDGES ALONG WITH MEMBERS OF THE LGBT COMMUNITY HAS DENIED EVERY MOTION, I PRESENTED IN EVERY COURT AND THE IDENTITIES OF EVERY BLACK WOMAN OR MAN WHO WENT ALONG WITH THESE VICIOUS HUMAN RIGHTS CRIMES.
MOST BLACK OR COLORED INDIVIDULS ARE SELECTED IN POSITIONS SIMPLY TO OPPRESS AND VIOLATE THE CIVIL AND HUMAN RIGHTS OF THEIR OWN ETHNIC GROUPS
CHICAGO, ILLLINIOS POLITICAL ARENA IS LIKE A PLANTATION CONTRARY TO EVERYONE IS SUPPOSED TO BE "FREE" THE LEGALSYSTEM DO NOT RECOGNIZE FREE MEN OR WOMEN, THEY ONLY ACCEPT THOSE WHO WILL ALLOW THEMESELVES TO BE USED OR WALKED ON AS A DOORMAT
LOOK AT WHAT SO MANY DID TO AN INNOCENT MAN, FOR SO MANY YEARS TRYING TO COVER UP THE FACT. HE WAS NEVER THE FATHER OF HER CHILD WHO WAS ALLEGEDLY CONCIEVED VIA INCEST.
Joe Louis
Motion for Judicial Notice, Request for Assignment of Visiting Circuit Judge, Request for Out-of-Circuit Designation (28 U.S.C. §§291-296) Request for Circulation to Active Judges of the Court and Statement of Structural Due Process Violations
Plaintiff had been on Welfare with his wife and five children since 1990’s when the CTA refused to pay workman’s compensation
- The Defendant was scientifically excluded by two independent laboratories
- Reported probabilities were mathematically impossible
- Genetic markers conclusively disproved paternity
- The State knew of non-paternity by 1987
- Subsequent actions required suppression, distortion, or disregard of truth
- The injustice that followed was not accidental, but structural
·
· The Cook County Test: Mathematical Impossibility of Inclusion
· The Cook County report recorded a Combined Paternity Index of approximately 17,905, which was EXCLUSION OF PATERNITY which was then falsely interpreted as reflecting a 99.99% probability of paternity.
· This interpretation is mathematically impossible.
· Under accepted genetic-statistical standards, the relative chance of paternity is calculated by dividing the Combined Paternity Index by the prior probability denominator (typically 100 or 1000, depending on the model used). A CPI of 17,905 does not yield a 99% probability of paternity. It yields an exclusionary probability, consistent with non-paternity.
· Put plainly:
· One cannot mathematically arrive at 99% certainty from a figure that does not meet the required threshold.
· Numbers do not lie
The American Red Cross Test: Genetic Exclusion by Mendelian Law
The American Red Cross test independently excluded the Defendant as well.
Most critically, the test revealed a genetic marker listed as UNDETECTED in the child, while present in both the mother and the alleged father. Under the Mendelian laws of inheritance, this is dispositive:
· A child must inherit one genetic marker from each parent.
· A child cannot possess a marker absent in both parents.
· The presence of an undetected marker constitutes direct exclusion.
Respectfully Submitted Notary
____________________
Joe Louis Lawrence
PO Box 4353
Chicago, IL. 60680
UNITED STATES COURT OF APPEALS
FOR THE SEVENTH CIRCUIT
CHICAGO, ILLINOIS 60604
Joe Louis Lawrence } Appeal from the
United
} States
District Court for
} the Northern District of
Plaintiff –Appellant }
Illinois, Eastern Division
V
}
}
No. 26-1226
}
Verizon Communications, Inc et al. }
Defendants-Appellants } Judge Robert Blakey
Motion
for Judicial Notice, Request for Assignment of Visiting Circuit Judge, Request
for Out-of-Circuit Designation (28 U.S.C. §§291-296)
Request
for Circulation to Active Judges of the Court and Statement of Structural Due
Process Violations
PURSUANT TO 28 U.S.C. §§
291–296 AND FOR REASSIGNMENT IN THE INTEREST OF JUSTICE
Motion for Judicial Notice, Request
for Assignment of Visiting Circuit Judge, Request for Out-of-Circuit
Designation (28 U.S.C. §§291-296) Request for Circulation to Active Judges of
the Court and Statement of Structural Due Process Violations
Appellant respectfully
moves the Court, pursuant to Federal Rule of Evidence 201, to take judicial
notice of publicly documented statements and publications concerning
institutional concerns related to the treatment of pro se litigants within the
Seventh Circuit.
Appellant respectfully moves this Court to request the designation and assignment of
a visiting circuit judge from outside the Seventh Circuit
pursuant to 28 U.S.C. §291,
to ensure the fair and impartial administration of justice in the present
appeal.
These materials are not
presented to impugn the integrity of any individual judge, but rather to
provide context for the structural due process issues raised in this appeal and
to ensure that the Court is aware of matters that have already been publicly acknowledged
by respected members of the judiciary.
I. LEGAL STANDARD FOR JUDICIAL
NOTICE
Federal Rule of Evidence
201 permits a court to take judicial notice of facts that are not subject to
reasonable dispute because they:
A-
Are generally known within
the court’s territorial jurisdiction, or
B-
can be accurately and readily determined from sources whose
accuracy cannot reasonably be questioned.
Courts routinely take
judicial notice of public records, widely reported statements, and publications
when those materials are relevant to issues before the court.
II. MATERIALS SUBJECT TO
JUDICIAL NOTICE
Appellant respectfully
requests that the Court take judicial notice of the following materials:
A. Public Statements of
Former Seventh Circuit Judge Richard Posner
Former Seventh Circuit
judge Richard A. Posner publicly described concerns regarding the treatment of
pro se litigants within the United States Court of Appeals for the Seventh
Circuit following his retirement from the bench in 2017.
In reporting published by
the American Bar Association in the ABA Journal (September 11, 2017),
Judge Posner stated:
“The basic thing is that
most judges regard these people as kind of trash not worth the time of a
federal judge.”
Judge Posner further
explained that appeals filed by pro se litigants are frequently screened
through staff attorney memoranda which are then presented to judicial panels.
Judge Posner publicly
stated that he attempted to personally review such memoranda in order to ensure
meaningful judicial consideration of pro se appeals but that his colleagues
declined to allow him to assume that role.
These statements were
further discussed in interviews reported by The New York Times following his
retirement.
Ex A, New York Times, (9/11/2017)
Journalist Adam Liptak: An Exit Interview With Richard Posner, Judicial
Provocateur
Ex B, ABA JOURNAL, (9/11/2017) Journalist
Debra Cassens Weiss: Most Judges regard pro se litigants as ‘kind of trash not
worth the time’.
Ex C, ABA JOURNAL,
(9/26/2017) Journalist Debra Cassens Weiss: Posner says he is open to
litigating on behalf of pro se litigants, defends book.
B. Public Reporting
Concerning Internal Disagreements Regarding Pro Se Appeals
Public reporting has
documented that Judge Posner’s disagreements with other members of the court
regarding the treatment of pro se litigants contributed to his decision to
retire from the bench.
The accuracy of these
reports can be readily verified through widely available publications and
public interviews.
III. RELEVANCE TO THE PRESENT
APPEAL
The materials described
above are relevant to this appeal because they address institutional practices
affecting the treatment of pro se litigants, which directly relates to the
structural due process concerns raised by Appellant.
These materials provide
important context demonstrating that questions regarding the handling of pro se
appeals within the circuit have been publicly recognized by a former member of
the court itself.
The requested judicial
notice would therefore assist the Court in evaluating the broader institutional
context surrounding the issues raised in this case.
Appellant respectfully
moves this Court for an order requesting the designation of a judge or panel
from outside the Seventh Circuit pursuant to 28 U.S.C. §§ 291–296, or in
the alternative reassignment of the case, in order to safeguard the
constitutional guarantee of a neutral tribunal.
This motion is based on
substantial concerns regarding the appearance of structural bias and
repeated failure to address documented due-process violations originating in
the district court proceedings.
A-
No. 07 C
1191, Petitioner prepared a Brief
RECEIVED
USCA-7th Circuit
DEC 14, 2016 NR
B-
Petitioner 07-16-90079 lost her
home of 65 years now sister as a result to the illegal foreclosure.
C- No. 11-3481 Two Independent Medical
Labs Excluded the accused Father from Paternity in 1986 under 85 D 068184
and Dismissed September 17, 1987, In 1987, the court stated, “the State of Illinois ordered Joe Lawrence to
pay child support. He did not comply, and
consequently the state revoked his driver's license. He appealed the revocation
to the Secretary of State, but his appeal was denied. Lawrence also
unsuccessfully sued his former
employers, International Brands Corporation and the Chicago Transit Authority,
in state and federal court for embezzlement and theft.
"The appellees were not served
with process in the district court and are not
participating in this appeal.
Case was
refiled without his knowledge Defaulted May 18, 1988 never Vacated or Child
Support ever entered but, he has been Remanded into Custody five Times for
Allegedly owing Child Support.
Cook County Judges are continuing to treat this 41-year-old
woman as if she is a minor On
February 8, 2026, the Defendant received a letter from the Public Aid Child
Support Division enclosing an order signed by a judge entitled Support for
Children. with an entry date of Order of
Support, the payment of $228.00 as of Nov. 5, 2025.
D-
Petitioner has never
Been Discharged from the CTA and Affidavit Rider (March 9, 2026) has been
tendered with the Motion to Proceed Informa Pauperis particularizing all events pursuant to Federal Rule 8 and
9 detailing why he is not physically
at his employment.
E-
26-1226 District Court received a Motion Jan 2, 2026 via email
court was closed it was a holiday and granted the attorney his request to
answer because they stated “Motion for Leave to File Answer Out of Time”
(Kelly, Matthew) Jan 6, 2026 without any Notices to the opposing side
and before his Wednesday Court Calendar.
Plaintiff
has never received Due Process or Appointment of Counsel and has been many
times denied and deemed Frivolous, or Fanciful and on all accounts of Retired
Judge Richard Posner statement about Pro se litigants as being deemed Trash has
been corroborated by those who have reviewed the egregious injustices he has
experienced in the courts exceeding thirty decades.
I. LEGAL BASIS FOR
OUT-OF-CIRCUIT DESIGNATION
Federal law expressly
provides for the temporary designation of judges across circuits when
the public interest requires.
Under 28 U.S.C. §
291(a), the Chief Justice of the Supreme Court of the United States may
designate a circuit judge from another circuit to perform judicial duties.
Similarly:
- 28 U.S.C. § 292(d) authorizes assignment of
district judges across circuits.
- 28 U.S.C. §§
294–296 authorize designation of senior judges for service outside their
home circuits.
These provisions exist to
address circumstances where recusal, conflicts, or institutional
considerations make outside judicial assignment appropriate.
II. CONSTITUTIONAL
REQUIREMENT OF A NEUTRAL TRIBUNAL
The Due Process Clause guarantees litigants the
right to adjudication before an impartial court.
The Supreme Court of
the United States has held that due process is violated where circumstances
create a serious risk of actual bias or prejudgment.
Relevant precedent
includes:
- Caperton v. A.T. Massey Coal Co., 556 U.S. 868 (2009)
- Tumey v. Ohio, 273 U.S. 510
(1927)
- Offutt v.
United States, 348 U.S. 11 (1954)
These decisions emphasize
that courts must avoid even the appearance of justice being compromised.
Congress has expressly authorized the temporary assignment of circuit
judges across circuits where the public interest so requires.
Under 28 U.S.C. §291(a), the Chief Justice of the Supreme Court
of the United States may designate and assign a circuit judge from another
circuit to perform judicial duties when necessary for the proper administration
of justice.
This statutory mechanism exists to address circumstances in which recusal
issues, institutional concerns, or other considerations make outside
judicial participation appropriate.
The Supreme Court of the United States has repeatedly emphasized
that courts must guard not only against actual bias but also against
circumstances that create an appearance of compromised neutrality.
Assignment of a visiting judge under §291 would help ensure that the
issues raised in this appeal are evaluated with the independence and
impartiality required by the Constitution.
III. GROUNDS SUPPORTING
OUTSIDE ASSIGNMENT
Appellant respectfully
submits that reassignment or outside designation is warranted due to the
following circumstances documented in the record:
- Repeated refusal to address recusal issues raised under
28 U.S.C. §455.
- Failure to
correct clear procedural violations originating in the district
court.
- Patterned
dismissal of constitutional claims without analysis, despite
controlling precedent.
- Institutional
conflict concerns arising from the appellate court reviewing the
conduct of judges within its own circuit.
Where appellate review
involves alleged misconduct or bias of district court judges within the same
circuit, the use of outside judicial designation may be necessary to
ensure public confidence in the integrity of the proceedings.
The appeal presents questions concerning:
- structural due process
protections in federal proceedings;
- the treatment of pro se litigants
within the appellate process; and
- the review of conduct originating
within the courts of the same circuit.
Where an appellate court is called upon to evaluate issues implicating
the functioning of courts within its own circuit, the participation of a
visiting judge can serve as an important safeguard ensuring independent and
impartial review.
IV. PRESERVATION OF
STRUCTURAL DUE PROCESS CLAIM
The Supreme Court of the United States has repeatedly recognized
that due process is violated not only by actual bias but also by structural
circumstances that create a serious risk of bias or prejudgment.
Structural due process violations arise where the institutional framework
of the proceedings creates a substantial risk that claims will not receive
meaningful judicial consideration.
In the present matter, Appellant respectfully submits that several
circumstances reflected in the record raise such concerns, including:
- the treatment of constitutional
claims raised by a pro se litigant;
- the procedural handling of
motions raising judicial recusal and due process violations;
- the appellate review of actions
originating within courts of the same circuit; and
- publicly documented concerns
regarding institutional practices affecting pro se appeals.
Former Seventh Circuit judge Richard A. Posner publicly
acknowledged concerns regarding the treatment of pro se litigants within the
circuit, stating that many judges regard such litigants as “not worth the time
of a federal judge.”
While Appellant does not attribute improper motives to any individual
judge, such statements underscore the importance of ensuring that pro se
litigants receive the full measure of judicial consideration guaranteed by
the Constitution.
When circumstances raise reasonable questions regarding the structural
fairness of the adjudicative process, courts possess both the authority and the
responsibility to implement safeguards that preserve the appearance and reality
of impartial justice.
Such safeguards may include:
- designation of visiting judges
from other circuits,
- broader judicial circulation of
the case, and
- recognition of institutional
concerns through judicial notice.
Appellant therefore respectfully submits that the relief requested in
this motion is necessary to protect both the rights of the litigant and the
integrity of the judicial process.
Appellant raises this
motion in order to preserve the constitutional issue that continued
adjudication within the present judicial structure may deny a neutral tribunal,
in violation of the Fifth Amendment.
Failure to consider
outside designation would therefore implicate:
- the Due Process Clause,
- 28 U.S.C. §455, and
- the statutory
framework governing judicial designation.
V. REQUEST FOR RELIEF
Appellant respectfully
requests that this Court:
- Request designation of a judge or panel from outside the Seventh
Circuit pursuant to 28 U.S.C. §§291–296; or
- Refer the
matter to the Chief Justice for outside assignment; or
- Grant such
other relief necessary to ensure adjudication by a neutral tribunal.
- Appellant therefore respectfully submits that the
relief requested in this motion is necessary to protect both the
rights of the litigant and the integrity of the judicial process.
VI. CONCLUSION
For the foregoing reasons,
Appellant respectfully requests that this Court grant the requested relief and
ensure that the matter is adjudicated in a manner consistent with the constitutional
guarantee of an impartial judiciary.
Respectfully submitted
Appellant
Pro Se
Date: March 9, 2026
Respectfully submitted,
DECLARATION UNDER PENALTY OF PERJURY
I declare under penalty of perjury under the laws of the United States of
America that the foregoing is true and correct to the best of my knowledge.
Executed on: March 9, 2026
City & State: Chicago, Illinois
JOE LOUIS LAWRENCE
Plaintiff, Pro Se
IN THE
UNITED STATES
COURT OF APPEALS
FOR
THE SEVENTH CIRCUIT
CHICAGO, ILLINOIS 60604
Joe Louis Lawrence } Appeal from the
United
} States
District Court for
} the Northern District of
Plaintiff –Appellant }
Illinois, Eastern Division
V
}
}
No. 26-1226
}
Verizon Communications, Inc et al. }
Defendants-Appellants } Judge Robert Blakey
CERTIFICATE
OF SERVICE
I Joe Louis Lawrence certify that on March 9 2026 I have
caused proper service to be had on the Defendant’s counsels and noted parties
in the Certificate of Service via electronic/email delivery.
To
Camille R. Nicodemus, Esq. (IL #2452849)
Quilling,
Selander, Lownds, Winslett & Moser, P.C.
10333 North
Meridian Street, Suite 200
Indianapolis, IN
46290
Telephone: (317) 497-5600, Ext. 601
Fax: (317) 899-9348
E-Mail: cnicodemus@qslwm.com
Hope
Blankenberger
Counsel for
Defendant Trans Union LLC
POLSINELLI PC
By: /s/ Rodney L. Lewis
Rodney L. Lewis
Kevin M. Hogan
Polsinelli PC
150 North Riverside Plaza, Suite 3000
Chicago, Illinois 60606
Tel. (312) 819-1900
Fax (312) 819-1910
rodneylewis@polsinelli.com
kmhogan@polsinelli.com
Attorneys for
Defendant Equifax Information Services, LLC
/s/ Stephen D. Lozier
Stephen D. Lozier
Troutman Pepper Locke LLP
111 S. Wacker Dr, Suite 4100
Chicago, Illinois 60606
Telephone: (312) 759-3203
stephen.lozier@troutman.com
Attorneys for Defendant Experian Information
Solutions, Inc
Segal McCambridge
Singer & Mahoney, LTD 233 S
Wacker Dr. Suite 5500
Chicago, Illinois 60606
Matthew D. Kelly mkelly@msm.com
Attorneys for Verizon Communications, Inc.
Chief Judge Charles Beach U.S. Attorney Andrew S. Boutras
ocj.chief@cookcountyil.gov 219 S. Dearborn, Street 5th
floor
Dir. FBI,
Hon Mayor Brandon
Special Agent in Charge (FBI) City Hall 7th floor
Chicago, IL. 60601
2111 West Roosevelt Road
Chicago,
Il 60608
Cook
County Clerk, Mariyana Spyropoulos
CCCWebsite@cookcountycourt.com
Attorney General Cook County
States Attorney
Kwame Raoul alexandrina.shrove@ilag.gov Eilene O’Neil Burke
555 West Monroe Suite
1300 statesattorney@cookcountyil.gov
Chicago, Ill. 60601
PLEASE BE ADVISED that on March 9,
2026 A Motion
for Judicial Notice, Request for Assignment of Visiting Circuit Judge, Request
for Out-of-Circuit Designation (28 U.S.C. §§291-296) et al has been filed in the
Seventh Circuit
Respectfully submitted,
Joe Louis Lawrence
Plaintiff, Pro Se
PO Box 4353
Chicago, Illinois 60680
312
965-6455
joelouis565@yahoo.com
