THE PATERNITY CASE 1988 D 079012 HIGHTOWER V LAWRENCE IS A FIXED PATERNITY CASE FRAUGHT WITH FRAUD AND CORRUPTION WHERE AN INNOCENT MAN WHO HAVE BEEN EXCLUDED FROM PATERNITY IN 2 SEPERATE TESTS UNDER THE 85 D 068184 CASE WHERE LEAD ASSISTANT STATES ATTORNEY OBRIETTA SCOTT INFORMED THE DEFENDANT THIS WAS NOT HIS CHILD.
GOVERNORS, ALDERMEN, MURDERERS, CAR JACKERS AND RAPISTS' ETC HAVE BEEN CONVICTED SENT TO PRISON AND ARE BACK AT HOME, BUT AN INNOCENT MAN HAS BEEN LANGUISHING IN THE COURTS FOR ALMOST 40 YEARS WHERE EVERY JUDGE OF IRISH OR POLISH ETHNICTY HAVE ALL ILLEGALLY SIGNED COURT ORDERS PROVING JUST HOW RACIST AND CORRUPT CHICAGO IS TOWARDS PERSONS OF COLOR.
ILLINOIS JUDGES ARE STILL ENFORCING JIM CROW LAWS OR RACIAL APARTHEID IN THE COURTS--NO BLACK OR COLORED POLITICIAN IS ALLOWED TO SPEAK UP ABOUT THESE INJUSTICES UNLESS IT WAS ICE OR PRESIDENT TRUMPS POLICIES INVOLVED.
I HAVE BEEN LOCKED UP 5 TIMES FOR ALLEGEDLY OWING CHILD SUPPORT WHILE ON PUBLIC AID AND OFF WORK WITH THE CTA WITH A WORK-RELATED INJURY.
AFFIDAVIT RIDER
SUPPORTING THE MOTION TO PROCEED INFORMA PAUPERIS
Particularized Reasons for the Plaintiff’s Indigency
I Joe Louis Lawrence Pro Se being duly sworn on oath states the aforementioned pleadings enumerated within said Affidavit, the undersigned certifies that the statements set forth in this instrument are true and correct, except as to matters therein stated to be on information and belief and as to such matters, the undersigned certifies as aforesaid that he verily believes the same to be true.
That Cook County Judge engineered the unlawful warrant in 1994 (WAS RONALD BARTKOWICZ A FORMER CTA ATTORNEY FROM THE WORKMAN'S COMPENSATION DEPARTMENT) forcing the Plaintiff off of his job to allegedly conceal the identity of the judge who signed a garnishee for Joseph V. Roddy to extort money from his wages in said child matter for legal fees.
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
Thousands have been jailed in Cook County for not paying child, spousal support
People who fail to pay court-ordered support to their children or former spouses can land in jail. Expanding access to lawyers for parents at the start of divorce cases could mean fewer problems in paying, as would a better take on what they can pay, experts say.
For parents navigating family court in Cook County, falling behind on child support and other court-ordered payments can carry consequences that extend far beyond mounting debt.
It can mean going to jail.
Over the past decade, more than 2,500 people — nearly all of them men — have been locked up after Cook County judges found them in what’s called indirect civil contempt.
Most were detained for failing to comply with court-ordered payments to children or former spouses, according to Cook County sheriff’s records.
Those jailed spent an average of eight days in custody. But about 100 people were held for 50 days or longer. Of them, about 25 were locked up for more than 100 days, according to sheriff’s data from April 2016 to the end of March 2026.
One man, Steve Fanady, has been in jail for nearly four years.
A Chicago Sun-Times’ analysis of sheriff’s records exposes what some say is a punitive side of a system that civil rights advocates and some court observers say offers little legal help to those unable to afford a lawyer.
Unlike criminal defendants, people accused of violating support orders in civil court aren’t automatically entitled to legal representation even though they might face incarceration.
In Cook County’s sprawling domestic relations court system — which handles roughly 40,000 divorce and child-support cases each year — advocates estimate that at least half of the litigants come to court without a lawyer. Most are Black.
“Generally speaking, this is a bad system,” said Elizabeth Monkus, senior staff attorney with Chicago Appleseed for Fair Courts, an advocacy group focused on judicial reform.
Legal scholars say such cases point up the tension at the center of the child-support system: how to enforce court orders while recognizing the financial realities facing parents.
In Illinois, that support lasts until a child is 18 — 19 if the child is finishing high school. And parents can be required to pay for college, too.
Elizabeth Katz, a University of Florida law professor who has studied civil contempt in family courts, said the court system in the United States creates significant risks because people can be jailed without the procedural protections available in criminal cases.
“Most of these people are incarcerated based on civil contempt, so they did not have access to a public defender,” Katz said. “That’s a problem in jurisdictions where courts have limited time and resources to dig in on whether the failure to pay is willful.”
“There’s a real risk,” she said, “that people are being incarcerated for reasons beyond their control and in a manner that is counterproductive.”
There are parallels to another legal process that’s drawn wide criticism: civil asset forfeiture. People who face having their cars or cash forfeited because cops suspect the property was tied to a crime also don’t have an automatic right to an attorney.
In criminal courts, people accused of anything from shoplifting to murder have the right to a public defender if they don’t have the money to pay a lawyer. Not so, though, in the civil court system.
Cook County has established a rule to connect low-income litigants in domestic relations cases with volunteer lawyers through bar associations when they face possible orders of indirect civil contempt for failing to pay their support.
But Monkus said those efforts have largely faltered. She said bar associations in Chicago are not recruiting lawyers to take cases involving involuntary civil contempt on a volunteer basis or maintaining comprehensive lists of attorneys available for appointment. Even when such lists existed, judges often did not rely on them, she said.
“It sounds like most of the judges were not making the appointments anyway,” Monkus said.
Chief Cook County Judge Charles S. Beach II didn’t respond to a request for comment.
In 2017, Cook County created a program in which hearing officers assist self-represented litigants with navigating family court proceedings. But those hearing officers are prohibited from giving legal advice.
Monkus describes the program as “generally successful” but insufficient to address the broader lack of legal representation.
“There is the sense that a lot of the failure to pay could be prevented if the parent had representation earlier in the process,” she said.
Most of the contempt cases differ sharply from the highly publicized examples of wealthy parents failing to pay large support judgments, advocates say.
“The issue is often, ‘Can I pay my rent versus can I pay my child support?’ ” Monkus said.
At the heart of whether someone is found in contempt for not paying is whether the failure to pay was “willful.”
Fanady has been held in jail for indirect civil contempt of court since June 28, 2022. The Illinois appeals court found his incarceration was proper because he was able to turn over $10 million in stock awarded to his former wife.
In a court filing, Fanady said it was impossible to award his former wife the stock she is seeking because the shares awarded in the judgment “no longer exist” and were determined to “belong to others.”
But the appeals court said he “had not met his burden to show that it was impossible to comply with the order.” He was “the architect of his own predicament,” the court said in a decision in June 2025.
Fanady, who now represents himself in court, couldn’t be reached for comment.
In another case, the same appeals court decided to free civil rights lawyer David Cerda, who had spent three months in the Cook County Jail as a result of not paying about $250,000 in support. He owed the money to the children he has with his ex-wife, former Fox 32 new anchor Roseanne Tellez.
Cerda “purged” his contempt several times when his father made payments of $5,000 on his court-ordered debt. But he testified he couldn’t pay the full amount of past-due child support because he owed more than $400,000 in taxes.
On Sept. 17, 2024, Cook County Circuit Judge Regina Scannicchio, presiding judge of the county’s domestic relations courts, had enough. She ordered Cerda jailed until he paid the full amount, dismissing his “defense of poverty and misfortune.” She questioned why he wasn’t using his law license to make the money he needed to pay his debt.
“It is unfortunate that you continue to make certain choices, Mr. Cerda, that have pretty dire consequences,” the judge said.
In a court filing in early December 2024, Tellez’s lawyers wrote: “David was given the opportunity to provide evidence regarding his supposed indigency and lack of funds during the course of a multi-day hearing on contempt and yet failed to do so.”
But just before Christmas of 2024, the appeals court ordered Cerda’s release from jail, finding that Scannicchio failed to adequately determine whether Cerda had the financial ability to comply with the order.
“The trial court abused its discretion by ordering him jailed without making a finding that he had the ability to pay the purge amount,” the court said.
There’s been no activity documented in the case since January 2025.
Cerda didn’t respond to a request for comment.
Some family courts have experimented with ways to divert parents from a course that might end with a contempt order and jail. “Parental accountability courts” have been operating in Georgia for 17 years. The aim is to help noncustodial parents find employment and job training and combat substance abuse so they can make a dent in their support debts without repeated contempt findings or jail stays.
According to state officials in Georgia, child-support collections have risen significantly after people “graduate” from these courts.
A similar accountability court in downstate Madison County was launched in 2016 — the first of its kind in Illinois. But it no longer exists in the county’s array of specialty courts. A court official there couldn’t explain why the court is no longer operating.
Katz said more study is needed to determine which approaches are most effective in helping parents meet their child-support obligations, especially in cases involving people who are barely scraping by.
“It’s incredibly hard to see how to fix the system,” she said. “The issue of how to financially support children with low-income parents has plagued courts and legislatures for over 100 years.”
THE SECRETARY OF STATE ATTORNEYS DID NOT SUSPEND MY DRIVERS LICENSE BECAUSE THERE WAS NO VALID COURT ORDER ORDERING ANY CHILD SUPPORT PAYMENTS
IN THE CIRCUIT COURT OF COOK COUNTY ILLINOIS
CHANCERY DIVISION
Joe Louis Lawrence
Case # 10 CH 23588
Plaintiff
VS
Hon. Mary L. Mikva
Jesse White, Illinois Secretary
of State
Room 2508
Et al
Defendants
MOTION FOR RECONSIDERATION/VACATE(Jan. 20, 2011) ORDER
Due TO “FRAUD” ON COURT “PERJURY” JUDGES CORROBBORATION IN AN ORGANIZED CHAIN
CONSPIRACY “CIVIL RIGHTS VIOLATIONS” & OTHER IRREGULARITIES w/AFFIDAVIT
Now comes Petitioner, Joe Louis Lawrence,
Counsel Pro Se, in this cause respectfully represents to this court the reasons
and files herewith his Affidavit in support for said Motion Objecting
Defendant’s Motion to Dismiss due to “Fraud” On Court “Perjury” Criminal Chain
Conspiracy “Corruption” other Civil Rights Violations, pursuant to the provisions of the Admin. Rev. Law, 735 ILCS 5/3-101,
Section 1983 of U.S.C.S., S.H.A. Criminal Ch. 38, 33-3, Civil Rights Act of
1964, Canon 3D (1) Reporting Judicial Misconduct, 3D (2) Reporting Lawyer
Misconduct;
Respectfully Submitted,
Joe Louis Lawrence
Counsel Pro Se
(312) 927-4210
STATE OF ILLINOIS
)
)
AFFIDAVIT
Joe Louis Lawrence being first duly sworn on oath deposes
and state as follows:
1.)
I am Joe Louis Lawrence, Counsel Pro Se.
2.)
That on Feb. 28, 2011, Hon. Mary L. Mikva Ordered AAG
Tyler Roland to produce the records of case# 10 CH 23588;
A- Tyler
Roland tried to finagle his way with the Judge telling her she DISMISSED
Plaintiff’s complaint;
B-
Plaintiff objected and informed the court, “he filed the proper motion objecting
Defendant’s motion to dismiss and you did not dismiss the complaint”;
C-
That Judge Mikva motioned the Plaintiff in a
courteous manner as he gestured to respond, she stated to Tyler in a
professional authoritative manner, “I did
not dismiss his complaint only certain portions naming defendants and parts
that do not relate to the record”;
PRIOR EVENTS THAT LED TO THE
AFOREMENTIONED:
1A.) That on Jan. 20, 2011,
Plaintiff meritoriously argued the facts of the case in a legally comprehensible manner;
2B.) FACT AAG Tyler Roland’s defense was that Plaintiff’s complaint was
not properly plead, Judges response, “oh it was properly plead, I understood
what he was saying. Just because you were taught and trained to prepare
pleadings a certain way does not mean the way he pleads differently from the
way you were taught does not mean that his pleadings is not properly plead
correctly, his are construed differently, this is about the suspension of his
license;
3C.) Judge Mikva stated, “this is a very old case and her
jurisdiction is limited to what is in the record, before the Adm. Hearings
body” –Plaintiff, interjected respectfully, stated, “Your Honor, there is no record and recited numerous allegations of
politically connected Judges and Asst States Attys. signing court orders
appearing on behalf of the woman who is a Police Officer, court orders signed
he never seen and that he had been locked up 5 times for allegedly owing child
support” she appeared shocked and flushed as Plaintiff argued his case, she
said, “their has to be a judgment
somewhere otherwise we would not be here”
Tyler did not say a word; Plaintiff said, “no it’s not”!
4D.) The Hearing seemed to have
reached an impasse at this point, the Judge dismissed the Default Petition,
Petition to Supplement Rule to Show Cause et al and Plaintiff’s Response
Request to Admit the Genuineness et al., seemingly the only presumption was
that it was premature even though counsel did not respond or object, she
ordered the Chicago Volunteer Legal Services to represent the Plaintiff it was
convoluted, the case advanced so far without a record was mind boggling;
3.) FACT Feb. 28, 2011, CVL DECLINED to
represent the Plaintiff, Judge asked the Plaintiff, “if he had anything to add or he wanted to say”, his reply, “your honor it is not surprising this law
firm is refusing this case nobody in this City wants to go up against the “Good ol boys” the men that are
politically connected to City Hall, unfortunately, I have had several lawyers
who have been either intimidated or threatened off this case where some of the
lawyers gave me back my retainer, legal Aid refused this case, so I am in a
position where I have to represent myself.”
4.) FACT Judge Mikva reiterated the fact
Plaintiff’s response must be limited to the record when he prepares his brief,
Plaintiff reminded the Judge, “he has no
record” no Judge ever had a record even when he was locked up unlawfully all of the documents have been prepared off my
memory of what has transpired in the courts and at the hearing”, she asked
Tyler, Do you have the record? “When is he going to receive a copy of the
record”? Tyler’s response, “by the
end of this week no later than the 7th”;
5.)
FACT AAG
Tyler Roland never answered Plaintiff’s complaint, which places him in DEFAULT!!!!!
A-
He never asked leave of the court to file an answer
late;
B-
Judge Mikva never Ordered him to file an answer;
a. Pursuant
to 735 ILCS 5/2-610 where allegations of complaint are not denied, there
is admission of all facts well-pleaded by adversary, and such admission, drawn
from failure to plead, may be considered as evidence. Hecht v. Hecht, App. 1 Dist. 1977, 7 Ill. Dec. 169, 49 Ill. App. 3d
334, 364 N.E. 2d 330.
b. Pursuant
to 735 ILCS 5/2-612 Counsel never Objected to the sufficiency of
Petitioners pleadings, Objections to sufficiency of pleadings either in form or
substance must be made In trial court, and if not so made, they will be
considered waived and cannot be raised for the first time on appeal. People ex rel. Deynes v. Harris, App.
1948, 77 N.E. 2d 439, 333 Ill. App. 280.
C-
He Induced Reliance upon the court when he noted in the
court order Respondent shall file the answer on or before March 7, 2011;
6.)
FACT AAG
Tyler Roland filed an answer to the Plaintiff’s complaint Feb. 28, 2011, demonstrates
Plaintiff’s Default Motion and Motion to Supplement Petition for Rule to Show
Cause et al was in fact timely and properly presented in accordance to Illinois
Supreme Court Rules and Rules of Illinois Civil Procedure;
7.)
FACT AAG
Tyler Roland contemptuously with vexatious arrogance “Perjured” himself
before the court knowing “DAM” well Plaintiff did not owe any child
support, hereto attached, Ex 16, Line
1-17 from court transcript demonstrates Plaintiff had no knowledge of the
illegal court proceedings had against him;
8.)
FACT AAG
Tyler Roland was aware the Hearing Officer Angelia Young, Sec. of State Atty.
Edmund Michalowski was acting in concert in said conspiracy, both of them was
aware from the record everything asserted was alleged, hereto attached, Ex. 17 Line 15- 23, establishes
veracity to the above;
A-FACT
Plaintiff properly filed the Rule to Show Cause on the above named individuals
and said summons was properly served on them in a timely manner;
9.)
FACT AAG
Tyler Roland was aware and conspired in Terrorist actions against the Plaintiff
by violating his Civil Rights, in that, Ex
22, hereto attached, filed March 8, 2010, reflects “ALLEGED ARREARAGE” of $49670.66, said court order was not
certified had no signature on it;
A-
That Pursuant to
Sup Ct. Rule 272 “if at the time of announcing final
judgment the judge requires the submission of a form of written judgment to be
signed by the judge et al” the judgment becomes final only when the signed
judgment is filed—there is no signed COURT ORDER from the FINAL
JUDGMENT!
B- Where
the trial court requests that a written judgment be prepared, and where the
attorney who obtains the judgment prepares it and submits it to the judge for
approval and entry, the judge’s oral announcement of his decision and the
reasons thereof have no effect; the judgment is not the act of the court until
it is signed or approved and entered of record. In re Marriage of Dwan, App 1st Dist. 1982, 64 Ill. Dec
340, 108 Ill. App 3d 808, 439 N. E. 2d 1005. That the Judges in the
Appellate Court, Supreme Court, States Attorneys, Attorney Generals and a host
of Public Officials never followed the
law or rules of Illinois Civil Procedure or the laws of the United States Constitution,
they DENIED everything he presented establishing his innocence due to him being
non-white;
10.)
FACT AAG
Tyler Roland was aware and conspired with other Terrorists against the
Plaintiff using their positions and authorities violating his Civil Rights,
hereto attached, Ex 27, Letter
falsified and prepared by an alleged IDHFS authorized representative;
11.)
FACT AAG
Tyler Roland was aware but ignored Ex
33, hereto attached, dated 8-16-92, Accts Rec. Summary ZERO BALANCE;
A-
Aurelia Pucinski as clerk of the Circuit Court ordered
her clerks to give to the Plaintiff anything he requested relating to this
paternity matter because he was a Pauper, it was brought to his attention he
was up against the “Good ol boys”
and that they were not going to let him defeat them in any court” the May 18,
1988 court order kept coming up missing in the court files along with a court
order ordering him not to have any visitation of the child;
B-
He was instructed to stay on top of the case because “those guys are not to be underestimated,
they are capable of anything”—during this period Aurelia was a smooth sweet
white woman, Plaintiff never dated her;
12.)
FACT AAG
Tyler Roland was aware but ignored Ex.
34, hereto attached, an Acct statement, 1-26-2004, Bal. ZERO;
13.)
FACT AAG
Tyler Roland was aware but ignored Ex.
36, hereto attached, complete history was done on the Paternity case (June
16, 2004);
A-
Ex. 35,
hereto attached, from Dorothy Browns Child Support, “According to our records, no payments have been received under this
case number”;
14.)
FACT AAG
Tyler Roland was aware but ignored General Counsel Elena Demo’s letter hereto
attached, Ex 37, sent to Plaintiff (May
29, 2008) “Your complaints revolve
around issues, which I observe should be appropriately handled in the first
instance in the civil courts, or through State Adm. Agencies appointed to
investigate charges of civil rights violations, discrimination and corruption claims”;
15.)
FACT AAG
was aware States Attorney Anita Alvarez through her Chief General Litigation
Division, hereto attached, as Ex 39
forwarded a letter pursuant to a court subpoena certifying Ex. 60 -61, May 18, 1988 Court Order; Finding the Plaintiff
to be the father of the child by DEFAULT, the record is clear, he was never
served, never had any paternity tests, but most importantly, he was never ordered to pay child
support;
16.)
FACT AAG
Tyler Roland was aware former States Atty. Richard Devine and Judge Murphy
received a Certified letter, Ref as Ex
40, hereto attached, detailing ASA Carolyn Kennedy falsifying everything
necessary in Judge Murphy’s court as she aided and assisted other Terrorists as
they acted in concert violating Plaintiff’s Civil Rights in the court room,
she was a black woman;
17.)
FACT AAG
Tyler Roland was aware most importantly, a Notarized Chronology of Unlawful
Contempt Charges w/Affidavit was sent to Attorney General Lisa Madigan, Ref
as Ex. 42, she ignored all Civil
Rights Violations perpetrated at the Plaintiff because she is a co conspirator;
18.)
FACT when
allegations of Torture was had on black men in custody, Lisa Madigan did not
prosecute John Burge, or anyone else involved in that matter, the Federal Govt.
came after and prosecuted him;
A- FACT That on Sun. Mar. 6th ,
2011, Sun Times Columnist Mary Mitchell, page 10A, records that a Police
Officer murdered an innocent bystander claiming he was struggling for his gun,
CTA’s video camera revealed officer Weems lied, --“showed little regard for Pleasance’s life”
B-
Former Police Supt. Phil Cline rejected that the
officer be fired gave him a 30 day suspension and rewarded him a promotion to
Detective;
C-
That in 2004, another Police Sergeant raped a woman
described as a crack addict, after a bench trial John Hermann was sentenced to
25 years in prison by the judge, The Illinois Appellate Court reversed the
conviction;
19.)
Hereto attached, Group
Ex. A, Motion for Reconsideration/Vacate Order Due to Judges
Corroboration in an Organized Chain Conspiracy Civil Rights Violations and other Irregularities;
A-
That said Motion is unchallenged it details how Judges
in the Appellate Court intercept cases unlawfully to “fix” them for their buddies as they engage in Criminal
Civil Rights Violations against a Mexican American;
20.)
FACT That State Officials like Lisa Madigan and every
other Racist Terrorist have closed their eyes to the heinous atrocities lodged
at blacks and Hispanics, they have installed the necessary blacks with no
back bone, no voice who would “lie” “cheat” for the Political Machine commit
any unlawful criminal act, so as to protect the actual Racist Terrorists who
are in charge of running this City as
demonstrated entirely through out all legal documents;
21.)
That every person who participated in this conspiracy
against the plaintiff have committed Treason
like Offenses, nobody took the initiative to demonstrate some level of
integrity by refusing to follow the directives of the “Gate keeper”
A-
The person at City Hall obviously promised them
immortality in the after life, they are a part of his ARMY, he is likened to Pharaoh, everybody does
what they are told, and nobody refuses his Directive;
B- That
the “Political Machine” is nothing
more than a recycled action of “JIM CROWISM” these Racist practices have been outlawed by
the United States Supreme Court, Like Pharaoh’s army who was swallowed up in
the red sea while they were many, the Ten Commandments provided a visual of the
Political Machines fate here in this State City of Chicago;
Scripture records the
fate of greed in Luke 12: 15-31;
That when the Plaintiff
informed Public Aid he needed an increase in food stamps and cash because he
was being forced to pay child support for a child that did not belong to him,
they looked him up in the computer and saw no evidence of what was being asserted,
even after trying to present documents where it was alleged he owed child
support, he was Ordered to take a drug test and see a psychiatrist if he
refused they were going to remove him from the welfare grant as head of the
household;
That a psychiatrist
(Traci Powell MD) told the plaintiff what he was asserting was impossible part
of what he was asserting was real and the other was a part of some type of
delusion and wanted to prescribe pills for his delusion, said there is no such
thing as being in contempt of court for allegedly owing child support and the
papers, he had in his possession could have been something he made up as a part
of some type of grandiose seeking attention;
Plaintiff had to attend
weekly therapy sessions with Bipolar and Schizophrenic patients at the mental
health clinic so as to remain compliant with public aids directive all tests
were retuned on him as negative, no person was experiencing anything similar to
what he was going through and everyone was taking medicine, they were all good
people;
The therapists he had
were great they explained to him as a black man when you make assertions white
men are doing something wrong, they will term you crazy (the politically
correct term is mentally ill) because a black man is not suppose to talk back
or question what a white man does, that statement drew an interesting parallel;
a Judge, William Maddux told the Plaintiff in the year of 1993, “he admired what he had done in the courts
trying to return back to work with the CTA”, Plaintiff explained to him, “he followed the laws in the books did
everything correctly”, Judge reply, “yes you did, but up here things are done
differently your Union is suppose to have you reinstated” Plaintiff
explained, “nobody wants to go up against
the CTA, I am a CTA employee”, his reply, “I understand that, but you are out of your league you are a bright kid
take it back to the union”
22.)
Finally, hereto attached, Ex B, a Certified Court Order from Hon. Lester Bonoguru ordering
the Plaintiff to continue his efforts to be reinstated to the CTA, the
Amalgamated Transit Union never had the Plaintiff reinstated even though he is
a certified CTA employee;
The Law
is CLEAR: Properly alleged facts within an
affidavit that are not contradicted by counter affidavit are taken as true,
despite the existence of contrary averments in the adverse party’s pleadings. Professional Group Travel,
Ltd. v. Professional Seminar Consultants Inc., 136 ILL App 3d 1084, 483 N.E. 2d
1291; Buzzard v. Bolger, 117 ILL App 3d 887, 453 N.E. 2d 1129 et al.
The Law is clear: The purpose
of a Motion to Vacate is to alert the trial court to errors it has made and to
afford an opportunity for their correction. In re Marriage of King, App. 1 Dist. 2002, 270 Ill. Dec. 540, 336 Ill.
App. 3d 83, 783 N.E. 2d 115, rehearing denied pending appeal; et al.
The
Law is clear: Motions for Reconsideration are designed to bring to the
court’s attention newly discovered evidence that was unavailable at time of
original hearing, changes in existing law, or errors in court’s application of
law. Continental Cas. Co. v. Security
Ins. Co. of Hartford, App. 1 Dist. 1996, 216 Ill. Dec. 314, 279 Ill. App. 3d
815, 665 N.E. 2d 374, appeal dismissed, et al.;
Supreme Court
Rule [137] provides in pertinent part:
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.
23.)
That
because AAG Tyler Roland and a
plethora of other Terrorist conspirators are exercising laws outside of their
immunity and jurisdiction and in accordance to other Political/Fraternal laws
makes the Court order signed by Judge Mary L. Mikva a Void Order;
That because of the above; Fraud admissibility great latitude is permitted in proving fraud C.J.S. Fraud
104 ET Seg. Fraud 51-57. where a question of fraud and deceit is the issue
involved in a case, great latitude is
ordinarily permitted in the introduction of evidence, and courts allow the
greatest liberality in the method of examination and in the scope of inquiry Vigus
V. O’Bannon, 1886 8 N.E 788, 118 ILL 334. Hazelton V. Carolus, 1907 132 ILL.
App. 512.
INDUCING RELIANCE
To prevail in a cause of action for
fraud, plaintiff must prove that defendant made statement of material nature
which was relied on by victim and was made for purposes of inducing reliance,
and that victim’s reliance led to his injury. Parsons V. Winter, 1986, 1 Dist., 491 N.E.
2d 1236, 96
In Carter V. Mueller 457
N.E. 2d 1335 ILL. App. 1 Dist. 1983 The Supreme
Court has held that: “The elements of a cause of action for fraudulent
misrepresentation (sometimes referred to as “fraud and deceit” or deceit) are:
(1) False statement of material fact; (2) known or believed to be false by the
party making it; (3) intent to induce the other party to act; (4) action by the
other party in reliance on the truth of the statement; and (5) damage to the
other party resulting from such reliance.
24.)
That AAG Tyler Roland have
corroborated/admitted beyond all legal standards of the law engaging in a
criminal conspiracy and implicating the Attorney General’s office covering up for
the Political machine operatives; and how the office uses inferior ethnic
groups outside their ethnicity to enforce their doctrines on innocent non-white
men like the Plaintiff as noted throughout all documents;
A-
That their has not been a single person to
stand up against the Racist Atrocities lodged at the Plaintiff in every layer of this conspiracy ILL. App. (1st
Dist. 2000). A “VOID JUDGEMENT OR ORDER” is one that is entered by a court
lacking jurisdiction over the parties or the subject matter, or lacking the
inherent power to enter the particular order of judgment, or where the order
was procured by FRAUD- in re Adoption of E.L., 248 ILL. Dec. 171, 733 N.E. 2d
846, 315 ILL. App. 3d 137- Judgm 7, 16, 375.
B-
U.S 2003.
Essence of a conspiracy is an agreement to commit an unlawful act.-U.S. v.
Jimenez Recio; 123 SCt. 819, 537 U.S. 270, 154, L. Ed.2d 744, on remand 371
F.3d 1093;
Agreement to commit an unlawful act, which
constitutes the essence of a conspiracy, is a distinct evil that exist and be
punished whether or not the substantive crime ensues,-id.
Conspiracy poses a threat to the public over
and above the threat of the commission of the relevant substantive crime, both
because the combination in crime makes more likely the commission of other
crimes and because it decreases the part from their path of criminality-id;
C Section 1983 of U.S.C.S.
contemplates the depravation of Civil Rights through the Unconstitutional
Application of a Law by conspiracy or otherwise. Mansell v. Saunders (CA
5 F 1A) 372 F 573, especially if the conspiracy was actually carried into
effect, where an action is for a conspiracy to interfere with Civil Rights
under 42 U.S.C.S. 1985 (3), or for the depravation of such rights under 42
U.S.C.S. 1983, if the conspiracy was actually carried into effect and plaintiff
was thereby deprived of any rights, privileges, or immunities secured by the
United States Constitution and Laws, the gist of the action maybe treated as
one for the depravation of rights under 42 U.S.C.S. 1983, Lewis v. Brautigam
(CA 5 F 1a) 227 F 2d 124, 55 Alr 2d 505, John W. Strong, 185, 777-78 (4 th
ed. 1992).
25.)
REPORTING
JUDICIAL MISCONDUCT
CANON 3D (1)
Under Section 3D (1), a judge who receives information that indicates “a
substantial likelihood that another judge “ has violated the Code of Judicial
“should take appropriate action”. The Canon does not require the judge to hold
a hearing and make a definitive decision that a violation has occurred before
the reporting requirement is triggered and at least one state’s judicial ethics
committee has advised that the reporting requirement is triggered when the
judge has “sufficient information” to conclude that a “substantial issue” has
been raised that a violation has occurred, Mass. Comm. On Judicial Ethics, Op.
2002-04 (2002)
“Appropriate action” may include direct
communication with the judge who has committed the violation and reporting the
violation to the appropriate or other agency or body. See Commentary to Canon
3D (1). “Appropriate authority” is the authority with responsibility for
initiation of disciplinary proceedings with respect to the violation reported.
Some jurisdictions’ rules specify to whom a judge must report misconduct. For
instance, Massachusetts Rule 3D (1) provides that if a judge becomes aware of
another judge’s unprofessional conduct he must report his knowledge to the
Chief Justice of the Massachusetts Supreme Court and the court of which the
judge in question is a member.
Note that the term “knowledge”, as defined
in the Terminology Section, denotes actual knowledge of the fact in question
and as such, a person’s knowledge may be inferred from circumstances. In
drafting Section 3D (1), the Committee rejected the suggestion that the
criteria of raising substantial question as to honesty or trustworthiness be
applied in the context of reporting judicial misconduct as well, on the grounds
that those criteria are implicit in the present criterion of raising a
substantial question as to a judge’s fitness for office.
Under Section 4 of the Ku Klux
Klan Act of 1871:
The President had additional
power in case of rebellion within a state to suspend the writ of habeas corpus
and to declare and enforce marital law. Cong.
Globe, supra note 1, at 317. With respect to a definition of rebellion,
Section 4 provided;
“Whenever
in any State or part of a State……unlawful combinations……..shall be organized
and armed, and so numerous and powerful as to be able, by violence, to either
overthrow or set at defiance the constituted authorities of such State, or when
the constituted authorities are in complicity with or shall connive at the
unlawful purposes of such powerful and armed combinations; and whenever, by
reason of either or all of the causes aforesaid, the conviction of such
offenders and the preservation of the public safety shall become….
Impracticable, in every such case such combinations shall be deemed a rebellion
against the Government of the United States….”
Corruption is so widespread
in this State the Clerk in the Illinois Supreme Court sent a letter and Court
Order (Feb. 7, 2011) stating he owed to them a debt, hereto attached, Court
Order from Supreme Court Justice Freeman allowing him to proceed informa pauperis, Plaintiff is still on
Public Aid where the Racist Conspirators placed him, keeping him from being
reinstated to the CTA in an attempt to cover-up the theft of his wages and
unlawful withholdings of child support garneesheed from his wages ;
FURTHER AFFIANTH SAYETH NOT
Under penalties as provided by law pursuant to 735 1265 5/1
-109, the undersigned certifies that the statements set forth in this
instrument are true and correct, except as to matters therein stated to be on
information and belief and as to such matters, the undersigned certifies as
aforesaid that he verily believe the same to be true.
Respectfully submitted,
Joe Louis Lawrence
Counsel Pro Se
Name Joe
Louis Lawrence
Attorney for Pro Se
Address P.O.
490075
City, State
Chicago, Illinois 60649-0075
Phone (312) 927- 4210
IN THE CIRCUIT COURT OF COOK COUNTY ILLINOIS
CHANCERY DIVISION
Joe Louis Lawrence
Case # 10 CH 23588
Plaintiff
VS
Hon. Mary L. Mikva
Jesse White, Secretary of
State
Room 2508
Et al
Defendants
NOTICE OF
MOTION FOR RECONSIDERATION/VACATE(JAN. 20,
2011) ORDER DUE TO “FRAUD” ON COURT “PERJURY” JUDGES CORROBBORATION IN AN
ORGANIZED CHAIN CONSPIRACY “CIVIL RIGHTS VIOLATIONS” & OTHER IRREGULARITIESw/AFFIDAVIT
TO: Dir. Mueller FBI Washington D.C.
Robert
Grant/James Chatto FBI 2111 West Roosevelt Road, Chicago, Ill. 60612
U.S. Atty.
Patrick Fitzgerald, 219 S. Dearborn, Suite 500
AAG Tyler Roland
Chief Judge Timothy Evans, Daley Center, Chg. Ill. 60601
100 West Randolph, 13th floor Presiding Judge
Jacobius, Daley Center, Chg. Ill. 60601
Hearing Officer, Angelia L. Young, 17 N. State, Suite 1200,
Chg. Ill. 60602
Secretary of State Atty. Edmund Michalowski, 17 N. State,
Suite 1200
Please be advised that on
March 8th, 2011
Plaintiff has filed before this Circuit
Court, Motion et al; and will present
said legally sufficient instrument before the Honorable Mary L. Mikva, March
14, 2011, @9:00am in room 2508.
Respectfully Submitted,
Joe Louis Lawrence
Petitioner
PO Box 490075
Chicago, Illinois 60649-0075
CERTIFICATE OF
SERVICE
The undersigned hereby certifies that the above notice and
all attachments were caused to be personally delivered, or via facsimile or
deposited in the U.S. mail to the above parties at the addresses provided
before 5:00 pm on March 8, 2011.
___________________________
Joe Louis Lawrence
Counsel Pro Se
In The
Chancery
Division
(
(
Joe Louis
Lawrence
(
( Case # 10 CH
23588
PLANTIFF
(
(
-VS-
(
(
Jesse White,
Secretary of State
( Hon. Judge Mary
Lane Mikva
Et al
( Room 2508
DEFENDANTS
(
ORDER
This cause coming before the Court on
Plaintiff’s Motion for
Reconsideration/Vacate (Jan. 20, 2011) Order due to Corroboration of Perjury/Criminal Mail
Fraud Civil Rights Violations/Contempt of Court other Irregularities
Remand/Body Attachment Instanter Impose Sanctions
Plaintiff
appearing Attorney Pro Se and the Court being duly advised in the premises, IT IS HEREBY ORDERED:
(1) Plaintiff’s Motion to Supplement Petition for Rule to
Show Cause et al. Motion for Default et al & Plaintiff’s Response Request
to admit the Genuineness et al, is GRANTED;
(2) Defendant’s shall be REMANDED INTO CUSTODY FOR
CONTEMPT OF COURT;
(3) Defendant’s shall appear before this
court on the Merits of Sanctions and other noted Punitive Damages ($200,000) a
month for Irregularities mentioned in Plaintiffs Petition and Affidavits
without further notice, by separate order of this court..
ENTERED:
Joe Louis
Lawrence
P. O. Box
490075
Chicago,
Illinois 60649-0075
312 927-4210
Atty. No 99500
_______________________
Hon. Mary Lane Mikva
_______________________
Date
In The
Chancery
Division
(
(
Joe Louis
Lawrence
(
( Case # 10 CH
23588
PLANTIFF
(
(
-VS-
(
(
Jesse White,
Secretary of State
( Hon. Judge Mary
L. Mikva
Et al
( Room 2508
DEFENDANTS
(
ORDER
This cause coming before the Court on
Plaintiff’s Motion for Reconsideration/Vacate (Jan. 20, 2011) Orders Due to
“Fraud” on Court “Perjury” Judges Corroboration in an Organized Chain
Conspiracy, “Civil Rights Violations” & other Irregularities with
Affidavit
Plaintiff
appearing Attorney Pro Se and the Court being duly advised in the premises, IT IS HEREBY ORDERED:
(1) Plaintiff’s Motion for Reconsideration
due to “Fraud” on Court Perjury Criminal
Chain Conspiracy, “Corruption” and other Civil Rights Violations is GRANTED Instanter;
.
ENTERED:
Joe Louis
Lawrence
P. O. Box
490075
Chicago,
Illinois 60649-0075
312 927-4210
Atty. No 99500
_______________________
Hon. Mary L. Mikva
_______________________
Date
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