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. 26-2385
}
Verizon Communications, Inc et al. }
Defendants-Appellees } Judge Robert Blakey
APPELLANT'S MOTION FOR JUDICIAL NOTICE OF
ADJUDICATIVE FACTS, NOTICE OF STRUCTURAL DUE PROCESS VIOLATIONS, AND
REQUEST THAT THE COURT CONSIDER THE DISTRICT COURT'S DENIAL OF IMPARTIAL
ADJUDICATION & SEEK THE JURISDICTION OF THE FBI TO DETERMINE PUBLIC
CORRUPTION ALLEGATIONS DUE TO THIS CASE NO LONGER BEING PERSONAL CIVIL
INVOLVING THE APPELLANT
Appellant respectfully moves this Court pursuant to Federal Rule of
Evidence 201, 28 U.S.C. §§ 455 and 2106, and the Due Process Clause of the
Fifth and Fourteenth Amendments to take judicial notice of adjudicative facts
contained in the record and accompanying public documents demonstrating
structural irregularities affecting the fairness of the proceedings below.
I. Grounds for the Motion
- Appellant submits certified court
records, DNA test results, service records, docket entries, and other
public documents establishing that significant factual and procedural
irregularities occurred during the underlying litigation.
- The evidence demonstrates that
Appellant was subjected to proceedings resulting in child-support
arrearage enforcement despite evidence that:
A- DNA testing excluded Appellant
as the biological father.
B-
Appellant contends he was never properly served in the action that
resulted in the default judgment.
C-
The default judgment was entered without personal jurisdiction, rendering
subsequent enforcement proceedings void if the lack of jurisdiction is
established.
D-
Arrearages were later assessed despite Appellant's contention that no
valid child-support order requiring payment had ever been entered.
E-
Appellant presented affidavits, court transcripts, legal precedents,
Summary judgments no licensed attorney state or otherwise ever denied to any of
the pleadings or submitted counter
affidavits.
F-
That pursuant to Rule 56.1 Summary Judgment 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).
G-
The Cook County Judiciary having admitted to Appellant’s pleadings Cook
County judges do not honor Equal Protection of the Laws to Pro se litigants
with or without attorneys et al.
H-
That Case No. 11-3481, Democratic judges Diane S.
Sykes, Ann Claire Williams and Kenneth Ripple In 1987 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. After examining the appellant's brief and the record, we have concluded
that oral argument is unnecessary. Thus, the appeal is submitted on the brief
and record. See FED. R. APP. P. 34(a)(2)(c).
I-
Appellant’s license has never been suspended and in 1987 Richard J.
Daley, States Attorney had his top Super Attorney Obrietta Scott to non-suit
the charges of paternity against him due to the Paternity Tests excluding him
and the CTA never discharged him from employment and was off work with IBC with
a work-related injury fell off the truck tore his rotator and never received
workman’s compensation only welfare but someone else collected his workman’s
compensation.
J-
Hon Robert Blakey worked under Dick Devine 1996- 2000 as an Assistant
States Attorney and Chief,
Special Prosecutions Bureau, Cook County [Illinois] State's Attorney's Office,
2009-2014 during this whole cloud of irregularities of the State
representing then Police Officer Francoise Hightower in this extortion scheme
disguised as child support arrearage.
K-
Appellant prepared an Affidavit
to Dick Devine Jan 3, 2007 of the unlawful Remands and it was never investigated
but continuously covered-up and ignored the Civil Rights Violation’s
perpetrated on him.
L-
- Appellant further requests that
this Court take judicial notice that the district judge previously served
as an Assistant State's Attorney. Appellant's claims include allegations
of misconduct by Assistant State's Attorneys during the underlying
proceedings. Appellant does not assert that prior public employment alone
requires disqualification. Rather, when viewed together with the district
court's rulings challenged on appeal, Appellant contends these
circumstances raise issues concerning the appearance of impartiality that
should be evaluated under 28 U.S.C. § 455.
A- Structural unfairness
B- One-sided rule deviations
C- Loss of public confidence in
judicial neutrality
D- Illinois courts have held
that in such circumstances, actual prejudice has been required to FORCE REMOVAL
of a judge from a case, that is, either prejudicial trial conduct or personal
bias. Rosewood Corp. n Transamerica Insurance Co., 57 Ill 2d 247, 311 N.E.
2d 673.
E- Federal courts recognize
cumulative procedural defects as sufficient grounds for recusal.
F- The
cumulative procedural defects here rise to the level of structural errors,
undermining confidence in the integrity of the proceedings. Atwood,
941 F.3d at 885.
- Appellant also seeks review of
the district court's denial of leave to proceed in forma pauperis,
arguing that the denial improperly prevented meaningful appellate review
despite evidence of financial eligibility.
II. Legal Authority
Federal Rule of Evidence 201 authorizes judicial notice of facts that are
not subject to reasonable dispute because they are capable of accurate and
ready determination from sources whose accuracy cannot reasonably be
questioned.
Under 28 U.S.C. § 455(a), a federal judge shall disqualify himself in any
proceeding in which his impartiality might reasonably be questioned.
The Supreme Court has recognized that due process requires a fair and
impartial tribunal. See In re Murchison, 349 U.S. 133 (1955); Caperton
v. A.T. Massey Coal Co., 556 U.S. 868 (2009); Liljeberg v. Health
Services Acquisition Corp., 486 U.S. 847 (1988).
A judgment entered without personal jurisdiction because of defective
service is void. See Peralta v. Heights Medical Center, Inc., 485 U.S.
80 (1988).
Federal appellate courts possess broad authority under 28 U.S.C. § 2106
to vacate, reverse, or remand where justice requires.
The United States Supreme Court
acknowledged the judicial corruption in Cook County, when it stated that Judge
"Maloney was one of many dishonest judges exposed and convicted through
'Operation Greylord', a labyrinthine federal investigation of judicial
corruption in Chicago". Bracey v. Gramley,
Since judges who do not report
the criminal activities of other judges become principals in the criminal
activity, 18 U.S.C. Section 2, 3 & 4, and since no judges have reported the
criminal activity of the judges who have been convicted, the other judges are
as guilty as the convicted judges.
Under Federal law which is applicable to all states, the U.S.
Supreme Court stated that if a court is "without authority, its judgments
and orders are regarded as nullities. They are not voidable, but simply void;
and form no bar to a recovery sought, even prior to a reversal in opposition to
them. They constitute no justification; and all persons concerned in executing
such judgments or sentences, are considered, in law, as
trespassers." Elliot v. Piersol.
III. Relief Requested
WHEREFORE, Appellant respectfully requests that this Court:
A. Take judicial notice of the accompanying adjudicative facts and public
records.
B. Consider whether the record presents an appearance-of-impartiality
issue under 28 U.S.C. § 455.
C. Review the district court's denial of Appellant's application to
proceed in forma pauperis.
D. Consider the cumulative effect of the jurisdictional and due-process
violations alleged by Appellant.
E. Grant such other and further relief as justice requires, including
vacatur and remand if appropriate.
F- Treat the Appellant as a Freeman Born & Raised in the United
States pursuant to the laws of the United States Constitution
“Any judge who does not comply with his
oath to the Constitution of the United States wars against that Constitution
and engages in acts in violation of the Supreme Law of the Land. The judge is
engaged in acts of treason. Having taken at least two, if not three oaths of
office to support the Constitution of the United States, and the Constitution
of the State of Illinois, any judge who has acted in violation of the
Constitution is engaged in an act or acts of treason. If a judge does not fully
comply with the Constitution, then his orders are void, In re Sawyer, 124 U.S. 200 (1888) he/she is without
jurisdiction , and he/she has engaged in an act or acts of treason.”
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: July 27, 2026
City & State: Chicago, Illinois
JOE LOUIS LAWRENCE
Plaintiff-Appellant, 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. 26-2385
}
Verizon Communications, Inc et al. }
Defendants-Appellants } Judge Robert Blakey
CERTIFICATE
OF SERVICE
I Joe Louis Lawrence certify that on July 30, 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
Commander
& Chief Acting
Attorney General of United States
President Donald
Trump Todd
Blanche
The White
House U.S. Department of Justice
1600 Pennsylvania Avenue
NW 950 Pennsylvania Avenue, NW
Washington, DC
20500
Washington, DC 20530-0001
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.
Nicole E. Stoelton
Venable, LLP
227 West Monroe, Suite 1900
Chicago, Illinois 60606
312 820-3400
Attorneys for Experian Information Solutions, 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 July 30,
2026 A Motion
for JUDICIAL NOTICE OF ADJUDICATIVE FACTS, 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
No comments:
Post a Comment