ARDC v. JMD 13 PR 1–Motion to Reconsider Interrim Suspension

https://drive.google.com/file/d/0B6FbJzwtHocwV0VUSmNaajJabTQ/view?usp=sharing

And the Text is below.

I would like to thank everyone for preparing declarations for this Motion and sharing your stories and for reviewing the brief and providing your helpful comments.

Many thanks.

I am most grateful to have so very many loyal clients help me and want me so that I can continue to serve the indigent and lower middle class and NFP’s that help everyone in Chicago.

You have all been very, very kind to me and I greatly appreciate it.

JoAnne

The brief is also in text below.

MOTION TO RECONSIDER ORDER FOR
INTERIM SUSPENSION1
The undersigned attorney, who primarily serves those who cannot
otherwise find counsel in probate matters, and those who require very low cost or
pro bono service, herewith files her Supplemental Reply to the Administrator’s
request for an interim suspension pursuant to Rule 774 which was filed with the
Supreme Court of Illinois on the basis that Respondent has engaged in conduct
involving fraud or moral turpitude or which threatens irreparable injury to
the public, clients or orderly administration of justice. Id. Respondent has
done none of that, all she has done is own and maintain a blog for the public and
Probate Victims that openly and honestly discusses all problems, troubles and
issues in probate, and especially in the Illinois Probate courts, although probate
fraud and abuse appears to be rampant all across the US. The Tribunal in its
decision never explained how the undersigned’s probate blog–or any blog, for
1REGARDING ADMINISTRATOR’S REQUEST FOR AN INTERRIM SUSPENSION
UNDER RULE 774 CORRECTED 3/24/15. A copy of this pleading was also sent to Steven
Splitt for informational purposes only
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that matter, is a danger to the public.2 It further never explained how a blog or
any publication interferes with the “orderly administration of justice.” While it
states that the Tribunal believe the case was bogged down in ancillary issues, it
never gave any proof that was due to Respondent’s blog–or any blog, which all
the blogs were saying the same thing. Gloria contacts them all and posts on
them all. Why single out Respondent’s blog? The Tribunal complains about
Jurisdiction being the key to the problems, but it never could explain why Exhibit
A, Sheriff Dart had written a letter he had no evidence that Mary Sykes was ever
served. Mary was never served. Sheriff Dart admitted it. Was the Tribunal
calling the Sheriff and his office liars? If so, why does the Tribunal get to make
this highly defamatory claim in its decision, but Respondent cannot truthfully
make the claim on her blog that Mary was never served.
This question was never answered by the Tribunal.
The undersigned had filing a Request to Supplement because 1) she was
unable to upload a copy of the Record on Appeal from the Tribunal which shows
their shameful behavior during trial, attacking family members for no reason and
banning necessary blogging experts during the trial and obstructing important
2To constitute defamation per se based on imputing the commission of a crime,
the crime must be an indictable one, involving moral turpitude and punishable by death
or imprisonment rather than by fine. Moore v. People for the Ethical Treatment of
Animals, Inc., 402 Ill.App.3d 62, 69, 342 Ill.Dec. 321, 932 N.E.2d 448 (2010). The
words do not need to meet the technical requirements necessary for an indictment. Id.
However, the words must fairly impute the commission of a crime. Id.
Jacobson v. Gimbel, 2013 IL App (2d) 120478, 986 N.E.2d 1262, 369 Ill.Dec. 626 (Ill.
App., 2013)
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testimony. Nine disks were enclosed for each of the Illinois Supreme Court
justices. These were in a prior Supplement, which was rejected, but it is
requested that they be incorporated into this Motion for Reconsideration
First and foremost, a blog is not “fraud or moral turpitude”. The tribunal did
not make a finding of “fraud” in its lengthy decision. It also did not make a
finding of “moral turpitude” in its finding. In fact, the word “fraud” is not found
anywhere in the decision, nor is moral turpitude. In the case of Green v. Trinity
Intern. University, 801 N.E.2d 1208, 344 Ill. App.3d 1079, 280 Ill.Dec. 263 (Ill.
App., 2003), the Plaintiff did not state a claim for defamation, because the
statements she alleged defendants made amounted to an inference of “moral
turpitude” were in fact protected by the First Amendment. Id at. 1219.3
3 In Anderson, our supreme court held that an employer’s comments to an
employee’s prospective employer that she did not “follow up on assignments” and did
not get along with her coworkers could reasonably be construed to signify “nothing
more than that the plaintiff did not fit in with [the defendant’s] organization and
perform well in that particular position.” Anderson, 172 Ill.2d at 415, 217 Ill.Dec. 720, 667
N.E.2d 1296. In Marczak v. Drexel National Bank, 186 Ill.App.3d 640, 643, 134 Ill.Dec. 441,
542 N.E.2d 787 (1989), the court ruled that the following statement was capable of
innocent construction: “`[The plaintiff] did not perform up to the high standards
expected of officers of the Bank. She had some problems getting along with her
supervisors and other officers; at times she was uncooperative and did not have the
Bank’s best interest at heart; and she did recently refuse to perform one of the
responsibilities of her position.'” In so holding, the court concluded that the statement
could be interpreted to mean that the plaintiff had trouble getting along with others
and did not fit into the organization. Marczak, 186 Ill.App.3d at 645, 134 Ill.Dec. 441, 542
N.E.2d 787. Beitzel’s comments about plaintiff can reasonably be construed in a similar
fashion. Plaintiff has not cited any authority in which statements similar to those at issue
in this case have been sufficient to sustain a cause of action for defamation per se
[which requires an assertion of “a crime of moral turpitude”. Green v. Trinity Intern.
University, 801 N.E.2d 1208, 344 Ill. App.3d 1079, 280 Ill.Dec. 263 (Ill. App., 2003)
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It is most interesting that the ARDC is equating and asserting that
blogging or publication of thoughts and opinions regarding attorney’s courtroom
behavior and antics amount to “fraud” or “moral turpitude” requiring an interim
suspension. Many defamation case revolve around claims of allegations of
“moral turpitude” to state a case for defamation, yet under the First Amendment,
Illinois courts resoundingly dismiss those causes of action, leaving the press free
and open. There should be no difference with Illinois blogs and those in
particular regarding courtroom activities.
Also, we bear in mind that whether the publication in an
alleged libel action is capable of defamatory meaning is a question,
in the first instance, for the court. Chapski v. Copley Press, 92 Ill.2d
344, 352, 65 Ill.Dec. 884, 888, 442 N.E.2d 195, 199. If the
publication is not capable of defamatory meaning in the first
instance, the court is required to rule that the publication is not a
defamation as a matter of law and the suit should be dismissed.
This is not merely an aphorism or Illinois law, it is part of the
first amendment guarantee of free speech which we all enjoy
as Americans. See Greenbelt Co-op Publishing Ass’n v. Bresler
(1970), 398 U.S. 6, 90 S.Ct. 1537, 26 L.Ed.2d 6; New York Times
Co. v. Sullivan (1964), 376 U.S. 254, 84 S.Ct. 710, 11 L.Ed.2d 686,
714. Flip Side, Inc. v. Chicago Tribune Co., 564 N.E.2d
1244, 206 Ill.App.3d 641 (Ill. App. 1 Dist., 1990).
While the Tribunal claims that the blog interfered with the “orderly
administration of justice” no testimony was presented that Gloria Sykes did not
have other counsel, when in fact she did. In fact, Gloria Sykes had a long string
of attorneys from Jay Dolgrin to Joel Brodsky and others who advised her quite
frequently, with or without filing an appearance. Pleadings that Gloria filed, with
her own legal advice and counsel appeared on the blog, but Respondent did not
draft any of them. They were drafted by other attorneys and paralegals. Those
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pleadings appeared after the fact they were presented in court–each of them
ignored or stricken, accordingly it is difficult to understand why the Tribunal found
that the blog incited Gloria Sykes to write pleadings “which bogged down the
proceedings.” The blog publishes what has been presented in court, and does
not draft pleadings for clients, though there are plenty of sample pleadings on
the blog for others to follow. Saying that a blog incites a litigant to file frivolous
pleadings is the same thing as saying pro se litigants must not have access to
law libraries else they will file improper and frivolous pleadings that bog down a
court.
The Sykes court had its opportunity to allow Respondent to represent
Gloria, it turned that down, leaving Gloria Sykes without counsel and a complete
mistrust of the court, the judicial system and all probate lawyers. After that,
Gloria Sykes did her best on her own to draft and file pleadings. She never
wanted to hire another lawyer again. That is what the probate court and
attorneys wanted and wished for, and that is what they received. For the most
part, they struck or ignored Gloria’s pleadings, so it is not understood how
striking and ignoring pleadings “bogs the court down.” Or, for that matter, how a
blog about probate can be used to incite others to f ight for justice and file
improper pro se pleadings that bog down a court. No connection between the
conclusion and the facts were ever made.
Fraud on the Court
What is “Fraud on the Court?”–from http://www.marygsykes.com, written by a
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pro se litigant, Ms. Rosanna Miller of Ohio, herself, also a probate victim
turned her own paralegal.4
A judge is an officer of the court, as well as are all attorneys.
A state judge is a state judicial officer, paid by the State to act
impartially and lawfully. A federal judge is a federal judicial
officer, paid by the federal government to act impartially and
lawfully. State and federal attorneys fall into the same general
category and must meet the same requirements. A judge is not the
court. People v. Zajic, 88 Ill.App.3d 477, 410 N.E.2d 626 (1980).
2. What is “fraud on the court”?
Whenever any officer of the court commits fraud during a
proceeding in the court, he/she is engaged in “fraud upon the
court”. In Bulloch v. United States, 763 F.2d 1115, 1121 (10th Cir.
1985), the court stated “Fraud upon the court is fraud which is
directed to the judicial machinery itself and is not fraud
between the parties or fraudulent documents, false statements
or perjury. … It is where the court or a member is corrupted or
influenced or influence is attempted or where the judge has
not performed his judicial function — thus where the impartial
functions of the court have been directly corrupted.”
“Fraud upon the court” has been defined by the 7th Circuit
Court of Appeals to “embrace that species of fraud which
does, or attempts to, defile the court itself, or is a fraud
perpetrated by officers of the court so that the judicial
machinery can not perform in the usual manner its impartial
task of adjudging cases that are presented for adjudication.”
Kenner v. C.I.R., 387 F.3d 689 (1968); 7 Moore’s Federal Practice,
2d ed., p. 512, ¶ 60.23. The 7th Circuit further stated “a
decision produced by fraud upon the court is not in essence a
decision at all, and never becomes final.”
3. What effect does an act of “fraud upon the court” have upon the court
4Post from Jan. 14, 2014 written and submitted by Rosanna Miller whose Father
was found living in filth and feces after leaving him with her brother James who
allegedly stole hundreds of thousands from the Father and let him live in filth and
squalor in the family home courtesy of the Probate court and Attorney Fansler who
inserted himself in Claire Miller’s POA and revoked Rosanna’s. That case remains
unresolved.
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proceeding?
Fraud upon the court” makes void the orders and judgments
of that court. It is also clear and well-settled Illinois law that
any attempt to commit “fraud upon the court” vitiates the
entire proceeding. The People of the State of Illinois v. Fred E.
Sterling, 357 Ill. 354; 192 N.E. 229 (1934) (“The maxim that fraud
vitiates every transaction into which it enters applies to
judgments as well as to contracts and other transactions.”);
Allen F. Moore v. Stanley F. Sievers, 336 Ill. 316; 168 N.E. 259
(1929) (“The maxim that fraud vitiates every transaction into which
it enters …”); In re Village of Willowbrook, 37 Ill.App.2d 393 (1962)
(“It is axiomatic that fraud vitiates everything.”); Dunham v.
Dunham, 57 Ill.App. 475 (1894), affirmed 162 Ill. 589 (1896); Skelly
Oil Co. v. Universal Oil Products Co., 338 Ill.App. 79, 86 N.E.2d
875, 883-4 (1949); Thomas Stasel v. The American Home Security
Corporation, 362 Ill. 350; 199 N.E. 798 (1935).
Under Illinois and Federal law, when any officer of the court
has committed “fraud upon the court”, the orders and
judgment of that court are void, of no legal force or effect.
As an example of Fraud on the Court, the ARDC Tribunal still has not
provided the undersigned with the audio portion of the transcript which shows
how Judge Stuart changed her testimony on the stand and went from denying
that she ever had her deputies chain Gloria Sykes and threatened her pets with
euthanasia to changing her testimony mid sentence that she did.
Further, additional information reveals that the reason why Lisa Madigan
has not investigated the Sykes case and other probate is cases is due to the f act
her real name is Lisa Murray, she is the daughter of Joel Murray, not Mike
Murray and Joel Murray was a prominent criminal attorney in New York
defending major drug distributors in the US during the 1980’s.
1. Joel Murray was born and raised in Bronx New York, by Hirsch circuit
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vaudeville performer Al Murray and Catskills hotel operator Claire Stier Murray.
He was sent to University of Wisconsin in 1960 on a boxing scholarship and later
received his law degree. He began legal practice in Illinois during 1964 as a
criminal defense attorney, representing drug dealers, corrupt politicians and mob
associates. He suddenly closed his practice in 1979 and began running
Simmons Airlines with his brother. Accelerated growth, and operating agreement
using American Eagle brand led to Murray’s eventual sale of Simmons in 1988 to
AMR parent for $78 million.
In 1988, Murray moved to residence in Laurel Canyon area of Los Angeles and
began financing and producing Broadway plays. Murray’s national touring
company was incorporated in Illinois during 1992. He maintained his Chicago
Gold Coast residence and condo in Florida as well.
Murray died in October 2009 and after funeral showing in Chicago was buried in
his hometown of Bronx in Jewish only cemetery, next to Lisa Murray’s paternal
grandparents. Lisa Murray was the only child of Joel Murray.
2. Fred Roti, son of mobster Bruno Roti, was a long time Chicago Alderman who
was indicted in Operation Greylord for fixing court cases. The DOJ in 1999
stated Fred Roti was a known mafia figure aka “made man”. His daughter
Rosemary now works for Tim Evans. His son Bruno F. Roti was indicted in 1980
in CPD motor pool kick back scandal and pled guilty serving brief time in prison.
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Despite conviction, Bruno appears to now work for Sheriff Dart’s office or is on
payroll.
Fred Roti’s grandson John Walz works in Attorney General office under Lisa
Madigan.
3. Sang Yul-Lee, ARDC hearing officer in Denison case, is law firm partner of
Thomas Matyas, father in law to Tiffany Madigan, half sister of AG Lisa Murray
Madigan. This fact was never revealed to Respondent before, during or after her
trial. The Chair had been advised that Respondent went to Lisa Madigan asking
for help on troubled probate cases repeatedly, and only received one letter
saying that her offices did not prosecute court corruption (though she is sworn to
do so), and no help or assistance or any prosecutions or investigations ever
ocurred.
This also explains why, after numerous letters to States Attorney Anita
Alvarez and Illinois Inspector General, Diane Saltoun, they wrote back the
undersigned, informing her that “they did not investigate or prosecute court
corruption,” when in fact they are sworn to eliminate it. These letters have been
published on the Subject Blog.
In addition, it appears that Presiding Judge Timothy Evans not only has
two daughters or granddaughters working for him in court scheduling for $100k
per year, he also has Rosemary Roti, daughter of Frank Roti, a known mobster
from New York. This explains how many cases are transferred to the “right”
judges for disposition (Vara v. Polastek, et alia). There are also stacks of files in
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one presiding judge’s offices which have fallen off the docket and where one has
to track them down and the clerk says these are “special cases”–cases where
victims have filed Protective Orders (Sykes) and cannot get them heard on the
merits because the files are sequestered. This was reported to the authorities.
And in addition, after it is now famous in the probate division that
transcripts are changed by the “Official Court Reporters” (Estate of Frank
Wurster, Sykes 09 P 4585 case and others), it appears that the head of this
nefarious operation is Marilyn Filishio
(FILISHIO MARILYN A – ADMIN OF COURT REPORTING SERV Cook $151,049.04)
(from the Official court reporter’s website)
and court reporters have disclosed to the undersigned they have quit or been
forced out after they were told to alter or suppress transcripts and they refused.
(Smart ladies)
Complaints have been filed with the ARDC but have gone no where. The
ARDC says that Mr. Tom Zimmerman is to investigate that organization (which
does not file any Ethics Reports under the mandatory Ethics Reporting Act of
2009), yet he repeatedly sends back letters (Exhibit A, Motion to Supplement)
denying any investigation of valid complaints.
A listing of the pro bono clients (or low cost attorneys) via their affidavits is
attached hereto.
The undersigned has done nothing but blog and investigate, blog and
investigate. For this, she has received death threats, her husband has received
death threats, she has had repeated damage to her car (in one instance being
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blocked in by 2 suburban vehicles and a heavy object thrown at her car late at
night (2 am) on the Kennedy expressway, and in another sugar in the gas tank
leading to a $2,500 repair. The people involved are dangerous and a threat to
the citizens of the State of Illinois.
No one else does pro bono probate in the Probate division of Chicago and
Rockford. Case are run without jurisdiction (Sykes, Payton and Reichert) and
the undersigned is the only attorney who cares about all these probate and court
corruption victims. Recently, the undersigned has driven down to Moultrie
County for a court corruption victim (Lyle Harrison) because no one will help him.
He is jailed indefinitely merely because he will not withdraw counterclaims in his
case where the judges involved are protecting Hardware State Bank for failing to
fund a trust account for 9 children!5 Out of dozens and dozens of attorneys he
has contacted for help, only Ms. Denison has filed an appearance to help him.
He has no one and is wrongfully jailed indefinitely so that he will not lose his
farmland (1400 acres of prime farmland in Moultrie/Paitt counties). He has no
one.
All of this is Fraud upon the Court. Respondent’s ARDC proceedings
involve layer upon layer of Fraud upon the Court–transcripts altered, a sitting
Judge changing her testimony on the stand, etc. Mr. Amu was suspended for
talking about 3 judges in Cook County who are known to be corrupt and each
5His transcripts have been changed also, and no one investigates. Upon
information and belief, the court reporter in question works for Judges Flannell and
Brosch and is controlled by them.
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judge reversed a corrupt decision. Mr. Ditkowsky was suspended for
investigating the Sykes case, a case running without jurisdiction where $1 million
in gold coins (or near that amount) has gone missing and both the ARDC and the
09 P 4585 court have consistently quashed subpoenas and blocked discovery
upon the GAL’s involved–Stern, Farenga, Schmeidel, Soehlig, etc.
The ARDC has acted repeatedly in the Sykes case to quash discovery
and subpoenas on the missing gold coins. They are there somewhere.
Someone needs to find them for Mary and Gloria Sykes. Nonetheless, upon
information and belief, Mr. Sang Yul Lee knew this and did not recuse himself as
chair. He did not disclose his relationship at all to the Madigans and a possible
conflict knowing that Lisa Madigan had written Respondent a letter that her
offices would not prosecute probate court corruption, yet in fact she is charged
by her oath of office as being mandated to do so.
B. Respondent Moves the Illinois Supreme Court to declare her a
Whistlebower entitled to judicial protection.
Due to the contents of Respondent’s blog, the relentless persecution of her and
Ken Ditkowsky and Lanre Amu for merely speaking the truth, and the fact there
is a pattern of conduct in the Illinois court system and with the ARDC to hide and
cover up Truth and Justice, by means of distortion of the Rules of Professional
Conduct for Attorneys, Respondent herewith requests that the Illinois Supreme
Court protect her and save her from the injustices and persecution she is
currently experiencing by declaring her a “Protected Whistleblower” for her
actions in publishing her Blog. She requests that this status be awarded
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Kenneth Ditkowsky and Lanre Amu as well.
(740 ILCS 174/10)
Sec. 10. Certain policies prohibited. An employer may not
make, adopt, or enforce any rule, regulation, or policy
preventing an employee from disclosing information to a
government or law enforcement agency if the employee has
reasonable cause to believe that the information discloses a
violation of a State or federal law, rule, or regulation.
In this case, in effect, the ARDC is the ultimate employer for all attorneys.
In effect, the ARDC has created and enforced a “code of silence” that attorneys
must not talk about or disclose misconduct, even if it is serious or egregious, and
even if it leads to the illegal use of chemical restraints on disabled persons, and
even if it leads to their isolation, death by narcotics and a quick cremation.
Accordingly, when valid citizen complaints are filed, the ARDC refuses to
investigate and dismisses them out of hand.
Respondent is herewith asking the Illinois Supreme Court to rule that
attorney whistleblowers are protected from tied in courts, undisclosed deals and
crooked lawyers and judges. Further, Respondent requests, that the ARDC and
all probate attorneys file their Mandatory Ethics reports under the Illinois Ethics
Reporting Act of 2009 which requires that the head of the agency (ie, SCOI)
order the filing of reports by employees when they have not done so. During
phone calls to the ARDC, 90% of the attorneys became enraged when told they
had to ethics report and slammed the phone down angrily. Only one or two were
horrified they should be ethics reporting.
Respondent also claims protection as a Whistleblower when the ARDC
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fails to file Ethics Reports, when it appears there have been $1.2 million in
mortgage payoffs to Mr. Jerome Larkin and he refuses to disclose why or how
this has happened and he himself refuses to file ethics reports disclosing all
sources of income when asked to do so. Respondent is respectfully asking
leave to file subpoenas for financial information and bank records on all of the
following: Jerome Larkin, Sharon Opryszek, Melissa Smart, Leah Black and
further, to subpoena US Bank/Pullman Bank to find out who drilled out the lock
box of Mary and Gloria Sykes without a court order and without informing Judge
Stuart to pull the video tape of the person removing the contents of the box, and
to serve a subpoena for a deposition upon her. Without this, there can be no
valid entry of any judgment against Respondent and her entire case is Fraud on
the Court–a tort that has no Limitations Period and must be taken seriously every
time a pleading is filed.
B. Behavior during Review Board hearing
During the Review Board hearing on April 10, 2015, approximately 10
probate victims/court corruption victims were in attendance. (Ditkowsky, Amu,
Frake, Shannon X, Tony Phillips, Gloria Sykes, Bev and Ken Cooper, Kaufman,
Frake, etc.) and most notably, Gloria Sykes stood up and gave a speech on how
she provided the undersigned with the information for the blog and it was wrong
of the ARDC to ban her as a witness at trial during the undersigned’s oral
argument because it was all true what was posted on the Subject Blog.
Incredibly, when the undersigned hired a court reporter for the hearing,
she was told by the clerk “not to set up” because they “don’t do transcripts” at
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oral argument before the Review Board–which is an incredulous statement. The
clerk said he would check, but he never did. The undersigned was not
represented, had no assistant at the hearing and didn’t know the reporter had
not set up prior to beginning. After the proceeding, the clerk came up and said
that Ms. Denison was supposed to have asked and he indicated he never asked!
Regardless, the undersigned had most of her argument written out and it
is attached here to as Exhibit B to the Motion to Supplement which should be
considered as if fully incorporated into this pleading.
Honest Attorneys Threatened in Probate
In addition, dozens and dozens of clients have now been left without pro
bono or low cost representation in Probate. All of the undersigned’s clients have
been entirely supportive and understanding of the present situation. They have
known the only attorney you can get in probate is either one that is dishonest
and will drain the estate and sell homes for pennies on the dollar, or if you
happen to find one good honest one, the others will work to disbar that attorney.
Atty Ken Ditkowsky was threatened by Adam Stern that if he investigated
the Sykes case, Mr. Stern would have Mr. Ditkowsky disbarred.
The undersigned attorney was threatened not once, but twice by Judge
(now Justice) Maureen Conners if she tried to represent Gloria Sykes she would
be disbarred, despite the fact that there was no real conflict, the undersigned
had never represented Mary Sykes, she had filed no appearance, done no
work–the disqualification was merely for notarizing a document! Gloria Sykes
has never recovered from that miscarriage of justice and she is still pro se filing
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papers everywhere she possibly can. She trusts no attorney. The ARDC blames
the blog, but the blog teaches the law. What Gloria is doing now, often falls
outside what competent counsel will do. If the miscreants in probate wished
Gloria no counsel, they have received their wish–and then some. Gloria has
struck back with a vengeance and then some. Gloria needed counsel and she
was wrongfully denied by the court in a very difficult emotionally charged case.
She has now become judgment proof and files pleading after pleading to save
her mother, get her mother’s $1 million in coins back and has pled the
Americans with Disabilities Act which is being ignored over and over in Probate
Cases–especially those where money and wealth is involved.
Cases without Jurisdiction
a) Mary Sykes. No evidence of service of Summons and Petition for
Guardianship upon Mary Sykes. The two Elderly Sisters never served with 14
day advance notice of the time, date and place of jurisdiction
b) MVP – Client’s son never served with time, date and place of hearing. Alleged
Disabled kept in lock down with a “nurse” that reports her every move, takes her
cell phone away and ensures she cannot contact anyone at any time. Client
does not want a guardianship. She is lucid and clear regarding what she wants.
Prize to “guardians”? Multimillion dollar mansion in valuable location
c) Miss LVP. Served on Friday Federal Express for hearing on guardianship on
Monday. All assets depleted in 8 years. Once had $300k home and $150k bank
account. Forced into locked down nursing home where she escaped. Now lives
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in dilapidated housing where OPG left her which is dirty, filthy and she lives with
dangerous persons. After escape she lived on streets for 2 years begging for
food and housing money from the OPG. Most of the time, they did not answer
her calls. They never gave her any money. Eventually, they provided some
meager housing while OPG took massive fees. Housing was substandard and
one time they failed to pay bill (in winter no less) and she was on the streets for 2
months! Miss LVP once had a beautiful bungalow in Chicago with beautiful
furnishings and a paid up Cadillac. She had the finest things. All gone. She is
now afraid for her life, now money is depleted.
Clients left unrepresented and are at Risk
1) Dominic Spera. Was locked out of all his bank accounts by Rockford probate
attorneys. The undersigned counsel was the only attorney to represent him to
get an allowance. Client was homeless during winter for 5 months. Slept in park,
on porches in Rockford. Ate one meal out of garbage cans–all the while his
mother had over $800k in assets. Assets were in her name and Dominic’s
name. Father died 10 years earlier leaving all to wife and son. Probate
attorneys claimed it all and put it into Estate. Dominic repeatedly asked for an
allowance, but was always refused, leaving him homeless, penniless and without
food or shelter.
Dominic is an elderly, disabled adult, as declared by the court.
The undersigned got him an allowance, has helped with housing and
assistance. Dominic, without counsel, is now at risk. She has managed to patch
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together one attorney for one appearance but nothing further is guaranteed.
A declaration from his priest, Father Jim, is attached hereto that
Respondent’s work is blessed and must not be interfered with. In the Catholic
Church, the words of a Father are the Word of God. To violate the Word of God
is to intentionally sin.
2) Tony Phillips
Years ago, had no counsel who would go up against David Martin. Now
he still has no counsel. Former counsel Nejla Lane was booted out of significant
contingent fees for a favored firm, and she has received only pennies on the
dollar for all her work. As a result, no attorney will represent this co-guardian.
Before the undersigned appeared, the prize of a $3 million vacant lot on Wabash
went from “purchaser” to “purchaser” without any hard money down. The
undersigned and Tony Phillips insisted on hard money to fund the estate,
obtained a contract from Capstone and $25,000 per month for holding the
property until finally sold. Now the Estate is well funded. The ploy? Let the
property go to foreclosure and have a “friend” buy it up cheap there. Tony
Phillips and the undersigned stopped all those shennanagins. Now it is likely the
property will go to foreclosure and sold for pennies on the dollar. David Martin
already wants to pay 25% of Respondent’s fee petition, even though she was
able to get Tony and his Mother out of poverty (that’s right, he was receiving
$1100 per month for support, while the attorneys for the estate had liened all the
properties with their fees for over $200k). Atty David Martin opposes all
attorneys, his fee petitions of hundreds of thousands of dollars are routinely paid
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in full (for throwing properties into foreclosure) while opposing counsel gets
pennies on the dollar.
As an example, the undersigned finally presented her fee petition for
$50,000 after getting the family out of poverty and finding a hard money buyer.
She represented Tony Phillips for 2 years arguing for a fair deal and justice to
the estate. David Martin and others have been awarded hundreds of thousands
of dollars in fees. David Martin is asking, and will probably get, an award limiting
the undersigned’s fees to $14,000. He knows that the money will go to fight for
justice–and he does not want that.
3) Barabara Monaghan and the Estate of Sophie Reichert
Barbara Monaghan was a beloved Daughter in Law who was named
Successor Trustee and POA for her mother in law, Sophie Reichert whom she
knew for decades and they loved one another dearly, despite the divorce (which
was because the son Ronald was a known alcoholic). Work on this case?
Enormous. But Barbara has no counsel–due to the ARDC and SCOI. The OPG
stepped in, presented a trial so pathetic, the judge immediately sealed it and the
transcripts. The client, Barbara Monaghan was given 14 days for written
discovery and 10 days to disclose witnesses–a deadline impossible to meet so
all her witnesses and exhibits were stricken at trial.
All of a sudden, on the day of trial, Sophie changes her mind (per the
GAL) and does not object to the OPG being guardian (despite “severe”
dementia–which is it), and does not want to be present at her trial (though she
was adamant about this before and came to all court appearances before the
-18-
OPG stepped in to “manage” her) and she has said all along, for many long
months she wants Barbara as her guardian. Of course, none of these “sudden”
changes and waiver of important rights are video recorded by the GAL.
Upshot? Barbara was handling Sophie and her valuable, $2.5 million
building for $2400 per month. The OPG is now “guardian” and is draining the
estate at $10k per month–for the same services. While what the OPG does is
“valuable and laudable”, what Barbara did was “self dealing”–at four times the
cost! And with a Trust and POA which the OPG invalidates with a rubber stamp.
Son Ryan Reichert (who was immediately isolated from Sophie when the OPG
took over, as well as another grandstepson the OPG refuses to acknowledge but
was treated as a grandchild for years), is now 18 and wants to be Guardian. So,
what does the court do? At one hearing in February 2015 he files a cross
petition for guardianship. The court says it is “premature”. Within days later, the
OPG is appointed, and his petition never considered! In this case, the
undersigned and client were told ONLY the OPG could be guardian in the case
and no one else. Restraint of trade? Prior deal? No one will ever know.
But wait, there’s more:
4) Susan Block Former counsel, for months, never served her with foreclosure
proceedings. She was defaulted and on a Motion to Vacate filed by the
undersigned, was refused. She could have done a Deed in Lieu, or short Sale
but that was all gone. The undersigned should be filing a malpractice or asking
for fees and reimbursements, but she cannot.
-19-
5) Bella Perlman Kept in a nursing home for months against her will (the
nursing home kept on telling her that she could not leave without a doctor’s
signature, then she had to have a POA, then the POA was not good enough,
then she had to have a friend sign for her, etc.), the nursing home sued her for
$12k in fees–for one month after she was there claiming a “cancellation fee”, the
undersigned was to file counterclaims in her action. Now that is all gone.
6) Janet Bedin and Alexander Bedin
In late summer 2010, Dolores Bedin was finally diagnosed with pancreatic
cancer. I say finally because Janet Bedin, her daughter, decided to change her
mother’s medical team to Northwestern Memorial Hospital in Chicago due to
their reputation and advertising they were the best in geriatric care. In summer
of 2010, after years of severe stomach pain and vomiting, and after MRI’s every
6 months of her abdomen to “watch a hernia” which was causing the pain,
Daughter Janet found out that her mother had massive pancreatic cancer that
had invaded the hepatic artery and was now incurable. Immediately she
obtained all the medical records and found out that 2.5 years earlier a small
benign polyp had formed on her mother’s pancreas. However, the doctors at
NMH never told her about it. As a result, the tumor grew over the years. At the
time of diagnosis in late summer of 2010, both mother and daughter were
distraught. Daughter Janet asked for her mother to receive cancer rehab, but
instead, NMH went on a terror campaign to send the mother home without
further treatment, ostensibly to die. When Mother Bedin did not leave NMH, the
-20-
staff enlisted the help of probate attorneys in Rockford to guardianize her and
forcibly remove her from the hospital to a dilapidated Chicago South Side
nursing home! On Friday, Janet Bedin was served with papers for her mother to
be guardianized on the next Monday. When she arrived in court on Monday she
was threatened by the probate attorneys they would institutionalize her brother,
who was developmentally delayed and a disabled adult, they would lock her
mother away forever in the worst nursing home on the South Side of Chicago
they could find and they would then take her assets and her mother’s assets to
pay fees. The family sued, the undersigned was pro bono counsel for Deft.
Alexander Bedin who was disabled, but now he has no counsel. The case is up
on appeal and it is unlikely that either Janet or Alexander can afford the
appellate process without her.
7. Estate of Janie Thomas
Marie Owens is a dedicated sister and caregiver to Janie Thomas for
years. She takes her into her home and makes sure she has food and clothes,
is clean and well groomed and well cared for. An estranged brother files for
Guardianship, and Marie files a cross petition for Guardianship. The OPG then is
nominated by one of the probate attorneys–one it turns out has terrorized the
family in the past, and the court awards guardianship to the OPG. When other 3rd
parties are mentioned, all the attorneys and the court find that the case MUST go
to the OPG, as if it were a done deal. They would consider no other petitioners.
Soon as the OPG is appointed, the family is isolated with a Monday to Friday 8
to 3 visitation order, when the OPG knows most of the family works.
-21-
Subsequently, Janie is frequently found at a nursing home without proper fitting
clothes, (hers are mostly missing so the clothes are makeshift), she is dirty and
unkempt, she has no personal toiletries no hairbrush, toothbrush, toothpaste,
deodorant and she is dirty and smelly. She is often found by Marie and others
dazed and confused with too many psychotropic medications either wandering
the halls in a daze or left sitting alone on a toilet calling for help.
Marie had problems finding counsel before because the court will not pay
out of the estate, they ignore POA clauses to pay attorneys and claim this is “self
dealing” when it is not, they freeze assets so only favored attorneys can be paid,
etc.
So now Janie is left alone and dirty and her POA sister Marie has had her
powers summarily and unjustly ripped away and there is no hope for Janie.
Reports of abuse to the court (first Judge Stuart, now Judge Aicha MacCarthy)
go right back to the abusers where nothing happens.
8. Gary Frake and Estate of Alan Frake
Gary Frake is the son of Alan Frake. When he found out a certain James
Stouffer had plundered perhaps hundred of thousands of dollars from his father’s
estate, he turned to the probate courts for help. They appointed Tom Kleinhenz
as the Guardian of the Person and Kerry Peck was his counsel of record. Since
that time, the case turned into a nightmare with a loving sister Jean Semrow
suffering as the victim of a wrongful Protective Order, a cousin Mike Messer who
can no longer call Alan Frake, and Alan Frake himself a victim of the court
system. Alan Frake has an estate of about $9 million. He was a strong, vibrant
-22-
elderly concrete business owner in Northbrook. He had about 10 rental
properties which should be rented out each at $2k per month. James Stouffer
steals from the estate and is given a pass. He rents on the site a $2k per month
property for $25 per month. The rest of the properties have been vacant for 24
months. A court appointed property manager does nothing to rent out the
properties. Gary Frake brings the estate renters, calls the property (mis)
manager and nothing happens.
Next, Alan Frake (“Father Alan”) wants to live at home, so Mr. Kleinhenz
brings in 2 professional “caretakers”. Instead of caretaking, Alan Frake is
enraged one day when he finds them engaging in romantic considerations in the
bedroom next to his and physically throws them out of his home. But who is
punished? Of course, the ward. Alan is promptly place at a locked down facility
and drugged with psychotropic drugs as chemical restraints to keep him there.
He has been drugged so violently, his cousin Mike Messer has not been able to
call him and talk to him for perhaps 18 months, the reports from credible sources
including his son Gary, is that he can barely lift his head, he can barely speak
and when he does all he can say is that he is in pain (undiagnosed hip pain) and
he wants to die. The reports of abuse are repeatedly filed with the court and the
court hands back reports of abuse to his abusers–Kerry Peck and Tom
Kleinhenz and Atty Footlick who all deny everything. At first they denied the
psychotropic drugging and then they admitted to it, but it “was only a little.”
The abuse continues and all–Gary Frake, Mike Messner and Jean
Semrow (sister) know that they are killing Alan. No one can stop any of this.
-23-
Now the family has no representation. No one is there to help Alan Frake,
imprisoned in a drugged body and in pain. The family, with Respondent’s
suspension, has given up all hope of justice.
8. Barbara Stone
Barbara Stone is an attorney licensed both in Florida and in New York. In
2012 or thereabouts she determined her brother had forged $700k in checks
from her mother’s accounts. She was told to hire an attorney and file for
guardianship, which she did. But what happened was a nightmare. The
Guardian and her attorney promptly obtained an order to remove Barbara from
the mother’s home in Florida, and they put in her place two Haitian “caretakers”
who barely spoke English and had no credentials or certifications. They moved in
all their belongings, TVs, refrigerators into the 2 bedrooms of Helen Stone’s
condo in Florida and began to “care” for her. They “cared” for her so well, that
just a few months later, Helen Stone was rushed to the ER with pneumonia,
lacerations, contusions, fractures, malnutrition (a drop in body weight in months
of 40 lbs, 145 lbs to 105 lbs), and she spent 3 weeks in the hospital recovering.
But in addition to removing Barbara from the home, banning her from seeing her
mother since January of 2014, they had her arrested for “interfering with the care
of a disabled person” and she has either been in jail or with ankle bracelet
monitoring since that time. She had done nothing other than 1) oppose her
mother from taking the drug Miralax, a drug that comes with black box warnings
not to use on the elderly or disabled and which agitates the patient (agitation
they blame on Barbara–not the wrongful use of a prescription medication); 2)
-24-
she also took her mother out for lunch and found she did not need a feeding
tube, her mother ate quite well6. Again, she was charged with “interfering with
the care and custody of a disabled person” and went to jail a second time.
Currently she is under a body attachment for filing pleadings in Probate Court in
Florida for merely trying to protect her mother, who is in grave danger from
isolation and psychotropic drugging.
The undersigned has helped Barbara with her situation, yet Barbara’s
mother remains drugged and in danger, and Barbara has not seen her mother
since January of 2014. Helen Stone remains in danger to this day. Barbara is
vigorously filing suits against the Judge and other miscreants in a brave effort to
save her mother from impending death and doom.
What has happened of the $600,000 in checks her brother forged?
Nothing. No Citations to Recover, nothing. The miscreants are focusing on the
fees they can take from the estate and Helen Stone is not at home, but in a
nursing home with drugs and a feeding tube at one end and a diaper at the
other. Respondent’s suspension means she cannot help Barbara by appearing
Pro Hac Vice in Florida, another jurisdiction rampant with tied in probate
attorneys that threaten honest attorneys with groundless bar complaints, and
now even arrest and imprisonment–all for merely filing pleadings.
6Feeding tubes are often placed in the elderly under guardianship not only so
that no one needs to take the time to feed a person that eats slowly, but also to deliver
psychotropic drugs they otherwise would not take. Of course, all of this is illegal under
the case of In Re Tiffany.
-25-
Odd statements by the Tribunal indicating ambivalence for what they did
Respondent presented favorable character testimony. Her character
witnesses described Respondent as a person who was generous
with her time, made herself available to persons who needed help
and did so pro bono. P. 53, Decision of Tribunal
While Respondent acted with reckless disregard for the truth of her
accusations, based on our impressions of Respondent, we do
not believe she was acting out of a deliberate purpose of
harming the judges and attorneys involved. Respondent
genuinely, though unreasonably, believed something was
wrong with the proceedings in the Sykes case. Respondent
knew Mary and Gloria before the guardianship. While
Respondent used decidedly misguided means, we believe
she was acting out of a sincere desire to help Mary. We
were also convinced Respondent truly believes there are
abuses in the probate system and the system needs to be
changed, to protect persons who are the subject of adult
guardianship proceedings. From our perspective, it appears
Respondent has genuine concern for senior citizens and
perceives the senior population as vulnerable, especially to
financial exploitation. This concern, as a general matter, is
a legitimate one, even though Respondent had no reasonable
basis for believing the judges or attorneys in Mary’s case were
corrupt.7 Id.
We do not believe Respondent acted with a self-serving
motive. The evidence did not support a theory that Respondent
was reaping a significant financial benefit from her activities
including operation of the blog.
7This is despite the fact that Judge Stuart “suddenly resigned”. Judge
Kowamoto, who was the judge on the Estate of 99 year old Alice Gore also “suddenly
resigned” approximately six weeks after the blog published that she was isolated from
20+ friends and family for 10 months and then her 29 gold teeth were pulled and she
was put on a feeding tube laced with drugs and a diaper at the other. She was then
killed with drugs and was sticks and bones at the time of death. Nothing has been
investigated by the ARDC despite numerous complaints filed by the family–all published
on the Subject Blog. If the Tribunal seriously believes that this behavior is acceptable
for sitting judges and probate attorneys to engage in, then they are as well part of the
problem and not part of the solution.
-26-
No one told the Tribunal to make these statements, they did them
voluntarily.
Character Witnesses:
From Bev Cooper, who runs a local cable TV show for decades:
A. It’s an hour program uninterrupted.
Q. Okay. And I think the Panel is
looking for you to give testimony regarding my
character.
When did you first meet me?
A. About three years ago — three,
four years ago, found you on a blog and was
very interested because we were experiencing
the same problems regarding probate that you
were blogging about.
Q. And we have had conversations; is
that correct?
A. Oh, yes.
Q. Numerous conversations?
A. Absolutely.
Q. Okay. And I’ve also — you’ve also
had at least probably five, ten hours to
talk to me and assess my character and
qualifications?
A. Absolutely. The highest of
integrity. Absolutely.
Q. Thank you. And with respect to —
you’re also aware of the work I do, correct?
A. Yes, I am.
Q. And is a lot of the work I do unpaid?
A. Oh, it is. Unfortunately, it is,
charitable.
Q. And are you aware of the numerous
clients I have helped unpaid?
A. Oh, yes. Yes.
Q. Can you give us an example of the
names that you are aware that I have helped
without pay?
MS. OPRYSZEK: Mr. Lee, I’m going to
object. I don’t know what this has to do with
character and fitness.she — that she has worked on a pro bono basis.
-27-
Ms. Denison’s testified to that. I think the
record is clear. I think more specifics are
unnecessary.
MR. ALNAQIB: Yeah. Why do we need
to know the names?
MS. DENISON: All right. We don’t
need to — that’s fine. I’ll withdraw the
question.
MR. ALNAQIB: I’m asking. I’m not
telling you you don’t have to. I’m just trying
to understand why would we need —
MS. DENISON: Well, there’s a number
of people that I have helped, and I just wanted
her to establish the numerosity of that issue.
MR. ALNAQIB: She could give us a
number then.
BY MS. DENISON:
Q. All right. They just want a number
and not a name. Okay?
A. Many. You’ve spoken to me about
many. I can pick out two right now: Gloria
Sykes regarding her mother, Mary, and Dominic,
who is a homeless gentleman that you are
helping.
Q. Okay. But there are others, correct?
A. Oh, yes. There are others. I’m
sorry. I’m caught —
Q. And we have exchanged numerous
emails, right?
A. Oh, yes. Absolutely.
Q. Okay. And are you — and what are
you aware of my work hours?
A. Constant. 24/7.
Q. Okay. And do you consider me to be
very dedicated?
A. Absolutely dedicated, honorable, with
integrity, always charitable, consideration for
others before yourself. Absolutely wonderful,
wonderful person.
MS. DENISON: All right. I think
that’s all the questions I have for this
witness.
From Ken Cooper, her husband and who also runs the popular blog
-28-
Probate Sharks for nearly 10 years:
Q. Can the witness please state his name
for the record?
A. Kenneth A. Cooper.
Q. And what is your address, Mr. Cooper?
A. 2446 Ridge, Highland Park.
Q. Can you briefly give us some
information regarding your background?
A. Yes. I’m a manufacturer of bronze
plaques and name plates, and I also produce a
blog called ProbateSharks.com.
Q. And what about your educational
background?
A. I’ve got about three years of college
at Northwestern University.
Q. Okay. And how about your background
with respect to any charitable or eleemosynary
services?
A. Yes. I was a volunteer clown for the
Shrine Circus. I was a Shriner and a Mason for
about the last fifty years.
Q. Okay. And how have you come to know
me?
A. Through emails with a mutual friend,
Ken Ditkowsky; and eventually we met. I think
it was about — we knew you for about three
years, and then we met you about two years ago.
Q. Okay. And we’ve exchanged numerous
emails, have we not?
A. We have, yes.
Q. And we’ve talked in person numerous
times; is that correct?
A. We sure have.
Q. And you’re aware that I have been on
your wife’s cable TV show numerous times,
correct?
A. That is correct.
Q. All right. You are here today to
-29-
testify as to my character and whether or not
you consider me to be an asset to the legal
profession.
Do you consider me to be honest
and trustworthy?
A. I do. And I’d also like to add that
I believe that every young attorney who is
going through law school or passing the Bar
should see a movie called “A Man for All
Seasons.” And I believe that every attorney
should strive for the epitome of integrity as
Sir Thomas Mann.8
I also believe that you have
sacrificed and helped numerous people, and I
believe that you have arrived at that plateau
as a great person —
Q. Thank you.
A. — and a great attorney.
Q. Do you consider me to be hard working
and honest?
A. Always.
Q. And am I dedicated?
A. Yes.
Q. And have you learned of — let’s see.
And are you aware of my work schedule?
A. Yes, I am.
Q. And when can somebody reach me if
they have — if they need help or an issue?
A. Twenty-four hours a day, seven days a
week.
Q. And that is by email or my cell
phone, correct?
A. That’s correct. Certainly.
Q. And what is your opinion as to
whether or not I have helped people and how
8Sir Thomas Moore.
-30-
many I’ve helped?
A. You certainly have. Many, many
people. As the king fish of ProbateSharks.com,
I come in contact with numerous people who are
having difficulty with the Probate Court of
Cook County specifically but many, many other
Probate Courts throughout the United States;
and I believe that you’ve been a big help to
many of these people.
Q. Thank you. And are you aware from
what these people have communicated to you
regarding fees and charging people?
A. That’s right. I understand that most
of the work that you do is without charge.
Q. And do I require people to pay up
front in order to help them?
A. No, not at all. You’re most helpful
to anybody who requires help.
MS. DENISON: All right. And I think
that’s basically it for Mr. Cooper.
Additional Affidavits
Additional affidavits hereto attest to the undersigned’s help and
assistance to the indigent and lower middle class. There is no one to protect
them now, without Respondent.
The undersigned respectfully moves this honorable court to enter this
pleading and the Transcript of the Record on Appeal (provided in 9 disks
delivered to the Clerk of Court previously with the Motion to Supplement), as if
fully incorporated into this pleading, including the Writ of Cert authored by Mr.
Kenneth Ditkowsky which contains a plethora of caselaw on First Amendment
rights, 320 ILCS § 20 Elder Abuse Act and 47 USC § 230 on the Internet
-31-
Decency Act which affords full protection to blog owners and those who post on
blogs. Congress has provided a statutory scheme for objecting to posts and no
one, including the ARDC has followed or even attempted to follow the statutory
scheme set forth by the US Congress.
Wherefore, for all of the above reasons, and especially since dozens of
blogging clients and court appearance clients will be left without any
representation, the undersigned is asking that she not be suspended, or that she
be allowed to represent these clients on a pro bono basis until they can find
other counsel.
If the Illinois Supreme Court and the ARDC is not willing to do this, then
she is asking that the ARDC and SCOI find and assign pro bono and low cost
representation for her all clients and others that they might find justice in the
Illinois court system.
The undersigned will be glad to provide an ongoing list to the Illinois
Supreme Court and the IARDC of probate and court corruption victims needing
probono and low cost representation where families have been terrorized, have
lost, or are about to lose significant human and civil rights and liberties and she
would like to have these victims represented.
The undersigned needs no compensation for this. She wants those that
are poor and in need to have low cost or free representation against evil and
injustice. If the powers that be have decided she is somehow a threat to this
system, then she is asking that other attorneys step up and take her place.
These people currently have no one and no hope. The court system is in
-32-
a mess and it will take a panel of attorneys who serve without pay or recognition
to clean it up.
The Illinois Supreme Court and the ARDC should set up such a program
as Respondent has run. They have the funding and the staff to do it. The
Respondent does not have the funding or staff to correct these injustices but the
Illinois Supreme Court and the ARDC does.
` In addition, Respondent is asking that the ARDC/SCOI install a Federal
Monitor on the 18th Floor of the Daley Center where probate victims and
terrorized families can take their complaints that their human and civil
rights are being grossly violated. A perfect place to install this monitor is
in the “glass room” next to reception where many clients have indicated
that their cases were divvied up to the OPG or certain probate attorneys
and deals were made rather than justice being done.
She earnestly hopes that one day the ARDC and Illinois Supreme Court
will have character witnesses say for them (in lieu of the dozens and dozens of
valid citizen complaints Respondent receives on a regular basis):
And I’d also like to add that
I believe that every young attorney who is
going through law school or passing the Bar
should see a movie called “A Man for All
Seasons.” And I believe that every attorney
should strive for the epitome of integrity as
Sir Thomas Mann.9
9Sir Thomas Moore. Of course, for all his valor, honesty, truth and justice, he
was eventually beheaded by Henry VIII, his family had to flee to the Continent, and his
head was placed on a pole outside the Royal palace for a month until his daughter took
-33-
I also believe that you have
sacrificed and helped numerous people, and I
believe that you have arrived at that plateau
as a great person –
(Ken Cooper, owner of Probate Sharks , Character Testimony for
Respondent, January 2014)
RESPECTFULLY SUBMITTED
By: _____/esign/joannemdenison/____
Pro se
Prepared by
JoAnne M Denison
Justice 4 Every 1, NFP
5940 W. Touhy Ave, #120
Niles, IL 60714
312-553-1300 ph
joanne@denisonlaw.com
it down. Respondent hopes that the Illinois Supreme Court will not have her beheaded
and the ARDC/Jerome Larkin place her head on one of the flag poles outside 130 E
Randolph St in Chicago for a month or so–for blogging. Of course she stands by her
blog and Mr. Larkin can have her neck, for all it is worth to him. The System must
change and the SCOI and the ARDC must be at the forefront in instilling these crucial
changes to ensure truth and justice is being accomplished for every case.
-34-

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One thought on “ARDC v. JMD 13 PR 1–Motion to Reconsider Interrim Suspension

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