From EF – Speaking out against corruption re: Madigan, Burke,etc. It’s time for a change

**I give my permission to post this email on anti-corruption sites. 
 
Dear All,
 
I continue to report rampant  judicial corruption of ALL levels of Illinois Court system which  Democratic Party  Speaker Michael Madigan (father of IL AG Lisa Madigan) and Alderman Edward Burke (husband of IL Supreme Court Justice Anne Burke) flooded with their  cronies, under patronage of Chicago Board of Elections, who are perfectly aware WHO are judicial candidates they place on IL benches; and their close relationship with Madigan and/or Burke families.
 
Madigan/Burke cronies (about 80% ++ of all sitting judges in Cook County,  Appeal and Supreme Court) usually obtain judicial seats through IL Supreme assignments  and later purportedly get  “elected” (which is a farce  to mislead not-so-well-connected  lawyers  about their chances to be  judges in our Court  to collect from them millions of filing fees and donations ). Cronies who lost judicial election (regardless how many times) get to the Court through an Associate Judge Positions, like Thomas R. Mulroy, Jr.  and James E. Snyder, both of whom lost April 2008 judicial Elections and in August 2008 were Associate  Judges.  
 
After  those cronies obtain judicial seats,  they  start to mislead IL public about their options to find justice in IL Court to collect billions in filing fees; and hundreds of millions from IL budges to fund judicial paychecks and benefits, while  they  serve their  parties of interests, especially those who pay judges directly; and  fix cases in favor of  parties of interests:  banks, insurance  companies and corporations, all with total impunity. IL  judges are absolutely confident that Lisa Madigan and IL Judicial Inquiry Board will always cover and support their corruption.
 
On of text-book examples of judicial corruption in Cook County Court is Law Division Judge John C. Griffin who started to obstruct justice and lie to me from the bench from day one in my case, which he fixed in the most corrupt manner while concealed his personal connections with my Defendants from whom Griffin received election money (like CNA Insurance Company)  and my defendants’  lawyers, like Hinshaw&Culbertson LLP.
 
I have substantial  evidence  demonstrating that Judge John C. Griffin is a corrupt judge who makes decisions based on his personal interest, not the law.
Griffin obtained his position of public trust in an unethical manner and has personal connections with  defendants in my case which he concealed to defraud me.
 
Moreover, Judge Griffin repeatedly makes false statements from the bench that he does NOT know his election donors , one of whom was CNA insurance company   lawyer Anthony McMahon;  several top partners from Corboy&Demetrio, a well-connected law firm who regularly appears in Law Division ; other well-connected lawyers; insurance and real estate companies, whom Griffin claimed he “does not know”.  Griffin also insists that that he does not know that his law Firm and his family were his donors, which is a blatant lie.
 
Judge Griffin is did not earn his post by merit but through personal connections.  He first attained his seat at the judicial bench through assignment. 
 
The election that followed for him to keep his position was not free or fair. Griffin comes from a family of professionals with long-time ties to the Cook County court, including his father James L. Griffin, who was a judge; his aunt Helen Griffin, who worked for the Chief Judge for 25 years between about 1960-1985; and his uncle Joseph P. Griffin, who worked as a Treasurer Speaker Michael Madigan   and later served as a Commissioner of Court of Claims. I have absolutely no doubt that John C. Griffin’s 2008 appointment and election were procured through personal ties. Judge Griffin’s election donors are on public record. 
 
The records show that Griffin’s campaign employed vote buying from political organizations to obtain his judicial seat. For example, on September 21, 2009, Judge John C. Griffin’s Committee donated $500.00 to the Chicago Federation of Labor & Industrial Union Council PAC. The Union reciprocated the favor on June 16, 2010, by contributing $9,758.68 to Griffin’s campaign and giving him an official endorsement. It’s easy to guess that they reasonably expected a significant return on their money in the form of judicial favors from John C. Griffin.
 
On September 11, 2009, Griffin donated $1,000.00 to Local 399 Political Education Fund, who in return also endorsed Judge Griffin to the bench.
 
In addition, Judge Griffin donated $900.00 to Judicial Retention Committee in 2016 to keep his judicial seat despite Griffin’s highly adverse personal recordsa transaction that looks like a bribe rather than an altruistic donation to the organization.
 
In spite of these negative public records, John C. Griffin has been able to maintain his position as a judge due to his network of well-connected  cronies.
 
Below is my Motion to Reconsider Judge John C. Griffin’s Order where he denied my Petition to vacate his void Orders, with more details regarding case 14-L-3632, Fedorova v. Chicagoland Community Management, Inc.
 
I once again respectfully demand IL Judicial Inquiry Board and IL Board of Elections to  impeach  corrupt  judge John C. Griffin and stop supporting rampant  judicial corruption in our Court system and public offices.
 
Respectfully submitted,
Elena Fedorova, ProSe litigant
 
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, LAW DIVISION
 
Elena Fedorova, ProSe                                               )
Plaintiff/Defendant in 14-CH-11573                           )           Case 14-L-3632         
                                                                                    )
vs.                                                                                 )           (Consolidated  Case 14-CH-11573)
Chicagoland Community Management, Inc. et.al       )          
Defendant/Plaintiff in 14-CH-11573
 
PLAINTIFF’S FEDOROVA’S  MOTION TO RECONSIDER
 
1.                  Plaintiff Fedorova files this Motion to reconsider Judge Griffin’s Order denying her Petitions for relief from the void orders and void judgments in purportedly consolidated cases 14-L-3632 and 14-CH-11573. [1] On May 24, 2017, Fedorova filed a Petition where she specifically stated Judge John C. Griffin’s lack of jurisdiction to rule in Cases 14-L-3632 and 14-CH-11573 given that both cases were pending in Appeal Court. Furthermore, Fedorova demanded redress from Griffin’s decisions, which were influenced by his personal connections with the cases’ Defendants.
2.                  On June 28, 2017, Judge Griffin denied Fedorova’s Petition. Ignoring the fact that he lacked jurisdiction in the cases, Griffin continued to obstruct justice and defraud Fedorova from the bench. He again made false statements about his personal relationship with Fedorova’s defendants and his election donors, one of whom was CNA Insurance Company lawyer Anthony McMahon whose job as CNA lawyer involved coverage for litigations [2] [3] . Ex. 1.  CNA/Continental Casualty Co. is a Defendant  in Fedorova’s case who covers  legal bills for several  other Fedorova’s Defendants.
3.                  Fedorova demands reconsideration of Judge Griffin’s decision since she found additional evidence demonstrating that Judge John C. Griffin is a corrupt judge who makes decisions based on his personal interest, not the law. Griffin obtained his position of public trust in an unethical manner and has personal connections with Fedorova’s defendants. For these reasons Griffin is unqualified to hear Fedorova’s case. To the present day he continues to use his professional position to rob Fedorova of honest services in the court. Fedorova has ample evidence that Judge John C. Griffin is not qualified to hear her case.  
4.                  Judge Griffin is did not earn his post by merit but through personal connections. He first attained his seat at the judicial bench through assignment. The election that followed for him to keep his position was not free or fair. Griffin comes from a family of professionals with ties to the Cook County court, including his father James L. Griffin, who was a judge; his aunt Helen Griffin, who worked for the Chief Judge for 25 years between about 1960-1985; and his uncle Joseph P. Griffin, who worked as a Treasurer Speaker Michael Madigan [4]  and later served as a Commissioner of Court of Claims. Fedorova has absolutely no doubt that John C. Griffin’s 2008 appointment and election were procured through personal ties. Griffin not only concealed his family connections when running for office but has vehemently denied to Fedorova that he knows his election donors. This is a lie.
5.                  Judge Griffin’s election donors are on public record. The records show that Griffin’s campaign employed vote buying from political organizations to obtain his judicial seat. For example, on September 21, 2009, Judge John C. Griffin’s Committee donated $500.00 to the Chicago Federation of Labor & Industrial Union Council PAC. The Union reciprocated the favor on June 16, 2010, by contributing $9,758.68 to Griffin’s campaign and giving him an official endorsement. It’s easy to guess that they reasonably expected a significant return on their money in the form of judicial favors from John C. Griffin. On September 11, 2009, Griffin donated $1,000.00 to Local 399 Political Education Fund, who in return also endorsed Judge Griffin to the bench. In addition, Judge Griffin donated $900.00 to Judicial Retention Committee in 2016 to keep his judicial seat despite Griffin’s highly adverse personal records [5] [6], a transaction that looks like a bribe rather than an altruistic donation to the organization. In spite of these negative public records, John C. Griffin has been able to maintain his position as a judge due to his network of cronies. To note, no ordinary citizens have ever contributed to Griffin’s election campaigns. This alone disqualifies Judge Griffin from the bench and yet he continues to be the arbiter in Fedorova’s cases while Griffin conceals information about receiving election donations from Fedorova’se defendants.
6.                  In Fedorova’s case Judge John C. Griffin has acted corruptly from day one. In October 2014, when Judge Griffin first oversaw the case, he immediately created obstacles that prevented Fedorova from having a fair hearing. These include but are not limited to: (1) Griffin prohibiting Fedorova from collecting any information from her Defendants which could advance her case, like documents or records of inside communication, which was Griffin’s immodest support for well-connected lawyers and their corporate clients; (2) he denied a Motion where Fedorova demanded disclosures about her Defendants’ lawyers’ personal connections with judges, even though Fedorova has reasonable suspicion that these ties existed when on October 1, 2014, Judge James P. Flannery Jr. passed his seat to Judge Thomas L. Hogan, who then unlawfully consolidated Fedorova’s claim with frivolous “defamation” case 14-CH-11573 filed by Chicagoland Community Management while concealed information about numerous donations from Fedorova’s defendant’s lawyers Hinshaw &Culbertson, LLP; and (3) told Fedorova that he “does not even remember who are [his] election donors”.
7.                  This last statement – that Judge Griffin “ does not even remember” his donors – was a blatant lie. The largest donor to Judge John C. Griffin’s campaign was himself, so it is absolutely impossible that he can “forget” the $31, 695.98 he contributed to himself. Furthermore, Fedorova believe that Judge Griffin lied that he does not remember that he received money from lawyer Anthony McMahon [7], who works for CNA/Continental Casualty Co., a defendant in Fedorova’s case; who covers for other defendants’ legal bills.
8.                  Judge Griffin’s malfeasance continued when on October 20, 2016, Defendants Kovitz Shifrin Nesbit P.C. informed Judge Griffin that they planned to file a Motion for a Temporary Restraining Order against Fedorova to preclude her from collecting any documents from them. The hearing was set for November 13, 2014. On November 12, 2014 in the afternoon Fedorova’s other Defendants’ Carl Sandburg Village Condo Association #1 (CSVCA#1) lawyer Newt Marshall emailed Fedorova identical Motion for TRO which was scheduled before Judge Griffin on November 19, 2014, or one day before Fedorova’s filing deadline, even though CSVCA#1 were aware of November 13thhearing in the morning and could easily present their Motion at the same time as KSN. Fedorova was already aware that Judge Griffin’s schedule is always filled at least two weeks in advance, so she had questions how her CSVCA#1  Defendants were able to secure a hearing for November 19th when it was requested with only 7 day notice. After the hearing on November 13th Fedorova went to the Clerk’s Office on 8th Floor to discover that Judge Griffin’s next available hearing date was November 26th. Under ordinary circumstances Defendants CSVCA#1 should not have been able to obtain the hearing on November 19th with Judge Griffin. These extraordinarily favorable circumstances for the Defendants created reasonable suspicion that they were able to schedule the hearing on short notice directly from Griffin’s chambers. Fedorova suspects this was a joint tactic between the Defendants and the Judge to disorient her by having hearings on short notice, giving her opponents the upper hand.
9.                  On November 19, 2014, Fedorova asked Judge Griffin how her defendants managed to secure a hearing on short notice when his calendar was already filled two weeks in advance. Judge Griffin instantly dismissed Fedorova’s inquiry telling her that he “does not know” how CSVCA#1 got the hearing for 19th. Griffin’s harried reply supported Fedorova’s suspicion that her Defendants are engaged in ExParte communication with Judge Griffin, who placed their Motion on his calendar from the chambers, not from the Clerk.
10.              Griffin continued to act in violation of the law when he ruled in both cases, 14-L-3632 and 14-CH-11573, after Fedorova filed her Notice of Appeal on November 17, 2014, of which Griffin was perfectly aware. Nonetheless, he ordered Fedorova to file a Fourth Amended Complaint in BOTH consolidated cases, even though at that point it should have been the First Consolidated Complaint, and demanded to Answer Case 14-CH-11573 after Fedorova appealed its consolidation with her claim. Such demands from Griffin were made with the intent to sabotage Pro Se Fedorova’s ability to meet his requirements and discourage her from pursuing justice in the case.
11.              On July 17, 2015, Judge John C. Griffin, acting without jurisdiction, ruled in favor of Fedorova’s Defendants in violation of all applicable laws and binding precedents.
12.              Fedorova filed a Petition where she demanded to reconsider Griffin’s decision. On January 20, 2016, Fedorova appeared before Judge Griffin to contest his void orders. During this hearing a court reporter was present. Nearly all of the Defendants were absent, except Continental Casualty insurance Company and Dickler Khan Slowikowski & Zavell Ltd.. This again supported Fedorova’s intuition that Judge Griffin had ExParte communication with her Defendants and informed them about the court reporter present, encouraging them not to attend in order avoid being on official record for this particular hearing. Griffin denied Fedorova’s Petition without any explanations or applicable laws in support, even though many of her defendants had not even showed up to this hearing; and all absent defendants were purportedly represented by ONE lawyer, Paul Sheldon, who was representing insurance Company who covered other defendants’ lawyers legal bills, which was a glaring conflict of interests.
13.              More recently Fedorova has discovered additional evidence that Judge Griffin has multiple personal connections with her defendants’ lawyers, especially with Hinshaw & Culbertson LLP and its partner, Peter Sullivan. Hinshaw & Culbertson LLP represent Chicagoland Community Management in Fedorova’s case.
14.              Fedorova has reason to believe that Judge Griffin’s father, Judge James L. Griffin, and Peter Sullivan’s father, Harold Sullivan, were close friends in their personal and professional circles. Fedorova also believes that Judge Griffin is a relative of lawyer Joseph W. Griffin who was a top partner to Hinshaw & Culbertson LLP. Here again Fedorova sees enough evidence to support Griffin’s recusal from her case for conflict of interest, which Griffin refuses to do.
15.              Furthermore, Judge John C. Griffin failed to disclose his personal connections with his Judge Daniel J. Pierce, who was a major donor to Griffin’s election campaign. Pierce was the first judge in case 14-L-3632 (former 12-L7111) and acted highly prejudiced against ProSe Fedorova when she appeared before him in the court. 
16.              Given Griffin’s unlawful behavior and personal connections, Fedorova is absolutely confident that Judge Griffin fixed her case 14-L-3632 in exchange for monetary compensation commonly known as a bribe, defrauding her of honest services to have her case heard by an unbiased judge.
17.              Fraud upon the court’ is a basis for equitable relief.  Luttrell v. United States, 644 F.2d 1274, 1276 (9th Cir. 1980); see Abatti v. C.I.R., 859 F.2d 115, 118 (9th Cir. 1988)[8]   “It is beyond question that a [.] court may investigate a question as to whether there was fraud in the procurement of a judgment”. Universal Oil Products Co. v. Root Refining Co., 328 U.S. 575 , 66 S.Ct. 1176, 90 L.Ed. 1447.   The power [of the Court] to unearth such a fraud is the power to unearth it effectively. See Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238 , 64 S.Ct. 997, 88 L.Ed. 1250; Sprague v. Ticonic National Bank, 307 U.S. 161 , 59 S.Ct. 777, 83 L.Ed. 1184; and United States v. Throckmorton, 98 U.S. (8 Otto) 61, 25 L.Ed. 93.
15.       Rule 5/2-1401 does not limit a court’s power to redress fraud on the court. The term “fraud on the court” is a nebulous concept. A clear example is the corruption of judicial officersRoot Refining Co. v. Universal Oil Pros Co., 3 Cir., 169 F.2d 514 , 534, cert. denied sub nom. Universal Oil Pros v. William Whitman Co., 335 U.S. 912, 69 S.Ct. 481, 93 L.Ed. 444. [9]
16.       All orders rendered on the basis of those void orders also must be declared void .
17.       Judge Griffin committed fraud upon the Court, acted corrupt and in excess of his subject/matter jurisdiction when he (1) deprived ProSe Fedorova from Due Process and Equal Protection rights [10]; (2) accepted and favorably ruled on defendants’ legally insufficient as a matter of law Motions filed by licensed lawyers without Sworn Affidavits, in violation of 5/1-109; 5/2-605; 5/2-615; 5/2-619; IL S. Ct.R. 191; and F.R. 47 [11](3) ruled on purportedly consolidated cases 14- CH-11573 and 14-L-3632, while case 14-CH-11573 was in Appeal Court [12]; (4) acted partially in favor of his parties of interests; (5) applied double standards of review on ProSe Fedorova vis-à-vis licensed lawyers, for the identical claims; (6) mislead Fedorova about his election donors and his personal interests in defendants and their lawyers; (7) refused to reverse his Opinions and disqualify himself. When a judge acts as a trespasser of the law or does not follow the law, the judge loses subject-matter jurisdiction and the judges’ orders are void, of no legal force or effect.
18       T he trial court’s discretion is not unlimited. “Abuse occurs when a material factor deserving significant weight is ignored, when an improper factor is relied upon, or when all proper and no improper factors are assessed, but the court makes a serious mistake in weighing them.” Independent Oil and Chemical Workers of Quincy, Inc. v. Procter & Gamble Mfg. Co., 864 F.2d 927, 929 (1st Cir. 1988); see also Anderson v. Cryovac, Inc., 862 F.2d 910, 923 (1st Cir. 1988) (to warrant reversal for abuse of discretion, it must “plainly appear[ ] that the court below committed a meaningful error in judgment”). [13] A judge receiving a bribe from an interested party over which he is presiding, does not give the appearance of justice .
19.       Fedorova has proper material evidence that Judges Flannery and Griffin, with aid from ex-Judge Thomas L. Hogan, fixed cases 14-L-3632 Fedorova vs. CCM, et.al and 14-CH-11573 CCM v. Fedorova in favor of corporate defendants, all of whom belong to the sphere of these judges’ personal interests. Fedorova strongly believes that Judges Flannery, Griffin, and Hogan received indirect (election donations or promises for donations) and direct compensation for their favorable decisions for defendants in my case. In other words: they accepted bribes. A breadth of evidence backs Fedorova’s suspicions: public election records; the judge’s incessant deception; unjustified lenience to the defendants’ lawyers; acceptance of legally insufficient motions from defendants’ lawyers; extreme bias against Fedorova  as ProSe [14];  the defendants’ own claims that they have spent a “substantial amounts of money” to dismiss Fedorova’s  case; and judge Hogan’s rapid retirement from the bench after Fedorova’s complaint to FBI.
20.       Fedorova diligently pursued her legal options of vacate void order on consolidation of cases 14-CH-11573 with 14-L-3632 and void judgement entered by Judge Griffin on July 17, 2015 and November 5, 2015, in violation of all applicable laws, including §2-615 and §2-619. [15]
21.       Judges Flannery and Griffin acted from their position of power, repeatedly abused their discretion, acted corrupt and bias against Fedorova, applied double standards; refused to comply with the law or follow due process and equal protection clauses; deprived Fedorova from honest judicial services; fraudulently concealed and/or misled Fedorova about their personal conflicts of interests with defendants; readily accepted legally deficient motions filed by licensed lawyers; and customary ruled in favor of their preferred parties, in disregard of lawyers’ fatal deficiencies in pleadings and defendants’ false and contradicting statements.
22.       Judge Griffin refused to recuse himself despite his flagrant conflicts of interests with Fedorova; and continued to rule in favor of defendants, in the most corrupt and prejudice manner. Defendants were perfectly aware of his decision on November 5, 2015 and came to the hearing with a fully preprinted favorable verdict.
23.       In 1994, the U.S. Supreme Court held that “Disqualification is required if an objective observer would entertain reasonable questions about the judge’s impartiality. If a judge’s attitude or state of mind leads a detached observer to conclude that a fair and impartial hearing is unlikely, the judge must be disqualified.” [Emphasis added]. Liteky v. U.S., 114 S.Ct. 1147, 1162 (1994). [16]  That Court also stated that Section 455(a) “requires a judge to recuse himself in any proceeding in which her impartiality might reasonably be questioned.” [17] Judges do not have discretion not to disqualify themselves. By law, they are bound to follow the law. Should a judge not disqualify himself as required by law,then the judge has given another example of his “appearance of partiality” which further disqualifies the judge. Should another judge not accept the disqualification of the judge, then the second judge has evidenced an “appearance of partiality” and has possibly disqualified himself/herself.
24.       None of the orders issued by any judge who has been disqualified by law would appear to be valid. It would appear that they are void as a matter of law, and are of no legal force or effect.
25.       Should a judge not disqualify himself, then the judge is in violation of the Due Process Clause of the U.S. Constitution. U.S. v. Sciuto, 521 F.2d 842, 845 (7th Cir. 1996) (“The right to a tribunal free from bias or prejudice is based, not on Sec.144, but on the Due Process Clause.”).
26.       The Court specifically emphasized that when litigants rights under the due process clause of both the Illinois and United States Constitutions (US Const., amend. XIV; Ill. Const.1970, art.  I, §2) were violated by the trial court’s actions and”where an error that occurs during a [.] trial impinges upon the integrity of our judicial systemreversal is required “regardless of the weight of the other evidence.” People v. Thomas, 123 Ill.App.3d 857, 867,79 Ill.Dec. 278, 463 N.E.2d 832 (1984); People v. Baynes, 88 Ill.2d 225, 244, 58 Ill.Dec. 819, 430 N.E.2d 1070 (1981).
27.       Judge Griffin’s repetitive refusals to recuse himself from case 14-L-3632 after he had been automatically disqualified by law due to his bias and partiality, constitute judge Griffin’s lack of subject/matter jurisdiction, war against the Constitution, treason and anarchy.
28.       It supports Fedorova’s argument that judge Griffin’s favorable verdicts were procured by fraud upon the Court, corruption and undue influence, commonly known as a bribe.
29.       Fedorova was out of remedy and her only choice was to proceed with Sec. 5/2-1401 Petition to vacate void judgements; and remove bias judge Griffin from case 14-L-3632.
30.       Double standards in the court for judges’ Flannery and Griffin favored litigants are the norm in Fedorova’s case. As mentioned before, Judge Griffin applied the same law differently to the two parties before him when presiding over her case.
31.       After 75 days of intensive search, on July 17, 2015, Griffin dismissed with prejudice Fedorova’s Complaint in case 14-L-3632 (consolidated with 14-CH-11573, both were in Appeal during all this time), in the most bias and discriminatory manner. Judge Griffin advised Fedorova that she cannot expect equal treatment under the law and be fairly heard in his Court because she does not have a lawyer. In other words, Judge Griffin informed Fedorova that if her pleadings had been drafted by a lawyer, the same law would have been applied differently.
32.       Fedorova’s case is not a fluke. Judge Griffin regularly applies the law with double standards [18]. In case 14-L12093 Hesser v. Riviera HOA, Kovitz Shifrin Nesbit P.C., a case similar to Fedorova, but filed by three licensed lawyers, Judge Griffin applied the same law absolutely differently.(Ex.4)  In the case filed by lawyers, Griffin immediately recalled that section 2-603 (c) that requires pleadings to be liberally construed to do substantial justice between the parties. In 14-L-3632 case filed by a ProSe, Griffin solely relied on 2-603 (a) and (b) in which he applied the most adverse options for Fedorova’s pleadings. For the lawyers Judge Griffin also recalled that §2-615 standard for review must be done in the light most favorable for the plaintiff. See also Chicago Association of Realtors [19] and Virginia Downs v. Geller [20], Case 12-L-10003 [21] CAR filed a questionable defamation case, similar to 14-CH-11573 CCM v. Fedorova, which supports Fedorova’s argument that Judge Griffin’s assignment was not an accidental.
33.       Griffin’s standard for review in ProSe Fedorova case was totally opposite. According to Griffin, Fedorova was unable to prove any sets of facts that on October 2011 defendants conspired to collect unlawful debt of $3,614.35 originally fabricated in 2006 at the amount $1,481.12, after the HOA collected $900.00 in consecutive monthly rent for 5 years. In Hesser, Griffin found that the KSN lawyers owed duties to the plaintiff and breached their HOA’s declaration when they engaged in conspiracy with the Board to commit fraud against Hesser. Identical claims in Fedorova’s case were dismissed by Griffin with prejudice in a corrupt manner.   Fedorova’s  FDCPA claim against KSN was ignored in its entirety.
34.       Clearly, Griffin acts with extreme bias against ProSe litigants, with whom he prefers to act under the color of the law; and favors pleadings prepared by politically connected lawyers [22].
35.       Courts have repeatedly held that positive proof of the partiality of a judge is not a requirement, only the appearance of partiality. [23]   Fedorova states that Judge Griffin’s decision must be reversed as originally void due to his partiality, trespasses of the law and application of double standards for review . [24]   When a judge acts as a trespasser of the law or does not follow the law, the judge loses subject-matter jurisdiction and the judges’ orders are void, of no legal force or effect.     Judge Griffin committed intentional tort against Fedorova and intended to culpably oppress and deprive Fedorova from her rights, due administration of justice and equal protection under the law guaranteed by U.S. and Ill. Constitution Art. I, § 12. 
36.       Griffin committed unmitigated crimes punishable under Federal Criminal Code of Conduct 18 U.S.C. 242, deprivation of civil rights acting under colors of law; engaged into a Conspiracy to Interfere with Civil Rights under 42 U.S.C. 1985(3). Griffin  violated  42 U.S.C. 1986, when he neglected  to prevent the wrongs conspired to be done by defendants and its lawyers, as mentioned in section 1983 and 85 of this title , and having power to prevent or aid in preventing the commission of the same, neglected or refuses so to do.  
37.       In Fedorova’s case, the trial court abdicated its role when it favorably ruled on legally insufficient Motion; and entered adverse decisions in purportedly consolidated cases 14-CH-11573 and 14-L-3632 in violation of the law and without subject matter jurisdiction. The job of the trial court is to rule on questions of law, not to grant absolution to attorneys to disregard rules of evidence and civil procedure. “ 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. [25]
38.       The Order to Consolidate case 14-CH-11573 with case 14-L-3632 was obtained in corrupt manner, in violation of applicable laws and perpetrated by fraud, thus a complete nullity and without effect. Herring v. U.S. , 424 F.3d 384, at 386. [26]   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.”   The 7th Circuit stated “ a decision produced by fraud upon the court is not in essence a decision at all, and never becomes final.”
39.        Therefore,   all Orders entered by Judge John C. Griffin in consolidated cases  14-L-3632 and 14-CH-11573 from October 2014 until present time must be vacated as void, and case 14-L-3632 must be reviewed de novo, in accordance with the law and Due Process.   A court does not need subject-matter jurisdiction to vacate a void order; it only needs the inherent power of the court, which every court has, to vacate the void orders issued.  Since this court was without subject matter jurisdiction, this court only had the inherent power to vacate the void orders and judgments as originally void.  
CONCLUSION .
43.       V oid Judgement is one which has no legal force or effect, invalidity of which may be asserted by any person whose rights are affected at any time and at any place directly or collaterally. Fedorova properly petitions this Honorable Court and Judge Griffin to reconsider its decision on June 28, 2017, and vacate his Decision entered on July 17, 2015, approved on November 5, 2015 as void.
44.       Grant Fedorova’s request for Leave to File Amended Complaint in case 14-L-3632 ; to be reviewed de novo by a non-biased judge, who does not have a conflict of interest, and a judge who will act impartially who has enough professional pride to not accept bribes from litigants in his or her courtroom Any other relief.
 
Respectfully  submitted.
Elena Fedorova, ProSe. July 17, 2017
 
 


[1] Motion to vacate an order as void may be brought at any time and is not subject to the two-year limitations  under section 2-1401 . People v. Harvey , 196 Ill. 2d 444, 447, 753 N.E.2d 293, 295 (2001).  
[2] Other donors are real estate developers, insurance companies and well-connected lawyers who regularly appear in Judge Griffin’s Court, like Michael Demetrio, partner at Corboy&Demetrio and husband  of Appeal Court Justice Katherine Rochford; Robert J. Bingle, Corboy &Demetrio partner; Daniel S. Kirschner , Corboy&Demetrio Partner, Daniel Kotin, nephew to Phillip Corboy, former top partner to C&D and President of Chicago Bar Association who are responsible for judicial selections ( Corboy&Demetrio has at least three personal judges in this Court system: Katherine Rochford and Terrance Lavin (former Associate to C&D) in Appeal Court and Eve M. Railly in Municipal Division ; Joseph A. Power, Jr. son of well-connected Judge Joseph A. Power, Judge Griffin’s friend Daniel J. Pierce, who is a well-connected lawyer and former classmate with Justice Thomas E. Hoffman, who is a long time  crony with Edward Burke and his wife, Justice Anne Burke.
 

[4] Madigan regularly places his corrupt cronies to IL benches using his position of public trust.
[5] When in 2009 Griffin became the judge in Chancery Division, he started to deprive IL citizens from civil rights and fix foreclosure cases in favor of big banks. In 2009 Judge Griffin was a defendant in case 09CV5243, Gregory v. Judge Griffinet.al . for his  bias practices in a foreclosure case. Plaintiffs challenged court jurisdiction and alleged violations of Due Process and Equal Protection rights. Plaintiff contended that Defendant judges are involved in conspiracy in violation of 42USC1985, are legislating from the bench, are blatantly disregarding the law.
[6] In 2010 Judge John C. Griffin and his committee defrauded IL Board of election when they concealed in-kind contributions, which resulted in Administrative case 1-AP064.
[7] November 1, 2012. ChicagoLawyer magazine. Anthony McMahon, 44, works within the Coverage Oversight Unit of CNA Insurance. He typically involves himself in the day-to-day coverage issues that arise in the claims offices as well as any coverage litigation that may arise. His areas of concentration are business auto coverage, commercial general liability matters, trucking/transportation claims, municipality coverage matters and international workers’ compensation claims involving the Defense Base Act. He’s been in this position for four years and said he enjoys the variety of cases as well as the challenges they pose.
[8] To show fraud upon the court, the complaining party must establish that the alleged misconduct affected the integrity of the judicial process, either because the court itself was defrauded or because the misconduct was perpetrated by officers of the court. Alexander v. Robertson, 882 F.2d 421, 424 (9th Cir. 1989).
[9] In Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238 , 64 S.Ct. 997, 88 L.Ed. 1250, the Supreme Court extended the concept to a situation where a bogus scientific article was published to affect the outcome of patent litigation. The fabricated article was relied on, at least in part, by the court of appeals in its decision. Hazel-Atlas is an example of fraud which so defiles the court “that the judicial machinery cannot [sic] perform in the usual manner its impartial task of adjudging cases that are presented for adjudication.” Martina Theatre Corp. v. Schine Chain Theatres, Inc., 2 Cir., 278 F.2d 798 , 801, quoting 7 Moore, Fed. P. ¶ 60.33, at 512
[10] Due Process is a requirement of the U.S. Constitution. Violation of the United States Constitution by a judge deprives that person from acting as a judge under the law. He/She is acting as a private 
person, and not in the capacity of being a judge (and, therefore, has no jurisdiction). 
[11] The Court in Yates v. Village of Hoffman Estates, 209 F.Supp. 757 (N.D. Ill. 1962) held that “It is not a judicial function for a judge to commit an intentional tort even though the tort occurs in the courthouse.”
[12] To compare: Law Division Judge Brennan refused to hear any Motions in case 12-L-7111 (renumbered as 14-L-3632) when Fedorova filed interlocutory appeal on Judge Brennan’s Ex Parte Order to Quash Service. Brennan also ordered Fedorova to comply with Law Division Standing Order and reassign case 12-L-7111 after Appeal Court issued a Mandate.  Judge Griffin trespassed the law and acted in excess of his jurisdiction when continued to operate  in Case 14-CH-11573 during pending appeal; and never requested proper reassignment of case 14-CH-11573 from Chancery Division, where the Appeal Court Mandate was recorded, to Law Division, as required under Rule 1.3d and Law Division Standing Order.
[13] In Pfizer Inc. v. Lord, 456 F.2d 532 (8th Cir. 1972), the Court stated that “It is important that the litigant not only actually receive justice, but that he believes that he has received justice.” The Supreme Court has ruled and has reaffirmed the principle that “justice must satisfy the appearance of justice”, Levine v. United States, 362 U.S. 610, 80 S.Ct. 1038 (1960), citing Offutt v. United States, 348 U.S. 11, 14, 75 S.Ct. 11, 13 (1954).
[14]          Judge Griffin systemically apply double standards in his courts, which are always favorable for the parties of his interests , like licensed lawyers and the corporate defendants in Fedorova’s  case.
[15] Her attempts included but not limited to(1) Motion for Rehearing on consolidation (denied by Judge Flannery on October 20, 2014); (2) Motion to Deconsolidate (Sever) case 14-CH-11573 [15] and request for Judicial Opinion (denied by Judge Solganick without explanations on November 3, 2014); (3) Notice of Appeal final  Order on Consolidation of  case 14-CH-11573, filed on November 17, 2014); (4) Motion for Reconsideration (denied by Judge Griffin on November 5, 2015); (5) Petition  to Substitute Judge Griffin for Cause (denied by Judge Sherlock on August 17, 2015); (6) Rehearing on Petition to vacate (denied by Judge Flannery on October 9, 2015); (7) Complaint for Mandamus (filed on October 13, 2015, case 15-CH-15013); (7) Petition to Vacate Void Order on Consolidation in case 14-CH-11573 (Judge Flannery refused to hear on January 26, 2016, unlawfully consolidated case 14-CH-11573 with 15-CH-11727 and passed Fedorova’s Motion to prove jurisdiction to Chancery Judge Cohen).
[16] Courts have repeatedly held that positive proof of the partiality of a judge is not a requirement, only the appearance of partiality. Liljeberg v. Health Services Acquisition Corp., 486 U.S. 847, 108 S.Ct. 2194 (1988) (what matters is not the reality of bias or prejudice but itsappearance); US v. Balistrieri, 779 F.2d 1191 (7th Cir. 1985) (Section 455(a) “is directed against the appearance of partiality, whether or not the judge is actually biased.”) (“Section 455(a) of the Judicial Code, 28 U.S.C. §455(a), is not intended to protect litigants from actual bias in their judge but rather to promote public confidence in the impartiality of the judicial process.”).
[17] Taylor v. O’Grady , 888 F.2d 1189 (7th Cir. 1989).  Further, the judge has a legal duty to disqualify himself even if there is no motion asking for his disqualification. The Seventh Circuit Court of Appeals stated that “We think that this language [455(a)] imposes a duty on the judge to act sua sponte, even if no motion or affidavit is filed.” US v. Balistrieri, 779 F.2d 1191 (7th Cir. 1985) at 1202.
[18] In 2009 Judge Griffin was a defendant in case 09CV5243, Gregory v. Judge Griffinet.al . for his  bias practices in a foreclosure case. Plaintiffs challenged court jurisdiction and alleged violations of Due Process and Equal Protection rights. Plaintiff contended that Defendant judges are involved in conspiracy in violation of 42 USC1985, are legislating from the bench, are blatantly disregarding the law.
[19] Represented by Holland & Knight LLP, a global law firm with more than 1,100 lawyers in 24 U.S. offices.
[20] Represented by solo-practitioner Donald C. Battaglia, 5543 W. Diversey Ave.  Chicago, IL 60639
[21] Judge Griffin ruled: “Plaintiffs are NOT required to prove their case in the pleading stage. They merely are required to ALLEGE sufficient facts to state all the elements which are necessary to constitute each cause of action in their complaint”. A 2-615 Motion to dismiss should not be granted unless no sets of facts could be proven that would entitled the plaintiff to relief.”
[22] The Chicago Association of Realtors (“CAR”) and its CEO have settled (read: dropped) a defamation suit against Geller, under very questionable circumstances. Apparently, CAR lawyers were not able to prove any sets of facts against Geller, despite Judge Griffin’s favorable findings.  Geller’s lawyer Battaglia said CAR had agreed to dismiss its case against Geller as part of a settlement, but declined to discuss the terms of the settlement.
[23] Liljeberg v. Health Services Acquisition Corp ., 486 U.S. 847, 108 S.Ct. 2194 (1988) (what matters is not the reality of bias or prejudice but its appearance); United States v. Balistrieri, 779 F.2d 1191 (7th Cir. 1985) (Section 455(a) “is directed against the appearance of partiality, whether or not the judge is actually biased.”) (“Section 455(a) of the Judicial Code, 28 U.S.C. §455(a), is not intended to protect litigants from actual bias in their judge but rather to promote public confidence in the impartiality of the judicial process.”).
[24] People V. Gersch , 135 Ill. 2d 384, 553 N.E 2d 281 (1990); Agricultural Transp. Ass’n v. Carpentier, 2 Ill. 2d 19, 116 N.E. 863 (1963). Any act contrary to the above would be an action without lawful authority, a violation of the constitution and the judge’s oath. A judge has no discretion to engage in a war against the Constitution. Cooper v. Aaron, 358 U.S. 1, 78 S. Ct. 1401 (1958). The judge would be acting without subject-matter jurisdiction, and as stated below, would be engaged in an act of treason. US v. Will , 449 US 200, 216, 101 S. ct. 471, 66 L. Ed. 2d 392, 406 (1980); Cohens v. Virginia, 19 U.S. (6 Wheat) 264, 404, 5 L. Ed. 257 (1821).    In People v. Lambert, Case   2-94-1326the Appellate Court of IL, (1997, 2nd Dist.) held: a judge’s “ failure to enforce the law invites anarchy.”
[25] 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 ).
[26] “This rule does not limit the power of a court to entertain an independent action to relieve a party from a judgment, order, or proceeding, or to grant relief to a defendant not actually personally notified as provided in Title 28, U.S.C., § 1655, or to set aside a judgment for fraud upon the court.” Rule 60(b).

 

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One thought on “From EF – Speaking out against corruption re: Madigan, Burke,etc. It’s time for a change

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