THE ILLINOIS APPELLATE COURT,  FIRST DISTRICT

In the Circuit Court of Cook County, Illinois

Caroline P. Moore                                                         

CPM Foundationn                                                                Appeal from Cook County

Plaintiffs-Apppellants                                                            Circuit Court No.  02 L 002237

          V

John B. Cashion, et al                                                         Appellate Court No. 03-967

Defendants- Appellees                                            Trial Judge Judge J. Casciato                                                                                                                                                                  

 

Abbreviated Motion Title

Co-plaintiff-appellant CPM Foundation’s Verified Motion, 1.) to Move the Appellate Court to Accept the Transmission of  the  Trial Court Record on Appeal in Appeal No. 03-967 to the Appellate Court and to Permit the Filing of  Such Record Out of  Time and Instanter on 7/22/03; and  for Several Other Forms of  Relief

Complete Motion Title

Co-plaintiff-appellant CPM Foundation’s Verified Motion to Move the Appellate Court, 1.) to Accept the Transmission of  the  Trial Court Record on Appeal in Appeal No. 03-967 to the Appellate Court and to Permit the Filing of  Such Record Out of  Time and Instanter on 7/22/03; 2.) to Issue an Order Directing the Clerk of  the Circuit   Court of  Cook County to Prepare a Supplemental Record on Appeal in this Case, With Inclusion of  Some Acceptable Contingency in the Case that the Defendants Will not Cooperate in Stipulating to the Contents of  that Record, 3.) to   Provide Confirmation that it has been Provided Notice of    the Commitment of Co-plaintiff-appellant CPM Foundation to Implement What is Apprehended by CPM Foundation (“CPMF”) to Constitute the Totality of  the Rest of  the Measures Necessary to Get the Appeal to Its Briefing Stage  Before the End of  the Week Ending 8/9/03 in Any Scenario, Including a Conjectural Worst Case Scenario, Unless the Proceedings in Regard to the Preparation of  the Supplemental Record Cannot be Completed by Then,  4.)  to Provide Confirmation that it has been Provided Notice that CPM Foundation Will not,  under Any Arrangement of Circumstances, Accept any Illegitimate,  or Not Presumptively Non-counterfeit and/or Non-criminal  Resolution of  the Entities at Issue in this Appeal and  5.) to Provide, Correlative to the Provision of  the Relief Sought in #4.) supra, Confirmation that the Members of  the Appellate Court Panel Assigned to this Case  Will Require Themselves  to Conduct Whatever Activity Needs to Be Conducted to in This Case, According to Acceptable Standards so as to Avoid the  Replication of   the Obviously Counterfeit,  Appallingly Offensive, Fatally Defective,  Egregiously Unjust, Not-presumptively Non-malicious and Non-Criminal, and Tragically Socially Destructive, Approach  - to the “What is Made to Appear to Constitute”  Resolution  of  Matters Involving Parties of  Vastly Disparate Economic and Political Positions as was and is the Case in this Lawsuit in the Sham Proceedings Conducted in Regard Thereto in the Trial Court (That Evidently is the Approach that is Non-atypically  Employed in the Illinois Court System in this Geographical Area at This Juncture in Time, in Cases Involving Parties of  Such Disparate Positions)  - of  the Affirmative Implementation of  Measures for Purposes of  Preventing  the Financially and Politically Less-favorably Positioned Party in a Given Dispute from Superimposing the Structure Onto and Into a Given Adjudication That Would Have to Be Superimposed in a Given Case in Order to Prevent Any  Malice and Criminality that Has Been Present and Recognized in Such Given Case, from Being Left Un-identified, Un-ensconced, Un-educed, and Un-eliminated -  Which Type Approach, by Its Implementation in the Trial Court Proceedings in This Case, Naturally, Acted as  a  Proximate Cause of  the Damages Which has Resulted in this Appeal Having to Have Been Filed in the First Place, so that no more Harm be Caused, or Correlative Monetary or  Criminal Liability be Incurred, by Any Entity in The Adjudication of  This Case Than the Comparative Enormity of  That Which, at This Juncture,  Has Already Been Caused and Incurred and is Already Present in It, and, that 6.) Correlative to the Relief Sought in #’s 4 & 5 supra, that the Court Will Confirm that It Has Been Provided Notice that the CPM Foundation, Because There is no Evident Choice in the Matter, Will Prosecute this Appeal as it Must Prosecute Any Matter – According to a Non-counterfeit Standard that Requires  the Consideration of  All Matters Against the Backdrop of  the Provisions of  Title 18 of  the United State’s Code, Within the Context of  the Provisions of  the Constitutions of  the State of  Illinois and of  the U.S. of  A., Whose Establishing Document was  of  Course the Declaration of  Independence, the Establishing Document of  Which  was the Magna Charta and of  the Provisions Contained in Canon 2200.1 of  the 1917 Code of  Canon Law of  the Roman Catholic Church Which Addresses the Issue of  the Conditions in Which Malice Must Be Presumed in the Consideration of  the Moral Legitimacy or  Lack Thereof  of  any Moral Act and of  the Incontrovertible Logical Principle Known as the Principle of Non-contradiction, and, that 7.) the Court Confirm that It Will Ensure that Any Judge  Who is not, at a Bare Minimum, Categorically Opposed to Any and Every Possible Type of Abortion be Kept Off of  Whatever Panel Would Be Assigned to This Case so That if  What Happens in the Appellate Court in the Adjudication of  This Case is a Replication of  What Happened in the Trial Court in it (ie Another Miscarriage of  Justice), that Such Development Would not Be Imputable to Any Non-endeavor Imputable to CPMF to Keep Judges Who are Obviously Patently Unfit to Exercise Authority Off of  the Case, and that  8.) This Court  Stay the Briefing Schedule in This Case Until CPMF Can Get the Structure Superimposed on the Processing of  the Proceedings that it must be Presumed must be Superimposed in Order for Any Legitimate Decision(s) to be Rendered in this Appeal, 9.) that the Court Confirm that it has been Provide Notice that the CPMF will Submit Both an Amended Notice of  Appeal and a Docketing Statement Before the End of  the Week Ending 8/9/03 if  the Defendants will not just Settle This Case Before Then, and  Finally, that 10.) This Court Confirm that the Filing of  This Motion Constitutes for the Time Being, the CPMF’s Declaration of  No Legitimacy, No Finality, No Consent to Any Duty Breach or Crime, Non-abandonment of  Claims/Retention of  All Claims for Resolution in Whatever Forum They Must Ultimately be Resolved in, at this Juncture in the Proceedings.

 

 

NOW COMES THE  Co-plaintiff-appellant CPM Foundation, through its representative for purposes of  this motion, Robert J. More (“RJM”) (CPMF apologizes for the capitalizations used in the introduction and prayer for relief in this motion, but time constraints did not permit an adequate editing to remove them), to Move the Appellate Court, 1.) to Accept the Transmission of  the  Trial Court Record on Appeal in Appeal No. 03-967 to the Appellate Court and to Permit the Filing of  Such Record Out of  Time and Instanter on or before 7/24/03; 2.) to Issue an Order Directing the Clerk of  the Circuit   Court of  Cook County to Prepare a Supplemental Record on Appeal in this Case, With Inclusion of  Some Acceptable Contingency in the Case that the Defendants Will not Cooperate in Stipulating to the Contents of  that Record, 3.) to   Provide Confirmation that it has been Provided Notice of    the Commitment of Co-plaintiff-appellant CPM Foundation to Implement What is Apprehended by CPM Foundation (“CPMF”) to Constitute the Totality of  the Rest of  the Measures Necessary to Get the Appeal to Its Briefing Stage  Before the End of  the Week Ending 8/9/03 in Any Scenario, Including a Conjectural Worst Case Scenario, Unless the Proceedings in Regard to the Preparation of  the Supplemental Record Cannot be Completed by Then,  4.)  to Provide Confirmation that it has been Provided Notice that CPM Foundation Will not,  under Any Arrangement of Circumstances, Accept any Illegitimate,  or Not Presumptively Non-counterfeit and/or Non-criminal  Resolution of  the Entities at Issue in this Appeal and  5.) to Provide, Correlative to the Provision of  the Relief Sought in #4.) supra, Confirmation that the Members of  the Appellate Court Panel Assigned to this Case  Will Require Themselves  to Conduct Whatever Activity Needs to Be Conducted to in This Case, According to Acceptable Standards so as to Avoid the  Replication of   the Obviously Counterfeit,  Appallingly Offensive, Fatally Defective,  Egregiously Unjust, Not-presumptively Non-malicious and Non-Criminal, and Tragically Socially Destructive, Approach  - to the “What is Made to Appear to Constitute”  Resolution  of  Matters Involving Parties of  Vastly Disparate Economic and Political Positions as was and is the Case in this Lawsuit in the Sham Proceedings Conducted in Regard Thereto in the Trial Court (That Evidently is the Approach that is Non-atypically  Employed in the Illinois Court System in this Geographical Area at This Juncture in Time, in Cases Involving Parties of  Such Disparate Positions)  - of  the Affirmative Implementation of  Measures for Purposes of  Preventing  the Financially and Politically Less-favorably Positioned Party in a Given Dispute from Superimposing the Structure Onto and Into a Given Adjudication That Would Have to Be Superimposed in a Given Case in Order to Prevent Any  Malice and Criminality that Has Been Present and Recognized in Such Given Case, from Being Left Un-identified, Un-ensconced, Un-educed, and Un-eliminated -  Which Type Approach, by Its Implementation in the Trial Court Proceedings in This Case, Naturally, Acted as  a  Proximate Cause of  the Damages Which has Resulted in this Appeal Having to Have Been Filed in the First Place, so that no more Harm be Caused, or Correlative Monetary or  Criminal Liability be Incurred, by Any Entity in The Adjudication of  This Case Than the Comparative Enormity of  That Which, at This Juncture,  Has Already Been Caused and Incurred and is Already Present in It, and, that 6.) Correlative to the Relief Sought in #’s 4 & 5 supra, that the Court Will Confirm that It Has Been Provided Notice that the CPM Foundation, Because There is no Evident Choice in the Matter, Will Prosecute this Appeal as it Must Prosecute Any Matter – According to a Non-counterfeit Standard that Requires  the Consideration of  All Matters Against the Backdrop of  the Provisions of  Title 18 of  the United State’s Code, Within the Context of  the Provisions of  the Constitutions of  the State of  Illinois and of  the U.S. of  A., Whose Establishing Document was  of  Course the Declaration of  Independence, the Establishing Document of  Which  was the Magna Charta and of  the Provisions Contained in Canon 2200.1 of  the 1917 Code of  Canon Law of  the Roman Catholic Church Which Addresses the Issue of  the Conditions in Which Malice Must Be Presumed in the Consideration of  the Moral Legitimacy or  Lack Thereof  of  any Moral Act and of  the Incontrovertible Logical Principle Known as the Principle of Non-contradiction, and, that 7.) the Court Confirm that It Will Ensure that Any Judge  Who is not, at a Bare Minimum, Categorically Opposed to Any and Every Possible Type of Abortion be Kept Off of  Whatever Panel Would Be Assigned to This Case so That if  What Happens in the Appellate Court in the Adjudication of  This Case is a Replication of  What Happened in the Trial Court in it (ie Another Miscarriage of  Justice), that Such Development Would not Be Imputable to Any Non-endeavor Imputable to CPMF to Keep Judges Who are Obviously Patently Unfit to Exercise Authority Off of  the Case, and that  8.) This Court  Stay the Briefing Schedule in This Case Until CPMF Can Get the Structure Superimposed on the Processing of  the Proceedings that it must be Presumed must be Superimposed in Order for Any Legitimate Decision(s) to be Rendered in this Appeal, 9.) that the Court Confirm that it has been Provide Notice that the CPMF will Submit Both an Amended Notice of  Appeal and a Docketing Statement Before the End of  the Week Ending 8/9/03 if  the Defendants will not just Settle This Case Before Then, and  Finally, that 10.) This Court Confirm that the Filing of  This Motion Constitutes for the Time Being, the CPMF’s Declaration of  No Legitimacy, No Finality, No Consent to Any Duty Breach or Crime, Non-abandonment of  Claims/Retention of  All Claims for Resolution in Whatever Forum They Must Ultimately be Resolved in, at this Juncture in the Proceedings. to

 

 

 

Move this Appellate Court, 1.) to Accept the Transmission of  the  Trial Court Record on Appeal in Appeal No. 03-967 to the Appellate Court and to Permit the Filing of  Such Record Out of  Time and Instanter on 7/22/03; 2.) to Issue an Order Directing the Clerk of  the Circuit   Court of  Cook County to Prepare a Supplemental Record on Appeal in this Case and 3.) to   Provide Confirmation that it has been Provided Notice of    the Commitment of Co-plaintiff-appellant CPM Foundation to Implement What is Apprehended by CPM Foundation (“CPMF”) to Constitute the Totality of  the Rest of  the Measures Necessary to Get to the Briefing Stage of  this Appeal Before the End of  the Week Ending 7/27/03 in Any Scenario, Including a Conjectural Worst Case Scenario, 4.)  to Provide Confirmation that it has been Provided Notice that CPM Foundation Will not,  Under

Any Arrangement of Circumstances, Accept any Illegitimate,  or Not Presumptively Non-counterfeit and/or Non-criminal  Resolution of  the Entities at Issue in this Appeal and  5.) to Provide, Correlative to the Provision of  the Relief Sought in #4.) supra, Confirmation that the Members of  the Appellate Court Panel Assigned to this Case  Will Require Themselves  to Conduct Whatever Activity Needs to Be Conducted to in This Case, According to Acceptable Standards so as to Avoid the  Replication of   the Obviously Counterfeit,  Appallingly Offensive, Fatally Defective,  Egregiously Unjust  and Not-presumptively Non-malicious and Non-Criminal Approach  - to the “What is Made to Appear to Constitute”  Resolution  of  Matters Involving Parties of  Vastly Disparate Economic and Political Positions as was and is the Case in this Lawsuit (That Evidently is the Approach that is Non-atypically  Employed in the Illinois Court System in this Geographical Area at This Juncture in Time, in Cases Involving Parties of  Such Disparate Positions)  - of  the Affirmative Implementation of  Measures for Purposes of  Preventing  the Financially and Politically Less-favorably Positioned Party in a Given Dispute from Superimposing the Structure Onto and Into a Given Adjudication That Would Have to Be Superimposed in a Given Case in Order to Prevent Any  Malice and Criminality that Has Been Recognized in Such Given Case, from Being Left Un-identified, Un-ensconced, Un-educed, and Un-eliminated, Which Type Approach, by Its Implementation in the Trial Court Proceedings in This Case, Acted as  a  Proximate Cause of  the Damage Which has Resulted in this Appeal Being Filed in the First Place, so that no more Harm be Caused, or Correlative Monetary or  Criminal Liability be Incurred, by Any Entity in The Adjudication of  This Case Than the Comparative Enormity of  That Which, at This Juncture,  Has Already Been Caused and Incurred and is Already Present, and, that 6.) Correlative to the Relief Sought in #’s 4 & 5 supra, that the Court Will Confirm that It Has Been Provided Notice that the CPM Foundation, Because There is no Evident Choice in the Matter, Will Prosecute this Appeal as it Must Prosecute Any Matter – According to a Non-counterfeit Standard that Requires  the Consideration of  All Matters Against the Backdrop of  the Provisions of  Title 18 of  the United State’s Code, Within the Context of  the Provisions of  the Constitutions of  the State of  Illinois and of  the U.S. of  A., and of  the Provisions Contained in Canon 2200.1 of  the 1917 Code of  Canon Law of  the Roman Catholic Church Which Addresses the Issue of  the Conditions in Which Malice Must Be Presumed in the Consideration of  the Moral Legitimacy or  Lack Thereof  of  any Moral Act and of  the Incontrovertible Principle of Non-contradiction, and that 7.) the Court Confirm that It Will Ensure that Any Judge  Who is not, at a Bare Minimum, Categorically Opposed to Any and Every Possible Type of Abortion be Kept Off of  Whatever Panel Would Be Assigned to This Case so That if  What Happens in the Appellate Court in the Adjudication of  This Case is a Replication of  What Happened in the Trial Court in it, that Such Development Would not Be Imputable to Any Non-endeavor Imputable to CPMF to Keep Judges Who are Obviously Patently Unfit to Exercise Authority Off of  the Case and Finally, 8.) that the Court Confirm that the Filing of  This Motion Constitutes for the Time Being, the CPMF’s Declaration of  No Legitimacy, No Finality, No Consent to Any Duty Breach or Crime, Non-abandonment of  Claims at this Juncture in the Proceedings, and in support and explanation whereof, CPMF through its representative for purposes of this motion, Robert J. More, avers and explains as follows:

1. One of  the issues that has borne the most influence in the prosecution of  this case since it was first filed and indeed bore the most influence in the conducting of   the activities that resulted in its having to have been filed in the first place is the physical and mental condition of  the Co-plaintiff Caroline P. More (“CPM”) , who is a disabled chronic pain patient, whose life cycle basically has consisted over the years since she was first injured by a battery over ten years ago of  disabling, and according to her accounts -  in regard to which there exists a superabundance of  corroborating evidence, frequently, excruciating pain and of  the disabling effects of  the pain medication which she has had to cyclicly take to enable her to cope with this pain.

2. Given this medical condition, the fact that CPM is a single woman and is unable to work, has to live in Wisconsin in order to obtain medicines and treatment at less cost than she claims would be the case were she to live in Illinois, and other factors,  it is understandable that she would be subject to the temptation to be intimidated by several of  the entities and individuals who have played a role in the activities which have resulted in this appeal’s having to have been filed.

3. Further, given the present lamentable condition of  the Courts in Cook County,  Illinois, it is all the more understandable why she would be so strongly tempted to permit herself to be intimidated even into altogether conceding her constitutionally protected inalienable rights and liberties. Pro ses throughout the County have come to realize that just as Jack Richmond ended up paying the ultimate price for the exercise of  what were supposed to constitute constitutionally protected rights and liberties (cf. Richmond v Sheahan, 270 F. 3d 430 -  unarmed, physically disabled, pro se dies from Court ordered attack by sheriff’s deputies in Skokie Court Building for asking a question, without an answer to which, he would have been unable to defend his legitimate interests, on a traffic ticket), that they too may end up incurring the type of  consequences of  the wrath of the type of  authority-abusing tyrants, despots, criminals, violence-perpetrators and  iniquity-workers that have throughout human history, abused the authority of  their respective  offices, “thrown their weight around”, and subjected those so unfortunate as to not have succeeded in avoiding these types, in (a) given case(s), to the abuses, heavy-handedness, crimes and violence perpetrated under the color of  law, with which so many burden-bearing citizens in Cook County have by now come to be so familiar (Prov. 29:2 “When the wicked rule, the people suffer.”).

4. In a social setting in which the conduct of  the vast majority of  those licensed to practice law in this area, would  evidently render them thoroughly deserving of  the rebuke Jesus so emphatically issued to lawyers in the Gospels (cf. Mt. 23:23-36, Luke 11:37-46, et al), it is made even further understandable why a pro se in the circumstances of  Caroline More (“CPM”) would end up so afraid of  them all, that she would be unable to resist the temptation to just give up the opposition an able-bodied person would be obliged to impose against  these cretin-reptile, iniquity-working malefactors of  society.

5. The villains &/or criminals in this case, the original derelict Attorney and tortfeasor Corboy who inflicted a battery on the Plaintiff in the fiduciary relationship, subsequent derelict Attorney and tortfeasor Cashion who would not file a claim against Corboy and who defamed Plaintiff, derelict Attorney and tortfeasors Donald Brown, Charles Harper who corrupted the proceedings in this case in the trial court, and derelict Judge Joseph Casciato, who as a judge, conducted his activity in the role of  the advocate of  the deep-pocketed tortfeasors in using every means at his disposal to implode the Plaintiff’s case, howsoever many torts and crimes he had to commit to accomplish the objective;  have certainly ganged up like the cowardly bullies they are to scare the diminutive CPM right out of  her rights.

6. Providentially, God has left the aspirant to the title “Dragon-slayer” or at least more realistically “Brother - not categorically devoid of  any redeeming qualities”, Robert J. More, CPM’s brother, in a position in which he can, ala Daniel in Chapter 13 of  the Book of  Daniel, prevent these iniquity workers from perpetrating their evils and crimes with impunity.

7. The inclusion of  these  introductory paragraphs in this motion has been  necessitated by the deceitfulness and cut-throatedness of  the Defendant-appellees who it must be anticipated are going to modify thresholds, fabricate deceptions, redefined terms, present arguments consisting of  unjustified presumptions, invalid premises, logically fallacious reasoning processes, and inaccurate and untruthful presentations of  factual predicates as well as implement  assorted other presumptively malicious and criminal  ruses, artifices, and subterfuges in order to accomplish the objective of ensuring that this appeal is decided upon something other than what can be identified to constitute a legitimate basis.

8. Since the CPMF is  prosecuting this appeal on the No legitimacy, no finality, no consent – explicit or implicit - to any duty breaches or  crimes, non-abandonment of  moral claims to the property at issue basis, no entity will accomplish anything by conducting any activity in this adjudication according to the Reign of  Terror Standard (cf http://www.geocities.com/thirstforjustice/rolrotup ), which is the standard according to which it was adjudicated in the Trial Court, except to bring more trouble and cost upon him, her or it-self.

9. The matters involved in this appeal will be resolved, according to a standard God will presumably recognize and accept, in one forum or  another. Hopefully, they will not have to be resolved in the type of  forum in which the inalienable rights secured and/or recovered at Runneyemede England in 1215 A.D.  and again at Lexington MA, in 1775, and repeatedly thereafter  at places with names like Appomatox VA, and Chateau Thierry and Normandy France, and Okinawa Japan, among other places, were secured and recovered. Nonetheless, RJM is not one who is willing to abdicate the grave duty imposed by God’s moral law in cases in which  there is no other method by which violence can be  prevented, or  retribution acceptably accomplished in  a given case than to utilize the minimal force necessary in a given case to  ensure that violence and criminality not remain unjustifiably unopposed   and  that crimes committed not remain unpunished according to the historically time-and-again proven axiom “Qui Parcit Nocentibus, Punit Innocentes”.

10. So that CPMF can obtain a sanction if  Defendant Cashion endeavors to claim either that the CPMF is not a party in this appeal or that RJM cannot represent CPM in the appeal or to make any other such-type sham claim for purposes of  keeping RJM out of  this appeal - so as to enable  the shameless, ruthless criminal-villians in this case to succeed in  cannibalizing the essentially defenseless CPM -  which would be one of  the issues in regard to which the appeal has been filed in the first place, which would require CPMF to present a response thereto; it is herein claimed that no measure implemented by Cashion upon whatsoever pretext to keep RJM out of  the adjudication of  this appeal could possibly be presented to this Court in good faith.

11. If  Cashion’s knave representatives can spell the word “tautology” they might succeed in finding the definition of  that polysyllabic substantive in a dictionary, and if it is not too big a word for these individuals who have proved themselves to be such very, very, very, very  small and niggardly specimens, they might come to acknowledge or at least recognize that the types of  ploys they implemented in the trial court proceedings in their desperate attempt to derail CPM’s and CPMF ’s eminently meritorious claims in this case such as that of  inserting the conclusion of  a syllogism into its  main premise and then circuitously reasoning back into it, in categorical disregard of both all competent evidence incompatible with that upon which they proceed and of  the most fundamental rules of logic is not only not “nice” to utilize the nauseating terminology Cashion customarily employs himself, but is not a non-malicious and non-criminal method by which to conduct litigation in any court in this country (cf. 18 U.S.C. 241, 242, 1503, 1961 et seq. 2381) and that if  such type or similar method would be employed by Cashion in this appeal, that the CPMF would have to seek sanctions for such-type conduct.

12.    On Thursday 5/29/03, RJM on behalf of  the CPMF requested the Record on Appeal from the Clerk of  the Circuit Court of Cook County, in order to ensure its presentation to the appellate court by May 30, 2003 which was the date it was originally due.

13.    The clerk who responded to RJM’s request informed him that an extension of time in which to prepare the record had been issued in the case and that the record at that juncture had to be presented to the appellate court by 7/18/03.

14.    RJM did not obtain all the details as to the whats  or whys of why  this had occurred. He only responded to the information he received at that juncture and then when reviewing the record explained to that clerk that there were numerous documents appropriately filed by RJM on behalf of  the CPMF on 3/28.03 that were not at that time included in the record, that ought to have been included.

15.    Pursuant to the information RJM received from the attendant clerk in the Room 801 of the Daley Center on 5/29/03 regarding the availability of  the record on appeal and the Appellant’s duty to present it to the appeal’s court, RJM obtained and delivered to the Illinois Appellate Court, First District Office, at 160 N. LaSalle St. Chicago, Suite 1400, a copy of  Record on Appeal in Appeal No. 03-967, on 7/18/03.

16.    The Appellate Court Clerk informed RJM on 7/18/03 that she could not accept the record on that date without a motion to file it out of time and instanter since it had originally been due on 5/30/03, notwithstanding RJM’s explanation on behalf of  CPMF that the deadline for such transmission of  the record had been modified without CPMF’s knowledge in the matter. This document constitutes such motion.

17.    Since there are numerous documents in the Circuit Court file for Case No. 02 L 2237 that are not now in the Record on Appeal in this case, including the several documents filed by CPMF on 3/28/03 (the last day before the Trial Court lost jurisdiction over the case)  and since the transcripts for the hearings held in the case on 3/24/03 and 3/28/03 and the bystander’s reports for the hearings held on 9/25/02, 12/06/02, 1/23/03, 2/26/03, and 3/26/03 and 3/27/03 must all be added to the record in order for the entities in issue to be adequately addressed by this Court rather than summarily disregarded as so often  occurs in pro se cases to the incalcuable loss, grief and affliction of  the individual victims of  such egregious injustices and the ruin of  what has not already been destroyed of  the social order, and in order that the moral claims to property in the form of monetary damages of CPM and the CPMF be preserved regardless of what occurs in this appeal or in any other adjudication for that matter, the CPMF must herein move this Court to order the Clerk of  the Circuit Court of Cook County to prepare a supplemental record in this case, a proposed  exact enumeration of  the contents of which would be presented to this Court and the Defendants if  the Supplementary Record on Appeal cannot be prepared without such process being employed, shortly, but  in any case, before the end of  the first week of  August, 2003.

18.    recuse counsel

Stay the briefing schedule until CPMF can get the structure superimposed on the processing of  the proceedings that it must be presumed must be superimposed in order for any legitimate decision(s) to be rendered in this appeal – obviou- Court cannot in a manner compatible with requirements of  18, & const of  U.S. and IL

19.     

 

                                                  Civil

No appeal has been filed prior to this one, nor is any pertaining to the same matter pending in this court.

 

Counsel on Appeal:

For Appellant Caroline P. More: Caroline P. More, P.O. box 301, Monticello, WI 53570, 608 938-1333

For Appellant CPM Foundation: Nonattorney Robert More 2008 S. Blue Island, Chicago, IL 60608, 312 455-8385

For Appellees (both demonic and human): Charles Harper, Donald Brown, Donohue, Brown, Matthewson & Smyth, 140 S. Dearborn St. Chicago, IL 60603

Court Reporter:

Official Court Reporters

Ninth Floor

51 W. Washington St.

Chicago, IL 60601

McCorkle Court Reporters

Transcripts to be prepared – one half  hour hearing for 3/24/03 - McCorkle and one hour for 3/28/03 Official Court Reporters

 

Nature of the Case:

Order    x

Personal Injury  x

Tort  x

Time permitting, the contract aspect of  the case may be argued, as may some of  the presumptively more serious problems with the present condition of the local courtroom in which the case was handled at the trial level.

 

Brief description of the Nature of the Case and the Result in the Trial Court;

Plaintiff was injured by numerous breaches of identifiable and legally cognizable duties of the defendants by the defendants, and by numerous tortious acts committed by  the defendants. He filed a complaint for breach of contract, breach of various types of duties and for tortious acts; filing it with the most general terminology permissible without risking having it dismissed for failure to state a cause of action upon which relief can be granted. In June of 1999, the denial of records sought by plaintiff, in the possession of the defendant, needed by plaintiff, set case up for the problems that would ensue, by  rendering plaintiff unable to voluntarily dismiss the case with leave to refile within one year. Other unjustified decisions of the trial court, set the stage for the altogether unjustifiable granting of  the defendants’ Motion for Summary Judgment on 5/5/2000 and the subsequent denial of the plaintiff’s Motion to Reconsider on 8/9/2000.

 

General Statement of  Issues Proposed to be Raised:

1.                  Did the Circuit Court err in the granting of  Summary Judgment against plaintiff when conditions necessary for such granting were not present and in denying the plaintiff’s corresponding Motion to Reconsider, 2.  Did the Circuit Court err in denying the motion to strike the affidavit made in bad faith and  to not grant that motion and the relief sought therein, 3. Did the Circuit Court err in denying the plaintiff’s Motion to Re-amend the Amended Complaint, 4.  Did the Circuit Court err in denying the motion to impose sufficient structure on the Oral Hearing on the MTR of  that day, 6. Can the Appellate Court justify not implementing whatever measures must be implemented to ensure that neither plaintiff nor any future pro-se plaintiffs are ever again denied either directly or constructively/indirectly his/her/their procedural due process rights nor his/her/their Seventh Amendment Right to a Jury Trial in matters concerning more than $20.00, and to ensure that in the future pro se litigants are not subject to the types of vilification and constructive defamation to which this litigant has been subject, 7. Did the Circuit Court err in refusing the plaintiff access to the records of  the other drivers enumerated in  his original demand for production of  documents back in June of 1999  which he was denied on the grounds that there is a privacy privilege on records which are already public documents and upon which the names had already been redacted.

I  Robert J. More, a pro se appellant, hereby certify that on 9/8/2000, I asked the clerk of the Circuit Court to prepare the record on appeal, and on 9/21/2000, I  petitioned the trial court for a copy of the transcript of  the Oral Hearing held on 8/9/2000.

Date: 9/22/2000        __________________________________

                                                Appellant pro se

I hereby acknowledge that I have exercised considerable diligence to understand all compliance requirements regarding the docketing statement, and that as far as I can ascertain, there is nothing lacking in this docketing statement, and that if it should ever be found to be that there is; that I will promptly do what ever I am instructed it is necessary to do to accomplish constructive compliance with all requirements.

 

 

 

 

 

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