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.