**the following posting is experiencing problems which are
being worked; and for some reason this post keeps being a
problem
////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////

RATHER THAN ALLEGIANCE TO ETHICS, loyalty to personalities has
become a repelling social snare in New Orleans. Ill-placed loyalty
promotes charlatans, extortion, incompetence, cronyism, misuse of
public funds, addictions, and savagery. However even some
allegiants are clamoring for reformation of the New Orleans
“banana republic.”

Loyalty to those who use political positions to fatten personal
as well as crony coffers, would not so easily occur if more
verifiable information became exposed to the citizens who welcome
information for purposes of making good choices about
leadership.

Here is a slice of verifiable information about New Orleans
Civil Clerk of Court Dale Atkins’ abuse and betrayal of
public trust, as well as the ramifications of that breach. Further,
this is in response to being asked why I stated in my August 15th
posting (see below) that Dale Atkins should be indicted. Those
reasons extend beyond what I am writing here. (Below I minced no
words in saying that Dale Atkins as well as Civil Sheriff Paul
Valteau should be indicted. )

Also, in that earlier posting was information about the fact
that The Metropolitan Crime Commission reported Atkins’
unethical attempts to influence prosecutors. And the Commission
wrote a statement urging that Atkins not be considered as a federal
court judge because of Atkins’ questionable ethics. Adding
insult to the injury, even though Atkins admitted she went to the
prosecutors on behalf of her brother, Atkins said nothing was
inappropriate about what she did. Plus, throughout this site are
facts and evidence of judicial malfeasance –notwithstanding
additional upcoming information.

Put simply, because of Atkins’ misfeasance and her defiant
refusal to acknowledge and curtail impropriety, Clerk of Court Dale
Atkins is A DANGEROUS public official. The ultimate fact which
leads me to this conclusion derives from Atkins’ July 31,
2006 affidavit that Atkins filed in federal court case number
06-2435. Atkins’ affidavit was in response to my accusations
about Atkins’ (pre-Katrina) acts of steering newly-filed
lawsuits to the judges of Atkins’ choice. Note: The acronym
CDC is intended to mean “civil district court.”

Before, telling what Atkins did regarding my situation
–and how Adkins co-conspired with attorney Paul Rumage to
engineer my (pre-evacuation) August 24, 2005 state law conversion
lawsuit to the federal magistrate court of which she is the god
mother for federal magistrate Karen Wells Roby’s child
–and of which an order was signed on May 5, 2006 dismissing
that case, despite to due being displaced here in Shreveport, I was
oblivious the case had become moved to federal court; and of which,
long after various court orders and rulings, wheeling &
dealings were accomplished in federal case 06-1408, Roby Wells
decided to recuse herself– I want to call attention to the
far-reaching social ramifications of Atkins’ unmitigated
gall. (The May 5, 2006 dismissal was recalled, yet much havoc has
resulted.)

Requirement Of Newly-filed Lawsuits To Be Randomly Allotted To
CDC Judges, Atkins’ affidavit sought to explain away
Atkins’ routine practice of steering newly-filed lawsuits to
judges of Atkins’ choice, rather than RANDOM assigning /
allotting lawsuits as mandated by Louisiana Code of Civil Procedure
article 253.1; and as ratified by the Louisiana Supreme Court as
recently as April 17, 2006.

Contrary to Atkins’ misrepresentations, a key benefit of
randomly allotting cases is the possible outcome of updated
jurisprudence, improved and contemporary with changing times.
Assigning a lawsuit to a judge simply because that judge has
rendered decisions on the similar or same subject matter
–especially if the judge is inept, results not only in added
ineptness, but costs of covering up the ineptness at the expense of
public resources.

To reiterate, Atkins’ affidavit categorically said Atkins
routinely does not comply with article 253.1. Yet Atkins’
shifty excuse for this act of impropriety defies logic. In the
first place, assuming Atkins’ excuse for not randomly
allotting lawsuits, upon a person’s presenting a new lawsuit
to the intake filing clerk, that clerk would have get up from the
computer and go to Atkins or somebody who could supply that filing
clerk with which issue, and which parties should go to which
judges.

Despite Atkins’ proffering some citation as basis for not
randomly assigning cases, the bottom line is that it is impossible
for the filing clerk to know which judge to assign a newly-filed
lawsuit based on similarity to some prior case. The clerk would
have to have that other case in order to compare similarities; and
the clerk would have to have capacity to interpret jurisprudence in
order to –within minutes of being provided a
plaintiff’s new lawsuit– know which former lawsuit, the
newly-filed lawsuit is similar to. Also, despite Atkins’
convenient attempt to contort the impropriety of what she did, a
‘law’ that Atkins utilized does not align with article
253.1.

In stark contradiction to Akins’ untenable rationale,
Louisiana Code of Civil Procedure article 253.1(2006) states as
follows:

All pleadings filed shall be randomly assigned to a particular
section or division of the court by either of the following
methods:

(1) By drawing indiscriminately from a pool containing
designations of all sections or divisions of court in the
particular jurisdiction in which the case is filed.

(2) By use of a properly programmed electronic device or
computer programmed to randomly assign cases to any one of the
sections or divisions of court in the particular jurisdiction in
which the case is filed.

Further contradicting Atkins’ artful excuse for not
randomly assigning cases, as recently as April 2006, the Louisiana
Supreme Court reiterated that cases should be randomly assigned, in
Disaster Restoration Dry Cleaning, L.L.C. v. Pellerin Laundry Mach.
Sales Co., 927 So. 2d 1094 (La.04/17/2006). The supreme court
extensively expounded on the high court’s displeasure with
“judge shopping,” and the precise criterion of random
allotment of cases. Also, in Leard v. Schenker, 930 So. 2d 75,(La.
App.4 Cir.2006), along with Judge Tobias’s statement about
the record being void “of an explanation of how Judge
Landrieu continues preside over the present case since she has
rotated off the domestic docket at the Civil District Court,”
Judge Tobias specifically pointed out the statutory requirement of
“random allotment rules mandated by law.”

Also, the fact that cases related to Joseph v. Hosp. Serv. Dist.
No. 2, 805 So. 2d 413, (La.App.1 Cir.2001) became consolidated,
further proves random allotment of cases is a strict requirement;
otherwise, the Joseph cases would have from the beginning been
assigned to the same judge. See also, Watson v. Lane Memorial
Hospital, 743 So. 2d 676 (La. 5/28/99), and State v. Sprint
Communications Company, L.P., 699 So. 2d 1058 (La. 9/9/97), wherein
random allotment of cases was definitively explained.

Recapitulating, even assuming Atkins’ absurd justification
for ignoring article 253.1, the filing clerk –having no law
degree is not likely to be able to identity the purviews of a
newly-filed CDC lawsuit without at least getting up from the
computer and asking somebody. (And even a clerk’s asking
somebody would entail that clerks’ hasty interpretation of
the case.) Also, given the fact that scores of lawsuits were being
filed in CDC each day, and given the fact that the same filing
clerk is not the person who receives the new lawsuit, and given the
fact that the filing clerk remains at all times seated in front the
computer, there is no way for the law clerk to recognize which
subject matters, and which litigants, should be allotted to which
judges. And even then, given the busyness of CDC, (pre-Katrina) it
was literally impossible to be able to determine –at the time
a lawsuit is submitted for filing what the issues are from a mere
glance.

Overwhelmingly, the stark reality of “case
consolidation” utterly refutes Atkins preposterous defense!
It is an everyday occurrence in CDC and any other court of law, for
related cases to become consolidated. Therefore, if it was even
remotely possible for a newly-filed lawsuit to be assigned to a
certain judge, instead of random assignment of that lawsuit, then
what reason would there for consolidating cases afer those cases
became assigned to different judges as in Joseph v. Hosp. Serv.
Dist. No. 2.

But there’s another socially harmful reason why
Atkins’ unjust justification for not randomly assigning new
lawsuits is unfair, underhanded, unduly costly to litigants, and
disastrous for companies which do business in New Orleans and
within the surrounding area.

The Problem of Preselecting A Judge

The people who file lawsuits rightfully have expectations of
obtaining equity. But equity is impaired when a clerk of court such
as Dale Atkins takes it upon herself to select the judge whom
Atkins chooses for adjudicating a newly-filed lawsuit. Moreover, it
is underhanded for Atkins’ office to not inform the plaintiff
when his / her lawsuit is being assigned to preselected
judge’s court. Also, because selecting a particular judge for
a newly-filed lawsuit violates the required random assignment, the
lawyer or the pro se plaintiff who previously received an erroneous
or unfair ruling in a prior case would be unduly forced because of
Atkins to return to that same judge.

Furthermore, when a newly-filed lawsuit becomes sent to a
selected judge merely because that judge has previously decided
similar controversies, the judge is not likely to contradict his
prior ruling, especially if ego is more important than equity.
Also, if the plaintiff had received justice from that judge in a
prior related lawsuit, the plaintiff would probably not be filing a
new lawsuit, but rather, the plaintiff would likely have amended
the original lawsuit. Hence, deliberately sending a newly-filed
lawsuit to the same judge practically guarantees the same
outcome.

IN A CITY of acute poverty, pervasive violations of Fair Debt
Collection Practice Laws, injured employees subjected to unsafe
workplaces, domestic violence, fraudulent transfers of immovable
and moveable property, business decline, and deadbeat parents who
feel no threat of consequences for delinquent obligations, if the
same judges issue rulings on the same issues, the results will be
outdated jurisprudence. Progress in law consistent with modern
times becomes hindered when perspectives from other judges become
prevented due to selected courts. And judges become abreast of
different aspects of law when randomly assigned diverse subject
matters. Also, the fact that appellate court opinions often include
dissenting opinions, demonstrates the fact that even appellate
judges’ viewpoints and approaches to lawsuits can vary as
subjects become decided by the appellate majority.

Even more alarming is the possibility that the judge who
erroneously issued a ruling would be conferred with repeated
opportunities to render additional erroneous or incompetent edicts.
Also, as if it could not be worse, in almost every instance, even
blatant illogical rulings, and apparently corrupt judicial conduct
is excused from accountability because of Immunity.

Atkins’ brazen conduct of is NOT a small matter. In like
manner as it is incalculable how many people were adversely
affected because of convicted former New Orleans judges’
misuses of authority, countless people have likely been deprived of
justice because their cases were steered to a judge of
Atkins’ choice instead of randomly assigned.

Social conditions such as apathetic citizens, substance abuse,
road rage, substance abuses, angry / disheartened people are
directly related to difficulty that countless people have in
obtaining justice certain CDC courts. And a principle reason for
injustice is Atkins’ actions of selecting the judge.

What Atkins’ Judge Selection Caused Me

I had become increasingly suspicious about how my lawsuits
repeatedly became assigned to judge Lloyd Medley. (Or, as
explained, groundless removal of my case to federal court
occurred.)

Because years ago I had become acquainted with Dale Atkins, I
went to Atkins and questioned about repeated assignment of my cases
to Medley. Atkins expressly told me that it was purely coincidental
for Medley to keep being the judge. (I have filed: an injunction
petition, two unfair debt collection petitions, and the August 24,
2005 petition for Conversion. Only because the cases were swiftly
dismissed, the new lawsuits were filed for purposes of securing a
factfinding day in court.)

Despite what Atkins told me, not until Atkins filed a July 31,
2006 affidavit in response to my allegations about Atkins of
deliberately sending my cases to Medley, did Atkins admit that she
“routinely” sends cases (lawsuits) to certain judges.
And her affidavit cited some ‘law’ to purportedly
justify Atkins’ actions.

Contrary to Atkins’ excuse for repeatedly directing my
cases to the same Judge Lloyd Medley (who twice issued the
ludicrous ruling in the Landiak versus Richmond case –and was
upheld by the Fourth Circuit, prior to Louisiana Supreme Court
Justice Calogero’s profuse overruling both lower courts),
Atkins was required to comply with Civil Procedure article
253.1.

Medley’s ruling in Landiak was laughable, but
Medley’s ruling against me in favor of non-existent plaintiff
GE Capital Mortgage Services (which ceased to exist in October
2002), and denying my request for an injunction, caused continual
unjust hardships for me. Although an injunction hearing is not an
adjudication of the merits of a parties claims, Medley’s
injunction ruling in favor of the non-existent plaintiff has been
consistently been the sole instrument for contentions of res
judicata.

The fact of preselected judges creates critically unjust results
for victims of New Orleans debt collection abuses; as well as
people whose property was illegally transferred such as the sample
properties listed throughout this website.

However, this posting is to call attention to Atkins’
deceptive, galling acts of steering cases to judges of
Atkins’s choice. Because Civil Sheriff Valteau recorded a
deed on June 29, 2005 for my property in the name of non-existent
GE Capital, on August 24, 2005, my daughter and I filed a lawsuit
for Conversion. We also, included our request for a restraining
order to prevent being evicted as a result of the falsified deed.
Upon presenting the lawsuit to the intake filing clerk, the clerk
typed in our name, and as has happened in previous times, the
August 24, 2005 lawsuit was also sent to Medley.

Manifestly, due to the fact that in year 2003, Medley
intentionally issued rulings in favor of non-existent GE Capital,
it was not likely that Medley would see anything wrong with
fraudulent recordation of a property deed, and fraudulent
transference of real estate, as such is a common illegal practice
at CDC.

Atkins’ steering the August lawsuit to Medley was
underhanded, and a deliberate abuse of her authority, and in
violation of article 253.1. Because of Atkins’ act of
refusing to allow the Conversion lawsuit to be randomly assigned, I
am convinced that her ability to direct the traffic of
people’s lawsuits makes Atkins more dangerously powerful than
society can endure.

The totality of what is untruthful about Atkins’ affidavit
statement regarding Atkins’ practice of not randomly
allotting newly-filed lawsuits, is that it is impossible for the
intake clerk who receives new lawsuits to know which issue goes
with which judge –unless Atkins’ computer system is
programmed with a person’s name, rather than the
person’s legal issue. Thus, Atkins’ statement about
assigning similar issues to the same judge is either clearly
untrue, and clearly impossible without someone specifically telling
the intake person what issues were previously decided, by which
judge, pertaining to which litigants.

As mentioned, the only people involved when a new lawsuit is
presented for filing, is the plaintiff (usually the
plaintiff’s lawyer), and the intake person who receives and
types the lawsuit into the computer. That intake person then places
a case number and judge’s name on the lawsuit while seated in
front of the CDC computer. With no one else present to provide
information, how could an intake person have any idea who is who,
and what is what?

Moreover, programming a computer system with a person’s
name DOES NOT ENSURE THE ISSUES OF A NEW LAWSUIT ARE THE SAME AS A
PRIOR LAWSUIT. However, such programming doe ensure that that
person is TARGETED FOR A SELECTED JUDGE, RATHER THAN RANDOM
ASSIGNMENT. PROGRAMMING A PERSON’S NAMES MOREOVER SERVES TO
ENSURE THAT PERSON WILL FACE THE SAME JUDGE WHO RULED AGAINST HER,
WHICH IN ESSENCE IS UNDULY UNFAIR, AS WELL AS A WASTE OF TIME AND
MONEY, and UNDUE MENTAL ANGUISH, AND PREJUDICE.

Further, the fact that Atkins easily denied wrongdoing like she
did when she tried to influence those prosecutors –and the
fact that Atkins’ affidavit seeks to justify her incredibly
flawed method of deciding which plaintiff should be assigned to
which judge, makes it apparent that Atkins believes herself above
the law, and that she can play god with people’s lives.

But Atkins’ steering the conversion lawsuit to Medley is
not the conclusion of her deception! After the case became lodged
in Medley’s court (for 7 months), due to Hurricane Katrina
and being displaced 6 hours away from New Orleans, our long
distance calls to CDC was the primary means of finding out about
the August 2005 case.

On the other hand, Atkins’ affidavit misrepresents the
truth because not every single case filed by me involving
similarities was assigned to the same judge. CDC case number
2003-14010 was randomly allotted to Division “F.”
However, that case was deceptively removed to federal court, as it
did not serve CDC purposes for that case to be ruled on by any
judge other than Medley.

Also, on two separate occasions when I went to New Orleans, I
was not able to view the case record at CDC because I was told my
case was “in the division” (meaning Medley’s
chambers). Another long distant phone resulted in my finding out
that my March 27, 2006 pleadings and fees were received and entered
into the docket records for the Conversion case. I was not told
that the case had already been removed to Magistrate Judge Wells
and District Judge McNamara.

My March 27, 2006 pleadings included a motion for venue change
and an amended complaint wherein I added Atkins as a defendant for
her repeatedly acts of steering my cases to Medley and for fraud. I
also included filing fees and fees for sheriff service. Clearly, I
would not have sent the pleadings and $258.00 had I known the case
was no longer in CDC. Refunds are not given at CDC.

But Dale Atkins knew the case had been removed. Therefore,
Atkins should not have kept my money, except that Atkins intended
to delay me from finding out the case had been removed to federal
court, and of which federal dismissal of that conversion case was
just days away from being ordered dismissed in federal court.

Specifically, Atkins’ deliberate involvement in the scheme
to impede me from knowing about the removal was obvious on May 2,
2006 when Judge Gill-Jefferson denied my default judgment motions
(for defendants Adcock and Dean). Judge Jefferson wrote the
defaults were denied because the August 2005 case no longer in
state court. Afterwards, an employee confirmed with federal court
the removal had occurred, and the employee learned a dismissal of
the entire case was scheduled. (Dismissals such as these are the
reasons why new lawsuits became filed.)

The plot to do away with the conversion lawsuit was aided by
Atkins’ office continuing to make docket entries despite
removal, as well as aided by Atkins’ filing Atkins’
April 28, 2006 “motion” in the removed case for which
Judge Jefferson had signed the order granting Atkins’ motion
on May 1, 2006 –one day prior to my motions for default.

More specifically, the conversion lawsuit was held up in state
court while the preparations were being made to do away with the
case in federal court.

Assisted by Atkins’ deceptions, attorney Paul Rumage filed
the removal documents for the Conversion case. Rumage’s
removal pleading states that Rumage removed the conversion lawsuit
to federal court on grounds of federal question pertaining to
Freddie Mac. To the contrary, Freddie Mac has never been served the
conversion lawsuit. Furthermore, Rumage is not Freddie Mac’s
attorney.

Because I found out about the federal removal and upcoming
dismissal, their dismissal plot was foiled. The May 5, 2006 order
from McNamara dismissing the conversion case was rescinded. (But
McNamara still reset dates to rule on a Motion to Dismiss from
Freddie Mac, despite that no jurisdiction exists over Freddie Mac
due to lack of service of summons and process.)

The scheme to eradicate that case was almost accomplished,
except that I showed up in New Orleans just in time. Had enough
time lapsed between the dismissal order McNamara signed, I would
have been forced to file a costly federal appeal for which takes at
least one year for a federal appeal decision to be rendered.

To further show the acts done to have it appear the conversion
lawsuit was yet in state court, in addition to Atkins’
post-removal motion, various other pleadings were being filed and
docketed in state court. And Judges Gill-Jefferson and Lloyd Medley
signed various orders even though the case was no longer in state
court. In fact, Medley recused himself after the removal, and Judge
Gill-Jefferson signed an order on April 6, 2006 for a show cause
hearing and mailed to my Shreveport address notice of a May 26,
2006 hearing for the no longer in state court case. Atkins even
mailed to me a copy of Atkins’ state court request for
extension of time. Of course, Medley’s recusal and
Gill-Jefferson’s signed orders were null due to the case
being [unlawfully] removed by Rumage, as none of the parties in the
case affected federal question and there was no diversity.

In a nutshell, Dale Atkins refrained from randomly allotting the
Conversion lawsuit. Atkins unlawfully steered the conversion
lawsuit to Medley. Medley retained control over that lawsuit for 7
months while the preparations were being made in federal court to
quickly make the conversion lawsuit disappear. Even if it were a
coincidence that the case was sent to Medley, Medley knew he should
have recused himself from the very beginning because –as his
recusal order states, Medley was concurrently being sued by me for
court corruption, and that case is yet pending in appellate court.
Had Atkins randomly allotted the conversion lawsuit, discovery into
the impropriety of the June 29, 2006 deed could have been under
way. Had Atkins returned my pleadings and filing fees, I would not
be out of money that I paid regarding the Conversion state court
which had become a federal case. Furthermore, had Atkins not
steered the August 24, 2005 Conversion lawsuit to Medley, our
request for a restraining to prevent the eviction would have likely
been granted by a different judge.

Accordingly, how many other cases Atkins is steering to the
judge of her choice? And how many cases does Atkins assist in
arriving in federal court before the mother of Atkins’
godchild? A lawsuit for conversion is purely state law subject
matter. Therefore, no grounds to remove the conversion lawsuit
existed.

If all this is unclear, other postings on this website provides
even more information about what took place concerning the August
24, 2005 lawsuit, including actual exhibits of orders that
Gill-Jefferson and Lloyd Medley signed.

Alarmingly, Atkins should not only not be elected, she ought to
be impeached and indicted after investigations prove the unlawful
manipulation of cases that become filed in the Orleans Parish Civil
District Court which Atkins oversees.

Furthermore, I feel certain that attorneys who are oblivious to
Atkins’ acts selecting and steering cases to the judges of
Atkins’ choice, would appreciate knowing such a thing is
being done.

What Atkins did by steering my cases (aside from the fact of
documents becoming missing, other misleading documents placed into
the record of the conversion case after removal) –in addition
to Atkins’ ongoing arrogant denials of wrongdoing makes it
essential to make it known publicly about Atkins’ deficient
ethics as a public official.

**In conjunction with the foregoing, see the January 2006 essay
posted on this site, entitled: “Casualties From New
Orleans’ Ineptness and Corruption Are COMING TO A CITY NEAR
YOU: Some Are Sick Yet Lack Medical Records, Impoverished, Lonely,
Angry, Troubled, Grieving, HIV Infected, Domestically Embittered,
Child Molesters, Scared, Unskilled, Suicidal, Drug or Substance
Abusive,, and Crime Prone Hurricane Katrina Migrants.”NOTE: I
AM STILL .*

Proof of Orleans Parish Court Fraud(excerpts from pleadings
filed in Federal Court) Posted by Barbara Ann Jackson on May 19th
2006 to News

The following excerpts are from statements filed by Barbara Ann
Jackson on May 9th and May 18th in Federal Judge McNamara’s
court: (*See below,”Exhibits Proving New Orleans Court
Malfeasance”that prove Jackson’s averments)May 18,
2006Plaintiff Jackson informs this court that she did in fact, file
oppositions to the defendants’ motion and removal. The third
exhibit below shows the first page of Jackson’s opposition
that was file-stamped by the Eastern District pro se department.
The 22-page opposition informs the court –as well as proves
with overwhelming evidence, the plaintiffs’ oblivion about
their August 24, 2005 State Court case being in the Federal Eastern
District Court. Moreover, aside from the fact that the plaintiffs
did not know their case had been removed to Federal Court,
defendant Dale Atkins, the Clerk of Orleans Parish Court, on May 1,
2006 filed and received a court order from Judge Gill-Jefferson the
same day! Glaringly, as the clerk of Orleans Parish Court, Dale
Atkins was fully aware of removal statutes and procedures. Further,
unlike the plaintiffs’ unawareness of their case being
removed, Atkins knew! Furthermore, although the case was
purportedly removed March 17, 2006, Atkins was served the
plaintiffs’ original and amended Conversion and False Arrest
petitions, through State Court procedure, after the purported
removal, and after her co-defendants filed the Rule 12 Motion to
Dismiss the entire case.

Despite the plaintiffs’ unawareness of their case being
removed, Atkins knew! Furthermore, although the case was
purportedly removed March 17, 2006, the plaintiffs’ original
and amended Conversion and False Arrest petitions, through State
Court procedure, the purported removal, her co-defendants filed the
Rule 12 Motion to Dismiss the entire case. Further substantiation
for the plaintiffs’ reliance that their case was still in
State Court is the fact that long after the purported removal, on
April 6, 2006, Judge Gill-Jefferson signed a Show Cause order for
Jackson’s Venue Change Motion. Even further, Judge
Gill-Jefferson mailed to the plaintiffs’ Shreveport address,
the postcard exhibited below which shows that Judge Jefferson set
the Venue Motion for hearing on May 26, 2006. Clearly, from these
facts alone, the plaintiffs’ being displaced and impeded from
information about their case, had no possible reason to suspect
their case had been removed, for which had they known, they would
have immediately sought remand because they are convinced that
racism and inequality is the order of the day in the New Orleans
Eastern District Court of New Orleans, as long as it can occur in
obscurity. In addition, Jackson has proof that two certain New
Orleans federal judges have made clear their goals to harm Jackson,
and she is justifiably concerned. (It is of no moment that some
defendants are of the same race as the plaintiffs; New Orleans quid
pro quo and corruption is an undeniable, world-known despicable
reality.)

In addition, co-defendant Neisha Lange, the person who caused
Jackson to become falsely arrested, was served –through State
Court procedures, the plaintiffs’ original and amended
petitions well after the removal and well after the Rule 12 Motion.
As the fifth exhibit below shows, defendant Neisha Lange was served
the plaintiffs’ 2005-11458 petitions on May 2, 2006. In light
of all this, how then could the plaintiffs have realized their
August 24, 2005 case had been removed to federal court, and a Rule
12 dismissal imminent? Further, even if the plaintiffs had become
notified of the removal, the plaintiffs would have had every reason
to conclude any removal was a mistake, and their case remained in
State Court due to lack of federal jurisdiction. Aside from all
this, every time Barbara Jackson made long distance calls to the
Orleans Parish Clerk of Court’s office, the docket clerk for
Judge Medley (believed to be named Celeste) told Jackson convoluted
information; and that docket clerk always said the case was
“in the division” (meaning Judge Medley’s
chambers, of which Lange is the law clerk).

Put plainly, if the plaintiffs’ case was lawfully removed
on March 2006 from State Court, Atkins not only should not have
been served through State Court procedures, Atkins did not need to
file her May 1, 2006 State Court Motion for Extension of Time to
answer the plaintiffs’ purportedly removed August 24, 2005
lawsuit. Further, although on that same day of May 1, 2006, Judge
Gill-Jefferson signed an order granting Atkins’ deceptive
request, the following day when Jackson showed up with her motions
for default judgment, Judge Gill-Jefferson denied Barbara
Jackson’s default motions and wrote on Jackson’s motion
that the case had been removed to federal court. In addition to
pleadings and filings by Atkins, the other defendants also filed
pleadings and obtained court orders after the purported removal.
Thus, due to the fact that the plaintiffs live 6½ hours away
from New Orleans, the plaintiffs were forced to rely on the
misinformation they were provided when telephoning Atkins’
Clerk of Court’s office to enquire about their case. More,
poignantly, according to 28 U.S.C. §§ 1446(d), if a true
removal had occurred, after the filing of removal with the clerk of
the State court, “the State court shall proceed
nofurther.” In fact, after all the wheeling and dealing and
acquiring judicial signatures in State Court for their varied
pleadings that the defendants filed in State Court after the
purported removal,on May 5, 2006, defendant Dean filed yet another
State Court pleading and motion for the plaintiffs’
2005-11458 State court case to become signed by Judge
Gill-Jefferson.

Dean did not bother setting his May 5, 2006 motion to be heard.
However, Dean did decisively point out the mandates of §
1446(d) onlywith regard to the plaintiffs’ amended March 27,
2006 petition that was sent via FedEx to the Clerk’s office;
and Jackson’s $248.00 filing and services fees were kept.
Dean’s deceitful aim is apparent by the fact that Dean does
not seek to nullify any of the other numerous filings and court
rulings that were made by Dean’s co-defendants well after
Jackson’s March 27th amendment. Among the plausible reasons
for Dean’s duplicitous act, is to circumvent defendant Neisha
Lange’s tortious act of causing Jackson to be falsely
arrested on August 24, 2005. The docketed March 27th amendment is
exhibited in Jackson’s 22-page opposition.

. . .Orleans Parish State Court did not supply the
plaintiffs’ post-Katrina address to the defendants. Prior to
that phone call, the plaintiffs were unaware the defendants were
not provided their evacuated address. Even more specific, the
plaintiffs’ enquires about their case led them to believe
that their case was not advancing due to the need to re-allot their
case from Judge Lloyd Medley. In fact, after signing various orders
to benefit the defendants, Medley waited 7 monthsbefore he recused
himselffrom this case, and then Medley assigned this case to Judge
Gill-Jefferson. Because of these judicial anomalies, dislodged
documents from the record of this case, as well as negligence on
the part of the Orleans Parish State Court should not be charged to
the plaintiffs, and thus, unfairly result in this federal
court’s penalizing the plaintiffs and depriving them of their
constitutional rights of access to justice. (Indeed, when the
plaintiffs made their November 2005 request for service and long
arm citation for foreign defendant Freddie Mac, they had to provide
the pre-Katrina pleading as it was originally filed, and it did
contain the plaintiffs’ pre-Katrina address. But the
plaintiffs’ November 2005 request contained the
plaintiffs’ new address for which to mail the long arm
service. Further, with a pre-Katrina zip code of 70127, it was a
well-known reality that New Orleans East was not habitable in
November 2005. The plaintiff’s November 2005 correspondence,
that was sent via United States Postal Express Mail, is referenced
in the State Court docket record. However, those items, including
the November 2005 money order is missing. Also, Atkins’
office did not supply the long arm citation until April 2006. The
Orleans State court cannot assign blame on the Gonzales court. It
was the New Orleans court, and not Gonzales which cashed
Jackson’s November 2005 money order.

In light of the fact that the plaintiffs were never notified
that their non-federal subject matter lawsuit for Conversion and
False Arrest had been removed to federal court despite lack of
diversity, federal court has never properly acquired jurisdiction
for this case. Also, the fact that only 6 weeks after removal to
federal to federal court,this swift Rule 12 dismissal of the
plaintiffs’ case without due process, is manifest gross
injustice. Further, in light of the fact that the deceitfully filed
notice of removal is replete with falsehoods –including the
convoluted date as to when the plaintiff’s Conversion lawsuit
was filed -as well as void of any date whatsoever as to whenwere
the defendants servedthe lawsuit, it is glaringly unfair to ratify
the defendants’ multiple bad faith and prejudicious deceptive
federal court filings to the prejudice of the plaintiffs. Moreover,
despite the prerequisite for removing a case from State Court which
requires a removing defendant to state in his removal pleading when
was service made upon that defendant, this instant removal pleading
does not contain such information.

Even more glaring and deceptive is the fact thatcontrary to
distortions in the removal pleading, the only foreign
(non-Louisiana) defendant, Federal Home Loan (Freddie Mac)was not
even served the plaintiffs’ lawsuit until April
2006.Specifically, the Orleans Parish Clerk’s Office did not
provide Jackson her repeatedly requested Long Arm
CitationunitlApril 5, 2006.Thus at the time of the removalof this
case, all parties were Louisiana residents, no jederaljurisdiction
existed -for which, in a mere 6-week period, this case has
becomedismissed despite lack of notice tothe displaced/ evacuated
plaintiffs.”

MAY 9, 2006

On August 24, 2005, the plaintiffs filed State Court action
number 2005-11458 for Conversion. As in repeated times, the August
24, 2005 case was allotted to Judge Lloyd Medley, even though
Barbara Jackson’s prior lawsuit against Medley is still
pending. When the plaintiffs went August 24, 2005 to Medley’s
chambers, his law clerk, Neisha Lange subjected the plaintiffs to
emotional distress and Lange caused Barbara Jackson to be falsely
arrested. Seven months later, after Medley signed various orders in
favor of the above defendants, on March 23, 2006, Judge Medley
signed an order recusing himself from this case. On March 27,
20065, the 2005-11458 petition was supplemented and filed to
include defendants Atkins and Lange. Both Atkins and Lange have
been served plaintiffs’ original and supplemental petitions.
The plaintiffs, oblivious that Medley had finally relinquished this
–for which the file records were kept in Medley’s
chamber, also requested change of venue.

On April 6, 2006, Judge Gill-Jefferson signed a Show Cause Order
for the venue motion and mailed the plaintiffs a postcard informing
them of a May 26, 2006 hearing.On the plaintiffs filed State Court
action number 2005-11458 for Conversion. As in repeated times, the
August 24, 2005 case was allotted to Judge Lloyd Medley, even
though Barbara Jackson’s prior lawsuit against Medley is
still pending. When the plaintiffs went August 24, 2005 to
Medley’s chambers, his law clerk, Neisha Lange subjected the
plaintiffs to emotional distress and Lange caused Barbara Jackson
to be falsely arrested. Seven months later, after Medley signed
various orders in favor of the above defendants, on March 23, 2006,
Judge Medley signed an order recusing himself from this case. On
March 27, 20065, the 2005-11458 petition was supplemented and filed
to include defendants Atkins and Lange. Both Atkins and Lange have
been served plaintiffs’ original and supplemental petitions.
The plaintiffs, oblivious that Medley had finally relinquished this
–for which the file records were kept in Medley’s
chamber, also requested change of venue. On April 6, 2006, Judge
Gill-Jefferson signed a Show Cause Order for the venue motion and
mailed the plaintiffs a postcard informing them of a May 26, 2006
hearing.

The plaintiffs filed State Court action number 2005-11458 for
Conversion. As in repeated times, the August 24, 2005 case was
allotted to Judge Lloyd Medley, even though Barbara Jackson’s
prior lawsuit against Medley is still pending. When the plaintiffs
went August 24, 2005 to Medley’s chambers, his law clerk,
Neisha Lange subjected the plaintiffs to emotional distress and
Lange caused Barbara Jackson to be falsely arrested. Seven months
later, after Medley signed various orders in favor of the above
defendants, on March 23, 2006, Judge Medley signed an order
recusing himself from this case. On March 27, 20065, the 2005-11458
petition was supplemented and filed to include defendants Atkins
and Lange. Both Atkins and Lange have been served plaintiffs’
original and supplemental petitions. The plaintiffs, oblivious that
Medley had finally relinquished this –for which the file
records were kept in Medley’s chamber, also requested change
of venue. On April 6, 2006, Judge Gill-Jefferson signed a Show
Cause Order for the venue motion and mailed the plaintiffs a
postcard informing them of a May 26, 2006 hearing.On the plaintiffs
filed State Court action number 2005-11458 for Conversion. As in
repeated times, the August 24, 2005 case was allotted to Judge
Lloyd Medley, even though Barbara Jackson’s prior lawsuit
against Medley is still pending. When the plaintiffs went August
24, 2005 to Medley’s chambers, his law clerk, Neisha Lange
subjected the plaintiffs to emotional distress and Lange caused
Barbara Jackson to be falsely arrested. Seven months later, after
Medley signed various orders in favor of the above defendants, on
March 23, 2006, Judge Medley signed an order recusing himself from
this case. On March 27, 20065, the 2005-11458 petition was
supplemented and filed to include defendants Atkins and Lange. Both
Atkins and Lange have been served plaintiffs’ original and
supplemental petitions. The plaintiffs, oblivious that Medley had
finally relinquished this –for which the file records were
kept in Medley’s chamber, also requested change of venue. On
April 6, 2006, Judge Gill-Jefferson signed a Show Cause Order for
the venue motion and mailed the plaintiffs a postcard informing
them of a May 26, 2006 hearing. On the plaintiffs filed State Court
action number 2005-11458 for Conversion. As in repeated times, the
August 24, 2005 case was allotted to Judge Lloyd Medley, even
though Barbara Jackson’s prior lawsuit against Medley is
still pending. When the plaintiffs went August 24, 2005 to
Medley’s chambers, his law clerk, Neisha Lange subjected the
plaintiffs to emotional distress and Lange caused Barbara Jackson
to be falsely arrested. Seven months later, after Medley signed
various orders in favor of the above defendants, on March 23, 2006,
Judge Medley signed an order recusing himself from this case. On
March 27, 20065, the 2005-11458 petition was supplemented and filed
to include defendants Atkins and Lange. Both Atkins and Lange have
been served plaintiffs’ original and supplemental petitions.
The plaintiffs, oblivious that Medley had finally relinquished this
–for which the file records were kept in Medley’s
chamber, also requested change of venue. On April 6, 2006, Judge
Gill-Jefferson signed a Show Cause Order for the venue motion and
mailed the plaintiffs a postcard informing them of a May 26, 2006
hearing. On August 24, 2005, the plaintiffs filed State Court
action number 2005-11458 for Conversion. As in repeated times, the
August 24, 2005 case was allotted to Judge Lloyd Medley, even
though Barbara Jackson’s prior lawsuit against Medley is
still pending. When the plaintiffs went August 24, 2005 to
Medley’s chambers, his law clerk, Neisha Lange subjected the
plaintiffs to emotional distress and Lange caused Barbara Jackson
to be falsely arrested. Seven months later, after Medley signed
various orders in favor of the above defendants, on March 23, 2006,
Judge Medley signed an order recusing himself from this case. On
March 27, 20065, the 2005-11458 petition was supplemented and filed
to include defendants Atkins and Lange. Both Atkins and Lange have
been served plaintiffs’ original and supplemental petitions.
The plaintiffs, oblivious that Medley had finally relinquished this
–for which the file records were kept in Medley’s
chamber, also requested change of venue. On April 6, 2006, Judge
Gill-Jefferson signed a Show Cause Order for the venue motion and
mailed the plaintiffs a postcard informing them of a May 26, 2006
hearing. On August 24, 2005, the plaintiffs filed State Court
action number 2005-11458 for Conversion. As in repeated times, the
August 24, 2005 case was allotted to Judge Lloyd Medley, even
though Barbara Jackson’s prior lawsuit against Medley is
still pending. When the plaintiffs went August 24, 2005 to
Medley’s chambers, his law clerk, Neisha Lange subjected the
plaintiffs to emotional distress and Lange caused Barbara Jackson
to be falsely arrested. Seven months later, after Medley signed
various orders in favor of the above defendants, on March 23, 2006,
Judge Medley signed an order recusing himself from this case. On
March 27, 20065, the 2005-11458 petition was supplemented and filed
to include defendants Atkins and Lange. Both Atkins and Lange have
been served plaintiffs’ original and supplemental petitions.
The plaintiffs, oblivious that Medley had finally relinquished this
–for which the file records were kept in Medley’s
chamber, also requested change of venue. On April 6, 2006, Judge
Gill-Jefferson signed a Show Cause Order for the venue motion and
mailed the plaintiffs a postcard informing them of a May 26, 2006
hearing. On August 24, 2005, the plaintiffs filed State Court
action number 2005-11458 for Conversion. As in repeated times, the
August 24, 2005 case was allotted to Judge Lloyd Medley, even
though Barbara Jackson’s prior lawsuit against Medley is
still pending. When the plaintiffs went August 24, 2005 to
Medley’s chambers, his law clerk, Neisha Lange subjected the
plaintiffs to emotional distress and Lange caused Barbara Jackson
to be falsely arrested. Seven months later, after Medley signed
various orders in favor of the above defendants, on March 23, 2006,
Judge Medley signed an order recusing himself from this case. On
March 27, 20065, the 2005-11458 petition was supplemented and filed
to include defendants Atkins and Lange. Both Atkins and Lange have
been served plaintiffs’ original and supplemental petitions.
The plaintiffs, oblivious that Medley had finally relinquished this
–for which the file records were kept in Medley’s
chamber, also requested change of venue. On April 6, 2006, Judge
Gill-Jefferson signed a Show Cause Order for the venue motion and
mailed the plaintiffs a postcard informing them of a May 26, 2006
hearing.On August 24, 2005, the plaintiffs filed State Court action
number 2005-11458 for Conversion. As in repeated times, the August
24, 2005 case was allotted to Judge Lloyd Medley, even though
Barbara Jackson’s prior lawsuit against Medley is still
pending. When the plaintiffs went August 24, 2005 to Medley’s
chambers, his law clerk, Neisha Lange subjected the plaintiffs to
emotional distress and Lange caused Barbara Jackson to be falsely
arrested. Seven months later, after Medley signed various orders in
favor of the above defendants, on March 23, 2006, Judge Medley
signed an order recusing himself from this case. On March 27,
20065, the 2005-11458 petition was supplemented and filed to
include defendants Atkins and Lange. Both Atkins and Lange have
been served plaintiffs’ original and supplemental petitions.
The plaintiffs, oblivious that Medley had finally relinquished this
–for which the file records were kept in Medley’s
chamber, also requested change of venue. On April 6, 2006, Judge
Gill-Jefferson signed a Show Cause Order for the venue motion and
mailed the plaintiffs a postcard informing them of a May 26, 2006
hearing.

On August 24, 2005, the plaintiffs filed State Court action
number 2005-11458 for Conversion. As in repeated times, the August
24, 2005 case was allotted to Judge Lloyd Medley, even though
Barbara Jackson’s prior lawsuit against Medley is still
pending. When the plaintiffs went August 24, 2005 to Medley’s
chambers, his law clerk, Neisha Lange subjected the plaintiffs to
emotional distress and Lange caused Barbara Jackson to be falsely
arrested. Seven months later, after Medley signed various orders in
favor of the above defendants, on March 23, 2006, Judge Medley
signed an order recusing himself from this case. On March 27,
20065, the 2005-11458 petition was supplemented and filed to
include defendants Atkins and Lange. Both Atkins and Lange have
been served plaintiffs’ original and supplemental petitions.
The plaintiffs, oblivious that Medley had finally relinquished this
–for which the file records were kept in Medley’s
chamber, also requested change of venue. On April 6, 2006, Judge
Gill-Jefferson signed a Show Cause Order for the venue motion and
mailed the plaintiffs a postcard informing them of a May 26, 2006
hearing.

For different federal claims, on April 5, 2006, Barbara Jackson
filed RICO lawsuit number 06-0581 in the Federal Court of Caddo
Parish in Shreveport, Louisiana. By its nature, a RICO lawsuit
entails inclusion of former acts for purposes of showing a pattern
of conduct. It is necessary to point out that there is a
distinction exists between excessive lawsuits and exigent lawsuits;
and non-adjudicate justiciable wrongs are not claim precluded. In
fact, particularly because of swift Rule 12
dismissals–without granting leave to amend complaints, a new
lawsuit is often the only recourse –a reality some courts
refuse to consider. justiciable wrongs are not claim precluded. In
fact, particularly because of swift a new lawsuit is often the only
recourse –a reality some courts refuse to consider. All such
scenarios surround the controversies the parties of these
litigations. Moreover, during all former times, New Orleans federal
and state courts consistently refused to allow discovery; and there
has never been a trial of the plaintiffs’ claims. Rather, one
court after another utilized the fraudulently obtained October 2003
ruling from Judge Medley, as being equivalent to a trial of the
merits –although not even the party which received the
favorable October 2003 ruling appeared at the Medley hearing.
Because of conclusive June and August 2005 proof that all court
orders and rulings were actually obtained by use of a non-existent
entity, those fraudulently obtained court orders are void. It is
also plain that the persons involved in those schemes are guilty of
judicial fraud, and guilty of conspiring to commit judicial fraud.
Although the following facts pertain to Jackson’s federal
Caddo Parish lawsuits, since the defendants are attempting to
combine the issues, these stipulations are being made: With regard
to repetitive judicial frauds involving the defendants,
consistently, messages from New Orleans courts appear to be: (1)
Sheriff Valteau’s longtime, varied acts of property fraud
(aided by co-conspirators) are acceptable so long as property
owners are delinquent. (2) Non-existence of
“Plaintiffs” named in foreclosures, and named in
“lift stay” motions is not essential to being granted a
court order. (3) It is acceptable when Sheriff Valteau records
property deeds in the names of non-existent entities. (4) It is
acceptable to give undue rankings for proceeds of property sales.
(5) It is acceptable for the Sheriff’‘s Office to
falsify service of pleadings. (6) It is acceptable for the Orleans
Parish Clerk of Court’s office to intentionally employ
deceptive and unfair tactics which intentionally impede justice.
(7) Disregard for Federal Reserve Systems’ Consumer Laws
created to address rampant debt collection abuse. (8) And, the New
Orleans Federal, as well as State Court system has no regard for
New Orleans apartheid conditions stemming from corrupt and / or
inept court edicts. Sheriff Valteau’s longtime, varied acts
of property fraud (aided by co-conspirators) are acceptable so long
as property owners are delinquent. Non-existence of
“Plaintiffs” named in foreclosures, and named in
“lift stay” motions is not essential to being granted a
court order. It is acceptable when Sheriff Valteau records property
deeds in the names of non-existent entities. It is acceptable to
give undue rankings for proceeds of property sales. It is
acceptable for the Sheriff’‘s Office to falsify service
of pleadings. It is acceptable for the Orleans Parish Clerk of
Court’s office to intentionally employ deceptive and unfair
tactics which intentionally impede justice. Disregard for Federal
Reserve Systems’ Consumer Laws created to address rampant
debt collection abuse. And, the New Orleans Federal, as well as
State Court system has no regard for New Orleans apartheid
conditions stemming from corrupt and / or inept court edicts. In a
nutshell, the years of Sheriff Valteau’s multiple acts of
malfeasance which includes deceptive and fraudulent transfer of
properties is acceptable as long as there is a delinquent borrower.
Further, manifest court corruption is an accepted way of life in
New Orleans.

Not until after Barbara Jackson arrived in New Orleans and on
May 2, 2006 filed a motion for default judgment, did Jackson learn
of a purported removal of State case 2005-11458 to the New Orleans
Eastern District Court. Specifically, after making a telephone to
federal court, the staff person in Judge Jefferson’s court
chambers informed Jackson on May 2, 2006 of the removal, gave
Jackson a copy of the removal, and informed Jackson of the
impending dismissal hearing. Specifically, after making a telephone
to federal court, the staff person in Judge Jefferson’s court
chambers informed Jackson on May 2, 2006 of the removal, gave
Jackson a copy of the removal, and informed Jackson of the
impending dismissal hearing.

Services of process and various motions continued to be filed in
state court, and state court orders were rendered on at least 5
separate occasions AFTER the purported removal to federal court.
Also, because of being displaced, Jackson has twice sent to the
state court clerk’s office, pleadings and motions via postal
delivery, and via FedEx. Due to lack of information from the
clerk’s office concderning their August 25, 2005 petition,
the plaintiffs had only the benefit of their money orders being
cashed and their postal and FedEx receipts to confirm whether the
plaintiffs’ filings were being received and given to
sheriff’s office for service.

Documents and pleadingscontinued to be filed in state court, and
state court orders were rendered on the purported removal to
federal court. Also, because of being displaced, Jackson has twice
sent to the state court clerk’s office, pleadings and motions
via postal delivery, and via FedEx. Due to lack of information from
the clerk’s office concderning their August 25, 2005
petition, the plaintiffs had only the benefit of their money orders
being cashed and their postal and FedEx receipts to confirm whether
the plaintiffs’ filings were being received and given to
sheriff’s office for service.

Pleadings and motionscontinued to be filed in state court, and
state court orders were rendered on the purported removal to
federal court. Also, because of being displaced, Jackson has twice
sent to the state court clerk’s office, pleadings and motions
via postal delivery, and via FedEx. Due to lack of information from
the clerk’s office concderning their August 25, 2005
petition, the plaintiffs had only the benefit of their money orders
being cashed and their postal and FedEx receipts to confirm whether
the plaintiffs’ filings were being received and given to
sheriff’s office for service.

As of the date of this May 8, 2006 pleading, removal of case
2005-11458 has not yet become lawfully accomplished because no
notice of removal has been served upon the plaintiffs. Instead,
despite the plaintiffs providing their evacuated address, it
appears that the defendants used the pre-Katrina address. As of the
date of this May 8, 2006 pleading, removal of case 2005-11458 has
not yet become lawfully accomplished because no notice of removal
has been served upon the plaintiffs. Instead, despite the
plaintiffs providing their evacuated address, it appears that the
defendants used the pre-Katrina address.

The removal was not in accordance to law because the only two
served defendants are residents of Louisiana, as are the
plaintiffs. Thus, removal of the plaintiffs’ August 24, 2005
petition was not based on diversity jurisdiction. Further, foreign
defendant, Federal Home Loan Association was not even served until
after April 2006 aFTER the clerk’s office provided the
repeatedly requested long arm citation. Moreover, it does not
require a law degree to know that the 2005-11458, August 24, 2005
lawsuit for Conversion and False Arrest is not federal question
subject matter.

Further, the defendants’removal notice flagrantly
misrepresents the plaintiffs’ lawsuit as being filed in
January 2006. Also, the removal appears to attempt concealment of
the lawsuit’s damage claims arising from the August 24, 2005
false arrest of Barbara Jackson.

The most salient attestation to the fact that the plaintiffs had
no knowledge that their 2005-11458 petition had been removed to New
Orleans federal court, and therefore their entitlement to remand,
as well as their entitlement to demand jury trial is not expired,
is the evidence of the Orleans Parish Civil clerk’s office
accepted and filed Jackson’s Supplemental / Amended Petition
on March 27, 2006, and her motion for venue change AFTER the date
of purported removal to federal court. The supplement and venue
motion was sent via FedEx on March 25, 2006; and because of the
plaintiffs’ displacement in Caddo Parish they were oblivious
of the removal.

Removal of this August 24, 2005 state court case is dubious in
light of the fact that on March 27, 2006 –after the purported
removal, the Orleans Parish Clerk’s Office afterwards kept
Jackson’s filing fees, and filed and docketed Jackson’s
supplemental petition; and the Orleans Parish Sheriff Office
likewise accepted Jackson’s payment for service of process
for Jackson‘s March 27, 2006 pleadings upon Adcock, Dean,
Atkins, and Lange. In addition, on April 5, 2006 –after the
so-called removal, the clerk’s office put in Barbara
Jackson’s hand, the long arm citation for defendant Freddie
Mac. Further, the fact that Clerk of Court, Dale Atkins is a
defendant in this removed August 24, 2005 state case manifests that
notwithstanding the plaintiffs’ displacement in Shreveport,
the clerk’s office was fully aware of misleading the
plaintiffs and impeding their awareness a removal occurred. Nor
should the sheriff’s office have effected additional service
of process if the plaintiffs case had become removed from state
court jurisdiction. Such conduct is clear indication that, in
self-dealing fashion, the sheriff’s office and the
clerk’s intended to conceal from the Katrina-evacuated
plaintiffs, the federal court removal so to allow period for Remand
time to lapse, and the Rule 12 dismissal motion to be filed and set
for hearing in this federal court –all within a one-month
period of time!

The defendants’ bad faith removal, concealment of the
removal, and their hasty Rule 12 motions after this case ONLY being
in federal court ONE MONTH –as well as the fact that their
Rule 12 motion to this date has not been served on the plaintiffs,
impels need for a new cause of action to address wrongs that are
normally pled within the procedural course of prosecuting
one’s damage claims. Put plainly, instead of allowing a
lawsuit to take its proper procedural course, all that a rapid
dismissal motion (within one month) does is limit a courts capacity
to adjudicate all existing actionable claims affecting the parties.
In such instances –because prescriptive periods have not run,
a new lawsuit is the proper means for redress. Specifically, now
are subsequent actionable wrongs, not pled in the existing case,
done by persons such as Judge Lloyd Medley and his law clerk, by
the Orleans Parish clerk and sheriff‘s office, inter alia, in
violation of Louisiana deceptive practices (LUPTA), several tort
laws; as well as undue result of the plaintiffs’ current
unfounded subjection to the hostile, racist, biased, dangerous
Eastern District Federal Court –of which the plaintiffs had
irrefutable entitlement to a remand had more frauds, concealments,
and deception not occurred.

The only purpose served by hasty case dismissals and
forum-shopping is likely discourage certain injured people, and
cause undue time and expense. However, since New Orleans apartheid
is fore mostly maintained by judicial oppression, corruption, and
ineptness, the scourge and harm of [actionable] wrongs provides
significant opportunities for exposing and mitigating issues such
as court malfeasance, judicial tyranny and oppression, and abuses
of authority. Moreover, since the time of Hurricane Katrina, there
remains an ongoing nationwide public outcry against New Orleans
corruption, cronyism, and racism.

Further, aside from the fact the defendants did not send a
removal notice to the plaintiffs’ evacuated address that the
plaintiffs provided in November 2005 to the Orleans Parish
Clerk’s Office of which the plaintiffs’ letter is
referred to on the state court docket entry; and the fact that the
defendants failed to give the plaintiffs their Rule 12 motions in
accordance with federal local rules which require that hearings
shall not be set without opposing parties being given 15 actual
days notice, the May 10, 2006 hearing violates Constitutional due
process rights. Also, not until the defendants have served their
motions upon the plaintiffs in accordance to law, the plaintiffs
are procedurally entitled to an opportunity to file opposition to
the Rule 12 motion; and the plaintiffs are entitled to 15 days of
actual notice before the hearing date –of such is not has not
occurred.

These salient facts prove that the May 10, 2006 hearing cannot
go forward because: (1) The plaintiffs are not being afforded 15
days notice of the hearing. (2) The plaintiffs are entitled to be
served a copy of any Rule 12 motion –as well as entitled to
an opportunity to file their opposition. (3) This August 24, 2005
originally-filed state court case under docket number 2005-11458 is
not ripe for federal Rule 12 b motions to be heard in this forum
because removal notice was not served upon the plaintiffs; and
because the plaintiffs’ just cause for remand, as well as
their 30-day entitlement to seek remand cannot expire until the
plaintiffs are properly served notice of the removal. (4) The
notice of removal falsely states the 2005-11458 case was filed in
January 2006.

In so falsifying the date of the August 24, 2005 lawsuit, the
defendants appear to be attempting to obscure the cause of action
for the false arrest of August 24, 2005 wherein defendant Neisha
Lange is cited and has been served the plaintiffs’ original
and supplemental petitions. * Please see the above exhibit of the
court stamped verification of the filing and docketing. * Please
see theexhibit of the May 9, 2006 federal court stamped
verification of the filing and docketing Jackson’s response.*
Also, please see the above exhibit of the court stamped
verification of the filing and docketing of the plaintiffs‘
supplemental petition.The fact of the plaintiff’s March 27,
2006 supplement petition, and various continual filings by the
defendants in state court despite their purported removal of this
case, gives clear further indications that the May 10, 2006 hearing
should not be held, because it was impossible for the plaintiffs to
know their August 24, 2005, purely state law case was, unbeknownst
to the plaintiffs forum-shopped, and brought to federal court,
through employment of false representations. (6) Because of the
fact that defendant, Federal Home Loan Association (Freddie Mac)
did not become served until April 18, 2006, because the
clerk’s office did not give the repeatedly requested long arm
citation, proves that at the time of the filing of the Rule 12(b)
Motions, due to the fact that the claims of the August 24, 2005
state court case under docket number 2005-11458 are entirely state
court claims, and due to the fact that there was no diversity
jurisdiction, this court did not even have subject matter
jurisdiction over the state court 2005-11458 case.was, unbeknownst
to the plaintiffs forum-shopped, and brought to federal court,
through employment of false representations. Because of the fact
that defendant, Federal Home Loan Association (Freddie Mac) did not
become served until April 18, 2006, because the clerk’s
office did not give the repeatedly requested long arm citation,
proves that at the time of the filing of the Rule 12(b) Motions,
due to the fact that the claims of the August 24, 2005 state court
case under docket number 2005-11458 are entirely state court
claims, and due to the fact that there was no diversity
jurisdiction, this court did not even have subject matter
jurisdiction over the state court 2005-11458 case.* Also, please
see the above exhibit of the court stamped verification of the
filing and docketing of the plaintiffs‘ supplemental
petition.The fact of the plaintiff’s March 27, 2006
supplement petition, and various continual filings by the
defendants in state court despite their purported removal of this
case, gives clear further indications that the May 10, 2006 hearing
should not be held, because it was was, unbeknownst to the
plaintiffs forum-shopped, and brought to federal court, through
employment of false representations. Because of the fact that
defendant, Federal Home Loan Association (Freddie Mac) did not
become served until April 18, 2006, because the clerk’s
office did not give the repeatedly requested long arm citation,
proves that at the time of the filing of the Rule 12(b) Motions,
due to the fact that the claims of the August 24, 2005 state court
case under docket number 2005-11458 are entirely state court
claims, and due to the fact that there was no diversity
jurisdiction, this court did not even have subject matter
jurisdiction over the state court 2005-11458 case.* Also, please
see the above exhibit of the court stamped verification of the
filing and docketing of the plaintiffs‘ supplemental
petition.The fact of the plaintiff’s March 27, 2006
supplement petition, and various continual filings by the
defendants in state court despite their purported removal of this
case, gives clear further indications that the May 10, 2006 hearing
should not be held, because it was was, unbeknownst to the
plaintiffs forum-shopped, and brought to federal court, through
employment of false representations. Because of the fact that
defendant, Federal Home Loan Association (Freddie Mac) did not
become served until April 18, 2006, because the clerk’s
office did not give the repeatedly requested long arm citation,
proves that at the time of the filing of the Rule 12(b) Motions,
due to the fact that the claims of the August 24, 2005 state court
case under docket number 2005-11458 are entirely state court
claims, and due to the fact that there was no diversity
jurisdiction, this court did not even have subject matter
jurisdiction over the state court 2005-11458 case.

* Also, please see the belowexhibit of the court stamped
verification of the filing and docketing of the plaintiffs‘
supplemental petition.The fact of the plaintiff’s March 27,
2006 supplement petition, and various continual filings by the
defendants in state court despite their purported removal of this
case, gives clear further indications that the May 10, 2006 hearing
should not be held, because it was was, unbeknownst to the
plaintiffs forum-shopped, and brought to federal court, through
employment of false representations. Because of the fact that
defendant, Federal Home Loan Association (Freddie Mac) did not
become served until April 18, 2006, because the clerk’s
office did not give the repeatedly requested long arm citation,
proves that at the time of the filing of the Rule 12(b) Motions,
due to the fact that the claims of the August 24, 2005 state court
case under docket number 2005-11458 are entirely state court
claims, and due to the fact that there was no diversity
jurisdiction, this court did not even have subject matter
jurisdiction over the state court 2005-11458 case.

* Also, please see the belowexhibit of the court stamped
verification of the filing and docketing of the plaintiffs‘
supplemental petition.The fact of the plaintiff’s March 27,
2006 supplement petition, and various continual filings by the
defendants in state court despite their purported removal of this
case, gives clear further indications that the May 10, 2006 hearing
should not be held, because it was was, unbeknownst to the
plaintiffs forum-shopped, and brought to federal court, through
employment of false representations. Because of the fact that
defendant, Federal Home Loan Association (Freddie Mac) did not
become served until April 18, 2006, because the clerk’s
office did not give the repeatedly requested long arm citation,
proves that at the time of the filing of the Rule 12(b) Motions,
due to the fact that the claims of the August 24, 2005 state court
case under docket number 2005-11458 are entirely state court
claims, and due to the fact that there was no diversity
jurisdiction, this court did not even have subject matter
jurisdiction over the state court 2005-11458 case.

STATEMENT RELEVANT TO JACKSON’S APRIL 5, 2006 RICO LAWSUIT
When because of logistics, the Magistrate Judge for the Western
District Federal Court in Caddo Parish recommended the transferring
of Jackson’s April 5, 2006 Complaint under Caddo Parish
docket number CV 06-581, it is evident the Magistrate determined
that Jackson’s April 5, 2006 Complaint stated claims for
which relief could be granted.

On April 20, 2006, Jackson filed in Caddo Parish her
“Opposition To Transfer.” However, on May 1, 2006 the
transfer was ordered by the Caddo Parish court.

Manifestly, because Jackson’s Western District Federal
Court racketeering Complaint had not arrived at New Orleans Eastern
District prior to May 1, 2006, it is evident that no Rule 12
Motions could have been filed and timely set to be heard on May 10,
2006. Moreover, Jackson’s April 5, 2006 Caddo Parish Suit
Demands A Trial By Jury.

Even though the Caddo lawsuit is a different case, the
mysterious, deceptive state court April 28, 2006 docket entry seeks
to give an appearance that Jackson’s “opposition to
transfer” pertains to the plaintiffs’ August 24, 2005
case. In fact, the mysterious April 28, 2006 entry into the record
a pleading for the entirely different case reveals that someone
intended that entry to be engrafted with the 2005-11458 state court
lawsuit. Specifically, although pleadings being submitted to the
Orleans Parish clerk’s office are supposed to be originals,
someone even took pains to draw a line through the Caddo Parish
docket number and fraudulently write “2005-11458.”

WHEREFORE, based on the foregoing facts and evidence, the
defendants motions must be denied with prejudice, and the
plaintiffs must become served with the defendants’ pleadings,
and thereafter afforded entitlement to file the plaintiffs’
responses.

Exhibits Pertaining to August 24, 2005 State Court Lawsuit for
“CONVERSION;” After I became displaced due to Hurricane
Katrina, unbeknownst to me, this Conversion lawsuit was confiscated
by Federal Judge A. J. McNamara.

Posted by Barbara Ann Jackson on May 19th 2006 to News

Exhibit 1 >Certificate of Service dated December 2005 for the
defendants’ Rule 12 motion.

Exhibit 2 >Plaintiffs’ State Court Amended Petition
filed March 27, 2006

Exhibit 3 > Plaintiff’s letter attached to the Amended
Petition and filing fees

Exhibit 4 > Orleans Civil Court Long Arm Citation for Federal
Home Loan (Freddie Mac) dated April 5, 2006. The date of this
citation proves that Freddie Mac WAS NOT a participant in the
fraudulent removal of the plaintiffs’ Stat Court case that
was filed based on State Law claims for Conversion. This salient
fact proves that this case was not federal subject matter, nor
divesity jurisdiction forming any basis for removal this case
-unbeknownst to the evacuated plaintiffs- to federal Judge
McNamara.

Exhibit 5 > docket entries showing date lawsuit was filed,
and showing the fact of the plaintiffs’ November 2005
letter

Exhibit 6 > docket entries proving Clerk of Court Dale
Atkins’ April 28, 2006 post-removal State Court Motion, and
Judge Gill-Jefferson’s May 1, 2006 signing of Atkins’
post-removal motion. (However, on May 2, 2006, Judge Jefferson
denied Jackson’s default motions and wrote that case was
removed to federal court, Judge McNamara.

Exhibit 7 > On March 23, 2006 State Court Judge Lloyd Medley
recused himself 7 months after the case was commandeered to Medley
despite Medley was being sued by Jackson for court corruption in a
different case. Glaringly, Judge Medley’s March 23, 2006 act
of recusing himself and assigning the case to Judge Gill-Jefferson
is deceptive in light of the fact that the case was said to have
been removed to federal court on March 17, 2006.

Exhibit 8 > last page of March 27, 2006 amended petition
proving the plaintiffs’ post-Katrina address was provided to
the defendants; and therefore the defendants had no reason to mail
their federal pleadings to New Orleans from which the plaintiffs
had evacuated.

Exhibit 9 > Post card from Judge Gill-Jefferson informing of
the May 26, 2006 show cause hearing in State Court. INK
“http://www.lawgrace.org/wp-content/uploads/2006/05/post_02_021.png”
\o “post_02-02″

The above exhibits prove: The plaintiffs were never furnished
the defendants’ Rule 12 dismissal motion, and therefore,
federal court Judge McNamara’s May 5, 2006ruling granting
dismissal –despite that the plaintiffs were oblivious their
non-federal subject matter case had been deceptively removed to
federal court and plaintiffs were deprived of their right to timely
seek a remand of their case; and despite the fact that the
plaintiffs were never served the Rule 12 motion for which they
could have timely filed their opposition, violates the
plaintiffs’ due process rights. * * *

Federal Judge McNamara’s May 5, 2006 reasoning erroneously
disregarded the fact that the Judge McNamara had absolutely no
federal jurisdiction. Also, the Judge overlooked the lack of
existence of GE Capital Mortgage Services corporation, and hence,
the impossibility of that corporation being a May 19, 2005
successful bidder in light of the fact GE Capital Mortgage Services
became defunct on October 25, 2002. Further, the plaintiff’s
lawsuit for Conversion is based on the illegal fraudulent deed that
was recorded on June 29, 2005 for the plaintiffs’ property,
not a revisit of the fraudulent foreclosure. The New Orleans courts
have made it clear that fraudulent foreclosures are acceptable.

The gist of the matter is simple: Since it is an irrefutable
fact -as proven by the Louisiana Secretary of State listing for
corporations, that GE Capital Mortgage Services ceased to exist on
October 25, 2002, it is impossible to declare GE Capital Mortgage
Services bid on the plaintiffs’ residence in May 2005. In
addition, the fact of GE Capital’s non-existence makes it
unequivocally fraudulent for the June 29, 2005 recordation of a
deed in GE Capital’s name. Also, the fact of GE
Capital’s non-existence makes manifest GE Capital did not /
could not have possibly sold the plaintiffs’ residence to
Freddie Mac on August 2005.

The bottom line is that for several years, Sheriff Paul Valteau,
and debt collectors such as Herschel Adcock, Dean Morris, and
George Dean have been fraudulently seizing, recording, and
transferring real estate property.

Additionally, it defies intelligence to state that a property
owners’ becoming delinquent on his or her mortgage endows a
debt collector with authority to fraudulently repossess the
property.

In like manner as described in the Times Picayune article
wherein people’s property was seized and held for ranson in
that December 15, 2004 article entitled: “Homeowners Sue. .
.,” debtor collector Adcock held Jackson’s property for
an unjust ransom, but Jackson refused, the longstanding standoff
ensued; and actionable wrongs occurred, and continue to occur
thereafter.

The facts are glaringly simple:

1. Because it is true that on October 25, 2002, GE Capital
Mortgage Services, Inc., ceased to exist, there is no lawful
justification for perpetrating GE Capital as “the successful
bidder” May 19, 2005 for Jackson’s property.

2. The fact of GE Capital’s October 25, 2002 extinction
renders the deed that Sheriff Valteau recorded on June 29, 2005 in
the name of GE Capital fraudulent.

3. Due to the fact that GE Capital ceased to exist on October
25, 2002, any August 2005 transfer sale of Jackson’s property
by GE Capital to Freddie Mac is an impossibility.

4. Due to the fact that Freddie Mac did not lawfully obtain
ownership of the Jackson property, Freddie was without legal
authority to file and be granted its writ of possession.

5. In October 2003,when CT Corporation Systems pretended to yet
be the registered agent for GE Capital Mortgage Services, and
accepted service of Jackson’s September 17, 2003 Unfair Debt
Collection lawsuit, CT Corporation was the conduit for the
protracted deceptive scheme of using GE Capital’s
identity.

5. Whomever has been passing him or her self off as GE Capital
Mortgage Services, Inc., is committing willful fraud.

6. To blindly endorse unlawful debt collection is to be reckless
and obtuse.

7. Unequivocally, no lawsuit (foreclosure or otherwise) can be
brought, or maintained by a non-existent entity; and neither can a
non-existent entity bid at an auction.

ALSO SEE: Amended and Supplemental Petition for
CONVERSION (entered in Orleans Parish Civil State Court
docket March 27, 2006)
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