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Landrith_Lipari_Motion_for_Sanctions

Landrith_Lipari_Motion_for_Sanctions

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Published by Bret Landrith
Notice of intent to file sanctions against Chief Justice John Roberts of the US Supreme Court for his misconduct in the District of COlumbia trial court.
Notice of intent to file sanctions against Chief Justice John Roberts of the US Supreme Court for his misconduct in the District of COlumbia trial court.

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Published by: Bret Landrith on May 01, 2013
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05/01/2013

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!1!
 
In The United States District CourtFor The District Of Columbia
BRET D. LANDRITH, )SAMUEL K. LIPARI )
Case No. 12-cv-01916-ABJ
 
 Plaintiffs
))
vs.
))Hon. JOHN G. ROBERTS, JR., )Chief Justice of the United States )
 Defendant 
)
RULE 11 MOTION FOR SANCTIONS
 Comes now the plaintiffs, BRET D. LANDRITH and SAMUEL K. LIPARI,appearing
 pro se
and make the following motion for sanctions under Rule 11.
STATEMENT OF POINTS
1. Chief Justice JOHN G. ROBERTS, JR. committed the specific conduct alleged below to violate subdivision (b) of Rule 11 when USA Ronald C. Machen Jr., Chief CivilASA Daniel F. Van Horn, and ASA Claire Whitaker signed and filed the Renewed andSupplemental Motion to Dismiss pleading, Doc. #14 on 4/22/2013 as Chief Justice JOHNG. ROBERTS, JR.’s representatives and agents.2. The Renewed and Supplemental Motion to Dismiss pleading, Doc. #14 expresslystates at page 2 that it incorporates by reference the challenged contentions, allegation,and denials of the earlier Motion to Dismiss, Doc. #9 that Chief Justice JOHN G.ROBERTS, JR was given notice in the plaintiffs’ Amended Complaint Doc. # 11 at pages22-40, ¶¶ 74- 102 and plaintiffs’ 04/08/2013 Response To Order Of The Court Doc. # 13that he is required to withdraw and correct.
 
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A. Material Misrepresentations to the Tribunal
3. On 4/22/2013 in the pleading Renewed and Supplemental Motion to Dismiss pleading, Doc. #14 Chief Justice JOHN G. ROBERTS, JR., USA Ronald C. Machen Jr.,Chief Civil ASA Daniel F. Van Horn, and ASA Claire Whitaker knowingly made againthe misrepresentation in Motion to Dismiss (Doc. # 9) that “..there is no support inMcBryde for their proposition that this Court is authorized to impose injunctive relief onthe Chief Justice.” Chief Justice JOHN G. ROBERTS, JR. (Doc. #9 at pg. 7).4. On 4/22/2013 in the pleading Renewed and Supplemental Motion to Dismiss pleading, Doc. #14 Chief Justice JOHN G. ROBERTS, JR., USA Ronald C. Machen Jr.,Chief Civil ASA Daniel F. Van Horn, and ASA Claire Whitaker knowinglymisrepresented the plaintiffs’ original and amended complaints through omission of (Doc. 1 Pg. ¶22) “Neither plaintiff has appeared before the defendant in his capacity as a judge or justice” for the purpose of intentionally misrepresenting the application of 
 In re Marin,
956 F.2d 339, 340 (D.C. Cir.) to procure a dismissal through fraud on the court asthe compliant alleges District of Kansas USA Barry R. Grissom procured a dismissal of the W.D. of Oklahoma defendants.5. On 4/22/2013 in the pleading Renewed and Supplemental Motion to Dismiss pleading, Doc. #14 Chief Justice JOHN G. ROBERTS, JR., USA Ronald C. Machen Jr.,Chief Civil ASA Daniel F. Van Horn, and ASA Claire Whitaker knowinglymisrepresented the plaintiffs’ original and amended complaints through omission of expressly states ( Doc. 1 Pg. ¶22) “Neither plaintiff has appeared before the defendant inhis capacity as a judge or justice” and in Count I “The defendant is liable to the plaintiffsfor prospective injunctive relief restraining his ministerial and executive administration of 
 
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the Judicial Conference of the United States, where the Chief Justice Hon. JOHN G.ROBERTS, JR. functions in a ministerial capacity as the chief executive” ( Doc. 1 Pgs.22-23) to give notice that
 In re Marin,
956 F.2d 339 (D.C. Cir.) is inapplicable.6. On 4/22/2013 in the pleading Renewed and Supplemental Motion to Dismiss pleading, Doc. #14 Chief Justice JOHN G. ROBERTS, JR., USA Ronald C. Machen Jr.,Chief Civil ASA Daniel F. Van Horn, and ASA Claire Whitaker knowinglymisrepresented the plaintiffs’ original and amended complaints as seeking relief fromrulings by judges through the false statement “Nothing that the Chief Justice does in hiscapacity as “Chief Executive Officer” of the Judicial Conference relates in any way tocontrolling the manner in which federal judges rule. 28 U.S.C. §§ 331-32. Thus, there isno injury–in–fact that is connected to the Chief Justice’s conduct ” Chief Justice JOHNG. ROBERTS, JR. (Doc. #9 at pg. 8)”7. On 4/22/2013 in the pleading Renewed and Supplemental Motion to Dismiss pleading, Doc. #14 Chief Justice JOHN G. ROBERTS, JR., USA Ronald C. Machen Jr.,Chief Civil ASA Daniel F. Van Horn, and ASA Claire Whitaker knowingly made thematerial factual misrepresentation to this court (Doc. #9 at pg. 8) that he has nothing todo with judicial misconduct policy, when the complaint and amended complaint seeks tomodify the way judicial ethics complaints are published, a decision he made in theexercise of his administrative capacity power in response to Implementation of theJudicial Conduct and Disability Act of 1980
 A Report to the Chief Justice
The JudicialConduct and Disability Act Study Committee Stephen Breyer, Chair September 2006.8. On 4/22/2013 in Doc. 14 at page 3Chief Justice JOHN G. ROBERTS, JR., USARonald C. Machen Jr., Chief Civil ASA Daniel F. Van Horn, and ASA Claire Whitaker 

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