On July 2, 2013, an attorney from the Defendant’s law firm showed
up in Court in a
“limited appearance” claiming to not know if her firm was counsel of record or
corporate legal counsel.2.
By virtue of their own correspondence dated June 26, 2013, Clayborne, Wagner &
Sabo stipulates to being “corporate counsel” for the Defendants et al
Plaintiff prays the Court’s mercy in finding the Defendant’s et al and their legal
counsel, Michael Wagner to have perjured themselves pursuant to the Code of CivilProcedure for making statements known to be untrue and misleading to the Courtregarding who was corporate counsel for the City of East St. Louis on the morning of July 2, 2013;4.
On Monday, August 5 plaintiff received a registered letter dated June 26, 2013
containing the Defendant’s belated written response to Plaintiff’s Freedom of
Information Request dated March 27, 2013, five months (approximately 150 days)beyond the time limits set forth in Section 3 of the Freedom of Information Act (5ILCS 140) of five (5) business days.5.
On that same day, Plaintiff received a package via regular mail which contained aMotion to Dismiss Case #13-MR-190 amongst other documents;6.
At no point has Attorney Wagner or his agent(s) served this Motion to Dismiss to thePlaintiff or on my
normal place of abode
followed up by a mailed copy as required