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CES Letter to Clerk EDNY 09-Cv-4888 121809

CES Letter to Clerk EDNY 09-Cv-4888 121809

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Published by Chris Strunk
Strunk's Notice of intent for appearance at the Tuesday Hearing 12/22/09 in re Petitioner Request for Pre-motion conference to intervene as of right and to reconsider the 12/11/09 Decision and Order of Defendants Reply to responses due Monday 12/21/09. That this Notice is done following a phone call to Victor Joe, the Case manager, to ascertain the status of the Letter which has not been entered into the docket and that Declarant stated he would be present at the Hearing on Tuesday December 22. 2009; and is prepatory of an Original Proceeding in 2nd Circuit for a Extraordinary Writ of Mandamus on Wednesday absent substantive due process.
Strunk's Notice of intent for appearance at the Tuesday Hearing 12/22/09 in re Petitioner Request for Pre-motion conference to intervene as of right and to reconsider the 12/11/09 Decision and Order of Defendants Reply to responses due Monday 12/21/09. That this Notice is done following a phone call to Victor Joe, the Case manager, to ascertain the status of the Letter which has not been entered into the docket and that Declarant stated he would be present at the Hearing on Tuesday December 22. 2009; and is prepatory of an Original Proceeding in 2nd Circuit for a Extraordinary Writ of Mandamus on Wednesday absent substantive due process.

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Published by: Chris Strunk on Dec 19, 2009
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12/18/2009

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 1Christopher-Earl: Strunk in esse593 Vanderbilt Avenue - #281Brooklyn, New York 11238Cell phone: (845) 901-6767E-mail: chris@strunk.ws
 
Clerk of the CourtFor the United States District Court forThe Eastern District of New York 225 Cadman Plaza EastBrooklyn, New York 11201Regarding:
 ACORN et al. v. U.S.A. et al.
(09-cv-4888) (NG) (LB)Subject: Notice of intent for appearance at the Tuesday Hearing12/22/09 in re Petitioner Request for Pre-motion conferenceto intervene as of right and to reconsider the 12/11/09Decision and Order of Defendants Reply to responses dueMonday 12/21/09.Clerk of the Court,I am Intervener-petitioner, Christopher-Earl: Strunk in esse, state under penalty forperjury with 28 USC §1746, that Declarant is self represented without being an attorney, thaton December 16, 2009 I filed notice as a Letter with Local Rules, Chamber’s Rule 3 as to myrequest for a pre-motion conference for permission to file for intervention with Federal Rulesfor Civil Procedure (FRCvP) Rule 24(a) and Rule 24(b).That the Clerk of the Court filed my letter December 16, 2009 a copy of the stampedfirst page, see attached.That the Clerk has not entered the Letter into the Docket. However, at Docket 18Defendants’ motion dated December 16, 2009 (Docket No. 11), defendants move forreconsideration of the Court’s December 11, 2009, opinion and order granting plaintiffsmotion for a preliminary injunction. In the alternative, defendants seek amendment of theinjunction. Plaintiffs, on December 17, 2009, submitted an amended complaint. Plaintiffs alsoseek modification of the preliminary injunction. Defendants are directed to file their responseto plaintiffs motion by 5:00 PM on December 18, 2009. Plaintiffs are directed to respond todefendants motion by the same date and time. The parties are directed to appear for a hearingon their motions on Tuesday, December 22, 2009, at 2:30 PM, in Courtroom 6D South, 225Cadman Plaza East, Brooklyn, New York. Ordered by Senior Judge Nina Gershon on12/17/2009.Per Chamber’s Rule 3, Plaintiffs and Defendants are to respond to the Letter byMonday and as such Declarant will seek to speak at the hearing in reply as the Decision andOrder directly affects Declarant in an ongoing case
Strunk v. The US Department of Commerce Bureau of Census et al.
DCD 09-cv-1295 before District Judge Richard J. Leonwith an 18 USC 1964(c) cause of action in which Plaintiffs are alleged associates-in-fact inthe Enterprise in the conduct of the 2010 Census Enumeration that injures Declarant.
 
 2That this Notice is done following a phone call to Victor Joe, the Casemanager, to ascertain the status of the Letter which has not been entered into the docket andthat Declarant stated he would be present at the Hearing on Tuesday December 22. 2009.Dated: December 18
th
, 2009 /s/ Brooklyn New York __________________________Christopher-Earl: Strunk in esse593 Vanderbilt Avenue #281Brooklyn, New York 11238(845) 901-6767 / chris@strunk.wscc:
 
Magistrate Judge Lois Bloom
 
Darius Charney, Esq. Center for Constitutional Rights 666 Broadway, 7th Floor New York, NY 10012 212-614-6464 Fax: 212-614-6499 Email: dcharney@ccrjustice.org
 
Peter D. Leary USAAG Department of Justice 20 Massachusetts Avenue, NW Room 7322 Washington, DC20530 (202)514-3313 Fax: (202)616-8470 Email: peter.leary@usdoj.gov, bradley.cohen@usdoj.gov,franklin.amanat@usdoj.gov
 
Andrew Cuomo New York State Attorney General 120 Broadway 24
th
Floor New York New York 10271
 
New York State Supreme Court Justice David I. Schmidt 360 Adams Street Brooklyn New York 11201
 
Counsels to parties in
Strunk v. The US Department of Commerce Bureau of Census et al.
DCD 09-cv-1295before District Judge Richard J. Leon:Wynne P. Kelly,Assistant United States Attorney555 4th St., N.W.Washington, D.C. 20530(202) 305-7107Email:wynne.kelly@usdoj.gov Representing: Federal DefendantsJohn Marcus McNichols, Esq.WILLIAMS & CONNOLLY, LLP725 12th Street, NWWashington, DC 20005(202) 434-5043Email: jmcnichols@wc.com Representing:the Maryland Province of the Society of JesusJohn Michael Bredehoft, Esq.KAUFMAN & CANOLES, P.C.150 West Main Street – P.O. Box 3037Norfolk, VA 23514(757) 624-3225 Fax: (757) 624-3169Email: jmbredehoft@kaufcan.com Representing:The New York Province of the Society of JesusMs. Maria J. Rivera, Esq.TEXAS OFFICE OF THE ATTORNEY GENERALP.O. Box 12548Austin, TX 78711(512) 475-4099Email:maria.rivera@oag.state.tx.us Representing: the State of TexasSeth E. Goldstein,Deputy Attorney GeneralCalifornia Department of JusticeOffice of the Attorney General1300 “I” Street – Suite 125Sacramento, California 94244-2550(916) 327-2364Email:seth.goldstein@doj.ca.gov Representing: the State of CaliforniaStephen Kitzinger,Assistant Corporation CounselNew York City Law DepartmentOffice of Corporation Counsel100 Church StreetNew York, New York 10007(212) 788-0849 Fax: (212) 788-8877Email:skitzing@law.nyc.gov Representing: The city of New York and Mayor
 
'1
~'CT?ii~T
OURT
'
'
?Ic
TRICT
Senior
District
Judge ~inad)ershon
l
b
'6
For the United States District cod orThe Eastern District of New York225 Cadman Plaza EastBrooklyn, New York 11201Christopher-Earl: Strunk in
esse
593 Vanderbilt Avenue
-
#28 1Brooklyn, New York 11238Cell phone: (845) 901-6767E-mail: chris@strunk.wsRegarding: ACORN et
al.
v. U.S.A.
et
al.
(09m-4888)
(NG)
(LB)Subject: Request for Pre-motion conference to intervene as of right andto reconsider the 1211 1/09 Decision and Order of DefendantsSenior Judge,NinaGershon,I
am
he Intervener-petitioner, Christopher-Earl: Stnmk in esse, state under penalty forperjury with
28
USC
5
1746, that Declarant is self represented without being an attorney, herebyrequests with
Local
Rules, Chamber's Rule 3
('I
a pre-motion conference for permission to filefor: (i.) the intervener-petitioner notice of motion to intervene as of right and leave as apermissive Intervener-Defendant, that with Federal Rules for Civil Procedure (FXCvP) Rule
24(a)
and Rule 24@);
(ii.)
reconsideration of the December 11,2009 Decision and Order
b
enjoining Defendants in that the Court has made errors in matters of equity and law that exceeddiscretion in that the remedy afforded neglects readily available process that should be affordedto
protect
unnamed
individuals injured
by
Plaintiffs involvement in the alleged racketeeringenterprise otherwise properly protected by the Defendants Continuing Resolution (CR), (iii)defense and cross motion that there is an absence of essential parties-in interest; (iv.) defense thatno jurisdiction is afforded with the clean hands doctrine
as
Plaintiffs are estopped fiom seekingequity remedy;
(v.)
otherwise this matter goes to Declarant's additional application that theJudge recuse fiom further hearing with
28
USC
$455, applies in appearance of a fiiendly
case
is
the Court's impropriety bias antithetical to the oath to uphold the Constitution, favors the JesuitDoctrine of "Social Justice" disclosed by Plaintiffs' counsel at paragraph 1 of the Complaint.
3.
Motions
-
A.
Pre-Motion Conferences in Civil Cases.
For discovery motions, follow LocalCivil Rules 37.3 and 6.4. For motions other than discovery motions, in all cases w$ere the partiesare represented by counsel
and
in
other than habeas corpuslprisoner petitions and Social Securityand Bankruptcy appeals, a pre-motion conference with the court is required before making
any
dispositive motion, or motion for a change of venue.To arrange a pre-motion conference, the moving party shall submit a letter not to exceedthree (3) pages in length setting forth the basis for the anticipated motion. All parties so sewedmust serve and
file
a letter response,
not
to
exceed
three (3) pages within seven
(7)
days
from
service of the notification letter. Service of the letter by the moving
party
within the timerequirements of Rule 12 of the Fed. R. Civ. P. shall constitute timely service of a motion madepursuant to Fed. R. Civ.
P.
12 (b).
'L
The term "social justice" was coined by the Jesuit Luigi Taparelli in the 1840s, based on the

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