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NO.

M A-108796
________________________________________________________________________

IN THE SUPREME COURT OF THE STATE OF OKLAHOMA


________________________________________________________________________

LUCIOUS CLARENCE CONWAY, JR.,

Petitioner,

vs.

HONORABLE WILLARD L. DRIESEL,


Presiding Judge of The District Court
Of McCurtain County, Oklahoma

Respondent.
________________________________________________________________________

MANDAMUS FOR RECUSAL OF HON. WILLARD L. DRIESEL, TRIAL JUDGE

IN ACTION FOR QUIET TITLE OF REAL PROPERTY


________________________________________________________________________

APPELLANT’S SUPPLEMENTATION OF RECORD TO APPLICATION TO ASSUME


ORIGINAL JURISDICTION AND PETITION FOR WRIT OF MANDAMUS
________________________________________________________________________

LUCIOUS CLARENCE CONWAY, JR., PRO SE


HC 76 Box 54
Eagletown, OK 74734
(580) 835-2358
managermember@gmail.com

Pro Se Defendant Below

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INDEX

Summary of the Record………………………………....................................... 2-3

Standard of Review………………………………............................................. 3-8

Pierce v. Pierce, 2001 OK 97.……………………………................... 4

Miller Dollarhide, P.C. v. Tal, 2007 OK 58.………………………… 4

Clark v. Board of Education of IND. SCH. DIST. NO. 89, 2001 OK 56 .. 4

20 O.S., 1403.……………………………............................................. 5

12 O.S., Ch. 2, App., Rule 15..……………………………................... 6

Grounds for Disqualification of Trial Judge…………………………….…....... 8-10

Miller Dollarhide, P.C. v. Tal, 2007 OK 58.………………………..… 8

12 O.S., Ch. 2, App., Rule 15.……………………………..................... 9

5 O.S., Ch. 1, App. 3-A, Rule 3.5.……………………………............... 9

5 O.S., Ch. 1, App. 4, Section Canon 3.……………………………..... 10

Petitioner’s Right to Writ of Mandamus………………………………............. 10-12

20 O.S., Ch. 1, App. 2, Rule 7.……………………………................... 10

20 O.S., Ch. 1, App. 2, Rule 3.……………………………................... 11

12 O.S., Ch. 2, App., Rule 15.…………………………….................... 12

Conclusion………………………………........................................................... 12-13

12 O.S., Ch. 2, App., Rule 15.…………………………….................... 12

20 O.S., 1403.……………………………............................................. 12

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Pierce v. Pierce, 2001 OK 97.……………………………..................... 12

Clark v. Board of Education of IND. SCH. DIST. NO. 89, 2001 OK 56 12

Signature page and Certificate of Mailing………………………………........... 13

Appendix
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TABLE OF AUTHORITY

CITATION Page
No.

Pierce v. Pierce, 2001 OK 97.……………………………........................................4, 12

Miller Dollarhide, P.C. v. Tal, 2007 OK 58.…………………………….................4, 8

Clark v. Board of Education of IND. SCH. DIST. NO. 89, 2001 OK 56 .. ………4, 12

20 O.S., 1403.…………………………….................................................................5, 12

12 O.S., Ch. 2, App., Rule 15.…………………………….......................................6, 9, 12

5 O.S., Ch. 1, App. 3-A, Rule 3.5.…………………………….................................9

5 O.S., Ch. 1, App. 4, Section Canon 3.…………………………….......................10

20 O.S., Ch. 1, App. 2, Rule 7.…………………………….....................................10

20 O.S., Ch. 1, App. 2, Rule 3.…………………………….....................................11

12 O.S., Ch. 2, App., Rule 15.……………………………......................................12

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NO. M A-108796
________________________________________________________________________

IN THE SUPREME COURT OF THE STATE OF OKLAHOMA


________________________________________________________________________

LUCIOUS CLARENCE CONWAY, JR.,


Petitioner,

vs.

HONORABLE WILLARD L. DRIESEL,


Presiding Judge of The District Court
Of McCurtain County, Oklahoma

Respondent.
________________________________________________________________________

MANDAMUS FOR RECUSAL OF HON. WILLARD L. DRIESEL, TRIAL JUDGE

IN ACTION FOR QUIET TITLE OF REAL PROPERTY


________________________________________________________________________

APPELLANT’S APPENDIX TO SUPPLEMENTATION OF RECORD TO APPLICATION TO


ASSUME ORIGINAL JURISDICTION AND PETITION FOR WRIT OF MANDAMUS
________________________________________________________________________

Dated: November 11, 2010

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________________________________________________________________________

INDEX TO APPENDIX
________________________________________________________________________

PAGE

Appendix “A” (in camera meeting for recusal request, 6/14/10


Delivery Confirmation of request to Clerk of Court,
The Hon. Willard L. Driesel, 6/14/10) 2 Pages …..……...……………….. i

Appendix “B” (Defendant’s Motion To Recuse Judge, Defendant’s


Brief In Support Of Motion To Recuse Or Disqualify, Affidavit
In Support Of Motion To Disqualify Judge Driesel, Delivery
Confirmation of Motion, Brief and Affidavit to Kenneth R.
Farley, Attorney for Plaintiff‘s in lower case, 9/27/10) 15 Pages ……….. ii

Appendix “C” (Order Setting Hearing On Petition For Prohibitive


Injunction And For Writ of Assistance, 6/11/10,
Writ Of Assistance; Judge Driesel ruled on this petition
prior to date of Defendant’s notice and outside of
Defendant’s hearing, 6/18/10) 6 Pages …………………………………… iii

Appendix “D” (Order of Intra-District Assignment, Post-It Note


attached to Order, 6/28/10) 3 Pages ………………………………............ iii

Appendix “E” (Order of Recusal, 8/25/10) 1 Page ……………………………….iv

Appendix “F” (Court Minute Orders Denying Recusal,


Granting Plaintiffs Application To File Amended Petition) 1 Page …….. v

Appendix “G” (Clark v. Board of Education of IND. SCH. DIST.


NO. 89, 2001 OK 56) 5 Pages ………………………………................................ vi

Appendix “H” (Pierce v. Pierce, 2001 OK 97) 12 Pages ………………………… vii

Appendix “I” (Miller Dollarhide, P.C. v. Tal, 2007 OK 58) 12 Pages……………viii

Appendix “J” (12 O.S., Ch. 2, App., Rule 15) 1 Page…………………………….ix

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Appendix “K” (5 O.S., Ch. 1, App. 3-A, Rule 3.5) 1 Page………………………... x

Appendix “L” (20 O.S., 1403) 1 Page………………………………....................... xi

Appendix “M” (20 O.S., Ch. 1, App. 2, Rule 3) 1 Page…………………………… xii

Appendix “N” (20 O.S., Ch. 1, App. 2, Rule 7) 1 Page…………………………….xiii

Appendix “O” (5 O.S., Ch. 1, App. 4, Section Canon 3) 4 Pages………………….xiv


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IN THE SUPREME COURT OF THE STATE OF OKLAHOMA

LUCIOUS CLARENCE CONWAY, JR. )


)
Petitioner, )
vs. ) No. MA-108796
)
THE HONORABLE WILLARD L. DRIESEL )
PRESIDING JUDGE OF THE DISTRICT )
COURT OF MCCURTAIN COUNTY, )
OKLAHOMA, )
)
Respondent. )
________________________________________________________________________

SUPPLEMENTATION OF RECORD

COMES NOW LUCIOUS CLARENCE CONWAY, JR., Pro Se (hereinafter “Conway”),

Defendant in McCurtain County District Court Case number CV-2009-636 (hereinafter “lower court

case”), pursuant to 20 O.S., Section 1403, 12 O.S., Ch. 2, App., Rule 15, Rule 1.191 (b), Due Process

Clauses of the Const. amend. XIV, and V, as well as Art. 2 Section 7 of the Oklahoma

Constitution, and supplementing the record for his first Supplementation Of Record and applying to

this Court to assume original jurisdiction in this matter and grant a writ of mandamus directed to the

respondent judge, the Honorable Willard L. Driesel, Chief Judge Of The District Court of McCurtain

County as well as Presiding Judge of Oklahoma’s 17th Judicial District (hereinafter the Judge)

requiring him to disqualify himself and rescind any order he issued after the filing

of the Petitioners’ “Motion To Recuse Judge” in proceeding before him.

SUMMARY OF CASE:

1. That Petitioner here refers to his original Application To Assume Original Jurisdiction

And Petition For Writ of Mandamus on file herein and incorporates the same herein by reference.
2. On June 14, 2010, Conway hand delivered a letter to the clerk of the lower court case,
requesting an in camera meeting and to the Judge in the lower court case as well as to Kenneth R.
Farley, attorney for the plaintiff’s in the lower court case plainly asking the Judge for the opportunity
to “…discuss [his] disqualification or transfer of my case to another judge.” Also, Conway in the letter
stated “…you must disqualify yourself from further hearing, ruling or presiding over this case any
longer.”
3. Plaintiffs in lower court case filed Petition For Prohibitive Injunction And For Writ of
Assistance on June 8, 2010.
5. Order Setting Hearing On Petition For Plaintiff’s Prohibitive Injunction And For Writ of
Assistance was filed June 11, 2010, signed by the Judge set the hearing for July 7, 2010.
6. Plaintiffs in lower court case, on June 16, 2010 filed Motion to Continue Hearing on
their Petition For Prohibitive Injunction And For Writ of Assistance.
7. On June 18, 2010 the Judge granted and issued Plaintiff’s in the lower court case Writ of
Assistance without hearing.
8. On June 28, 2010, overruling Conway’s objections the Judge struck and reset Plaintiff’s
Proposed Scheduling Order filed May 7, 2010, after previously rescheduling same Proposed
Scheduling Order set for May 13, 2010 to June 11, 2010, and then to June 28, 2010, and then to July
27, 2010.
9. On June 28, 2010, “Pursuant to Rule 7 of the Rules for Administration of Courts,
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as promulgated my the Supreme Court of the State of Oklahoma” the Judge by Order Of Intra-District
Assignment, transferred the lower court case to the Honorable James Wolfe, Associate District Judge,
Choctaw County, Hugo, Oklahoma. And, mailed me a copy of said Order with post-it note attached
stating “Proposed Scheduling Order was sent to Judge Wolfe with the assignment.”
10. the Honorable Judge Wolfe did not appear at the aforementioned hearing on July 27,
2010. And, the Judge struck the aforementioned Proposed Scheduling Order from the docket and did
not reset it.
11. On August 25, 2010 the Honorable Judge Wolfe filed an Order Of Recusal stating no
reason therefore.
12. On September 27, 2010, Conway filed Defendant’s Motion to Recuse Judge,
Defendant’s Brief In Support Of Motion To Recuse/Disqualify, Affidavit In Support Of Motion To
Disqualify. And, Defendant’s Opposition To Plaintiff’s Motion For Leave To File Second Amended
Petition.
13. On October 6, 2010, the Judge Denied Motion For Recusal As Untimely And in
Violation Of Rule 15. And, granted plaintiffs in lower court case Application to File Amended Petition
Joining Necessary Parties.
14. The Judge has continuously served as the chief and presiding judge at all times
throughout the lower court case proceedings hereinto referred.
ARGUMENT AND AUTHORITY:

Standard of Review:

Any party to any cause pending in a court of record may in term time… file a written

application with the clerk of the court, setting forth the grounds or facts upon which the claim is made

that the Judge is disqualified, and request said judge to do so to

certify, after reasonable notice to the other side, same to be presented to such judge, and

upon his failure to do so within three (3) days before said cause is set for trial, application may be made

to the proper tribunal for mandamus requiring him to do so. Pierce v. Pierce, 2001 OK 97.

In Miller Dollarhide, P.C. v. Tal, 2007 OK 58, the Oklahoma Supreme Court ruled:

“…the three-step process for challenging the assigned judge’s neutrality


and detachment under District Court Rule 15: 1) the party must
first informally ask the trial judge in camera to recuse from the case
or to transfer it to another judge; 2) when met with an unsatisfactory response, the
requesting party must then formally request (not less than 10 days before the case is set for trial)
that the trial judge recuse or transfer the cause; 3; if the trial judge refuses to recuse, the party
may then re-present the earlier formal request to the chief judge of the county where the case is
pending. If the latter hearing should also result in an adverse order, the aggrieved
litigant may then seek relief by mandamus in this Court …when a trial court is presented with
a request to disqualify, it is not a matter of discretion to refrain from presiding over the case
until the disqualification ruling is memorialized and the movant has, at the movant’s option,
exhausted the Rule 15 procedure.”

Petitioner seeks an Order of this Court, prohibiting Hon. Willard L. Driesel from continuing as

judge in this cause for the following reasons:

a. Deprivation of Due Process to Conway

As stated hereinbefore, the Judge continued to preside over the lower court case after
Conway filed the formal Motion to Recuse Judge. As previously cited in Miller Dollarhide v. Tal, 2007

OK 58 this contravenes well settled Oklahoma law. Also see

Clark v. Board of Education of IND. SCH. DIST. NO. 89, 2001 OK 56 wherein the

Court states:

“A fundamental requirement of due process is a fair and impartial trial. A neutral


and detached judiciary is imperative to ensure procedural fairness
to individual litigants and to preserve public confidence in the integrity
of the judicial process.”

On June 14, 2010, Conway hand delivered a copy of the letter to the clerk of the lower court
case, requesting an in camera meeting and to the judge in the lower court case as well as to Kenneth R.
Farley, attorney for the plaintiff’s in the lower court case plainly asking the Judge for the opportunity to
“…discuss [his] disqualification or transfer of my case to another judge.” Also, Conway in the letter
stated “…you must disqualify yourself from further hearing, ruling or presiding over this case any
longer.”
Under 20 O.S., 1403:
“ Any party to any cause pending in a court of record may in term time
or in vacation file a written application with the clerk of the court, setting
forth the grounds or facts upon which the claim is made that the
judge is disqualified, and request said judge so to certify, after reasonable
notice to the other side, same to be presented to such judge, and upon his
failure so to do within three (3) days before said cause is set for trial,
application may be made to the proper tribunal for mandamus requiring
him so to do.”

Furthermore, in Pierce v. Pierce, 2001 OK 97, the Court stated:

“The original purposes of Section 1403 were to provide a procedure


to avoid a trial before a disqualified judge, and to create a court
record on the disqualification issue so that the jurisdiction of the
replacement judge would appear on the face of the record. Ex parte
Hudson, 1910 OK CR 3... We have explained that since the
adoption of section 1403 where a party had knowledge of the alleged
grounds of the disqualification of the trial judge for more than
three days prior to the trial, and that party did not use the
procedure prescribed by that section, the party cannot
urge the disqualification on appeal, or in a collateral attack, on the
judgment rendered and order made by said judge. State ex re.
5
Dabney v Ledbettter, 1932 OK 229,… quoting, Holloway v. Hall, 1920
OK 287, …Thus when the statute states that a party “may” file
a written application with the court clerk to disqualify a judge the
language is permissive in the sense that a party may or may
not file the application, but if the party seeks judge disqualification
we have held that filing the statutory application is mandatory…
We have stated: The procedure, under proper circumstances, may
be by mandamus, ”

Under this well settled law mandamus is an appropriate option for Conway as having followed

the aforementioned procedure considering Conway’s letter of request for judicial disqualification prior

to filing his Motion to Recuse Judge meeting the initial procedural requirement of 12 O.S., Ch. 2, App.,

Rule 15(a), which states in relevant part that:

“Before filing any motion to disqualify a judge, an in camera request


shall first be made to the judge to disqualify or to transfer the
cause to another judge…”

In addition, Conway filed his Motion to Recuse on September 27, 2010 when he realized that

the Judge was still making rulings in the case after the aforementioned letter requesting recusal had

been delivered to the lower court case clerk, adverse counsel and to the judge, fulfilling the mandate of

12 O.S., Ch. 2, App., Rule 15(a), which provides:

“…If such request is not satisfactorily resolved, not less than ten
(10) days before the case is set for trial a motion to disqualify a
judge or transfer a cause to another judge may be filed and a copy
delivered to the judge.”

Upon the Judge’s refusal to grant Conway’s Motion To Recuse entered October 6,

2010, Conway notified the judge in open court that he intended to exercise his procedural

rights under 12 O.S., Ch. 2, App., Rule 15(a), which in significant part states:

“Any … party who deems himself aggrieved by the refusal of a


judge to grant a motion to disqualify or transfer a cause to another
judge may re-present his motion to the Chief Judge of the county
in which the cause is pending or, if the disqualification of a Chief
Judge is sought , to the Presiding Judge of the administrative
district by filing in the case within five (5) days from the date of said
refusal a written request for re-hearing. A copy of the request shall be
mailed or delivered to the Chief Judge or Presiding Judge, to the
adverse party and to the judge who entered the original order…”

Here, this Court must determine an issue of first impression. Conway did re-present his Motion

To Recuse to the Presiding Judge as the judge in the lower court case is also the Chief Judge of the

District as well as the Presiding Judge of the administrative district. The request for re-hearing was

written and made orally, in light of the fact that it is the Motion to Recuse filed on September 27, 2010,

that must be re-heard and said document had in fact been filed and delivered to said Presiding Judge as

well as the adverse party and the Judge who entered the original order within the time prescribed by

statute, and was before the Presiding Judge at the time re-hearing was requested.

Additionally, Conway, orally requested re-hearing a minimum of two times after the Judge’s

initial denial of Conway’s Motion To Recuse Judge as witnessed by opposing counsel in the lower

court case and testified to before this tribunal in the hearing of Oral Argument on November 9, 2010,

making in effect, two more ore tenus motions for re-hearing. And, said motion was denied orally by the

Judge a minimum of

three times, and on the second denial Conway asked the Judge on what grounds his

denial relied and the Judge stated “For violation of Rule 15. You should have come to my chambers

that’s what in camera means.” Again, for the third time Conway asked the Judge to disqualify and the

Judge denied. And, in the same Court Minutes granted Plaintiffs in the lower court case leave to file an

amended petition.

12 O.S., Ch. 2, App., Rule 15(b) states in pertinent part that:

“If the hearing before the second judge results in an order adverse
to the movant, he shall be granted not more than five (5) days to
institute a proceeding in the Supreme Court… for a writ of mandamus…”

This Court has clear jurisdiction over this matter as hereinbefore shown, Conway has fulfilled

all the procedural requirements of 20 O.S., 1403, as well as 12 O.S., Ch. 2, App., Rule 15, in addition
to the well settled law established and cited in Pierce v. Pierce, 2001 OK 97, Miller Dollarhide, P.C. v.

Tal, 2007 OK 58, and Clark v. Board of Education of IND. SCH. DIST. NO. 89, 2001 OK 56.

Grounds for Disqualification of Trial Judge:

Clearly the orders of the Judge recorded in the lower court case minutes of October 6, 2010

demonstrates the bias of the Judge in depriving due process to Conway, and presents grounds more

than sufficient for his disqualification. In Miller Dollarhide, P.C. v. Tal, 2007 OK 58, this Court ruled

that:

“Pursuant to Clark v. Board of Education of IND. SCH. DIST. NO. 89,


supra, the actions of the trial court in its continued participation
while motions to disqualify are pending results in a deprivation
of due process and constitute reversible error… Because the
trial court continued to participate while motions to disqualify were
8
pending, the movant was deprived of due process and reversible
error occurred. “

12 O.S., Ch. 2, App., Rule 15(b) states:

“If the hearing before the second judge results in an order adverse
to the movant, he shall be granted not more than five (5) days to
institute a proceeding in the Supreme Court…”

Furthermore, the Judge’s reading and application of 12 O.S., Ch. 2, App., Rule 15(a) which

states:

“…an in camera request shall first be made to the judge to disqualify


or to transfer the cause to another judge.”

Together with 5 O.S., Ch. 1, App. 3-A, Rule 3.5 stating:

“A lawyer shall not:


(b) communicate ex parte with such a person during the proceeding
unless authorized to do so by law or court order;”

As well as Miller Dollarhide, P.C. v. Tal, 2007 OK 58 wherein this court found non-fatal nor

defective, but, sufficient and relevant, the written request for in camera meeting under 12 O.S., Ch. 2,

App., Rule 15(a):

“…but the following facts are relevant to disposition of this appeal.


The appellant, … sought to remove the trial judge when he made a
written in camera request under District Court Rule 15 for recusal…”

However, the Judge erroneously denied Conway’ in camera request, stating in open court that

Conway should have come to his chambers instead of putting the in

camera request in writing. The previous points of law and facts were pointed out to the

Judge in open court underscoring that Conway’s formal and informal requests for the Judge’s recusal

should have been answered with the Judge’s recusal.

5 O.S., Ch. 1, App. 4, Section Canon 3(E)(1)(a):

“Disqualification.
(1) A judge should disqualify himself … in a proceeding in which the judge’s
impartiality might reasonably be questioned, including but not limited to instances
where: (a) the judge has a personal bias or prejudice concerning a party…”

Conway has demonstrated the bias of the Judge in his continued ruling and presiding over the

lower court case while the Motion to Recuse is pending, which also under both Pierce and Clark, supra

also has shown the Judge’s abuse of discretion.

Petitioner’s Right to Writ of Mandamus:

Conway has shown that he has (1) first informally asked the trial judge in camera to recuse from

the case or to transfer it to another judge, (2) Conway has formally requested (not less than ten (10)

days before the case is set for trial) that the trial judge recuse or transfer the cause, (3) he has re-

presented the earlier formal request to both the Chief Judge of the County where the case is pending as

well as the Presiding Judge of the administrative district, and finally (4) he is seeking mandamus in this

Court. Clark, supra.

In his Order of Intra-District Assignment dated June 28, 2010, the judge invoked his authority

as both Chief Judge and Presiding Judge under 20 O.S., Ch. 1, App. 2, Rule
7, which in significant part states:

10

“Subject to the administrative authority of the Supreme Court and of

the Presiding Judge, the district judge shall have plenary control and

supervision of the court’s docket and shall be vested with the power

to prescribe by rules and directives how cases shall be assigned to

the judicial personnel serving the district courts within the district

court judicial district of which he is in charge… Such designated

judge shall be known as the Chief Judge of the court…”

and 20 O.S., Ch. 1, App. 2, Rule 3, which states in pertinent part:

“All orders of the Presiding Judge consigning judges and court officials
to a court other than that which they are regularly serving shall be
made only at the request of a district judge and on showing of good cause.”

The facts show that the Judge entered an Order of Intra-District Assignment which he could

only have done under the authority of Rule 7 as he cited with his request to and consent by himself as

the Presiding Judge having shown himself good cause under Rule 3, in assigning the Hon. James Wolfe

who serves the Hugo County District Court to serve in the lower court case hereinto referred which is

in McCurtain County District Court.

Under the following facts when Conway appeared before the Court in theory he would have

been appearing before the Judge as Presiding Judge and said formal Motion To Recuse would have

been effectively served to the Judge in that capacity, as the

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trial/Chief Judge transferred the case with the Presiding Judge‘s knowledge and consent. And, so when

the Motion To Recuse was filed it would have rightly been presented to the “second judge” of 12

O.S., Ch. 2, App., Rule 15(b) states in pertinent part that:


“If the hearing before the second judge results in an order adverse
to the movant, he shall be granted not more than five (5) days to
institute a proceeding in the Supreme Court… for a writ of mandamus…”

Conway has followed statutory procedural requirements to the letter. The Judge has not.

Conclusion:

Finally, a party seeking disqualification of a judge in a civil proceeding must follow the

procedure outlined in 12 O.S., Ch. 2, App., Rule 15 which procedure was followed by Conway. The

original purposes of 20 O.S., 1403 were to provide a procedure for parties to avoid a trial before a

disqualified judge which may only be remedied by mandamus. It is not a matter of discretion to refrain

from presiding over the case while a request to disqualify is pending and the Judge was not free to

proceed with the case until the challenge stood overruled of record following a judicial inquiry into the

issue which includes review by this very tribunal. Pierce and Clark.

The Judge has deprived Conway of his Constitutionally protected right to due process in

addition to gross abuse of discretion, and under Clark, Conway is entitled, as a matter of law to

mandamus relief and his Application to Assume Original Jurisdiction

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and Petition for Writ of Mandamus should be granted together with rescinding all orders

entered by the Judge during the pendency of Conway’s Motion to Recuse.

DATE: November 11, 2010.

________________________________
LUCIOUS CLARENCE CONWAY, JR.
HC 76 Box 54
Eagletown, Oklahoma 74734
(580) 835-2358
CERTIFICATE OF MAILING TO PARTIES AND COURT CLERK

I certify that a true and correct copy of the Supplementation of Record was mailed this 11th

day of November, 2010, to the District Court In And For McCurtain County, 108 N. Central, Idabel,

Oklahoma 74745 and Kenneth R. Farley, P.O. Box 748, Idabel, Oklahoma 74745 by depositing it in the

U.S. Mails, postage prepaid.

______________________________
Lucious Clarence Conway, Jr.

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