Your SlideShare is downloading. ×
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937
Upcoming SlideShare
Loading in...5
×

Thanks for flagging this SlideShare!

Oops! An error has occurred.

×
Saving this for later? Get the SlideShare app to save on your phone or tablet. Read anywhere, anytime – even offline.
Text the download link to your phone
Standard text messaging rates apply

MaryJaneDuchene_Mayor Candidate_WritProhibitionA10-937

765

Published on

Published in: News & Politics, Business
0 Comments
1 Like
Statistics
Notes
  • Be the first to comment

No Downloads
Views
Total Views
765
On Slideshare
0
From Embeds
0
Number of Embeds
0
Actions
Shares
0
Downloads
5
Comments
0
Likes
1
Embeds 0
No embeds

Report content
Flagged as inappropriate Flag as inappropriate
Flag as inappropriate

Select your reason for flagging this presentation as inappropriate.

Cancel
No notes for slide

Transcript

  • 1. State of Minnesota Minnesota Court of Appeals In Re: Petition for Writ of Prohibition COA court file no. A10-937 SUPPLEMENTAL MOTION Mary Jane Duchene, Petitioner AND MEMORANDUM OF LAW TO DECIDE JURISDICTION vs. AND FOR INJUNCTION RE: Petition for Writ of Prohibition City of West St. Paul, Respondent District Court file: 19WS-CR- 09-15734 ========================================================= COMES NOW, Petitioner Mary Jane Duchene to ask the Court of Appeals to make a ruling as to which court has jurisdiction. The Respondent is attempting to revest jurisdiction with the trial court (FIRST JUDICIAL DISTRICT Court file: 19WS-CR-09-15734) in order to PROCEED TO TRIAL ON JUNE 7, 2010, IGNORING THE Petition for Writ of Prohibition FILED HEREIN, AND WITHOUT HAVING COMPLETED THE REQUISITE LONG FORM COMPLIANT INCLUSIVE OF A SEPARATE STATEMENT OF FACT IN THAT COMPLAINT, WHICH SUPPORTS A CRIMINAL CHARGE AND SHOWS THE SPECULATION OF THE RESPONDENT IN SOME OTHER LIGHT, SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 1
  • 2. WHICH ENTITLES RESPONDENT TO PROCEED WITH A CRIMINAL PROSECUTION. In support of his motion Petitioner states as follows: 1) The Petitioner has made multiple made motions before the district Court to order Respondent to either amend the long form compliant to include a separate statement of fact that that is required by the Minnesota Rules of Criminal Procedure, and absent which, dismissal of the case is mandatory: Rule 17.06 Motions Attacking Indictment, Complaint or Tab Charge Subd. 1. Defects in Form. No indictment, complaint or tab charge shall be dismissed nor shall the trial, judgment or other proceedings thereon be affected by reason of a defect or imperfection in matters of form which does not tend to prejudice the substantial rights of the defendant. Subd. 2. Motion to Dismiss or for Appropriate Relief. All objections to an indictment, complaint or tab charge shall be made by motion as provided by Rule 10.01 and may be based on the following grounds without limitation: (1) Indictment. (a) The evidence admissible before the grand jury was not sufficient as required by these rules to establish the offense charged or any lesser or other included offense or any offense of a lesser degree; (b) The grand jury was illegally constituted; (c) The grand jury proceeding was conducted before fewer than 16 grand jurors; (d) Fewer than 12 grand jurors concurred in the finding of the indictment; (e) The indictment was not found or returned as required by law; (f) An unauthorized person was in the grand jury room during the presentation of evidence upon the charge contained in the indictment or during the deliberations or voting of the grand jury upon the charge. (2) Indictment, Complaint or Tab Charge. In the case of an indictment, complaint or tab charge: (a) The indictment, complaint or tab charge does not substantially comply with the requirements prescribed by law to the prejudice of the substantial rights of the defendant; SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 2
  • 3. (b) The court lacks jurisdiction of the offense charged; (c) The law defining the offense charged is unconstitutional or otherwise invalid; (d) In the case of an indictment or complaint, that the facts stated do not constitute an offense; (e) The prosecution is barred by the statute of limitations; (f) The defendant has been denied a speedy trial; (g) There exists some other jurisdictional or legal impediment to prosecution or conviction of the defendant for the offense charged, except as provided by Rule 10.02; (h) Double jeopardy, collateral estoppel, or that prosecution is barred by Minn. Stat. § 609.035. and: Rule 17.02 Nature and Contents Subd. 1. Complaint. A complaint shall be substantially in the form prescribed by Rule 2. Subd. 2. Indictment. An indictment shall contain a written statement of the essential facts constituting the offense charged. It shall be signed by the foreperson of the grand jury. Subd. 3. Indictment and Complaint. The indictment or complaint shall state for each count the citation of the statute, rule, regulation or other provision of law which the defendant is alleged to have violated. Error in the citation or its omission shall not be ground for dismissal or for reversal of a conviction if the error or omission did not prejudice the defendant. Each count may charge only one offense. Allegations made in one count may be incorporated by reference in another count. An indictment or complaint may, but need not, contain counts for the different degrees of the same offense, or for any of such degrees, or counts for lesser or other included offenses, or for any of such offenses. The same indictment or complaint may contain counts for murder, and also for manslaughter, or different degrees of manslaughter. When the offense may have been committed by the use of different means, the indictment or complaint may allege in one count the means of committing the offense in the alternative or that the means by which the defendant committed the offense are unknown. Subd. 4. Bill of Particulars. The bill of particulars is abolished. SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 3
  • 4. Subd. 5. Indictment and Complaint Forms--Felony and Gross Misdemeanors. For all indictments and complaints charging a felony or gross misdemeanor offense the prosecuting attorney or such judge or judicial officer authorized by law to issue process pursuant to Rule 2.02 shall use an appropriate form authorized and supplied by the State Court Administrator or a word processor-produced complaint or indictment form in compliance with the supplied form and approved by Information Systems Office, State Court Administration. If for any reason such form is unavailable, failure to comply with this rule shall constitute harmless error under Rule 31.01. . 2) This case is now in appeal, Petitioner has filed a Petition for Writ of Prohibition to restrain the trial court from continuing to trial notwithstanding the Respondent’s refusal to file an amended long form complaint that states facts which support a criminal charge, and compel dismissal if that refusal continues, and is before the Minnesota Court of Appeals (case #A10-937). 3) Petitioner has a public defender who is handling the district court case, and who is fiscally restrained from doing the appeal work who concurs that the Respondent has utterly failed to prove it’s case. 4) Petitioner has not waived or withdrawn the Petition for Petition for Writ of Prohibition not has Petitioner given permission to the public defender or any other party to waive or withdraw the Petition for Writ of Prohibition, and jurisdiction is believed to be with the Court of Appeal, 5) The parties have not stipulated and the Petition for Writ of Prohibition is not withdrawn, and Petitioner has no intention of withdrawing the Petition for Writ of Prohibition, and the District Court SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 4
  • 5. must rule on Petitioner’s motion to proceed in Forma Pauperis: 109.02 Motion for Leave to Proceed In Forma Pauperis in the Court of Appeals A party who desires to proceed in forma pauperis in the Court of Appeals shall file in the trial court a motion for leave so to proceed, together with an affidavit showing the party’s inability to pay fees and costs and a copy of the party’s statement of the case as prescribed by Rule 133.03, showing the proposed issues on appeal. Any such motion by a party initiating an appeal shall be filed on or before the date the appeal is commenced. The trial court shall rule on the motion within 15 days after it is filed, unless the Court of Appeals grants additional time. The party shall file a copy of the motion with the clerk of the appellate courts simultaneously with the notice of appeal or the petition that initiates the appeal. The trial court shall grant the motion if the court finds that the party is indigent and that the appeal is not frivolous. If the motion is denied, the trial court shall state in writing the reasons for the denial. The party shall promptly file a copy of the trial court’s order on the motion with the clerk of the appellate courts. If the trial court grants the motion, the party may proceed in forma pauperis without further application to the Court of Appeals. If a transcript is to be prepared for appeal, the party shall file the certificate as to transcript required by Rule 110.02, subdivision 2(a), within 10 days from the date of the trial court administrator’s filing of the order granting leave to proceed in forma pauperis or within 10 days after filing the notice of appeal, whichever is later. If the trial court denies the motion, the party shall, within 10 days from the date of the trial court administrator’s filing of the order, either: (a) pay the filing fee, post the cost bond, and file a completed transcript certificate, if a transcript is required; or (b) serve and file a motion in the Court of Appeals for review of the trial court’s order denying in forma pauperis status. The record on the motion shall be limited to the record presented to the trial court. (Adopted effective March 1, 2001.). 6) After filing the Petition for Writ of Prohibition Respondents have taken no action to oppose the Petition for Writ of Prohibition and the trial court became divested of jurisdiction over the Petitioner's person, because of the irreversible violation of Petitioner's constitutional rights that the Respondent is attempting to impose on Petitioner, seeking to manipulate SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 5
  • 6. legal process to unfairly prejudice Petitioner's ability to defend again frivolous criminal charges, which Respondent has brought for the sole purpose of harassing the Petitioner. No action was taken to revest jurisdiction and the Respondent should be directed to take her cause to the court of appeal where the Petition for Writ of Prohibition action is pending or to the Court of Appeals in some other manner. Petitioner contends that the Respondent has the burden to establish jurisdiction if Respondent intends to switch courts to the District court and attempt to proceed to trial on June 7, 2010; notwithstanding that Petitioner has filed a motion with the Court of Appeal requesting immediate stay of all proceeding in District Court, inclusive trial on June 7, 2010. 7) Judge Perkins was appointed as a “special judge” for the trial court matter and has stated that an appeal via Petition for Writ of Prohibition or otherwise should ensue in the event that Petitioner does not like his refusal to compel Respondents to file and/or amend a long form complaint in this matter, that is in compliance with the Minnesota Rules of Criminal Procedure. He is not an appellate judge and is not a judge from outside the First Judicial District. 8) Black Law Dictionary Sixth Edition id 842 defines a Writ of Prohibition as follows: "Prohibition is a process by which a superior court prevents an inferior court or tribunal possessing judicial or quasi-judicial powers from exceeding it's jurisdiction in matters over which it SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 6
  • 7. has cognizance or usurping matters not within it's jurisdiction to hear or determine. A means of restraint on judicial personnel or bodies to prevent usurpation of judicial power, and it's essential function is to confine inferior courts to their proper jurisdiction and to prevent them from acting without or in excess of their jurisdiction; it is preventive in nature rather than corrective." 9) Should this Court of Appeals rule it has jurisdiction and the trial court does not it would be appropriate for this court to issue an IMMEDIATE Injunction preventing the trial judge from exceeding his judicial authority or, in this case, acting in the absence of all judicial authority. 10) Respondent attorneys, Bridget Nason under the supervision of chief prosecutor Korine Land are licensed attorneys who have practiced law for years. They should know what the rules are and know what court has jurisdiction. A pro se litigant, such as myself, should not have the burden of having to instruct these seasoned lawyers as to what court has jurisdiction. Petitioner therefore contends that Respondent attorneys have filed a frivolous criminal case and continue in this action and should be sanctioned and that they should reimburse the Petitioner for his time and expenses, which has been nearly one year now. 11) Petitioner is confused as to the motives of Judges MCManus, Perkins and Chief Judge Lunch as to why same would want to agreed to have a trial after being clearly notified that he does not have jurisdiction and that to do SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 7
  • 8. so would violate the Minnesota Rules of Criminal Procedure regarding long form complaints and the Petitioner’s due process rights. Because of the unusual judicial behavior in going out of his way to proceed to trial despite the offense to Petitioner’s civil rights, and noting this judge's willingness to exceed his judicial authority and usurp the power of the Appellate Court even after notification thereof, the Petitioner is concerned that there exists an improper relationship between the Respondent's attorneys and the judge. 12) The Petitioner is conducting herself in a professional manner and is playing by the rules. Petitioner asks the court to uphold the rules and enforce the rules. That it is fundamentally unfair for the Respondents attorneys to be allowed to break the rules and subvert the administration of justice, and of course contrary to the public interest to allow this in criminal matters as this subverts justice and the United States legal system and rule of law. Memorandum of Law The Minnesota Rules of Criminal Procedure state fundamental legal principles in a criminal case and fundamental defense rights that compel the prosecution to clearly state facts which are relied on by the prosecution to support any criminal charge, in a long form complaint: Rule 17.06 Motions Attacking Indictment, Complaint or Tab Charge Subd. 1. Defects in Form. No indictment, complaint or tab charge shall be dismissed nor shall the trial, judgment or other proceedings thereon be affected by SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 8
  • 9. reason of a defect or imperfection in matters of form which does not tend to prejudice the substantial rights of the defendant. Subd. 2. Motion to Dismiss or for Appropriate Relief. All objections to an indictment, complaint or tab charge shall be made by motion as provided by Rule 10.01 and may be based on the following grounds without limitation: (1) Indictment. (a) The evidence admissible before the grand jury was not sufficient as required by these rules to establish the offense charged or any lesser or other included offense or any offense of a lesser degree; (b) The grand jury was illegally constituted; (c) The grand jury proceeding was conducted before fewer than 16 grand jurors; (d) Fewer than 12 grand jurors concurred in the finding of the indictment; (e) The indictment was not found or returned as required by law; (f) An unauthorized person was in the grand jury room during the presentation of evidence upon the charge contained in the indictment or during the deliberations or voting of the grand jury upon the charge. (2) Indictment, Complaint or Tab Charge. In the case of an indictment, complaint or tab charge: (a) The indictment, complaint or tab charge does not substantially comply with the requirements prescribed by law to the prejudice of the substantial rights of the defendant; (b) The court lacks jurisdiction of the offense charged; (c) The law defining the offense charged is unconstitutional or otherwise invalid; (d) In the case of an indictment or complaint, that the facts stated do not constitute an offense; (e) The prosecution is barred by the statute of limitations; (f) The defendant has been denied a speedy trial; (g) There exists some other jurisdictional or legal impediment to prosecution or conviction of the defendant for the offense charged, except as provided by Rule 10.02; (h) Double jeopardy, collateral estoppel, or that prosecution is barred by Minn. Stat. § 609.035. and: Rule 17.02 Nature and Contents Subd. 1. Complaint. A complaint shall be substantially in the form SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 9
  • 10. prescribed by Rule 2. Subd. 2. Indictment. An indictment shall contain a written statement of the essential facts constituting the offense charged. It shall be signed by the foreperson of the grand jury. Subd. 3. Indictment and Complaint. The indictment or complaint shall state for each count the citation of the statute, rule, regulation or other provision of law which the defendant is alleged to have violated. Error in the citation or its omission shall not be ground for dismissal or for reversal of a conviction if the error or omission did not prejudice the defendant. Each count may charge only one offense. Allegations made in one count may be incorporated by reference in another count. An indictment or complaint may, but need not, contain counts for the different degrees of the same offense, or for any of such degrees, or counts for lesser or other included offenses, or for any of such offenses. The same indictment or complaint may contain counts for murder, and also for manslaughter, or different degrees of manslaughter. When the offense may have been committed by the use of different means, the indictment or complaint may allege in one count the means of committing the offense in the alternative or that the means by which the defendant committed the offense are unknown. Subd. 4. Bill of Particulars. The bill of particulars is abolished. Subd. 5. Indictment and Complaint Forms--Felony and Gross Misdemeanors. For all indictments and complaints charging a felony or gross misdemeanor offense the prosecuting attorney or such judge or judicial officer authorized by law to issue process pursuant to Rule 2.02 shall use an appropriate form authorized and supplied by the State Court Administrator or a word processor-produced complaint or indictment form in compliance with the supplied form and approved by Information Systems Office, State Court Administration. If for any reason such form is unavailable, failure to comply with this rule shall constitute harmless error under Rule 31.01. Numerous US Supreme Court cases uphold these rights: U.S. Supreme Court, U S v. CRUIKSHANK, 92 U.S. 542 (1875), 92 U.S., 542, COLE V. ARKANSAS, 338 U. S. 345 (1949) and FARETTA V. CALIFORNIA, 422 U. S. 806 (1975): SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 10
  • 11. Page 422 U. S. 818: III This consensus is soundly premised. The right of self- representation finds support in the structure of the Sixth Amendment, as well as in the English and colonial jurisprudence from which the Amendment emerged. A The Sixth Amendment includes a compact statement of the rights necessary to a full defense: "In all criminal prosecutions, the accused shall enjoy the right . . . to be informed of the nature and cause of the accusation; to be confronted with the witnesses against him; to have compulsory process for obtaining witnesses in his favor, and to have the Assistance of Counsel for his defense." Because these rights are basic to our adversary system of criminal justice, they are part of the "due process of law" that is guaranteed by the Fourteenth Amendment to defendants in the criminal courts of the States. [Footnote 14] The rights to notice, confrontation, and compulsory process, when taken together, guarantee that a criminal charge may be answered in a manner now considered fundamental to the fair administration of American justice -- through the calling and interrogation of favorable witnesses, the cross-examination of adverse witnesses, and the orderly introduction of evidence. In short, the Amendment constitutionalizes the right in an adversary criminal trial to make a defense as we know it. See California v. Green, 399 U. S. 149, 399 U. S. 176 (Harlan, J., concurring). Regarding Jurisdiction 1. “Once jurisdiction is challenged, the court cannot proceed when it clearly appears that the court lacks jurisdiction, the court has no authority SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 11
  • 12. to reach merits, but, rather should dismiss the action.” Melo v. US 505, F2d 1026 2. In US v. Lopez and Hagan v. Levine decisions were render void because of lack of jurisdiction. If jurisdiction does not exist it cannot justify conviction or judgment. See also Broom v. Douglas, 75, ALA 268, 57, So. 860 and In re: FNB, 152 F64. 3. “There is no discretion to ignor lack of jurisdiction.” Joyce v. US, 474 21) 215 4. “The law provides that once state and federal jurisdiction has been challenged, it must be proven.” Main v. Thiboutot, 100 S. Ct. 2502 (1980) 5. “Jurisdiction can be challenged at any time.” and “Jurisdiction, once challenged, cannot be assumed and must be decided.” Nasso v. Utah Power and Light Co. 495 F2d 906, 910 6. “Defense of lack of jurisdiction over the subject matter may be raised at any time, even on appeal.” Hill Top Developers v. Holiday Pines Service Corp. 478 So. 2d. 368 (Fla 2nd DCA 1985) 7. “The burden shifts to the c ourt to prive jurisdiction.” Rosemond v. Lambert 469 F2d 416 8. “A court has no jurisdiction to determine its own jurisdiction, for a basic issue in any case before a tribunal is it’s power to act, and a court must have authority tp decide that question in the first instance.” Rescue Army v. SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 12
  • 13. Municipal Court of Los Angeles, 171 F2d 8, 331 US 549, 911. ed 1666, 67 S Ct. 1409. 9. “Where a court failed to observe safeguards, it amounts to denial of due process of law, court is deprived of juris.” Merritt v Hunter, C.A. Kansas, 170 F2d 739. Regarding Emergency situations Rule 121. Mandamus and Prohibition - Emergency Situations 121.01 Communication to the Court If an emergency situation exists and the provisions of Rule 120 are impractical, the attorney for a party seeking a writ of mandamus or of prohibition directed to a lower court may orally petition the reviewing court for such relief by telephoning or by personally contacting the Supreme Court Commissioner, if application is made in the Supreme Court, or the Chief Staff Attorney, if application is made in the Court of Appeals, who will communicate with the reviewing court relative to an early or immediate consideration of the petition. If the Commissioner or Chief Staff Attorney is unavailable, the oral petition may be made to a justice or judge of the reviewing court. WHEREFORE, Petitioner asks the court to IMMEDIATELY decide that district court, division one, does not have jurisdiction to proceed with any trial in the District court, or any related matters, on June 7, 2010, pending review and issue of Petitioner’s Petition for Writ of Prohibition thereby restricting courts with no jurisdiction from usurping the power of the Appellate Court and to issue sanction against Respondent's attorneys as it deems appropriate. June 6, 2010 Respectfully submitted: SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 13
  • 14. Mary Jane Duchene, BA, BS 1144 Ottawa Avenue West St,. Paul, MN 55118 Fax: 651 457 4376 MariJaynDuchene@aol.com SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 14
  • 15. SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 15
  • 16. SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 16
  • 17. SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 17
  • 18. SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 18
  • 19. SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 19
  • 20. SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 20
  • 21. SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 21
  • 22. SUPPLEMENTAL MOTION AND MEMORANDUM TO DECIDE JURISDICTION AND FOR INJUNCTION RE: Petition for Writ of Prohibition page 22
  • 23. motion coa injunction emergency Page 1 of 2 Subj: motion coa injunction emergency Date: 6/6/2010 1:44:25 P.M. Central Daylight Time From: DDAweb@comcast.net To: GLXgrove@msn.com EMERGENCY MOTION: http://www.ddaexchange.org/1144OttawaAvenue/supmotionjurisd www.ddaexchange.org/1144OttawaAvenue/supmotionjurisdiction Rule 121. Mandamus and Prohibition - Emergency Situations See motion to Court of Appeal attached RE: Writ Prohibition 121.01 Communication to the Court If an emergency situation exists and the provisions of Rule 120 are impractical, the attorney for a party seeking a writ of mandamus or of prohibition directed to a lower court may orally petition the reviewing court for such relief by telephoning or by personally contacting the Supreme Court Commissioner, if application is made in the Supreme Court, or the Chief Staff Attorney, if application is made in the Court of Appeals, who will communicate with the reviewing court relative to an early or immediate consideration of the petition. If the Commissioner or Chief Staff Attorney is unavailable, the oral petition may be made to a justice or judge of the reviewing court. Sunday, June 06, 2010 AOL: Sharon4Anderson
  • 24. motion coa injunction emergency Page 2 of 2 Mary Jane Duchene 1144 Ottawa Avenue St. Paul, MN 55118-2008 Fax: 651 457 4376 E-Mail:: MariJaynDuchene@aol.com Sunday, June 06, 2010 AOL: Sharon4Anderson
  • 25. MARY JANE DUCHENE FOR WEST ST. PAUL MAYOR - 2004 Page 1 of 3 Search: n The Web n Angelfire i j k l m j k l m Report Abuse « Previous | Top 100 | Next » Senior Citizen share: del.icio.us | digg | reddit | furl | facebook Primary Election Results 2 Community: • West St. Paul Native • Sibley High School Graduate • Disability and Senior Thank you all for vo Activist • Founder and Member: Diabetics/Disabled Anonymous • West St. Paul Resident and Homeowner Professional: • Owner, OpusArts LLC. • Lecturer on US Culture: American Embassy, England • Portrait Artist, Revlon International • Legal Education in London, England, and Member of the Honorable Society of Grays Inn • BFA in Fine Art from the Minneapolis College of Art and Design E-mail: marijaynduchene@aol.com or call: 651 457 4376 Quality Housing Program: http://www.angelfire.com/mn3/mj4mayor/ 6/6/2010
  • 26. MARY JANE DUCHENE FOR WEST ST. PAUL MAYOR - 2004 Page 2 of 3 • Mary Jane will work to ensure that available funding is obtained for required repairs low income and senior citizens in West St. Paul, so that these citizens do continue to be in danger of loosing their homes, from abatements added on to property taxes. • Mary Jane believes that the community in West St. Pa want to be caring and supportive of the disabled, low income and senior property owner, and will want to develop their neighborhood programs to include meaningful development of volunteer programs to assist these disadvantaged citizens with mandated home repair City Attorney: Mary Jane will work for the appointment of a city attorney resides and offices from West St. Paul, not South St. Paul; and no conflicts of interest that impede ethical action, see: www.DDAWEB.org www.MurderbyDiabetes.org http://www.angelfire.com/mn3/abuseofpower/index.html Diversity: Mary Jane has the experience and skill to work for a commu welcomes the disabled, seniors, and members of ethnic minoriti which enforces laws prohibiting the taking of unethical and ille advantage of people in these protected classes;- and will work d to remedy the current status quo to achieve these equitable resu http://www.angelfire.com/mn3/mj4mayor/ 6/6/2010
  • 27. MARY JANE DUCHENE FOR WEST ST. PAUL MAYOR - 2004 Page 3 of 3 It's Time for the Change to Tolerance, Dive and Ethical Government in West St. Pau Prepared and Paid for by the Duchene 4 Mayor Volunteer Committee, 1144 Ottawa Avenue, West St. Paul, MN 55118 New People in Government = CHANGE STOP REVOLVING DOOR POLITICS IN WSP http://www.angelfire.com/mn3/mj4mayor/ 6/6/2010

×