I. QUESTIONS PRESENTED FOR REVIEW1.   Whether EXTRAORDINARY and/or EXCEP-     TIONAL circumstances warrants the granting  ...
FUSED to address ALL issues raised in plead-           ings. See APPENDIX “6” - Appendix Chart           (“APPX CHART”) No...
terests had a duty to recuse themselves from     lawsuits – i.e. as Judge Tom S. Lee [see APPX     CHT No. “7” – Recusal O...
ants/Respondents are ONGOING and contin-    ues to date.12. Whether Newsome is entitled to injunctive re-    lief as a dir...
course of judicial proceedings, or sanctioned    such a departure, as to call for an exercise of    the Supreme Court of t...
citizens/litigants – for purposes of protecting     TOP/BIG/KEY Financial Campaign Contribu-     tors. Whether said Court ...
protected rights and/or deprive Newsome    equal protection of the laws, equal privileges    and immunities of the laws an...
31. Whether citizens of the United States have the    right to exercise First Amendment Rights and    Rights secured/guara...
36. What relationship (if any) does the law firm    Baker Donelson Bearman Caldwell & Berko-    witz, its employees and cl...
Committee on legislation and Congressional    oversight implicating civil and constitutional    rights, Congressional auth...
clients, others and the United States Depart-    ment of Justice play in the COVER-UP of    criminal/civil violations leve...
afford Newsome rights secured and guaran-    teed under the United States Constitution and    laws of the United States – ...
II.   2LIST   OF PARTIES      All parties appear in the caption of the case on thecover page and the following is the cont...
pated in the conspiracy(s)3 against Newsome and in suchmanner is responsible for the injuries and damages suf-fered by New...
III.       TABLE OF CONTENTSI.     QUESTIONS PRESENTED FOR REVIEW ..........................iII.      LIST OF PARTIES .......
DISQUALIFICATION OF JUDGE TOM S. LEE ..................... 22             IV.    INDEX TO APPENDICES       In compliance w...
(“OBJECTION(S) TO 08/02/12 ORDER”)        https://secure.filesanywhere.com/fs/v.aspx?v=8a7        2648b595e75bc719aAPPENDI...
Assignment; and Notice of Address     https://secure.filesanywhere.com/fs/v.aspx?v=8a7     2648b596070b8a6af13   08/15/12 ...
18   08/14/12 - Motion to Strike Defendants’ Response     In Opposition To Plaintiff’s Motion To Strike Mo-     tion To Di...
FEDERAL Judge or Magistrate     https://secure.filesanywhere.com/fs/v.aspx?v=8a7     2648b59626fb19fa824   DISQUALIFICATIO...
31   Morrow v. District of Columbia     https://secure.filesanywhere.com/fs/v.aspx?v=8a7     2648b596370a66ca832   Platt v...
40   Hare v. City of Corinth, Miss.     https://secure.filesanywhere.com/fs/v.aspx?v=8a7     2648b59656fbba96841   05/16/0...
2648b59676ea5a56c                  V.        TABLE OF AUTHORITIESAdams v. U.S. ex rel. McCann, 63 S.Ct. 236 (1942) ..........
Bryant v. Military Department of Mississippi,   597 F.3d 678 (5th Cir. Miss. 2010) ..........................................
2 S.Ct. 863, 27 L.Ed. 811 (1883) .................................... 40, 65, 69Ex parte Milwaukee R. Co., 72 U.S. 188 (18...
919 F2d 1136 (6th Cir. 1990) ....................................................... 51In re McDonald, 489 U.S. 180, 109 S...
Morrow v. District of Columbia, 417 F.Ed 728, 135 U.S.   App.Dc. 160 on remand 259 A.2d 592 (1969) ..........................
U.S. v. International Broth. Of Teamsters,  Chauffeurs, Warehousemen and Helpers of  America, AFL-CIO, 911 F.Supp. 743 (19...
M.E. White Co. (1935) 296 US 268,   80 L Ed 220, 56 S. Ct. 229)) ........................................................ ...
Article III, § 2, United States Constitution................................... 4H.R.Rep.No.93-1453, 93d Cong., 2d Sess. (...
VI.    CONCISE STATEMENT OF JURISDICTION            Ex parte Young, 209 U.S. 123, 165, 28            S.Ct. 441, 52 L.Ed. 7...
Page 2 of 80counsel/advisor Baker Donelson Bearman Caldwell &Berkowitz (“Baker Donelson”), his Administration as wellas hi...
Page 3 of 80d. Because of the EXTRAORDINARY and EX-   CEPTIONAL circumstances surrounding this   action, pursuant to Rule ...
Page 4 of 80           diction shall be filed as provided           in Rule 20.i. The jurisdiction of this Court is furthe...
Page 5 of 80                          exercise appellate jurisdiction.                          Id.                 Articl...
Page 6 of 80            l. The following statute may further apply: 28               USC §2403 - Intervention by United St...
Page 7 of 80                 STATUTES:                 d.      28 USC § 144 -Bias or prejudice of                         ...
Page 8 of 80      “6” – Docket Sheet at No. 1 incorporated here-      in by reference as if set forth in full herein.(2)  ...
Page 9 of 80      APPX CHT No. “14” incorporated herein by      reference as if set forth in full herein.(6)   On or about...
Page 10 of 80       In Opposition To Plaintiff’s Motion For Rule       11 Sanctions Of And Against Defendants; and       M...
Page 11 of 80              some’s Complaint WITH prejudice. See APPX              “1.”      (14)    On or about September ...
Page 12 of 80     IX.   REASONS FOR GRANTING THE PETITIONA.     CONFLICT OF INTEREST REQUEST:        Prior to addressing t...
Page 13 of 80 Chief Counsel, Acting Director, and  Acting Deputy Director of United  States Citizenship & Immigration  Se...
Page 14 of 80              Commissioner of Finance & Admin-               istration (Chief Operating Officer) -          ...
Page 15 of 80the United States of America. From research, Baker Do-nelson’s    LISTING      of    GOVERNMENT          posi...
Page 16 of 80         so that JUSTICE may be rendered UNBIAS         and IMPARTIALLY - i.e. rather than         TAINTED wi...
Page 17 of 80this Court’s Bench for purposes of PROMOTING its and itsclients’ PERSONAL/BUSINESS!       During Newsome’s re...
Page 18 of 80and DUE PROCESS of laws secured/guaranteed under theUnited States Constitution.      While Baker Donelson’s n...
Page 19 of 80Snow”) and Phelps Dunbar LLP (“Phelps Dunbar”).             Ofcourse, like Baker Donelson, their associating ...
Page 20 of 80gage in CRIMINAL and CIVIL viola-tions leveled against Newsome.www.slideshare.net/VogelDenise/051912-docket-s...
Page 21 of 80As well as Baker Donelson appearingon Judge Lee’s List of Law Firms RE-QUIRING his recusal:www.slideshare.net...
Page 22 of 80                  obtaining decisions in their favor and                  that of PARTNERING law firms as    ...
Page 23 of 80other Judges (i.e. Judge Bobby DeLaughter was INDICTEDand pled GUILTY and Judge G. Thomas Porteous as of ap-p...
Page 24 of 80      PC, counsel for the defendants, is on the      recusal list of the undersigned United States      distr...
Page 25 of 80         MATTER OF PUBLIC IMPORTANCE: It         goes to the VALIDITY of U.S. Supreme         Court’s Decisio...
Page 26 of 80            Conducting a Thorough Investigation7            Because discrimination often is subtle,          ...
Page 27 of 80GUN TRAIL left by Baker Donelson and its CONSPIRA-TORS/CO-CONSPIRATORS:      (a)   President Barack Obama “Bi...
Page 28 of 80      “DOMESTIC” Terrorist Attacks carried out      by CORRUPT Government Officials and      their counsel/ad...
Page 29 of 80tary of State Hillary Clinton) and theirLegal Counsel/Advisor Baker Donelsonmoved SWIFTLY it appears to “CLEA...
Page 30 of 80       dents)     who        was       KILLED/MURDERED       and       body dumped in a Waste       Landfill ...
Page 31 of 80          http://www.slideshare.net/          VogelDenise/lawrence-          eagleburger-wikipedia-          ...
Page 32 of 80          http://www.slideshare.ne          t/VogelDenise/baker-          donelson-wikipedia-info-          1...
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
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11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
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11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
11/19/12 - Petition  For Original Writ et al (PKH) - Supreme Court (Stamped)
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11/19/12 - Petition For Original Writ et al (PKH) - Supreme Court (Stamped)

  1. 1. I. QUESTIONS PRESENTED FOR REVIEW1. Whether EXTRAORDINARY and/or EXCEP- TIONAL circumstances warrants the granting of the Petition(s) sought.2. Whether Supreme Court of United States Jus- tices are required to RECUSE themselves in this lawsuit. Whether Conflict-Of-Interest ex- ist with Justices and/or Administrative Staff of this Court in this lawsuit.3. Should United States District Court Judge for the Southern District of Mississippi (Jackson Division) [“USDC-Jackson, MS”], the Honora- ble Tom S. Lee, who it appears has a business and personal relationship with Defendant(s) in the lower court action and appears have finan- cial and/or personal interests in this lawsuit, be disqualified from presiding in cases in which Baker Donelson Bearman Caldwell & Berkowitz, its PARTNERING firms as Phelps Dunbar LLP are used as FRONTS to shield/mask/hide the role it is playing in law- suits and/or legal actions involving Vogel Den- ise Newsome (“Newsome”)?4. Whether Judge Tom S. Lee has jurisdic- tion/legal authority to preside over lower court action where “Affidavit of Disqualification” has been filed against him. See APPENDIX (“APPX”) “5” and “Request for Conflict of In- terest Information, Notice of Opposition to Magistrate Judge Assignment; and Notice of Address” was filed; however, Judge Lee RE- i
  2. 2. FUSED to address ALL issues raised in plead- ings. See APPENDIX “6” - Appendix Chart (“APPX CHART”) No. “12” 1 Whether Judge Tom S. Lee submitted issues raised and in dispute to a JURY as timely demand- ed/requested. 5. Whether Judge Tom S. Lee owe a specific duty to Newsome to recuse himself from United States District Court – Southern District of Mississippi (Jackson Division) action. 6. Whether Newsome is entitled to know of “Con- flict of Interest” that exist between factfind- er(s)/judges/justices and/or opposing par- ties/counsel. 7. Whether Judges/Justices owe a specific duty to Newsome to recuse themselves when “conflict of interest” exists. Whether Judges/Justices remained on the bench in legal actions where Newsome is a party with knowledge there was a “conflict of interest” due to their relationship with opposing parties and/or their coun- sel/counsel’s law firm. 8. Whether judges/justices assigned cases involv- ing Newsome and supporting “THIRD- PARTIES’” (i.e. such as opposing law firm(s) as Baker Donelson Bearman Caldwell & Berkowitz, their employees and/or clients) in- 1 In accordance with the Rules of the Supreme Court of the UnitedStates and in good faith to mitigate costs to prepare an Appendix with theamount of VOLUMINOUS documents referenced, Newsome has provided theLINKS where supporting documents may be found supporting this pleading.Newsome has prepared at APPENDIX “6” an APPENDIX CHART (“APPXCHT”) containing the documents to be included in the JOINT APPENDIX inthis matter. ii
  3. 3. terests had a duty to recuse themselves from lawsuits – i.e. as Judge Tom S. Lee [see APPX CHT No. “7” – Recusal Orders executed be- cause of relationship to Baker Donelson Bearman Caldwell & Berkowitz - provided and incorporated herein by reference] – in which knowledge of CONFLICT OF INTEREST EX- ISTED. Whether judges/justices are allowed to discriminate in their compliance with laws governing recusal [see APPX CHT No. “8” – Docket Sheet (Newsome v. Entergy - wherein Baker Donelson Bearman Caldwell & Berko- witz appears as counsel of record - provided and incorporated herein by reference]. Wheth- er judges/justices should be IMMEDIATELY removed from the bench and/or the applicable legal actions initiated against judges/justices for removal when record evidence supports judges/justices failure to recuse. How does said failure of judges/judges to recuse themselves affect the public and/or Constitutional rights of citizen(s)?9. Whether Newsome’s Complaint and her sub- sequent pleadings in the lower court meet the PLEADING Requirements of Rule 8 of the Federal Rules of Civil Procedure.10. Whether Newsome’s Complaint can be dis- missed WITH prejudice upon Motion to Dis- miss for 42 § 1983 claims that are NOT the basis of her claims and when § 1983 claims were NEVER raised in her Complaint.11. Whether Newsome’s Complaint is governed by CONTINUING TORT – statute of limitations – when civil wrongs/violations of Defend- iii
  4. 4. ants/Respondents are ONGOING and contin- ues to date.12. Whether Newsome is entitled to injunctive re- lief as a direct and proximate cause of the ir- reparable injuries/harm sustained and contin- ues to date. Injunctive relief commanding and/or preventing the unlawful/illegal acts of Respondents.13. Whether Newsome, as a matter of Constitu- tional right, is entitled to JURY trial(s) when requested. Whether Newsome has been de- prived of Constitutional right to jury trial(s).14. Whether Newsome timely, properly and/or ad- equately DEMANDED jury trial on issues.15. Whether Newsome WAIVED her right to have issues tried before jury.16. Whether Judge Tom S. Lee possessed knowledge that Newsome timely, properly and adequately demanded JURY on ALL triable issues. Whether Judge Tom S. Lee possessed knowledge that he infringed upon Newsome’s Constitutional Rights. Whether Judge Tom S. Lee acts are arbitrary and/or capricious.17. Whether the United States District Court – Southern District of Mississippi (Jackson Divi- sion) entered a decision in conflict with the de- cision of another federal district and/or federal circuit court of appeals on the same important matter; has decided in important federal ques- tion in a way that conflicts with a decision by a federal court of last resort; and/or has taken a far departure from the accepted and usual iv
  5. 5. course of judicial proceedings, or sanctioned such a departure, as to call for an exercise of the Supreme Court of the United States’ su- pervisory power and/or original jurisdiction.18. Whether United States District Court – Southern District of Mississippi (Jackson Divi- sion) has decided an important question of federal law that has not been, but should be, settled by this Court; and/or has decided an important federal question in a way that con- flicts with relevant decisions of the Supreme Court of the United States.19. Whether the lower court has decided an im- portant federal question in a way that conflicts with the decision of another federal court of last resort or of a United States court of ap- peals.20. Whether lower court decision(s) raise ques- tion(s) as to the validity of the federal statute or treaty; raise a question statute statute/law relied upon is repugnant to the Constitution, laws or treaties of the United States; or ad- dress the contention that a right, privilege or immunity is “set up or claimed under the Con- stitution or statutes of, or any commission held or authority exercised under, the United States.”21. Whether the Supreme Court of the United States’ decision in Citizens United v Federal Election Commission, 558 U.S. 50 (2010), have provide courts with a license and/or defense to engage in criminal acts – i.e. provide arbi- trary/capricious decisions for purposes of cov- ering up criminal/civil wrongs leveled against v
  6. 6. citizens/litigants – for purposes of protecting TOP/BIG/KEY Financial Campaign Contribu- tors. Whether said Court NOTIFIED parties in the Citizens United matter and/or the PUBLIC that a CONFLICT-OF-INTEREST existed in its handing of said decision. Wheth- er the Supreme Court of United States’ DE- LIBERATE FAILURE to RECUSE and/or NOTIFY of Conflict-Of-Interest in the han- dling of Citizens United v. Federal Election Commission, renders its decision NULL/VOID and its acts ARBITRARY/ CAPRICIOUS.22. Whether Newsome has been deprived equal protection of the laws, equal privileges and immunities of the laws, and due process of laws secured under the United States of Amer- ica’s Constitution.23. Whether Newsome is a victim of “Pattern-of- Practices,” “Pattern-of-Abuse,” “Pattern-of- Injustices” and/or “PATTERN” of unlaw- ful/illegal practices as a direct and proximate result of her engagement in protected activi- ties.24. Whether Newsome is a victim of “Criminal Stalking.”25. Whether Newsome is a victim of Government “BULLYING.” Whether the United States Government/Courts allow parties opposing Newsome in legal matters (judicial and admin- istrative) to use their “political” and “financial wealth” for purposes of BULLYING Newsome. Whether said BULLYING is for purposes of intimidation, coercion, threats, bribery, blackmail, etc. to force Newsome to abandon vi
  7. 7. protected rights and/or deprive Newsome equal protection of the laws, equal privileges and immunities of the laws and due process of laws.26. Whether United States of America Govern- ment Officials and Newsome’s former employ- er(s) have engaged in criminal/civil wrongs leveled against her for purposes of BLACK- LISTING. Whether the United States Gov- ernment Agencies/Courts have placed infor- mation on the INTERNET regarding New- some that it knew and/or should have known was false, misleading and/or malicious.27. Whether Government agencies, their employ- ees and others have engaged in TERRORIST ACTS.28. Whether the United States citizens/public and/or Foreign Nations, their leaders and citi- zens are entitled to know of the crimes and civil injustices of the United States of Ameri- ca’s Government, its officials/employees and co-conspirators leveled against African/Black- Americans and/or people of color.29. Whether extraordinary circumstances exist to warrant granting of this petition.30. Whether conspiracy(s) leveled against New- some exist. Whether United States Govern- ment Officials’/Courts’ failure and “neglect to prevent” has created a “threat to the public” in allowing criminal(s) to remain at large in the general population. vii
  8. 8. 31. Whether citizens of the United States have the right to exercise First Amendment Rights and Rights secured/guaranteed under the United States Constitution and/or Rights secured un- der the laws of the United States without fear of reprisal.32. Whether United States Government Agencies and their Officials/Employees have the right to retaliate against Newsome for exercising rights protected and secured under the laws of the United States and United States Constitu- tion.33. Whether opposing parties, their insurance providers, special interest groups, lobbyists, and their representatives have legal authority to retaliate against Newsome for her engage- ment in protected activities. Whether oppos- ing parties and their conspirators/co- conspirators are allowed to stalk Newsome from job-to-job/employer-to-employer and state-to-state for purposes of terminating her employment, blacklisting, etc. in retaliation for Newsome having exercised and/or or en- gagement in protected activities.34. What role (if any) has the law firm Baker Do- nelson Bearman Caldwell & Berkowitz, its employees, clients and others played in the criminal/civil wrongs and conspiracies leveled against Newsome?35. What relationship (if any) does the law firm Baker Donelson Bearman Caldwell & Berko- witz, its employees and clients have to United States of America President Barack Obama and his Administration? viii
  9. 9. 36. What relationship (if any) does the law firm Baker Donelson Bearman Caldwell & Berko- witz, its employees and clients have to past Presidents of the United States of America and their Administration?37. What relationship (if any) does the law firm Baker Donelson Bearman Caldwell & Berko- witz, its employees and clients have to offi- cials/employees in the United States of Ameri- ca Senate and United States of America House of Representatives?38. What relationship (if any) does the law firm Baker Donelson Bearman Caldwell & Berko- witz, its employees and clients have in the ap- pointment of judges/justices to the courts?39. What role (if any) did the law firm Baker Do- nelson Bearman Caldwell & Berkowitz, its employees and clients have in the handling of criminal/civil complaints Newsome filed with the United States Department of Justice – i.e. based on relationship and KEY position(s) held with the Commission on Civil Rights [Chairman, etc.] which serve as a national clearinghouse for information in respect to discrimination or denial of equal protection of the laws; submitting reports, findings and rec- ommendations to the President and Congress; and issuing public service announcements to discourage discrimination or denial of equal protection of the laws . . . served as Chief Counsel to the U.S. House Judiciary Commit- tees Subcommittee on the Constitution, which responsibilities included advising the Chair- man and Republican Members of the Judiciary ix
  10. 10. Committee on legislation and Congressional oversight implicating civil and constitutional rights, Congressional authority, separation of powers, proposed constitutional amendments and oversight of the Civil Rights Division of the Department of Justice and the U.S. Com- mission on Civil Rights [see for instance AP- PENDIX DOCUMENTS CHART (“APPX CHT”) No. “9” – Baker Doneslon information regarding Bradley S. Clanton]40. What role (if any) did Baker Donelson Bear- man Caldwell & Berkowitz, its employees, its clients and the United States Department of Justice play in the COVER-UP of crimi- nal/civil violations leveled against Newsome reported on or about September 17, 2004 in “Petitioners Petition Seeking Interven- tion/Participation of the United States De- partment of Justice” - i.e. styled "VOGEL DENISE NEWSOME vs. ENTERGY SER- VICES, INC." [see APPIX “8”] in which New- some timely, properly and adequately reported the criminal/civil violations of Baker Donelson Bearman Caldwell & Berkowitz, Judge G. Thomas Porteous Jr. and others – to no avail.41. Whether the IMPEACHMENT of Judge G. Thomas Porteous, Jr. (i.e. having role as pre- siding judge in lawsuit involving Newsome) on or about December 8, 2010 [see APPX CHT No. “10” – Article “Senate Removes Federal Judge in Impeachment Conviction” incorpo- rated herein by reference], is perti- nent/relevant to this instant lawsuit.42. What role (if any) did Baker Donelson Bear- man Caldwell & Berkowitz, its employees, its x
  11. 11. clients, others and the United States Depart- ment of Justice play in the COVER-UP of criminal/civil violations leveled against New- some reported on or about September 24, 2004 in “Request for Department of Justices Inter- vention/ Participation in this Case” - i.e. refer- encing "Newsome v. Mitchell McNutt & Sams P.A." [See APPX CHT No. “11”] in which New- some timely, properly and adequately reported the criminal/civil violations of Mitchell McNutt & Sams – to no avail.43. Whether the INDICTMENT of Judge Bobby DeLaughter [i.e. having a role as presiding judge in lawsuit involving Newsome] on or about January 6, 2009, and his pleading GUILTY on or about July 30, 2009, is perti- nent and/or relevant to this instant lawsuit.44. Whether Baker Donelson Bearman Caldwell & Berkowitz, its employees and clients have an interest in the outcome of this lawsuit. If so, whether the Supreme Court of the United States is aware of said knowledge and/or in- formation.45. Whether attorneys and their client(s) are al- lowed to engage in criminal and civil wrongs for purposes of obstructing the administration of justice.46. Whether the EXTRAORDINARY and EX- CEPTIONAL circumstances surrounding this lawsuit supports the establishment of special court(s) to litigate matters. Whether the SPECIAL relationships of Judges/Justices to opposing party(s) in litigation involving New- some warrant the creation of special court(s) to xi
  12. 12. afford Newsome rights secured and guaran- teed under the United States Constitution and laws of the United States – i.e. equal protec- tion of the laws, equal privileges and immuni- ties of the laws and due process of laws.47. Whether attorneys and their client(s) are al- lowed to engage in criminal and civil wrongs for purposes of obstructing the administration of justice.48. Whether the EXTRAORDINARY and EX- CEPTIONAL circumstances surrounding this lawsuit supports the establishment of special court(s) to litigate matters. Whether the SPECIAL relationships of Judges/Justices to opposing party(s) in litigation involving New- some warrant the creation of special court(s) to afford Newsome rights secured and guaran- teed under the United States Constitution and laws of the United States – i.e. equal protec- tion of the laws, equal privileges and immuni- ties of the laws and due process of laws. xii
  13. 13. II. 2LIST OF PARTIES All parties appear in the caption of the case on thecover page and the following is the contact information foreach of their counsel/representative of record: Honorable Tom S. Lee – Judge J. T. Noblin – Clerk USDC-Southern District Mississippi (Jackson) 501 E. Court Street – Suite 2.500 Jackson, Mississippi 39201 PHELPS DUNBAR LLP c/o W. Thomas Siler, Jr., Esq. Jason T. Marsh, Esq. 4270 I-55 North Jackson, Mississippi 39211-6391 Post Office Box 16114 Jackson, Mississippi 39236-6114 At all times relevant to this instant action, Respond-ent Does 1 through 100 served in respective positions withtheir employer and/or in their individual capacity. New-some is ignorant of the true names and capacities of Does 1through 100, inclusive, and therefore sue these Respond-ents by such fictitious names. Newsome is informed andbelieves and thereon alleges that Respondent Does sonamed (and/or to be named) is responsible and/or partici- 2 BOLDFACE, ITALICS, UNDERLINE, CAPS, etc. of text in this Peti-tion is for purposes of emphasis. xiii
  14. 14. pated in the conspiracy(s)3 against Newsome and in suchmanner is responsible for the injuries and damages suf-fered by Newsome as set forth in this instant pleading.Newsome will amend Petition(s) for: ORIGINAL WRIT –WRIT OF MANDAMUS – WRIT OF PROHIBITION – WRIT OF CON-SPIRACY – WRIT OF EXIGI FACIAS - WRIT OF INJUNCTION -WRIT OF MANDAMUS - WRIT OF REVIEW - WRIT OF SUPER-SEDEAS - WRIT OF SUPERVISORY CONTROL - WRIT OF SECURI-TATE PACIS - EXTRATERRITORIAL WRITS (“OW-WOM, ET AL”)to state the true names and capacities of Respondents Does1 through 100, inclusive, when they have been identifiedand/or ascertained. Due to the extraordinary circumstanc-es and scope of CONSPIRACIES leveled against Newsomeat the time of the filing of this “OW-WOM, ET AL,” she isignorant of the names and capacities of Respondent Does –i.e. believing that during the course of litigation of this mat-ter and/or investigation by this Court into this matter, theidentity(s) of Respondent Does may become known. By en-gaging in the conduct described in this “OW-WOM, ET AL”Respondent Does acted under the course and scope of theiremployment with their respective employer as well as mayhave acted within their individual capacity. By engaging inthe discriminatory conduct described in this “OW-WOM, ETAL,” Respondent Does exceeded the authority vested inthem as an employee of their respective employer andcommitted acts of a personal nature, personal bias and/orfor personal and financial interest and gain. 3 Respondent (conspirator) becomes the agent of the other conspirator(s), and any act done by one of the combination is regarded under the law as theact of both or all. In other words, what one does, if there is this combination,becomes the act of both or all of them, no matter which individual may havedone it. This is true as to each member of the conspiracy, even those whoseinvolvement was limited to a minor role in the unlawful transaction, and itmakes no difference whether or not such individual shared in the profits of theactions. (Am. Jur. Pleading and Practice Forms, Conspiracy § 9). xiv
  15. 15. III. TABLE OF CONTENTSI. QUESTIONS PRESENTED FOR REVIEW ..........................iII. LIST OF PARTIES .............................................................. xiiiIII. TABLE OF CONTENTS ...................................................... xvIV. INDEX TO APPENDICES ................................................. xviV. TABLE OF AUTHORITIES ............................................ xxiiiVI. CONCISE STATEMENT OF JURISDICTION ................ 1VII. CONSTITUTIONAL PROVISIONS, TREATIES,STATUTES, ORDINANCES and REGULATIONSINVOLVED IN CASE ........................................................................ 6VIII. CONCISE STATEMENT OF THE CASE ...................... 7IX. REASONS FOR GRANTING THE PETITION .............. 12X. CONCLUSION and RELIEF SOUGHT ........................... 79XI. CERTIFICATE OF SERVICE ............................................ 80XII. APPENDIX ............................................................................... 1NOTICE OF FILING ........................................................................ 12OF AN “ORIGINAL” ACTION/APPEAL IN THE ...................... 12SUPREME COURT OF THE UNITED STATES ...................... 12WHEREFORE, PREMISES CONSIDERED, please docketthis instant NOTICE OF FILING OF AN “ORIGINAL”ACTION/APPEAL IN THE SUPREME COURT OF THEUNITED STATES. ............................................................................ 20PLAINTIFF’S REQUEST FOR CONFLICT OF INTERESTINFORMATION, NOTICE OF OPPOSITION TOMAGISTRATE JUDGE ASSIGNMENT; AND .......................... 21NOTICE OF ADDRESS .................................................................. 21VOGEL DENISE NEWSOME’S AFFIDAVIT OF ..................... 22 xv
  16. 16. DISQUALIFICATION OF JUDGE TOM S. LEE ..................... 22 IV. INDEX TO APPENDICES In compliance with the Rules of the Supreme Courtof the United States and in good faith of mitigating costsbecause Appendix is VOLUMINOUS, the documents that isto be included in the JOINT APPENDIX are provided atAPPENDIX “6” – Appendix Chart may be found at the fol-lowing link as well: https://secure.filesanywhere.com/fs/v.aspx?v= 8a72648b595e7377b06eAPPX DESCRIPTION 1 08/20/12 - Judgment DISMISSING Newsome’s Complaint WITH prejudice 2 08/20/12 - Order DENYING Newsome’s Motion to Disqualification and DEMAND for Jury Trial 3 08/20/12 - Memorandum Opinion GRANTING Named Defendants’ Motion to Dismiss for “failure to state a claim” 4 09/20/12 – Notice of Filing of an “ORIGINAL” Ac- tion/Appeal in the Supreme Court of the United States 5 Affidavit of DISQUALIFICATION [ONLY] and Link for: OBJECTION(S) To August 2, 2012 Or- der Of Judge Tom S. Lee; Motion For DISQUAL- IFICATION; AND DEMAND FOR JURY TRIAL xvi
  17. 17. (“OBJECTION(S) TO 08/02/12 ORDER”) https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b595e75bc719aAPPENDIX “6” – APPENDIX CHART CONTAINS THE FOLLOW-ING: NO. 6 DOCKET SHEET – Newsome v. Page Kruger & Holland P.A., et al https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b595f6d7d6b9b 7 Recusal Orders by Tom S. Lee https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b595f6ea56c9c 8 Docket Sheet – Newsome v. Entergy https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b595f71b3b26a 9 Bradley S. Clanton – Baker Donelson Information https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b595f72ae9ca5 10 Judge G. Thomas Porteous Impeachment Articles https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b595f76ae9ca5 11 09/24/04 - Request for Department of Justices In- tervention/ Participation in this Case https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b59606eb2a1aa 12 05/15/12 - Request for Conflict of Interest Infor- mation, Notice of Opposition to Magistrate Judge xvii
  18. 18. Assignment; and Notice of Address https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596070b8a6af13 08/15/12 - OBJECTION(S) To August 2, 2012 Or- der Of Judge Tom S. Lee; Motion For DISQUAL- IFICATION; AND DEMAND FOR JURY TRIAL https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596075b96e9714 07/17/12 - Motion to Strike Motion To Dismiss and Memorandum In Support Of Motion To Dis- miss; Motion for Rule 11 Sanctions of and Against Defendants; and Motion for Default Judgment (Jury Trial Demanded in this Action) https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b59616dae9ca515 07/17/12 – Cover Letter to Court Filing https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b59616ebca99b16 07/30/12 - Motion to Strike Motion To Stay All Proceedings Pending A ruling On Defendants’ Motion To Dismiss and Memorandum In Support Of Motion To Stay All Proceedings Pending A Ruling On Defendants’ Motion To Dismiss; Mo- tion for Rule 11 Sanctions of and Against Defend- ants; and Motion for Default Judgment (Jury Tri- al Demanded in this Action) https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b59616fb1a0a917 08/02/12 – Order GRANTING Motion to Stay https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596170afaf67 xviii
  19. 19. 18 08/14/12 - Motion to Strike Defendants’ Response In Opposition To Plaintiff’s Motion To Strike Mo- tion To Dismiss and Memorandum In Support Of Motion To Dismiss; Motion To Strike Defendants’ Response In Opposition To Plaintiff’s Motion For Rule 11 Sanctions Of And Against Defendants; and Motion To Strike Defendants’ Response In Opposition To Plaintiff’s Motion For Default Judgment; Plaintiff’s Motion for Rule 11 Sanc- tions of and Against Defendants; and Motion for Default Judgment (Jury Trial Demanded in this Action) https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b5961717d6c9b19 Baker Donelson - Listing of Government Posi- tions https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b59617275ae6d20 Baker Donelson – Listing of Government Posi- tions (09/11/04) https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b5961747aa0a221 Baker Donelson’s Website Listing of Government Positions https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596176b3a06b22 07/18/11 – Newsome’s Letter to Supreme Court of United States https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b59626db3b36a23 Conduct or Bias of Law Clerk or Other Judicial Support Personnel As Warranting Recusal of xix
  20. 20. FEDERAL Judge or Magistrate https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b59626fb19fa824 DISQUALIFICATION of Supreme Court Justic- es: The Certiorari Conundrum https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596270769c9e25 HOOD vs. HOFFMAN-LAROCHE, LTD, District of Columbia District Court, Case No. 1:06-cv- 01484 https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596271bcaa6926 Phelps Dunbar and Page Kruger & Holland Cli- ent Listings: https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596272b19fa827 W. Lee Rawls Information https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596273bdac6a28 President Barack Obama’s “Secret Kill List” Arti- cle https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596275b8a7af29 David Addington Information https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b59636db6a4ad30 28 USC § 1651 https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b59636eb2b169 xx
  21. 21. 31 Morrow v. District of Columbia https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596370a66ca832 Platt v. Minnesota Min. & Mfg. Co. https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596372b0af6733 De Beers Consol. Mines v. U.S. https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596374aead6734 Google Search Information Regarding Vogel Newsome https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596375a76eaa35 Adams v. U.S. ex rel. McCann https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596376bcab6a36 Ex parte Milwaukee R. Co. https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b59646ea66d9d37 Platt v. Minnesota Min. & Mfg. Co. https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596471bead6c38 Liljeberg v. Health Services Acquisition Corp. https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596474769c9e39 COMPLAINT – Newsome v. Page Kruger & Hol- land et al. https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596476759b9d xxi
  22. 22. 40 Hare v. City of Corinth, Miss. https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b59656fbba96841 05/16/06 – TERMINATION Email (Page Kruger & Holland) https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596571769c9e42 Salinas v. U.S https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596573aa72a243 Porter v. Lee https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596574b5b46c44 Heckler v. Ringer https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596576b96e9945 U.S. ex rel. McLennan v. Wilbur https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b59666fa8709f46 U.S. v. Hoffman https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b596671b0af6747 La Buy v. Howes Leather Company https://secure.filesanywhere.com/fs/v.aspx?v=8a7 2648b59676d79b19748 Fisher v. District Court of Sixteenth Judicial Dist. of Montana, in and for Rosebud County https://secure.filesanywhere.com/fs/v.aspx?v=8a7 xxii
  23. 23. 2648b59676ea5a56c V. TABLE OF AUTHORITIESAdams v. U.S. ex rel. McCann, 63 S.Ct. 236 (1942) .................. 47Albert v. R.P. Farnsworth & Co., 176 F 2d 198 (5th Cir. 1949) ........................................................ 55Aman v. Cort Furniture Rental Corp., 85 F.3d 1074, 1081-82 (3rd Cir. 1996) ....................................... 26Anderson v. McLaughlin, 263 F.2d 723 (1959)........................... 38Andrade v. Chojnacki, 338 F.3d 448 (5th Cir. 2003) .................. 52Archibeque v. Wylie, 16 F.3d 415,1994 WL 41272, *3 (10th Cir.(N.M.)) ........................................... 56Bagley v. Byrd, 534 U.S. 1301, 122 S.Ct. 419, 419-420, 151 L.Ed. 2d 370 (2001) ............. 41, 66Baylis v. Travellers’ Ins. Co., 113 US 316, 28 L Ed 989, 5 S Ct 494 ............................................................... 54Benjamin J. Shipman, Handbook of Common-Law Pleading § 341, at 542 (Henry Winthorp Ballantine ed., 3d ed. 1923) ....................... 75Bennett v. Schmidt, 153 F3d 516 (7th Cir. 1998) ....................... 53Brown v. Gilmore, 533 U.S. 1301, 122 S.Ct. 1, 2-3, 150 L.Ed. 2d 782 (2001) ................................ 64 xxiii
  24. 24. Bryant v. Military Department of Mississippi, 597 F.3d 678 (5th Cir. Miss. 2010) ............................................. 61Chessman v. Teets, 354 U.S. 156, 77 S.Ct. 1127, 1 L.Ed.2d 1253 (1957) ....................................... 44Citizens United v Federal Election Commission, 558 U.S. 50 (2010) ........................................................................... vConduct or Bias of Law Clerk or Other Judicial Support Personnel As Warranting Recusal of FEDERAL Judge or Magistrate.......................................................................xix, 16, 4Connor v. Coleman, 440 U.S. 612, 624, 99 S.Ct. 1523, 59 L.Ed. 2d 619 (1979) .......................... 40, 65, 70Cox v. C. H. Masland & Sons, Inc., 607 F 2d 138 (5th Cir. 1979) ........................................................ 55Davis v. Board of School Comm’rs, 517 F2d 1044 (5th Cir. 1975) ....................................................... 51De Beers Consol. Mines v. U.S., 65 S.Ct. 1130, 325 U.S. 212, 89 L.Ed. 1566 (1945) ........................................... 39DISQUALIFICATION of Supreme Court Justices: The Certiorari Conundrum ............................ 17Estate of Cole by Pardue v. Fromm, 94 F.3d 254, 260 (7th Cir.1996) ................................................. 56Ex parte Fahey, 332 U.S. 258, 260, 67 S.Ct. 1558, 91 L.Ed. 2041 (1947) .............................. 36, 41, 66Ex parte Harding, 219 U.S. 363, 374; 31 S.Ct. 324, 55 L.Ed. 252 (1911) ........................................ 41, 67Ex parte Hung Hang, 108 U.S. 552, 553, xxiv
  25. 25. 2 S.Ct. 863, 27 L.Ed. 811 (1883) .................................... 40, 65, 69Ex parte Milwaukee R. Co., 72 U.S. 188 (1866) ......................... 48Ex parte Siebold, 100 U.S. 371, 374, 25 L.Ed. 717 (1879) ........................................................... 40, 65, 69Ex parte United States, 242 U.S. 27, 52, 37 S.Ct. 72, 61 L.Ed. 129 (1916) .................................... 40, 65, 70Ex parte Young, 209 U.S. 123, 165, 28 S.Ct. 441, 52 L.Ed. 714 (1908) .................................... 1, 42, 67Fisher v. District Court of Sixteenth Judicial Dist. of Montana, in and for Rosebud County, 96 S.Ct. 943 (1976) ....................................... 77Gasperini v. Center for Humanities, Inc., 518 U.S. 415, 116 S.Ct. 2211, 135 L.Ed.2d 659 (1996) (quoting Byrd v. Blue Ridge Rural Elec. Cooperative, Inc., 356 U.S. 525, 537, 78 S.Ct. 893, 901, 2 L.Ed.2d 953 (1958)) ................................................................... 57Greason v. Kemp, 891 F.2d 829, 835 (11th Cir.1990) ............... 56Hall v. Doering, 185 FRD 639 (1999) ........................................... 48Hare v. City of Corinth, Miss., 949 F.Supp. 456 (N.D.Miss.E.Div.,1996) ................................................................ 55Heckler v. Ringer, 104 S.Ct. 2013 (1984) .................................... 74Hendrix v. City of Yazoo City, Miss., 911 F.2d 1102 (5th Cir. Miss. 1990) ........................................... 59Hodges v. Easton, 106 US 408, 16 Otto 408, 27 L Ed 169, 1 S Ct 307 ............................................................... 54In re Aetna Casualty & Surety Co., xxv
  26. 26. 919 F2d 1136 (6th Cir. 1990) ....................................................... 51In re McDonald, 489 U.S. 180, 109 S.Ct. 993 (1989)................. 43In re Michael Sindram, 498 U.S. 177, 179, 111 S.Ct. 596, 112 L.Ed. 2d 599 (1991) .............................. 41, 66In re Murchison, 75 S.Ct. 623 (1955) ............................................ 52Ir re Parmalat Sec. Litig., 375 F.Supp. 2d 278 (2005) .............. 53Kirk v. Simpson, 35 F.3d 566, 1994 WL 443461, *1 (6th Cir.(Tenn.)) ...................................... 56La Buy v. Howes Leather Company, 77 S.Ct. 309 (U.S.,1957)............................................................... 76Liljeberg v. Health Services Acquisition Corp., 486 US 847, 100 L Ed 2d 855, 108 S Ct 2194 (1988) ............ 49Lyon v. Mutual Ben. Health & Acci. Asso., 305 US 484, 83 L Ed 303, 59 S Ct 297, reh den (1939) 306 US 667 .......................................................... 54Macklin v. Spector Freight Systems, Inc., 478 F.2d 979 (1973) ...................................................................... 59Marbury v. Madison, 5 U.S. (1 Cranch) 137, 147, 2 L.Ed. 60 (1803) ........................................................... 4, 40, 65, 69McDonnell Douglas Corp. v. Green, 411 U.S. 792, 801 (1973) .............................................................. 26MCullough v. Cosgrave, 309 U.S. 634, 635, 60 S.Ct. 703, 84 L.Ed. 992 (1940) .................................. 40, 65, 70Miller v. Schoenen, 75 F.3d 1305, 1311 (8th Cir.1996) ............ 56Mongelli v. Mongelli, 849 F.Supp. 215 (1994) ............................ 47 xxvi
  27. 27. Morrow v. District of Columbia, 417 F.Ed 728, 135 U.S. App.Dc. 160 on remand 259 A.2d 592 (1969) .......................... 37Parliament Ins. Co. v. Hanson, 676 F.2d 1069 (5th Cir. 1982) ...................................................... 52Pennsylvania v. Wheeling Belmont Bridge Co., 59 U.S. 421, 431, 15 L.Ed. 435 (1885) .......................... 40, 65, 69Platt v. Minnesota Min. & Mfg. Co., 84 S.Ct. 769, 376 U.S. 240, 11 L.Ed.2d 674 (1964) .......... 38, 48Porter v. Lee, 66 S.Ct. 1096 (U.S.Ky.,1946) ................................ 73Potashnick v. Port City Const. Co., 609 F.2d 1101 (1980) ....... 22Randolph v. Lambert, 926 So.2d 941 (Miss.App.,2006) ........... 60Reeside v. Walker, 52 U.S. 272 (1850) ......................................... 74Roche v. Evaporated Milk Ass’n, 319 U.S.21, 25, 63 S.Ct. 938, 941, 87 L.Ed. 1185 ................................................ 39Sable v. General Motors Corp., 90 F.3d 171 (1996) ................... 46Salinas v. U.S., 118 S.Ct. 469 (1997) ............................................ 70Stevens v. Lake, 615 So.2d 1177 (Miss.,1993) ............................ 60Supervisors v. U.S., 85 U.S. 71 (1873) ......................................... 74U.S. ex rel. McLennan v. Wilbur, 51 S.Ct. 502 (1931) .............. 74U.S. v. Comstock, 130 S.Ct. 1949 (U.S.,2010) ............................ 77U.S. v. Denedo, 129 S.Ct. 2213 ...................................................... 36U.S. v. Hoffman, 71 U.S. 158 (1866) ............................................. 75 xxvii
  28. 28. U.S. v. International Broth. Of Teamsters, Chauffeurs, Warehousemen and Helpers of America, AFL-CIO, 911 F.Supp. 743 (1996) ........................... 46U.S. v. New York Tel. Co., 98 S.Ct. 364, 434 U.S. 159, 54 L.Ed.2d 376 ..................................................... 46U.S. v. Oregon State Medical Soc., 72 S.Ct. 690 (1952) ........... 72U.S. v. Schaffer, 586 F.3d 414 (C.A.6.Ohio,2009) ...................... 71United States v. Brown, 539 F2d 467 (5th Cir. 1976) ................ 50United States v. IBM Corp., 475 F.Supp. 1372 affd 618 F2d 923 (2nd Cir. 1980) ............... 50Wagner, Original Jurisdiction of National Supreme Courts, 33 St. John’s L. Rev. 217 (1959) ..................................... 40, 65, 69Waldens Lessee v. Craigs Heirs, 39 U.S. 147 (U.S.Ky.,1840) ......................................................... 72Wayman v. Southard, 23 U.S. 1 (U.S.Ky.,1825) ........................ 72Weber v. Henderson, 275 F.Supp.2d 616 (2003) ........................ 43Will v. United States, 389 U.S. 90, 95, 88 S.Ct. 269, 19 L.Ed. 305 (1967) ........................................ 41, 66Winters v. AmSouth Bank, 964 So.2d 595 (Miss.App.,2007) ................................................. 60Wisconsin Right to Life, Inc. v. Federal Election Comm’n., 542 U.S. 1305, 125 S.Ct. 2, 159 L.Ed. 2d 805, 807 (2004).......................... 37, 64Wisconsin v. Pelican Ins. Co., 127 US 265, 32 L Ed 239, 8 S Ct. 1370 (1888) (ovrld in part on other grounds by Milwaukee County v xxviii
  29. 29. M.E. White Co. (1935) 296 US 268, 80 L Ed 220, 56 S. Ct. 229)) ........................................................ 78Woodard v. Atlantic C.L. R. , 57 F 2d 1019 (5th Cir. 1932). ..... 55WW, Inc. v. Rainbow Casino-Vicksburg Partnership, L.P., 2011 WL 4037024 (Miss. 2011) ................ 61Zuber v. Allen, 90 S.Ct. 314 (1969) ............................................... 76Statutes28 U.S.C. § 455 ...................................................................... 22, 23, 2428 U.S.C. § 1251 .................................................................................. 328 U.S.C. § 1257 ...................................................................... 3, 77, 7828 U.S.C. § 1651 .............................................................. 35, 40, 64, 6542 U.S.C.A. § 1981 ............................................................................ 6028 U. S. C. § 2403 ............................................................................ 5, 680th Congress House Report No. 308 ............................................ 40Vol. 22 Moore’s Federal Practice, § 400.04 Supervisory Authority of Supreme Court Over Inferior Federal Courts ....................................................... 5§ 402.02 Article III Jurisdiction and Its Limitations .................. 4___ , § 520.02 Considerations Governing Issuance Of Extraordinary Writ ....................................................................... 64Vol. 23 Moore’s Federal Practice, § 520.02[2] (Matthew Bender 3d ed.) ................................................. 41, 66, 7080th Congress House Report No. 308 ............................................ 40Other AuthoritiesAm. Jur. Pleading and Practice Forms, Conspiracy § 9 ......................................................................... xiv, 70 xxix
  30. 30. Article III, § 2, United States Constitution................................... 4H.R.Rep.No.93-1453, 93d Cong., 2d Sess. (1974), Reprinted in 1974 U.S.Code Cong. & Admin. News, pp. 6351, 6352-54 .............................................................. 23Vol. 23 Moore’s Federal Practice, § 520.02 Considerations Governing Issuance Of Extraordinary Writ ....................................................................... 64RulesRule 14.1(e)(v) ...................................................................................... 6Supreme Court of United States Rule 20 ...................................... 3U.S. Supreme Court Rule 29(b) ....................................................... 5United States Supreme Court Rule 17(1) ...................................... 3United States Supreme Court Rule 20 .......................................... 3United States Supreme Court Rule 29(b) ...................................... 5 xxx
  31. 31. VI. CONCISE STATEMENT OF JURISDICTION Ex parte Young, 209 U.S. 123, 165, 28 S.Ct. 441, 52 L.Ed. 714 (1908) - [HN1] The Supreme Court of the United States will not take jurisdiction if it should not; but it is equally true that it must take jurisdiction if it should. The judiciary cannot, as the legislature may, avoid a measure because it approaches the con- fines of the Constitution. The court cannot pass it by because it is doubtful. With whatever doubts, with whatever difficulties, a case may be attended, the court must decide it, if it is brought be- fore it. The court has no more right to decline the exercise of jurisdiction, which is given, than to usurp that which is not given. The one or the other would be treason to the Constitution. Ques- tions may occur which the court would gladly avoid, but the court cannot avoid them. All the court can do is to exercise its best judgment, and conscientiously perform its duty. This is a matter that is birthed out of the UnitedStates District Court – Southern District of Mississippi(Jackson Division) denial of Newsome’s Affidavit of Dis-qualification and DEMAND for JURY Trial on ALL issuestriable by jury. Because of the EXTRAORDINARY andEXCEPTIONAL circumstances surrounding this matter,Newsome seeks the Supreme Court of the United States’(“U.S. Supreme Court”) Original Jurisdiction through Ex-traordinary Writ(s) Newsome believes that the role of a sit-ting United States President (Barack H. Obama), his legal
  32. 32. Page 2 of 80counsel/advisor Baker Donelson Bearman Caldwell &Berkowitz (“Baker Donelson”), his Administration as wellas his SPECIAL INTEREST Groups’, Lobbyists’, etc. role inthe lower courts’ actions (which are clearly prohibited bylaw) supports the extraordinary and exceptional circum-stances which exist warranting the relief sought throughExtraordinary Writ(s) and/or applicable action the U.S. Su-preme Court deems appropriate. In further support of saidCourt’s Original Jurisdiction, Newsome states: a. On or about May 15, 2012, Newsome’s Com- plaint (i.e. with TIMELY JURY DEMAND) styled, Vogel Denise Newsome v. Page Kruger & Holland P.A., et al., Civil Action No. 3:12-cv- 00342 was filed in the United States District Court – Southern District of Mississippi (Jack- son Division). See APPX CHT No. “6” – Dock- et Sheet at No. 1 incorporated herein by refer- ence as if set forth in full herein. b. On or about May 15, 2012, a TIMELY plead- ing entitled, “Request for Conflict of Interest Information, Notice of Opposition to Magis- trate Judge Assignment; and Notice of Ad- dress.” See APPX CHT No. “12” incorporated by reference as if set forth in full herein. Low- er Court FAILED to address the ALL issues raised therein. c. On or about August 15, 2012, Newsome’s pleading entitled, “OBJECTION(S) To August 2, 2012 Order Of Judge Tom S. Lee; Motion For DISQUALIFICATION; AND DEMAND FOR JURY TRIAL” was filed in the lower court. See APPX CHT No. “13” incorporated herein by reference as if set forth in full here- in.
  33. 33. Page 3 of 80d. Because of the EXTRAORDINARY and EX- CEPTIONAL circumstances surrounding this action, pursuant to Rule 17 – Procedure in an Original Action - of the U.S. Supreme Court, “A petition for an extraordinary writ in aid of the Court’s appellate jurisdiction shall be filed as provided in Rule 20” of this Court.e. Pursuant to U.S. Supreme Court Rule 20 – Procedure on a Petition for an Extraordinary Writ – issuance by the Court of an extraordi- nary writ is authorized by 28 USC § 1651(a).f. The jurisdiction of the U.S. Supreme Court is invoked under 28 U.S.C. § 1257(a).g. The jurisdiction of the U.S. Supreme Court is invoked under 28 U.S.C. § 1251 – Original Ju- risdiction: (a) The Supreme Court shall have original and exclusive jurisdiction of all controversies between two or more states. . . .h. Jurisdiction is invoked under U.S. Supreme Court Rule 17(1) – Procedure in an Original Action: This Rule applies only to an ac- tion invoking the Courts original jurisdiction under Article III of the Constitution of the United States. See also 28 U. S. C. §1251 and U. S. Const., Amdt. 11. A pe- tition for an extraordinary writ in aid of the Courts appellate juris-
  34. 34. Page 4 of 80 diction shall be filed as provided in Rule 20.i. The jurisdiction of this Court is further in- voked pursuant to Article III, § 2, United States Constitution - - Section 2: The judicial Power shall extend to all Cases, in Law and Equity, arising under this Constitution, the Laws of the United States, and Treaties made, or which shall be made, under their Authority ... § 402.02 Article III Jurisdiction and Its Limi- tations [1] – Original Jurisdiction of Supreme Court Under Article III [a] Nature of Original Jurisdiction: The Supreme Court is generally a source of appellate review, but it can act as a trial court in certain instances. Original juris- diction means the following, as Justice Marshall explained in Marbury v. Madison; 5 U.S. (1 Cranch) 137, 174, 2 L.Ed. 60 (1803): [The Court has] the power to hear and decide a lawsuit in the first instance . . . [A]ppellate ju- risdiction means the authority to review the judgment of an- other court which has already heard the lawsuit in the first instance. Trial courts are courts that exercise original ju- risdiction; courts of appeals. . .
  35. 35. Page 5 of 80 exercise appellate jurisdiction. Id. Article III of the U.S. Constitution pre- scribes the Supreme Court’s original ju- risdiction (See U.S. Constitution, Article III, § 2 cl. 2). Under the first clause of Section 2 of Article III, federal courts have jurisdiction over the following: [A]ll Cases, in Law and Equity, arising under this Constitution, the Laws of the United States, and Treaties made, or which shall be made, under their Authority. j. Vol. 22 Moore’s Federal Practice, § 400.04 Su- pervisory Authority of Supreme Court Over Inferior Federal Courts [1] SUPREME COURT HAS EXTENSIVE RULEMAK- ING POWER: The Supreme Court has powers beyond its duty to entertain cases within its original and appellate jurisdiction. The Court has extensive power to prescribe rules of prac- tice and procedure for civil actions. . . The Su- preme Court, of course, has the power to promulgate rules governing practice and pro- cedure before itself, and has done so. k. Pursuant the U.S. Supreme Court Rule 29(b), 28 USC § 2403(a) may apply.4 4 U.S. Supreme Court Rule 29(b): In any proceeding in this Court inwhich the constitutionality of an Act of Congress is drawn into question, andneither the United States nor any federal department, office, agency, officer, oremployee is a party, the initial document filed in this Court shall recite that 28U. S. C. § 2403(a) may apply and shall be served on the Solicitor General of theUnited States, Room 5614, Department of Justice, 950 Pennsylvania Ave., N.W., Washington, DC 20530-0001. In such a proceeding from any court of theUnited States, as defined by 28 U. S. C. § 451, the initial document also shallstate whether that court, pursuant to 28 U. S. C. § 2403(a), certified to the At-
  36. 36. Page 6 of 80 l. The following statute may further apply: 28 USC §2403 - Intervention by United States or a State; Constitutional Question: (a) In any action, suit or proceeding in a court of the United States to which the United States or any agency, officer or employee thereof is not a party, wherein the constitutionality of any Act of Congress affecting the public interest is drawn in question, the court shall certify such fact to the Attorney General, and shall permit the United States to intervene for presentation of evidence, if evidence is otherwise admissible in the case, and for argument on the question of constitutionality. The United States shall, subject to the applicable provisions of law, have all the rights of a party and be subject to all liabilities of a party as to court costs to the extent necessary for a proper presentation of the facts and law relating to the question of constitutionality. VII. CONSTITUTIONAL PROVISIONS, TREATIES, STATUTES, ORDINANCES and REGULATIONS INVOLVED IN CASE CONSTITUTION: a. United States Constitution b. United States Constitution – Amendments 1, 7, 13 through 15 c. Article III, § 2, United States Constitutiontorney General the fact that the constitutionality of an Act of Congress wasdrawn into question. See Rule 14.1(e)(v).
  37. 37. Page 7 of 80 STATUTES: d. 28 USC § 144 -Bias or prejudice of judge e. 28 USC § 455 - Disqualification of justice, judge, or magistrate judge f. 28 USC § 1651 - Writs g. 28 USC § 1915 - Proceedings in forma pauperis h. 28 USC § 1257 - State courts; certi- orari i. 42 USC § 1983 - Civil action for deprivation of rights j. 42 USC § 1985 - Conspiracy to in- terfere with civil rights k. 42 USC § 1986 - Action for neglect to prevent 5 VIII. CONCISE STATEMENT OF THE CASE (1) On or about May 15, 2012, Newsome’s Com- plaint styled, Vogel Denise Newsome v. Page Kruger & Holland P.A., et al., Civil Action No. 3:12-cv-00342 was filed in the United States District Court – Southern District of Missis- sippi (Jackson Division). See APPX CHT No. 5 Every person who, having knowledge that any of the wrongs con-spired to be done, and mentioned in section 1985 of this title, are about to becommitted, and having power to prevent or aid in preventing the commission ofthe same, neglects or refuses so to do, if such wrongful act be committed, shallbe liable to the party injured, or his legal representatives, for all damagescaused by such wrongful act, which such person by reasonable diligence couldhave prevented; and such damages may be recovered in an action on the case;and any number of persons guilty of such wrongful neglect or refusal may bejoined as defendants in the action; . . .
  38. 38. Page 8 of 80 “6” – Docket Sheet at No. 1 incorporated here- in by reference as if set forth in full herein.(2) On or about May 15, 2012, the lower court filed Newsom’e pleading entitled, “Request for Conflict of Interest Information, Notice of Op- position to Magistrate Judge Assignment; and Notice of Address” See APPX CHT No. “12” in- corporated herein by reference as if set forth in full herein.(3) On or about July 5, 2012, lower court Defend- ants (Page Kruger & Holland P.A., Thomas Y. Page, Louis G. Baine III, Linda Thomas [“Named Defendants”]) submitted for filing their pleadings entitled, “Motion To Dismiss” and “Memorandum In Support Of Motion To Dismiss.” See APPX CHT No. "6” at Docket Nos. 5 and 6.(4) On or about July 16, 2012, in FURTHER ABUSE of the lower court’s electronic filing system Named Defendants filed pleadings en- titled, “Motion to Stay All Proceedings Pend- ing a Ruling on Defendants’ Motion to Dis- miss” and “Memorandum in Support of Motion to Stay All Proceedings Pending a Ruling on Defendants’ Motion to Dismiss.” See APPX CHT No. “6” – Doc. Nos. 9 and 10 respectively.(5) On or about July 17, 2012, Newsome’s plead- ing entitled, “Motion to Strike Motion To Dis- miss and Memorandum In Support Of Motion To Dismiss; Motion for Rule 11 Sanctions of and Against Defendants; and Motion for De- fault Judgment (Jury Trial Demanded in this Action)” was filed with the lower court. See
  39. 39. Page 9 of 80 APPX CHT No. “14” incorporated herein by reference as if set forth in full herein.(6) On or about July 17, 2012, the lower court filed a copy of Newsome’s cover letter which addresses the PUBLIC/GLOBAL/INTER- NATIONAL interests in documents posted in SOCIAL Forums by her. See APPX CHT No. “15” incorporated herein by reference as if set forth in full herein.(7) On or about July 30, 2012, Newsome’s plead- ing entitled, Motion to Strike Motion To Stay All Proceedings Pending A ruling On Defend- ants’ Motion To Dismiss and Memorandum In Support Of Motion To Stay All Proceedings Pending A Ruling On Defendants’ Motion To Dismiss; Motion for Rule 11 Sanctions of and Against Defendants; and Motion for Default Judgment (Jury Trial Demanded in this Ac- tion) was filed in the lower court. See APPX CHT No. “16” incorporated by reference as if set forth in full herein.(8) On or about August 2, 2012, Judge Tom S. Lee entered Order GRANTING Named Defend- ants’ Motion to Stay and DENYING New- some’s Motion to Strike the Motion to Stay – i.e. in which Newsome TIMELY demanded a JURY TRIAL on issues raised. See APPX CHT No. “17.”(9) On or about August 14, 2012, Newsome’s pleading entitled, Motion to Strike Defend- ants’ Response In Opposition To Plaintiff’s Motion To Strike Motion To Dismiss and Memorandum In Support Of Motion To Dis- miss; Motion To Strike Defendants’ Response
  40. 40. Page 10 of 80 In Opposition To Plaintiff’s Motion For Rule 11 Sanctions Of And Against Defendants; and Motion To Strike Defendants’ Response In Opposition To Plaintiff’s Motion For Default Judgment; Plaintiff’s Motion for Rule 11 Sanc- tions of and Against Defendants; and Motion for Default Judgment (Jury Trial Demanded in this Action) was filed in the lower court. See APPX CHT No. “18” incorporated herein by reference as if set forth in full herein.(10) On or about August 15, 2012, Newsome’s pleading entitled, “OBJECTION(S) To August 2, 2012 Order Of Judge Tom S. Lee; Motion For DISQUALIFICATION; AND DEMAND FOR JURY TRIAL” was filed in the lower court. See APPX CHT No. “5” incorporated herein by reference as if set forth in full here- in.(11) On or about August 20, 2012, Judge Tom S. Lee entered ORDER DENYING Newsome’s Motion to Disqualification and DEMAND for Jury Trial. See APPX “2.”(12) On or about August 20, 2012, Judge Tom S. Lee entered Memorandum Opinion GRANT- ING Named Defendants’ Motion to Dismiss for “failure to state a claim” - defense based on 42 USC § 1983 claims when NO such claim(s) under § 1983 is raised at all in Newsome’s Complaint [EMPHASIS ADDED] - and DENYING Newsome’s Motion to Strike Mo- tion to Dismiss. See APPX “3.”(13) On or about August 20, 2012, Judge Tom S. Lee entered Judgment DISMISSING New-
  41. 41. Page 11 of 80 some’s Complaint WITH prejudice. See APPX “1.” (14) On or about September 20, 2012, Newsome’s pleading entitled; “Notice of Filing of an “ORIGINAL” Action/Appeal in the Supreme Court of the United States” was filed in the lower court. See APPX “4” incorporated herein by reference as if set forth in full herein.This is a matter that involves a sitting United States ofAmerica President (Barack H. Obama)/his Administra-tion/his Legal Counsel (Baker Donelson Bearman Caldwell& Berkowitz) and their SPECIAL Interest Groups who allhave interests (i.e. financial/personal) in the outcome of thislawsuit. This is a matter of EXTRAORDINARY and EX-CEPTIONAL circumstances in which Newsome is notaware whether the Supreme Court of the United States hasseen anything like it. In preservation of rights secured toNewsome under the United States of America Constitution,Laws of the United States of America (“United States”) andother governing statutes/laws, she submits her Petition(s)for: ORIGINAL WRIT – WRIT OF MANDAMUS – WRIT OF PRO-HIBITION – WRIT OF CONSPIRACY – WRIT OF EXIGI FACIAS -WRIT OF INJUNCTION - WRIT OF MANDAMUS - WRIT OF RE-VIEW - WRIT OF SUPERSEDEAS - WRIT OF SUPERVISORY CON-TROL - WRIT OF SECURITATE PACIS - EXTRATERRITORIALWRITS (hereinafter, “OW-WOM, ET AL”) and states the fol-lowing in support thereof: a. Also see facts set forth at Concise State- ment of Jurisdiction above of this instant pleading.
  42. 42. Page 12 of 80 IX. REASONS FOR GRANTING THE PETITIONA. CONFLICT OF INTEREST REQUEST: Prior to addressing the reasons for granting the“OW-WOM, ET AL,” Newsome, in the interest of justice aswell as for PUBLIC/WORLDWIDE interest, Newsome re-quest that the U.S. Supreme Court Jus-tice(s)/Administration advise her of whether or not “CON-FLICT OF INTEREST” exists in the handling of this mat-ter. Newsome has obtained information which will sup-port that Respondents engage in conspiracies with THIRD-Parties - i.e. for instance, Baker Donelson Bearman Cald-well & Berkowitz [“Baker Donelson”] who advertises itsSPECIAL relationships/ties to “highly distinguished indi-viduals, people who have served as:”  Chief of Staff to the President of the United States  United States Secretary of State  United States Senate Majority Lead- er  Members of the United States Sen- ate  Members of the United States House of Representatives  Director of the Office of Foreign As- sets Control for United States  Department of Treasury  Director of the Administrative Office of the United States
  43. 43. Page 13 of 80 Chief Counsel, Acting Director, and Acting Deputy Director of United States Citizenship & Immigration Services within the United States Department of Homeland Security Majority and Minority Staff Director of the Senate Committee on Appro- priations Member of United States President’s Domestic Policy Council Counselor to the Deputy Secretary for the United States Department of HHS Chief of Staff of the Supreme Court of the United States Administrative Assistant to the Chief Justice of the United States Deputy under Secretary of Interna- tional Trade for the United States Department of Commerce Ambassador to Japan Ambassador to Turkey Ambassador to Saudi Arabia Ambassador to the Sultanate of Oman Governor of Tennessee Governor of Mississippi Deputy Governor and Chief of Staff for the Governor of Tennessee
  44. 44. Page 14 of 80  Commissioner of Finance & Admin- istration (Chief Operating Officer) - State of Tennessee  Special Counselor to the Governor of Virginia  United States Circuit Court of Ap- peals Judge  United States District Court Judges  United States Attorneys  Presidents of State and Local Bar AssociationsEMPHASIS ADDED in that this information is pertinentto establish - “though not parties to original action . . .arein position to frustrate implementation of court order orproper administration of justice” - the CONSPIRACY andPATTERN-OF-CRIMINAL/CIVIL wrongs leveled againstNewsome out of which this instant relief is sought. Thisinformation was originally located at: http://www.martindale.com/Baker-Donelson- Bearman-Caldwell/law-firm-307399.htmSee APPX CHT No. “19” attached hereto and incorporatedby reference as if set forth in full herein. It is such infor-mation which had been posted for several years. See AP-PENDIX “20” of listing pulled approximately September 11,2004. However, Baker Donelson moved SWIFTLY forDAMAGE-CONTROL purposes and SCRUBBED this in-formation from the Internet. It is a GOOD THING NEW-SOME RETAINED HARD COPIES so that the PUB-LIC/WORLD can see the COVER-UP and COWARDLY tac-tics of one of the most Powerful Leaders (BarackObama)/Countries (United States) attempting toHIDE/MASK their CRIMES/CIVIL WRONGS leveledagainst Newsome, members of her class and/or citizens of
  45. 45. Page 15 of 80the United States of America. From research, Baker Do-nelson’s LISTING of GOVERNMENT positionsheld/controlled may also be found on its website. See APPXCHT No. “21.” Newsome hereby DEMANDS that this Court adviseher of any/all CONFLICTS-Of-Interest that exist. CON-FLICTS are MANDATORILY required to be made KNOWNto Newsome as a matter of statutes/laws governing saidmatters. It is a matter of PUBLIC/GLOBAL/ INTERNA-TIONAL interests in that this Court is the HIGHESTCourt of the ONCE MOST powerful Country (United Statesof America) in the World. The HIGHEST Court in which itappears one has to be either CATHOLIC or JEWISH to beappointed to the Bench – i.e. DISCIMINATORY and UN-CONSTITUTIONAL practices in themselves. The UnitedStates of America in which its CONGRESS (at the time ofthis filing) consist of approximately an 100% ALL WHITESenate and approximately 90% ALL WHITE House of Rep-resentatives as recent as the YEAR 2012! The record evidence of this Court will support thatNewsome on or about July 18, 2011, demanded that theJustices of the U.S. Supreme Court STEP DOWN, be RE-MOVED and/or IMPEACHED: PLEASE TAKE NOTICE: . . .Newsomes REQUEST that ALL Justices of the United States Supreme Court be IMMEDIATELY REMOVED from the BENCH (by FRIDAY, July 22, 2011) - i.e. IMPEACHED, or in ac- cordance with the applicable laws governing REMOVAL and/or IMPEACHMENT! While such request(s) may be UNPRECEDENT it is one of URGENT and NATIONAL SECU- RITY; as well as in PUBLIC/WORLDWIDE Interest that the Supreme Court of the Unit- ed States be PURGED of such CRIMINALS
  46. 46. Page 16 of 80 so that JUSTICE may be rendered UNBIAS and IMPARTIALLY - i.e. rather than TAINTED with the likes of this Courts pre- sent Judicial Panel. PLEASE TAKE NOTICE: That the PUB- LIC/WORLD would be better served and the United States may be SPARED further EM- BARRASSMENT (sic) and HUMILIA- TION/DISGRACE/DISHONOR if the Justic- es of this Court and those involved in the CORRUPTION, COVER-UP of Criminal Civ- il wrongs leveled against Newsome STEP DOWN IMMEDIATELY!See APPX CHT No. “22” attached hereto and incorporatedby reference as if set forth in full herein. It appears this Court is FULLY AWARE and is al-lowing its RELATIONSHIPS with Baker Donelson Bear-man Caldwell & Berkowitz to CONTROL and MANIPU-LATE “Supreme Court DECISIONS” through CRIMINALacts and practices. Moreover, the Justices and the Staff ofthis Court are WILLING PARTICIPANTS in Baker Donel-son’s CONSPIRACIES and CRIMINAL activities, and,therefore, present CONFLICTS-Of-Interest warrantingRECUSAL. See APPX CHT No. “23” – Conduct or Bias ofLaw Clerk or Other Judicial Support Personnel As War-ranting Recusal of FEDERAL Judge or Magistrate (i.e.which INCLUDE Justice(s) of the U.S. Supreme Court, at-tached hereto and incorporated by reference as if set forthin full herein. The Justices of this Court havingKNOWLEDGE that it is Baker Donelson’s ACCESS andCONTROL of the EXECUTIVE Branch/WhiteHouse/United States of America Presidents and LEGISLA-TIVE Branch/Congress/United States Senators as their Le-gal Counsel/Advisor that led to their NOMINATION andAPPOINTMENT of Justices Baker Donelson wanted on
  47. 47. Page 17 of 80this Court’s Bench for purposes of PROMOTING its and itsclients’ PERSONAL/BUSINESS! During Newsome’s research on said matter(s), shecame across an article in the Minnesota Law Review enti-tled, “DISQUALIFICATION of Supreme Court Justices:The Certiorari Conundrum,” in which for instance, providean example: . . .the recent nomination of Stephen Breyer to the Supreme Court of the United States raised the question of his participation as a “name” in a Lloyd’s of London insurance syndicate. During the confirmation hearings, Justice Breyer pledged that he would not participate in any cases that im- plicated Lloyd’s financial interests. As a member of the Court, he has de- clined to sit on cases involving Lloyd’s either directly or indirectly. Other nominees in less controversial circum- stances have made similar disqualifi- cation commitments. Since 1992, there have been OVER 350 cases, peti- tions, motions or applications in which one or more Supreme Court Justices “took NO part. . .”at Page 659 See APPENDIX “24” – attached hereto and in-corporated by reference as if set forth in full herein. Never-theless, when Newsome comes before this Court, its Justic-es CLEARLY having KNOWLEDGE of the CONFLICTS-Of-Interest that exist FAIL to recuse themselves and pro-ceed on to ENGAGE in CRIMINAL wrongdoing and ful-filling their ROLES in Conspiracies to DEPRIVE NewsomeEQUAL protection of the laws, immunities and privileges
  48. 48. Page 18 of 80and DUE PROCESS of laws secured/guaranteed under theUnited States Constitution. While Baker Donelson’s name may not appear as Le-gal Counsel in this Lawsuit, PROVISIONS have been madeto add them and their Client(s) as a party when applicableand upon receipt of DISCOVERY evidence which will pro-vide additional evidence as to the ROLE it has played andis playing in the CONSPIRACIES leveled against New-some– and their INTERESTS in this instant lawsuit. Sablev. General Motors Corp., 90 F.3d 171 (1996); U.S. v. NewYork Tel. Co., 98 S.Ct. 364, 434 U.S. 159, 54 L.Ed.2d 376and Mongelli v. Mongelli, 849 F.Supp. 215 (1994) Under All Writs Act, federal courts has authority to issue commands as necessary to effectuate orders it has previously issued and extends to per- sons who were not parties to original action but are in position to frustrate implementation of court order.Furthermore, Newsome’s RESEARCH has yielded infor-mation wherein Baker Donelson engages in “TAG-TEAMLitigation” – i.e. lawsuits in which Baker Donelson COW-ARDLY SHIELDS/HIDES its role in lawsuits involvingNewsome by relying upon what are known as “FRONTINGFirms” wherein it SHARE Clients and interests of theseother Law Firms and SHARE in the expenses and PROF-ITS from representation of clients for purposes of REMAIN-ING UNDETECTED! In this instant “OW-WOM, ET AL”the “FRONTING” law firm being used by Baker Donelson isPhelps Dunbar LLP. For instance, see HOOD vs. HOFF-MAN-LAROCHE, LTD, District of Columbia District Court,Case No. 1:06-cv-01484 – APPENDIX “25” attached heretoand incorporated by reference as if set forth in full herein –where Baker Donelson TAG-TEAMS with Law Firms asButler Snow O’Mara Stevens & Cannada PLLC (“Butler
  49. 49. Page 19 of 80Snow”) and Phelps Dunbar LLP (“Phelps Dunbar”). Ofcourse, like Baker Donelson, their associating law firms en-joy sharing their CLIENT LISTINGS with the PUBLIC.See for instance APPX CHT No. “26” – Phelp Dunbars List-ing and that of Page Kruger & Holland attached hereto andincorporated by reference as if set forth in full herein. List-ing such clients as those provided in document at the fol-lowing link: https://secure.filesanywhere.com/fs/v.a spx?v=8a72648b596272b19fa8Information that is relevant in that it provides informationto further support RECUSAL and CONFLICT-OF-INTEREST requests of Newsome. SUBSTANTIAL EVI-DENCE is apparent through lawsuits in which Newsomeengages. For instance: In Newsome vs. Mitchell McNutt & Sams, Butler Snow at- tempted to enter that lawsuit WITH- OUT making an appearance. New- some TIMELY, PROPERLY and AD- EQUATELY objected to these CRIM- INAL and CIVIL violations! To date that lawsuit sits DORMANT as the CRIMINAL CONSPIRACIES leveled against Newsome ESCALATES! Newsome believes that Baker Donel- son is involved and merely using But- ler Snow as a FRONTING Firm to HIDE/SHIELD its ROLE and person- al, business and financial INTER- ESTS in lawsuit. This case is just sit- ting DORMANT as Baker Donelson and its CONSPIRATORS and BRIBED/TAINTED and CORRUPT Judge(s) OBSTRUCT the administra- tion of justice and CONTINUE to en-
  50. 50. Page 20 of 80gage in CRIMINAL and CIVIL viola-tions leveled against Newsome.www.slideshare.net/VogelDenise/051912-docket-sheet-mms A lawsuit in which one of PhelpDunbar’s Employees (F. Keith Ball)has been assigned as the MagistrateJudge:www.slideshare.net/VogelDenise/071812-fax-to-phelps-dunbar-w-thomas-siler-jr-jason-t-marsh This is alawsuit in which it appears Baker Do-nelson had Magistrate Ball ABUSEhis Authority and WITHOUT Juris-diction, etc. enter a NULL/VOID Or-der STAYING the lawsuit. Now it ap-pears a matter which may also have tobe brought before this Court as anORIGINAL action pursuant to Rules17 and 20 of the Supreme Court of theUnited States and other statutes/lawsgoverning said matters. In Newsome vs. Page Kruger &Holland, et al., Phelps Dunbar has ap-peared as counsel and is acting as theFRONTING Firm for Baker Donelsonand their personal, business and fi-nancial INTERESTS. Judge Tom S.Lee is assigned this matter. JudgeLee appears on Baker Donelson’sLISTING of Judges:www.slideshare.net/VogelDenise/baker-donelson-ties-to-judgesjustices-as-of120911-11566964
  51. 51. Page 21 of 80As well as Baker Donelson appearingon Judge Lee’s List of Law Firms RE-QUIRING his recusal:www.slideshare.net/VogelDenise/lee-judge-recusal-orders-11574531 For instance, Newsome TIME-LY, PROPERLY and ADEQUATELYmade her OBJECTIONS KNOWN inthe lower court. However, it appearsthat as recent as August 20, 2012,Judge Tom S. Lee too has ABUSEDhis authority, USURPED jurisdictionover this lawsuit in which he lacksand, as a matter of law, is required toRECUSE himself. Nevertheless,Judge Tom S. Lee is ADAMANT aboutstaying in the lawsuit for CRIMINALintent and the FULFILLMENT of hisROLE in the CONSPIRACIES leveledagainst Newsome that CONTINUESto date. A matter which is now beingbrought before this Court as an ORIG-INAL action pursuant to Rules 17 and20 of the Supreme Court of the UnitedStates and other statutes/laws govern-ing said matters. It appears this instant “OW-WOM, ET AL” is before this Court be-cause of the CONSPIRACIES andCRIMINAL acts of Baker Donelsonand TOP/KEY Clients (i.e. as LIBER-TY MUTUAL INSURANCE COMPA-NY). It appears Baker DonelsonCONTROLS and RUN the entire JU-DICIAL system. Moreover, engage inCRIMINAL activities for purposes of
  52. 52. Page 22 of 80 obtaining decisions in their favor and that of PARTNERING law firms as PHELPS DUNBAR and their clients (i.e. in this instant lawsuit Judge Tom S. Lee, Named Defendants, etc.). Wherefore, Newsome believes this request is made ingood faith in that the record evidence will support that inapproximately a one-year period, Judges and/or their Aidesassociated in legal matters regarding Newsome have been“INDICTED” and/or “IMPEACHED” – i.e for instanceJudge John Andrew West’s (Judge in the Hamilton CountyCourt of Common Pleas matter former Bailiff, Damon Rid-ley, was found GUILTY for attempted bribery for takingmonies for purposes of getting cases dismissed as JudgeWest and opposing parties in that action are attempting todo without legal authority and cause).6 Furthermore, two 6 Potashnick v. Port City Const. Co., 609 F.2d 1101 (1980) - [n.4] Ajudge faced with a potential ground for disqualification ought to consider howhis participation in a given case looks to the average person on the street; use ofthe word “might” in statute was intended to indicate that disqualificationshould follow if reasonable man, were he to know all the circumstances, wouldharbor doubts about judges impartiality. 28 U.S.C.A. § 455(a). Our first ground for reversal results from the trial courtjudges failure to disqualify himself from participation in the proceeding beforehim. . . . The parties do not allege that the judge exhibited any actual bias orprejudice in the case; they assert only that under the circumstances his impar-tiality might reasonably be questioned. . . . The Applicable Statute At the time this lawsuit was instituted, the . . . statute relating to judi-cial disqualification provided: *1108 Any justice or judge . . . shall disqualify himself in any case in which he has a substantial interest, . . . as to render it improper, in his opinion, for him to sit on the trial, appeal, or other proceeding therein. 28 U.S.C. § 455 (1970). While the case was pending, but prior to thecommencement of trial, 28 U.S.C. § 455 was amended to bring the statutorygrounds for disqualification of judges into conformity with the recently adopted
  53. 53. Page 23 of 80other Judges (i.e. Judge Bobby DeLaughter was INDICTEDand pled GUILTY and Judge G. Thomas Porteous as of ap-proximately December 8, 2010, has been IMPEACHED ac-cording to proceedings before the United States Senate)have been prosecuted for their unlawful/illegal practices.All acts in which the United States Department of Justicewas fully aware of and clearly having knowledge of NEXUSand/or relationship of Judge(s) in matters involving New-some because she reported concerns of criminal/civil wrongsby Judge(s) and/or their conspirators/co-conspirators (i.e. asBaker Donelson). To no avail. Court records will support for instance that New-some had concerns regarding “conflict of interest” and re-quested RECUSAL of Judge Tom S. Lee and MagistrateJudge in Newsome vs. Melody Crews, et al; USDC South-ern District of Mississippi (Jackson); Case No. 3:07-cv-00099 (see Docket Nos. 110, 104 and 160) due to relation-ship to opposing parties and/or their attorneys/attorneys’law firms. To no avail. Then Newsome finds that JudgeTom S. Lee (i.e. judge assigned her lawsuits) recused him-self based upon his relationship to Baker Donelson; never-theless FAILED to RECUSE in matters involving New-some: “Pursuant to 28 U.S.C. §455(a), the under- signed is compelled to disqualify himself in the above styled and numbered proceedings for the reason that the law firm of Baker, Donelson, Bearman, Caldwell & Berkowitz,canon of the Code of Judicial Conduct [FN2] relating to disqualification of judgesfor bias, prejudice, or conflict of interest. See H.R.Rep.No.93-1453, 93d Cong.,2d Sess. (1974), Reprinted in 1974 U.S.Code Cong. & Admin.News, pp. 6351,6352-54 (hereinafter cited as 1974 U.S.Code Cong. & Admin.News). . . . FN2. Canon 3C of the Code of Judicial Conduct was adopted by the Judicial Conference of the United States in April, 1973.
  54. 54. Page 24 of 80 PC, counsel for the defendants, is on the recusal list of the undersigned United States district judge. Accordingly, the undersigned does hereby recuse himself in this cause.”information which is of PUBLIC record and can be foundon the INTERNET and/or in court records for instance inJoni B. Tyler, et al. vs. JPF1, LLC, et al.; Civil Action No.3:09-cv-338 TSL-FKB (Recusal Order dated March 25,2010); and Joyce Walker vs. Captain D’s LLC, et al., CivilAction No. 3:09-cv-679 TSL-JCS (Recusal Order dated No-vember 13, 2009); however, Judge Lee failed to recuse him-self when presiding over said lawsuit with KNOWLEDGEthat Baker Donelson was and its client(s) were involved.See APPX CHT No. “7” - Recusal Orders attached heretoand incorporated by reference. In the Newsome vs. Spring Lake Apartments, et al.matter, Newsome TIMELY had this case PULLED andsubmitted to the United States of America Congress forhandling. However, it appears that Baker Donelson is AL-SO legal counsel for the LEGISLATIVE Branch/Congressas well. See APPX CHT No. “19.” What a MESS! Newsome further believes that a reasonable per-son/mind may conclude that the assignments to the U.S.Supreme Court of Justices Sonia Sotomayor and Elena Ka-gen were recommended for appointment for vacancieswhich arose with this Court by United States PresidentBarack Obama appears to have been done under the DI-RECTION, LEADERSHIP and GUIDANCE of Baker Do-nelson; therefore, leaving Newsome and/or a reasonableperson/mind with valid concerns whether the Justices ofthis Court can remain impartial in deciding this matter.Why are such FACTS and EVIDENCE relevant?
  55. 55. Page 25 of 80 MATTER OF PUBLIC IMPORTANCE: It goes to the VALIDITY of U.S. Supreme Court’s Decisions regarding the Health Care Reform Bill (a/k/a ObamaCare) as well as its decision in Citizens United v Federal Election Commission, 558 U.S. 50 (2010) - in that these decisions as well as any/all other decisions by the U.S. Supreme Court may be NULL/VOID and properly CHALLENGED due to such CRIMINAL and UNETHICAL violations of the Justices and the Administration of said Court. Furthermore, it is FACTUAL evidence to support just how TAINTED and CORRUPT the JUDICIAL system has become and the CONSTITUTIONAL and LEGAL rights of Americans have been HEAVILY BREACHED and/or COMPROMISED! The Extraordinary Writs that Newsome seek to bringwill further provide additional facts, evidence and legalconclusions to support matters such as the following whichare of PUBLIC/GLOBAL/INTERNATIONAL interests – i.e.matters which will EXPOSE CRIMINAL Acts WORSE thanthe U.S. President Richard Nixon “WATERGATE Scandal!”
  56. 56. Page 26 of 80 Conducting a Thorough Investigation7 Because discrimination often is subtle, and there rarely is a “smoking gun,” [Fn. 45 - See Aman v. Cort Furniture Rental Corp., 85 F.3d 1074, 1081-82 (3rd Cir. 1996)(“It has become easier to coat vari- ous forms of discrimination with the ap- pearance of propriety, or to ascribe some other less odious intention to what is in reality discriminatory behavior. In other words, while discriminatory conduct per- sists, violators have learned not to leave the proverbial ‘smoking gun’ behind.”); cf. McDonnell Douglas Corp. v. Green, 411 U.S. 792, 801 (1973). . .] determining whether race played a role in the deci- sionmaking requires examination of all of the surrounding facts and circumstances. The presence or absence of any one piece of evidence often will not be determina- tive. Sources of information can include witness statements, including considera- tion of their credibility; documents; direct observation; and statistical evidence such as EEO-1 data, among others . . .Yes ObamaFraudGate is WORSE than the Richard Nixonmatter and it appears that President Barack Obama’s Le-gal Counsel Baker Donelson is RIGHT-IN-THE-THICK ofthe CRIMINAL and FRAUDULENT acts that have beenPERPETRATED on the Citizens of the United States ofAmerica as well as those committed against Citizens ofForeign Nations. It is time to FOLLOW the SMOKING 7 Taken from EEOC’s Compliance Manual Section 15: Race and Color Dis-crimination
  57. 57. Page 27 of 80GUN TRAIL left by Baker Donelson and its CONSPIRA-TORS/CO-CONSPIRATORS: (a) President Barack Obama “Birther Issue” – i.e in which Baker Donelson advertises position as Chief Counsel, Acting Direc- tor, and Acting Deputy Director of United States Citizenship & Immigration Ser- vices within the United States Depart- ment of Homeland Security http://www.slideshare.net/VogelDenise/ devine-robert-chowobamagotcolb http://www.slideshare.net/VogelDenise/ devine-robertbio-infocolb WHAT DOES THIS MEAN? That the last FOUR years of President Barack Obama may have to be ERASED from the HISTORY BOOKS. ALL those bills that he allegedly signed into law are VOID – MEANINGLESS! That’s just HOW SCANDALOUS and SERIOUS these criminal acts of Re- spondents and their Conspirators/ Co- Conspirators are. (b) Alleged Killing/Murder of Osama Bin Laden; (c) United States Of America’s EXECUTIVE Branch, LEGISLATIVE Branch and JU- DICIAL Branch (U.S. Supreme Court) role in the CRIMINAL acts, CORRUPTION and COVER-UP of the September 11, 2001
  58. 58. Page 28 of 80 “DOMESTIC” Terrorist Attacks carried out by CORRUPT Government Officials and their counsel/advisor Baker Donelson and its Conspirators/Coconspirators;(d) Role United States of America President Barack Obama and his Administration with the advice of their Legal Coun- sel/Advisor Baker Donelson appears to have played in the recent attacks and KILLING/MURDER of U.S. Ambassador to Libya (Christopher Stevens) and three others in that attack – i.e. and the at- tempts by President Barack Obama and Baker Donelson to COVER-UP their crimes through the SPREADING and PROMOTION of the “Muhammad Movie.”(e) “Pattern-Of-Criminal/Murderous Sprees” for this Court’s, the United States of America’s CONGRESS and United States of America’s WHITE HOUSE to act on Complaints filed by Newsome in efforts of COVERING UP Corrupt Government Of- ficials and their Lawyers/Attorneys and their CONSPIRATORS criminal and civil violations leveled against Newsome as well as other citizens here and abroad! For instance, after Newsome’s October 2010 filing entitled, “Emergency Motion to Stay; Emergency Motion for Enlarge- ment of Time and Other Relief The Su- preme Court of the United States Deems Appropriate To Correct The Legal Wrongs/Injustices Reported Herein,” in the Stor-All Alfred v. Newsome matter, it appears President Barack Obama, his Administration (i.e. which includes Secre-
  59. 59. Page 29 of 80tary of State Hillary Clinton) and theirLegal Counsel/Advisor Baker Donelsonmoved SWIFTLY it appears to “CLEANHOUSE” of those individuals they be-lieved to be a THREAT and EXPENDA-BLE – i.e for instance: On or about December 5, 2010 – W. Lee Rawls (Employee of Baker Donelson, Chief of Staff/Senior Counsel to Feder- al Bureau of Investigation Robert Mueller) – See APPX CHT No. “27” W. Lee Rawls information. Approximately EIGHT days later; (ii) On or about December 13, 2010 – Richard Holbrooke (Special Envoy to Pakistan and Afghanistan) who just co- incidentally was in a meeting with Secretary of State Hilla- ry Clinton when this meeting ENDED on a DEATH NOTE – Approximately EIGHTEEN days later; http://www.slideshare.net/ Vo- gelDenise/holbrookerichard -deathmeeting-with- hillary-clinton (iii) On or about December 31, 2010 – John Wheeler III (U.S. Military Expert who served THREE Republican Presi-
  60. 60. Page 30 of 80 dents) who was KILLED/MURDERED and body dumped in a Waste Landfill – Approximately FOUR Months later; http://www.slideshare.net /VogelDenise/wheeler- john-parsons-iii(iv) On or about May 1, 2011, al- leged KILLING/MURDER of Osama Bin Laden; however, NO PROOF to support death/killing has been made PUBLIC as required under the Freedom of Information Act (“FOIA”); however, this instant lawsuit by Newsome will provide the PUB- LIC/WORLD with the long sought after information re- quested – Approximately ONE Month later;(v) On or about June 4, 2011, Lawrence Eagleburger (Em- ployee of Baker Donelson, Secretary of State to U.S. President George H.W. Bush, Under Secretary of State to U.S. President Ronald Reagan, Member on the Board of Directors for Halliburton) – Approximately TWO Months later;
  61. 61. Page 31 of 80 http://www.slideshare.net/ VogelDenise/lawrence- eagleburger-wikipedia- information(vi) On or about August 6, 2011, the KILLING/MURDER of U.S. Navy Seals. It appears members in the same Seal 6 Unit allegedly used to kill/murder Osama Bin Laden. Most likely Navy Seals killed/murdered to SILENCE them. http://www.slideshare.net /VogelDenise/navy-seal- helicopter-down-080611 http://www.slideshare.net /VogelDenise/navy-seal- helicopter-shot-down- 080611 Who is the SECRETARY of Navy? None other than BAKER DONELSON’S em- ployee Raymond Mabus; http://www.slideshare.ne t/VogelDenise/mabus- raymondemploy-ties http://www.slideshare.ne t/VogelDenise/baker- donelson-wikipedia- information- withraymondmabusinfo
  62. 62. Page 32 of 80 http://www.slideshare.ne t/VogelDenise/baker- donelson-wikipedia-info- 11566741(vii) Now the recent killing/murder of U.S. Ambassador to Libya Christopher Stevens for what appears to be a COVER-UP by Secretary of State Hillary Clinton, President Barack Obama and their Legal Coun- sel/Advisor Baker Donelson for purposes of covering up Hillary Clinton’s Interview admitting to U.S. Wars being implemented and the LEAV- ING of U.S. STINGERS and then LAUGHING about it: http://www.slideshare.net /VogelDenise/082112- hillary-clinton-dealing- with-the-united-states-of- americas-stingers http://youtu.be/6Yxrsfhs MDc or https://secure.filesanywh ere.com/fs/v.aspx?v=8a71 648d60616ea970a0 for Middle Eastern Nations to deal with and threatening Sanctions if they don’t like it. Secretary Hillary Clinton

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