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Page 1 of 27
IN THE UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF MISSISSIPPI
IN RE:
LADYE M. TOWNSEND CHAPTER 7
DEBTOR CASE NO. 11-00167-ee
OBJECTION TO DECEMBER 8, 2015, ORDER ON OBJECTION TO NOVEMBER 4, ORDER
ON MOTION (sic) RELIEF FROM SEPTEMBER 30, 2015, FINAL JUDGMENT ON
CREDITOR’S (VOGEL NEWSOME) MOTION FOR RELIEF FROM ORDER/JUDGEMENT
(sic); MOTION FOR RULE 11 SANCTIONS OF AND AGAINST ROBERT REX McRANEY
JR./McRANEY & McRANEY; and REQUEST TO BE ADVISED OF CONFLICT-OF-
INTERESTS (DKT. #34); REITERATION FOR RULE 11 SANCTIONS OF AND AGAINST
ROBERT REX McRANEY, JR./McRANEY & McRANEY; REQUEST TO BE ADVISED OF
CONFLICT-OF-INTERESTS; and REITERATION FOR MOTION FOR RECUSAL OF JUDGE
EDWARD ELLINGTON1
COMES NOW Creditor Vogel Newsome (“Newsome”) without waiving her rights, without
submitting to the jurisdiction of this Court, without waiving previous defenses and claims set forth in her
pleadings filed with this Court and files this her “OBJECTION TO DECEMBER 8, 2015, ORDER ON
OBJECTION TO NOVEMBER 4, ORDER ON
MOTION (sic) RELIEF FROM SEPTEMBER 30,
2015, FINAL JUDGMENT ON CREDITOR’S
(VOGEL NEWSOME) MOTION FOR RELIEF
FROM ORDER/JUDGEMENT (sic); MOTION
FOR RULE 11 SANCTIONS OF AND
AGAINST ROBERT REX McRANEY
JR./McRANEY & McRANEY; and REQUEST TO BE ADVISED OF CONFLICT-OF-INTERESTS
(DKT. #34); REITERATION FOR RULE 11 SANCTIONS OF AND AGAINST ROBERT REX
MCRANEY, JR./McRANEY & McRANEY; REQUEST TO BE ADVISED OF CONFLICT-OF-
INTERESTS; and REITERATION FOR MOTION FOR RECUSAL OF JUDGE EDWARD ELLINGTON”
1
NOTE: Boldface, italics and underline, etc. represents “emphasis” added.
Page 2 of 27
(“OT12-08-15OrderOnObjection”) pursuant to Rule 60 of the Federal Rules of Civil Procedure
(“FRCP”), FRCP Rule 11, 28 USC § 455; FRCP Rule 12(G) – consolidation of matters – and other
statutes/laws governing said matters. In support thereof, Newsome states the following REITERATED
UNCONTESTED FACTS ignored by this Court in its December 8, 2015 Order:
I. LACK OF JURISDICTION – The record evidence STRONGLY supports this Court’s and
opposing Counsel’s INABILITY to PROVIDE EVIDENCE as well as CASE LAWS to
rebut the EVIDENCE as well as LEGAL CONLUSIONS provided below and in
PREVIOUS pleadings brought by Creditor Newsome. Therefore, Creditor Newsome is
AGAIN reiterating and incorporating by reference said defense(s) as set forth in her
previously filed pleadings in this instant Bankruptcy action:
PLEASE NOTE: As required by Rule 8 (General Rules of Pleading) of the Federal Rules of
Civil Procedure, for instance as mentioned in previous filing, Creditor Newsome’s October
13, 2015 Pleading (DOCKET NO. 64) specifically sets forth “short and plain statement(s)”
of the grounds for relief/claims; however, the record evidence WILL SUPPORT this
Court’s/Judge Edward Ellington’s INABILITY to REBUT the FACTS, EVIDENCE and
LEGAL CONCLUSIONS that this Court/he “LACKS” Jurisdiction in this matter.
There is authority that dismissal of a bankruptcy case does not
mandate dismissal of all pending adversary proceedings.
However, if an entity joined as a party in an adversary
proceeding raised the defense that the court lacks jurisdiction
over the subject matter and that defense is sustained, the court
must dismiss such entity from the adversary proceeding.
Fed.R.Bankr.P. 7019(1).
Mississippi Case: Rice v. McMullen, 43 So.2d 195 (Miss. 1949)
- A court must have jurisdiction of the subject matter and of the
person of the parties, to give validity to its final judgments,
orders and decrees, and legislature cannot under the Constitution
dispense with notice, actual or constructive.
Illinois Cent. R. Co. v. Mississippi Public Service Commission,
135 F.Supp. 304 (S.D.Miss.Jackson.Div.,1955) - “Judicial
power” is the legal right, ability and authority to hear and decide
a justifiable issue or controversy, and such power is ordinarily
vested in a court of justice.
U.S. Supreme Court Case: U.S. v. O'Grady, 89 U.S. 641(1874)
- “Jurisdiction” is the power to hear and determine a cause.
In re N.L.R.B., 58 S.Ct. 1001 (1938) - “Jurisdiction” means, in
one sense, the power to hear and determine the controversy
presented, but a court has “jurisdiction,” in another sense, to
determine whether such power is conferred upon it in the
circumstances disclosed, and if it finds such power is not
Page 3 of 27
granted, it lacks “jurisdiction” of the subject matter and must
refrain from an adjudication of rights in connection therewith.
Other Court Cases: In re Jahelka, 2010 WL 5558990 (Bankr.,
2010) - Subject matter jurisdiction is threshold question in every
case.
In re AE Liquidation, Inc., 435 B.R. 894 (2010) - A motion to
dismiss for lack of subject matter jurisdiction challenges the
power of the federal court to hear a claim or case. Fed.Rules
Civ.Proc.Rule 12(b)(1), 28 U.S.C.A.
Issue of court's subject matter jurisdiction can be raised
in any manner, including on motion of one of the parties or by
the court sua sponte. Fed.Rules Civ.Proc.Rule 12(b)(1), 28
U.S.C.A.
1. Newsome DOES NOT waive her defense to the jurisdictional issue which arises
in this matter. Therefore, Newsome does not submit to the jurisdiction of this
Court. While the laws are clear that Newsome cannot waive jurisdictional rights,
she believes it is necessary to provide information regarding decisions of court(s)
on said issue(s):
In re Kirkland, 600 F.3d 310 (2010) - Subject matter jurisdiction
cannot be forfeited or waived, and can be raised by party, or by
court sua sponte, at any time prior to final judgment.
2. This instant “OT12-08-15OrderOnObjection” is submitted in good faith and
has not been submitted for purposes of delay, harassment, hindering proceedings,
embarrassment, obstructing the administration of justice, vexatious litigation,
increasing the cost of litigation, etc. and is filed to protect and preserve the
rights of Newsome secured/guaranteed under the United States Constitution
and other laws of the United States.
3. For the purposes of expedition, saving of time and minimize costs associated
with litigation, Newsome consolidate her motions/pleadings herein pursuant to
FRCP Rule 12(G) which states:
FRCP Rule 12(g) Joining Motions.
Right to Join. A motion under this rule may be joined
with any other motion allowed by this rule.
4. Townsend’s Title 11 – Chapter 7 Bankruptcy – proceeding is merely acts in
FURTHERANCE of PATTERN-OF-ABUSE (i.e. for instance, under
CRIMINAL LAWS may be known as “Engaging in a PATTERN of CORRUPT
ACTIVITY”, etc.) to engage in criminal/civil wrongs and efforts to engage/solicit
this Court to cover up such legal injustices. Now it appears from this Court’s
June 27, 2014 Order relying upon a PROPOSED Order provided by Counsel for
Debtor Townsend (Robert Rex McRaney, Jr.) that a Motion to Dismiss –which
has NOT been served on Newsome – was filed with this Court. Service of
process providing Newsome with a copy of the Debtor Townsend’s Motion to
Dismiss has NOT been completed.
Page 4 of 27
In re Spencer, 137 B.R. 506 (1992) - All courts possess inherent
power to protect their jurisdiction and process from abuse. In re
Higginbotham, 111 B.R. 955 (1990).
5. Newsome’s December 3, 2010, filing of the lawsuit – United States District
Court; Southern District of Mississippi (Jackson Division); Civil Action 3:10-cv-
704 - protected her rights and secured District Court with jurisdiction and any
such actions as that brought by Townsend on or about January 18, 2011.
Newsome’s December 3, 2010, lawsuit filed in this action secured the District
Court with jurisdiction to hear any such bankruptcy Townsend may attempt to
assert in that Chapter 7 Bankruptcy filing arises out of the relief Newsome seeks
through the District Court Civil Lawsuit. Therefore, it appears that Townsend
has “HIT-A-BRICK-WALL” in her efforts to try and run and hide from the
liability Newsome seeks of and against her for the legal wrongs addressed in the
District Court Complaint. As a matter of law, Newsome is to be dismissed from
Townsend’s Bankruptcy action or matter involving Newsome transferred to the
United States District Court for purposes of keeping legal matters combined.
Matter of Wood, 825 F.2d 90 (5th
Cir. Miss. 1987) - If
proceeding involves right created by federal bankruptcy law, or
is one which would only arise in bankruptcy, it is core
proceeding, but if proceeding does not invoke substantive right
created by federal bankruptcy law and is one that could exist
outside of bankruptcy, it is noncore proceeding, though it may be
related to bankruptcy because of its potential effect on debtor's
estate. 28 U.S.C.A. § 157.
In re OCA, Inc., 551 F.3d 359 (5th
Cir. 2008) - Bankruptcy
court's adjudicative authority is constrained if the adversary
proceeding is non-core.
6. As a matter of law, the United States District Court – Southern District of
Mississippi (Jackson Division) on December 3, 2010, FIRST retained
jurisdiction over this matter.
Jurisdiction is the power to decide; it must be conferred,
not assumed. Matter of Chicago, Rock Island and Pacific R.
Co., 794 F.2d 1182 (7th
Cir. 1986). All bankruptcy jurisdiction is
given in the first instance to the United States district courts.
Acolyte Elec. Corp. v. City of New York, 69 B.R. 155 (Bankr.
E.D. N.Y. 1986), ordered aff’d, 1987 1987 WL 47763 (E.D.
N.Y. 1987); In re Double TRL, Inc., 65 B.R. 993 (Bankr. E.D.
N.Y. 1986).
The district courts are granted jurisdiction over
bankruptcy cases, that is cases under the Bankruptcy Code and
over three categories of bankruptcy proceedings: (1) civil
proceedings arising under Title 11; (2) civil proceedings arising
in a case under Title 11; and (3) civil proceedings related to
cases under Title 11. 28 U.S.C. § 1334(b). As used in this
statute, the phrase “arising under Title 11” is meant, not to
distinguish between different matters, but to identify collectively
a broad range of matters subject to the bankruptcy jurisdiction of
federal courts. Matter of Wood, 825 F.2d 90 (5th
Cir. 1987).
Page 5 of 27
On or about December 16, 2010, Newsome served Debtor (Ladye M. Townsend
[“Townsend”]) with the required: (a) “Notice of Lawsuit and Request to Waive
Service of Summons;” and (b) “Waiver of the Service of Summons” which was
accompanied by Notification Accompanying Waiver of Service of Summons.
According to United States Postal Service information, Townsend received these
documents on or about December 27, 2010.
7. Newsome believes given the facts, evidence and legal conclusions not only in
this Bankruptcy matter, but that in the United States District Court, that
Townsend’s Title 7 Bankruptcy proceeding naming Newsome under “Creditors
Holding Unsecured Nonpriority Claims” has been submitted: in bad faith, for
purposes of harassment, for delay, for vexatious litigation, for purposes of
increasing the costs of litigation, for embarrassment, for false and frivolous
reasons in attempts to provide her with a defense to Newsome’s Civil lawsuit
filed in the United States District Court – Southern District of Mississippi
(Jackson Division) [“USDC-MS proceeding”]on or about December 3, 2010;
and other willful, malicious and wanton reasons known to Townsend for the
filing of this Chapter 7 Bankruptcy proceeding. Therefore, supporting the
dismissal of Newsome from Townsend’s Chapter 7 Bankruptcy proceeding:
A district court may transfer a bankruptcy case or
proceeding to a district court . . .in the interest of justice or for
the convenience of the parties. 28 § 1412. In contrast with the
general venue transfer statutes, this provision allows transfer to
any district, not only to districts in which venue would have been
proper had the case been brought in that district.
In determining whether to transfer a bankruptcy case, the
court should consider the following factors: (1) the proximity of
creditors to the court; (2) the proximity of the debtor to the court;
(3) the proximity of the witnesses necessary to the administration
of the estate; (4) the location of the assets; (5) economic
administration of the estate; (6) the necessity of ancillary
administration if liquidation should result. See In re
Commonwealth Oil Refining Co., 596 F.2d 1239, 1247 (5th
Cir.
1979), cert. denied, 444 U.S. 1045 (1980) (construing former 28
U.S.C. § 1475, substantially similar to present § 1412O.
Newsome does not believe that based upon the willful, malicious and wanton
acts of Townsend and the filing of this FRIVOLOUS Chapter 7 Bankruptcy
proceeding as a defense to Newsome’s “USDC-MS proceeding,” that a transfer
of this case is warranted or even qualifies for transfer. Therefore, in the
interest of justice and expedition of this case, Newsome timely, properly and
adequately requested to be dismissed as a “Creditor” from Townsend’s Chapter 7
Bankruptcy action in that this Court lacks jurisdiction over Newsome to proceed;
furthermore, that this Court(if it insist on entertaining Townsend’s Bankruptcy
action), in the interest of justice and convenience of parties transfer matter
regarding Newsome to the United States District Court – Southern District of
Mississippi (Jackson Division) for consolidation of cases and convenience to
parties. Townsend’s filing of the Chapter 7 Bankruptcy action clearly supports
that she would not be prejudiced by the transfer of this matter in that it will
remain in SAME venue; however, JURISDICTION of the United States District
Court – i.e. NOT Bankruptcy Court.
Page 6 of 27
Time, Inc. v. Manning, 366 F.2d 690 (5th
Cir. 1966) - Both
jurisdiction and venue are designed to test fairness to defendant
and degree of inconvenience caused him by requiring him to
litigate in a particular court, but jurisdiction is relatively more
concerned with fairness and venue more with inconvenience.
8. It appears that Townsend and her counsel are attempting to get this Court to
usurp jurisdiction over this matter, the laws clearly prohibits such practices.
Brown v. Pyle, 310 F.2d 95 (5th
Cir. Miss. 1962) - “Jurisdiction”
is the power to hear and determine a cause-the power to
adjudicate; it is not to be confused with venue.
9. While Newsome does not claim to have knowledge of Chapter 7 Bankruptcy
laws, it is clear that Townsend did not bring this instant Chapter 7
Bankruptcy proceeding as an “ENTITY,” “BUSINESS” for “ESTATE
ADMINISTRATOR.” Therefore, Newsome believes the laws support her
concerns as to the motives for the Chapter 7 Bankruptcy filing and this
Bankruptcy Court’s jurisdiction over this matter.
10. Newsome further believes that Townsend’s Chapter 7 Bankruptcy proceeding
filed with this Court in her INDIVIDUAL capacity was filed as a DEFENSE to
Newsome’s “USDC-MS proceeding” and therefore, may be precluded by law
given the facts, evidence and laws governing said matters.
In re SemCrude, L.P., 428 B.R. 82 (2010) - As general rule,
subject matter jurisdiction of court is based on state of facts that
existed at time cause of action was filed.
11. Newsome further believes that a “FEDERAL” court judgment on her “USDC-
MS proceeding” may preclude Townsend from bringing Chapter 7 Bankruptcy
proceeding naming Newsome in efforts to avoid the liability owed for damages
Newsome sustained and is addressed in the “USDC-MS proceeding.” Under the
statutes/laws governing issues regarding CONFLICT OF INTERESTS,
Newsome’s Lawsuit in Southern District Court of Mississippi (Jackson) action
(Civil Action 3:10-cv-704) is still LEGALLY/LAWFULLY active despite the
CRIMINAL acts of said court to make it appear that the case is closed (when it is
NOT)!
12. Newsome is NOT a business entity, but a private citizen (individual) of the
United States and is seeking relief of and against Townsend and others in the
“USDC-MS proceeding.”
II. OBJECTION TO DECEMBER 8, 2015, ORDER ON OBJECTION TO NOVEMBER 4, ORDER
ON MOTION (sic) RELIEF FROM SEPTEMBER 30, 2015, FINAL JUDGMENT ON
CREDITOR’S (VOGEL NEWSOME) MOTION FOR RELIEF FROM ORDER/JUDGEMENT
(sic); MOTION FOR RULE 11 SANCTIONS OF AND AGAINST ROBERT REX McRANEY
JR./McRANEY & McRANEY; and REQUEST TO BE ADVISED OF CONFLICT-OF-
INTERESTS (DKT. #34); REITERATION FOR RULE 11 SANCTIONS OF AND AGAINST
ROBERT REX MCRANEY, JR./McRANEY & McRANEY; REQUEST TO BE ADVISED OF
Page 7 of 27
CONFLICT-OF-INTERESTS; and REITERATION FOR MOTION FOR RECUSAL OF JUDGE
EDWARD ELLINGTON”
Vogel Newsome (“Newsome) further OBJECTS to this Court’s December 8, 2015, “Order on
Objection To November 4, 2015, Order on Motion (sic) Relief From September 30, 2015, Final Judgment
On Creditor’s (Vogel Newsome) Motion For Relief From Order/Judgement (sic); Motion For Rule 11
Sanctions Of And Against Robert Rex McRaney Jr./McRaney & McRaney; and Request To Be Advised Of
Conflict-Of-Interests (DKT. #34); Reiteration For Rule 11 Sanctions Of And Against Robert Rex
McRaney, Jr./McRaney & McRaney; Request To Be Advised Of Conflict-Of-Interests; and Reiteration
For Motion For Recusal Of Judge Edward Ellington.” In further support thereof, Creditor states:
13. Pursuant to Rule 8 (General Rules of Pleading) of the FRCP, Creditor
Newsome’s pleadings in this instant Bankruptcy action specifically sets forth
“short and plain statement(s)” of the grounds for relief/claims; however, due
to this Court’s/Judge Edward Ellington’s INABILITY to respond in accordance
to said Rule to legally/lawfully REBUT the claims, allegations and/or arguments
set forth in Creditor Newsome’s pleadings,
this Court/Judge Ellington merely
CONTINUALLY proceeds on what appears
to be a MENTALLY DISTURBED and
RABID Judge/Law Clerk THROWING
TOGETHER a FRIVOLOUS and
BASELESS 8-PAGE rambling of
UNSUBSTANTIATED GARBAGE!
Further supporting and challenging Judge
Edward Ellington’s FITNESS as well as
MENTAL/PSYCHOLOGICAL state to
preside in this matter; moreover, his INABILITY to understand and interpret the
facts, evidence and legal conclusions provided in Creditor Newsome’s pleadings
providing in this Bankruptcy action.
14. UNCONTESTED are the facts, evidence and legal conclusions set out
PURSUANT to Rule 8 (General Rules of Pleading) of the FRCP regarding this
Court’s/Judge Edward Ellington’s LACK OF JURISDICTION!
15. UNCONTESTED are the facts, evidence and legal conclusions set out
PURSUANT to Rule 8 (General Rules of Pleading) of the FRCP regarding
Creditor Newsome’s pleadings seeking relief from FRIVOLOUS and
UNLAWFUL/ILLEGAL Orders and/or PREMATURE “FINAL JUDGMENT”
which this Court/Judge Edward Ellington LACKS Jurisdiction to enter!
16. UNCONTESTED are the facts, evidence and legal conclusions set out
PURSUANT to Rule 8 (General Rules of Pleading) of the FRCP regarding
“MOTION FOR SANCTION(S)” provided by Creditor Newsome in pleading(s)
Page 8 of 27
filed with this Court and said OBJECTION(S) for which this instant pleading is
filed.
17. UNCONTESTED are the facts, evidence and legal conclusions set out
PURSUANT to Rule 8 (General Rules of Pleading) of the FRCP regarding
“REITERATION FOR MOTION FOR RECUSAL OF JUDGE EDWARD
ELLINGTON” provided by Creditor Newsome in pleading(s) filed with this
Court and said OBJECTION(S) for which this instant pleading is filed.
PLEASE NOTE: All Creditor Newsome is concerned about doing is PROPERLY
“PRESERVING” (which this Court has CONFIRMED has been done – DOCKET 64 at Exhibit “1” at
Page 5/Lines 1 thru 5) her legal actions DESPITE of the FRUDULENT and CRIMINAL Acts this
Court/Judge Edward Ellington and CONSPIRATORS/CO-CONSPIRATORS are engaging in to
DECEIVE the PUBLIC/WORLD!
Creditor, Vogel Newsome in good faith submits this instant pleading for the above foregoing
reasons and, demands, relief requested herein. Creditor Newsome further reserves the right to amend
and/or correct said pleading in accordance with the statutes governing said matters. In the meantime, as
Newsome shared in previous filings with this Court as well as the September 18, 2015 hearing, her time is
being BETTER SPENT informing the PUBLIC/WORLD as to what their LEGAL/LAWFUL “DUTY” is
under such documents as the DECLARATION OF INDEPENDENCE and other governing
statutes/laws to REGAIN/RECLAIM the United States of America’s Government out of the hands of
such TERRORIST DESPOTISM Government Regimes SPEARHEADED by the likes of the KU KLUX
KLAN/WHITE SUPREMACISTS/JEWISH-ZIONISTS and Law Firms as Baker Donelson Bearman
Caldwell & Berkowitz. See documents that may be found in SlideShare.net Social Forums shared by
Creditor Newsome as the 11/11/15 Declaration Of Independence:
http://www.slideshare.net/VogelDenise/111115-declaration-of-independence-legal-lawful-right-to-
abolish-despotism-government
Page 9 of 27
which appears CONTINUES to have a PROFOUND IMPACT on the United States of America’s
STOCK MARKET – report as of 12/11/15:
and 12/17/15. The WHITE JEWISH-ZIONISTS release of FALSE and MISLEADING Stock
Reports is becoming a REALITY!
Page 10 of 27
When “WE THE PEOPLE” realize that the UNITED STATES OF AMERICA’S KU KLUX
KLAN/WHITE SUPREMACISTS/JEWISH-ZIONISTS have CLEANED out their
FINANCIAL/INVESTMENT Accounts (as it appears WHITE-JEWISH ZIONIST Bernard
“Bernie” Madoff, his JEWISH BANK JP Morgan Chase
and their JEWISH Law Firm Baker Donelson Bearman
Caldwell & Berkowitz did and CREATED FALSE and
MISLEADING Portfolios for their clients:
http://www.slideshare.net/VogelDenise/bernard-bernie-
madoff-ties-relationship-to-jp-morgan-chase-bank-ponzi-
scheme, http://www.slideshare.net/VogelDenise/madoff-
bernard-wiki-info,
http://www.slideshare.net/VogelDenise/bd-secmadoff) and
TAX DOLLARS through FINANCING their TERRORIST
Cells (as Taliban, ISIS, etc.) , the OVERTHROW and bringing these CRIMINALS to JUSTICE will
NOT be a PATTY-CAKE experience!
http://www.slideshare.net/VogelDenise/taliban-paid-360-million-us-tax-dollars
http://www.slideshare.net/VogelDenise/afghanistan-us-talks-with-taliban
http://www.slideshare.net/VogelDenise/taliban-us-paysterrorist2
Page 11 of 27
http://www.slideshare.net/VogelDenise/afghanistan-president-hamid-karzi-confirms-united-states-
cia-provides-bagsofcash-monthly
Page 12 of 27
http://www.slideshare.net/VogelDenise/hillary-clinton-united-states-of-americas-terrorist-roles
http://www.slideshare.net/VogelDenise/hillary-clinton-dealing-with-the-united-states-of-americas-
stingers
– YES, United States of America’s President Barack Obama’s WHITE-JEWISH Banker is NONE
other than WHITE-JEWISH Owned JP Morgan Chase Bank/Jamie Dimon:
Page 13 of 27
http://www.slideshare.net/VogelDenise/barack-obamas-relationship-with-jp-morgan-chase-bank
http://www.slideshare.net/VogelDenise/jamie-dimon-jp-morgan-chase-new-york-times-article
http://www.slideshare.net/VogelDenise/leggitt-lancesr-advisortopresidenthhscounselorgovofva
Page 14 of 27
TERRORIST CELLS created abroad for purposes of OVERTHROWING Foreign Governments and
using WHITE-JEWISH Control over the MEDIA Resources to show the IGNORANCE of
OVERTHROWN and/or DESTROYED Governments as the SOVIET Union, Iraq, Iran, etc. Leaders
to PROMOTE lies and APPEARANCE of CONFLICTS (when there are NONE) by SNAKES and
DECEPTIVE Foreign Government Leaders out to BETRAY the People of their Countries:
Page 15 of 27
http://www.slideshare.net/VogelDenise/syria-crisis-united-states-of-america-chemical-weapons-
attack
ALL are for MEDIA SHOW and RATINGS and TERRORIST Acts of WHITE-Jewish
Controlled Governments and IGNORANT Foreign Government Leaders BELIEVING their FORK-
TONGUE Lies and BETRAYING their Country and Citizens! NOT learning from PAST MISTAKES
and FATAL MISTAKES when the United States of America’s TERRORIST Government Regime and
their ALLIES grow WEARY of them:
Page 16 of 27
DIVIDE AND CONQUER
http://www.slideshare.net/VogelDenise/no-laughing-matter-united-states-allies-plans-to-overthrow-
governments-52342682
http://www.slideshare.net/VogelDenise/breaking-up-the-middle-east-united-states-allies-plans-to-
overthrow-governments
Page 17 of 27
The CHICKENS “WILL RETURN TO ROOST” and what the United States of America’s
TERRORIST Government Regime and its RACIST Allies have REAPED on other Foreign Nations
they sought to OPPRESS and OVERTHROW has NOW reached SOWING TIME! The time for
OPPRESSIVE Foreign Nations to also UNITE TOGETHER and bring the United States of America’s
TERRORIST Government Regime and its LAWYERS/ATTORNEYS as Baker Donelson Bearman
Caldwell & Berkowitz to JUSTICE and PUT them on TRIAL for their TERRORIST Acts as well as
WAR CRIMES, etc. that it appears they have LAUNCHED AGAINST other Foreign
Governments/Nations for purposes of gaining ACCESS to their MONIES, LAND/PROPERTY and
RESOURCES!
Creditor Newsome’s time is also being BETTER SPENT being sure that REJECTED News
Articles by the Jackson ADVOCATE regarding this DECEPTIVE “URBAN RENEWAL” Scam to
STEAL/ROB Black/African-Americans of their LAND/PROPERTY and to CIRCUMVENT laws as the
KU KLUX KLAN ACT:
Page 18 of 27
http://www.slideshare.net/VogelDenise/100715-urban-renewal-from-the-eyes-of-community-
activist-vogel-denise-newsome
are presently being EXPOSED through the filing of this instant pleading (so that the PUBLIC/WORLD
has a FRONT-ROW Seat for Battle Action as well as the POSTING of information to EDUCATE and
Page 19 of 27
INFORM the Public/World of the United States of America’s GENOCIDE practices:
http://www.slideshare.net/VogelDenise/tuskegee-tests
http://www.slideshare.net/VogelDenise/guatemala-experiments
Page 20 of 27
http://www.slideshare.net/VogelDenise/united-states-woman-speaks-out-about-being-
sterilizedgutted-by-government
KILLING and BRUTAL MURDER OF BLACK/AFRICAN-AMERICAN MALES as Trayvon
Martin by WHITE-JEWISH George Zimmerman and what appears to be his Law Firm’s BAKER
DONELSON BEARMAN CALDWELL & BERKOWITZ’ Cover-up, REMAINS a TOP/KEY interest
by Foreign Governments:
Page 21 of 27
http://www.slideshare.net/VogelDenise/english-040512
Page 22 of 27
Creditor Newsome’s time is also better spent advising the PUBLIC/WORLD on HOW to
LEGALLY/LAWFULLY OVERTHROW the DESPOTISM Terrorist Government Regimes and the
HOUSE NEGROES/UNCLE TOMS placed in Political Office for DECEPTIVE purposes:
http://www.slideshare.net/VogelDenise/111615-meeting-with-jackson-mayor-tony-yarber-siemens-
baker-donelson-scam
http://www.slideshare.net/VogelDenise/siemens-settling-bribery-case-to-cost-siemens-16-billion-
nytimes
http://www.slideshare.net/VogelDenise/baker-donelson-siemens-scam-project-city-approves-
financial-advisory-team-highlighted
– i.e. for instance in Jackson, Mississippi sharing with the PUBLIC/WORLD the LEGAL/LAWFUL
DUTY to OVERTHROW a DESPOTISM Government and NOT having to WAIT for the NEXT
ELECTIONS (State and/or Federal) to address DESPOTISM, POLITICAL CORRUPTION,
Page 23 of 27
JUDICIAL CORRUPTION, etc.! The POWER of the Government IS WITH “WE THE PEOPLE”
and NOT the KU KLUX KLAN/WHITE SUPREMACISTS/WHITE-JEWISH ZIONISTS whose time of
TERRORIST Activities has EXPIRED and EVICTION and OVERTHROW being INEVITABLE!
If such a DESPOTISM Terrorist/White Supremacist/White-Zionist Government Regimes want to
see Blacks/African-Americans as GORILLAS/MONKEYS/APES, at least they are aware of these
PRIMATES’ INEVITABLE OVERTHROW of the Government! SO BE IT! At least they KNOW of
the INEVITABLE OVERTHROW!
Page 24 of 27
There is yet PLENTY of work to do in the OVERTHROW of the United States of America’s
DESPOTISM TERRORIST Government Regime – in which it is GOOD to have a VISION and PLAN
to present to the PUBLIC/WORLD of what appears to be their LEGAL/LAWFUL DUTY to
OVERTHROW a DESPOTISM Government. . .
http://www.slideshare.net/VogelDenise/120815-vision-for-the-overthrow-of-the-despostism-
government-of-the-united-states-of-america
Page 25 of 27
WHEREFORE, PREMISES CONSIDERED, YES, there are LEGAL and LAWFUL ways to
TAKE DOWN such TERRORIST DESPOTISM Government Regimes. Moreover, there are laws
governing the PRESERVATION of legal cases as this instant Bankruptcy action and the filing of this
pleading is for said purposes. As for the September 18, 2015 Hearing, Creditor Newsome also uses such
opportunities to CONTINUE to produce and provide EVIDENCE regarding the JUDICIAL Injustices,
POLITICAL Corruption – in which MISSISSIPPI has appeared as the NO. 1 State for
CORRUPTION and TAINTED Elections.
http://www.slideshare.net/VogelDenise/most-corrupt-mississippi
http://www.slideshare.net/VogelDenise/most-corrupt-states
Page 26 of 27
While the United States of America’s DESPOTISM Government Regime SPEARHEADED by the likes
of the KU KLUX KLAN/WHITE SUPREMACISTS/JEWISH-ZIONIST are wanting a “RACE WAR,” the
AMERICAN REVOLUTION has ALREADY been fought and the DECLARATION OF
INDEPENDENCE provided to DIRECT and SUPPORT “WE THE PEOPLE’S” LEGAL/LAWFUL
DUTY to TAKE BACK their Government from the TERRORISTS that have HIJACKED IT!
IN SUMMARY: Creditor Vogel Denise Newsome who is
also a COMMUNITY ACTIVIST/CIVIL RIGHTS Activist has
better things to do with her time and at the BOTTOM of the LIST is
responding to such STUPID/FRIVOLOUS Orders from LUNATICS
as it appears to be the case with of this Court’s Judge Edward
Ellington. The LAWS provide LEGAL/LAWFUL access to
OVERTHROWING and REMOVING such CORRUPT JUDGES from the BENCH and this will be how
Creditor Newsome will be spending her time!
Page 27 of 27
The December 8, 2015, Order entered by this Court/Judge Edward Ellington IS clearly
BASELESS, FRIVOLOUS, full of ERRORS, cannot be UPHELD, supports CONFLICT –OF
INTERESTS, criminal acts and much more for purposes of AIDING and ABETTING Judge Edward
Ellington’s Legal Counsel Baker Donelson Bearman Caldwell & Berkowitz. Said December 8, 2015,
appears to be REDUNDANT and NOT worth the ink and paper written on!
Respectfully submitted this 18th
day of December, 2015.
___________________________________
Vogel Denise Newsome
Post Office Box 31265
Jackson, MS 39286
Phone: (513) 680-2922 or (601) 885-9536
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the forgoing pleading was
MAILED via U.S. Mail first-class to:
Robert Rex McRaney, Jr.
Post Office Box 1397
Clinton, Mississippi 39060
COUNSEL FOR DEBTOR (LADYE M. TOWNSEND)
Dated this 18th
day of December, 2015.
_____________________________________
Vogel Newsome
The December 8, 2015, Order entered by this Court/Judge Edward Ellington IS clearly
BASELESS, FRIVOLOUS, rull oF ERRORS, ainiwt be UPHELD, supports CONFLICT -OF
INTERESTS, criminal acts and much more for purposes of AIDING and ABETTING Judge Edward
Ellington's Legal Counsel Baker Donelson Bearman Caldwell & Berkowitz. Said December 8, 2015,
appears to be REDUNDANT and NOT worth the ink and paper written on!
The undersigned hereby certifies that a true and couect copy o f the forgoing pleading was
M A J L E D via U.S. Mail fu'st-class to:
Robert Rex McRaney, Jr.
Post Office Box 1397
Clinton, Mississippi 39060
COUNSEL FOR DEBTOR (LADYE M . TOVWSEND)
Dated this 18" day of December, 2015.
Respectfully submitted this 18'^ day of December, 2015.
Vogel Denise Newsome
Post Office Box 31265
Jackson, N4S 39286
Phone: (513) 680-2922 or (601) 885-9536
CERTIFICATE OF SERVICE
Vogel Newsome
Page 27 of 27
T

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121815 - OBJECTION TO 120815 ORDER ON OBJECTION (Townsend Matter)

  • 1.
  • 2. Page 1 of 27 IN THE UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF MISSISSIPPI IN RE: LADYE M. TOWNSEND CHAPTER 7 DEBTOR CASE NO. 11-00167-ee OBJECTION TO DECEMBER 8, 2015, ORDER ON OBJECTION TO NOVEMBER 4, ORDER ON MOTION (sic) RELIEF FROM SEPTEMBER 30, 2015, FINAL JUDGMENT ON CREDITOR’S (VOGEL NEWSOME) MOTION FOR RELIEF FROM ORDER/JUDGEMENT (sic); MOTION FOR RULE 11 SANCTIONS OF AND AGAINST ROBERT REX McRANEY JR./McRANEY & McRANEY; and REQUEST TO BE ADVISED OF CONFLICT-OF- INTERESTS (DKT. #34); REITERATION FOR RULE 11 SANCTIONS OF AND AGAINST ROBERT REX McRANEY, JR./McRANEY & McRANEY; REQUEST TO BE ADVISED OF CONFLICT-OF-INTERESTS; and REITERATION FOR MOTION FOR RECUSAL OF JUDGE EDWARD ELLINGTON1 COMES NOW Creditor Vogel Newsome (“Newsome”) without waiving her rights, without submitting to the jurisdiction of this Court, without waiving previous defenses and claims set forth in her pleadings filed with this Court and files this her “OBJECTION TO DECEMBER 8, 2015, ORDER ON OBJECTION TO NOVEMBER 4, ORDER ON MOTION (sic) RELIEF FROM SEPTEMBER 30, 2015, FINAL JUDGMENT ON CREDITOR’S (VOGEL NEWSOME) MOTION FOR RELIEF FROM ORDER/JUDGEMENT (sic); MOTION FOR RULE 11 SANCTIONS OF AND AGAINST ROBERT REX McRANEY JR./McRANEY & McRANEY; and REQUEST TO BE ADVISED OF CONFLICT-OF-INTERESTS (DKT. #34); REITERATION FOR RULE 11 SANCTIONS OF AND AGAINST ROBERT REX MCRANEY, JR./McRANEY & McRANEY; REQUEST TO BE ADVISED OF CONFLICT-OF- INTERESTS; and REITERATION FOR MOTION FOR RECUSAL OF JUDGE EDWARD ELLINGTON” 1 NOTE: Boldface, italics and underline, etc. represents “emphasis” added.
  • 3. Page 2 of 27 (“OT12-08-15OrderOnObjection”) pursuant to Rule 60 of the Federal Rules of Civil Procedure (“FRCP”), FRCP Rule 11, 28 USC § 455; FRCP Rule 12(G) – consolidation of matters – and other statutes/laws governing said matters. In support thereof, Newsome states the following REITERATED UNCONTESTED FACTS ignored by this Court in its December 8, 2015 Order: I. LACK OF JURISDICTION – The record evidence STRONGLY supports this Court’s and opposing Counsel’s INABILITY to PROVIDE EVIDENCE as well as CASE LAWS to rebut the EVIDENCE as well as LEGAL CONLUSIONS provided below and in PREVIOUS pleadings brought by Creditor Newsome. Therefore, Creditor Newsome is AGAIN reiterating and incorporating by reference said defense(s) as set forth in her previously filed pleadings in this instant Bankruptcy action: PLEASE NOTE: As required by Rule 8 (General Rules of Pleading) of the Federal Rules of Civil Procedure, for instance as mentioned in previous filing, Creditor Newsome’s October 13, 2015 Pleading (DOCKET NO. 64) specifically sets forth “short and plain statement(s)” of the grounds for relief/claims; however, the record evidence WILL SUPPORT this Court’s/Judge Edward Ellington’s INABILITY to REBUT the FACTS, EVIDENCE and LEGAL CONCLUSIONS that this Court/he “LACKS” Jurisdiction in this matter. There is authority that dismissal of a bankruptcy case does not mandate dismissal of all pending adversary proceedings. However, if an entity joined as a party in an adversary proceeding raised the defense that the court lacks jurisdiction over the subject matter and that defense is sustained, the court must dismiss such entity from the adversary proceeding. Fed.R.Bankr.P. 7019(1). Mississippi Case: Rice v. McMullen, 43 So.2d 195 (Miss. 1949) - A court must have jurisdiction of the subject matter and of the person of the parties, to give validity to its final judgments, orders and decrees, and legislature cannot under the Constitution dispense with notice, actual or constructive. Illinois Cent. R. Co. v. Mississippi Public Service Commission, 135 F.Supp. 304 (S.D.Miss.Jackson.Div.,1955) - “Judicial power” is the legal right, ability and authority to hear and decide a justifiable issue or controversy, and such power is ordinarily vested in a court of justice. U.S. Supreme Court Case: U.S. v. O'Grady, 89 U.S. 641(1874) - “Jurisdiction” is the power to hear and determine a cause. In re N.L.R.B., 58 S.Ct. 1001 (1938) - “Jurisdiction” means, in one sense, the power to hear and determine the controversy presented, but a court has “jurisdiction,” in another sense, to determine whether such power is conferred upon it in the circumstances disclosed, and if it finds such power is not
  • 4. Page 3 of 27 granted, it lacks “jurisdiction” of the subject matter and must refrain from an adjudication of rights in connection therewith. Other Court Cases: In re Jahelka, 2010 WL 5558990 (Bankr., 2010) - Subject matter jurisdiction is threshold question in every case. In re AE Liquidation, Inc., 435 B.R. 894 (2010) - A motion to dismiss for lack of subject matter jurisdiction challenges the power of the federal court to hear a claim or case. Fed.Rules Civ.Proc.Rule 12(b)(1), 28 U.S.C.A. Issue of court's subject matter jurisdiction can be raised in any manner, including on motion of one of the parties or by the court sua sponte. Fed.Rules Civ.Proc.Rule 12(b)(1), 28 U.S.C.A. 1. Newsome DOES NOT waive her defense to the jurisdictional issue which arises in this matter. Therefore, Newsome does not submit to the jurisdiction of this Court. While the laws are clear that Newsome cannot waive jurisdictional rights, she believes it is necessary to provide information regarding decisions of court(s) on said issue(s): In re Kirkland, 600 F.3d 310 (2010) - Subject matter jurisdiction cannot be forfeited or waived, and can be raised by party, or by court sua sponte, at any time prior to final judgment. 2. This instant “OT12-08-15OrderOnObjection” is submitted in good faith and has not been submitted for purposes of delay, harassment, hindering proceedings, embarrassment, obstructing the administration of justice, vexatious litigation, increasing the cost of litigation, etc. and is filed to protect and preserve the rights of Newsome secured/guaranteed under the United States Constitution and other laws of the United States. 3. For the purposes of expedition, saving of time and minimize costs associated with litigation, Newsome consolidate her motions/pleadings herein pursuant to FRCP Rule 12(G) which states: FRCP Rule 12(g) Joining Motions. Right to Join. A motion under this rule may be joined with any other motion allowed by this rule. 4. Townsend’s Title 11 – Chapter 7 Bankruptcy – proceeding is merely acts in FURTHERANCE of PATTERN-OF-ABUSE (i.e. for instance, under CRIMINAL LAWS may be known as “Engaging in a PATTERN of CORRUPT ACTIVITY”, etc.) to engage in criminal/civil wrongs and efforts to engage/solicit this Court to cover up such legal injustices. Now it appears from this Court’s June 27, 2014 Order relying upon a PROPOSED Order provided by Counsel for Debtor Townsend (Robert Rex McRaney, Jr.) that a Motion to Dismiss –which has NOT been served on Newsome – was filed with this Court. Service of process providing Newsome with a copy of the Debtor Townsend’s Motion to Dismiss has NOT been completed.
  • 5. Page 4 of 27 In re Spencer, 137 B.R. 506 (1992) - All courts possess inherent power to protect their jurisdiction and process from abuse. In re Higginbotham, 111 B.R. 955 (1990). 5. Newsome’s December 3, 2010, filing of the lawsuit – United States District Court; Southern District of Mississippi (Jackson Division); Civil Action 3:10-cv- 704 - protected her rights and secured District Court with jurisdiction and any such actions as that brought by Townsend on or about January 18, 2011. Newsome’s December 3, 2010, lawsuit filed in this action secured the District Court with jurisdiction to hear any such bankruptcy Townsend may attempt to assert in that Chapter 7 Bankruptcy filing arises out of the relief Newsome seeks through the District Court Civil Lawsuit. Therefore, it appears that Townsend has “HIT-A-BRICK-WALL” in her efforts to try and run and hide from the liability Newsome seeks of and against her for the legal wrongs addressed in the District Court Complaint. As a matter of law, Newsome is to be dismissed from Townsend’s Bankruptcy action or matter involving Newsome transferred to the United States District Court for purposes of keeping legal matters combined. Matter of Wood, 825 F.2d 90 (5th Cir. Miss. 1987) - If proceeding involves right created by federal bankruptcy law, or is one which would only arise in bankruptcy, it is core proceeding, but if proceeding does not invoke substantive right created by federal bankruptcy law and is one that could exist outside of bankruptcy, it is noncore proceeding, though it may be related to bankruptcy because of its potential effect on debtor's estate. 28 U.S.C.A. § 157. In re OCA, Inc., 551 F.3d 359 (5th Cir. 2008) - Bankruptcy court's adjudicative authority is constrained if the adversary proceeding is non-core. 6. As a matter of law, the United States District Court – Southern District of Mississippi (Jackson Division) on December 3, 2010, FIRST retained jurisdiction over this matter. Jurisdiction is the power to decide; it must be conferred, not assumed. Matter of Chicago, Rock Island and Pacific R. Co., 794 F.2d 1182 (7th Cir. 1986). All bankruptcy jurisdiction is given in the first instance to the United States district courts. Acolyte Elec. Corp. v. City of New York, 69 B.R. 155 (Bankr. E.D. N.Y. 1986), ordered aff’d, 1987 1987 WL 47763 (E.D. N.Y. 1987); In re Double TRL, Inc., 65 B.R. 993 (Bankr. E.D. N.Y. 1986). The district courts are granted jurisdiction over bankruptcy cases, that is cases under the Bankruptcy Code and over three categories of bankruptcy proceedings: (1) civil proceedings arising under Title 11; (2) civil proceedings arising in a case under Title 11; and (3) civil proceedings related to cases under Title 11. 28 U.S.C. § 1334(b). As used in this statute, the phrase “arising under Title 11” is meant, not to distinguish between different matters, but to identify collectively a broad range of matters subject to the bankruptcy jurisdiction of federal courts. Matter of Wood, 825 F.2d 90 (5th Cir. 1987).
  • 6. Page 5 of 27 On or about December 16, 2010, Newsome served Debtor (Ladye M. Townsend [“Townsend”]) with the required: (a) “Notice of Lawsuit and Request to Waive Service of Summons;” and (b) “Waiver of the Service of Summons” which was accompanied by Notification Accompanying Waiver of Service of Summons. According to United States Postal Service information, Townsend received these documents on or about December 27, 2010. 7. Newsome believes given the facts, evidence and legal conclusions not only in this Bankruptcy matter, but that in the United States District Court, that Townsend’s Title 7 Bankruptcy proceeding naming Newsome under “Creditors Holding Unsecured Nonpriority Claims” has been submitted: in bad faith, for purposes of harassment, for delay, for vexatious litigation, for purposes of increasing the costs of litigation, for embarrassment, for false and frivolous reasons in attempts to provide her with a defense to Newsome’s Civil lawsuit filed in the United States District Court – Southern District of Mississippi (Jackson Division) [“USDC-MS proceeding”]on or about December 3, 2010; and other willful, malicious and wanton reasons known to Townsend for the filing of this Chapter 7 Bankruptcy proceeding. Therefore, supporting the dismissal of Newsome from Townsend’s Chapter 7 Bankruptcy proceeding: A district court may transfer a bankruptcy case or proceeding to a district court . . .in the interest of justice or for the convenience of the parties. 28 § 1412. In contrast with the general venue transfer statutes, this provision allows transfer to any district, not only to districts in which venue would have been proper had the case been brought in that district. In determining whether to transfer a bankruptcy case, the court should consider the following factors: (1) the proximity of creditors to the court; (2) the proximity of the debtor to the court; (3) the proximity of the witnesses necessary to the administration of the estate; (4) the location of the assets; (5) economic administration of the estate; (6) the necessity of ancillary administration if liquidation should result. See In re Commonwealth Oil Refining Co., 596 F.2d 1239, 1247 (5th Cir. 1979), cert. denied, 444 U.S. 1045 (1980) (construing former 28 U.S.C. § 1475, substantially similar to present § 1412O. Newsome does not believe that based upon the willful, malicious and wanton acts of Townsend and the filing of this FRIVOLOUS Chapter 7 Bankruptcy proceeding as a defense to Newsome’s “USDC-MS proceeding,” that a transfer of this case is warranted or even qualifies for transfer. Therefore, in the interest of justice and expedition of this case, Newsome timely, properly and adequately requested to be dismissed as a “Creditor” from Townsend’s Chapter 7 Bankruptcy action in that this Court lacks jurisdiction over Newsome to proceed; furthermore, that this Court(if it insist on entertaining Townsend’s Bankruptcy action), in the interest of justice and convenience of parties transfer matter regarding Newsome to the United States District Court – Southern District of Mississippi (Jackson Division) for consolidation of cases and convenience to parties. Townsend’s filing of the Chapter 7 Bankruptcy action clearly supports that she would not be prejudiced by the transfer of this matter in that it will remain in SAME venue; however, JURISDICTION of the United States District Court – i.e. NOT Bankruptcy Court.
  • 7. Page 6 of 27 Time, Inc. v. Manning, 366 F.2d 690 (5th Cir. 1966) - Both jurisdiction and venue are designed to test fairness to defendant and degree of inconvenience caused him by requiring him to litigate in a particular court, but jurisdiction is relatively more concerned with fairness and venue more with inconvenience. 8. It appears that Townsend and her counsel are attempting to get this Court to usurp jurisdiction over this matter, the laws clearly prohibits such practices. Brown v. Pyle, 310 F.2d 95 (5th Cir. Miss. 1962) - “Jurisdiction” is the power to hear and determine a cause-the power to adjudicate; it is not to be confused with venue. 9. While Newsome does not claim to have knowledge of Chapter 7 Bankruptcy laws, it is clear that Townsend did not bring this instant Chapter 7 Bankruptcy proceeding as an “ENTITY,” “BUSINESS” for “ESTATE ADMINISTRATOR.” Therefore, Newsome believes the laws support her concerns as to the motives for the Chapter 7 Bankruptcy filing and this Bankruptcy Court’s jurisdiction over this matter. 10. Newsome further believes that Townsend’s Chapter 7 Bankruptcy proceeding filed with this Court in her INDIVIDUAL capacity was filed as a DEFENSE to Newsome’s “USDC-MS proceeding” and therefore, may be precluded by law given the facts, evidence and laws governing said matters. In re SemCrude, L.P., 428 B.R. 82 (2010) - As general rule, subject matter jurisdiction of court is based on state of facts that existed at time cause of action was filed. 11. Newsome further believes that a “FEDERAL” court judgment on her “USDC- MS proceeding” may preclude Townsend from bringing Chapter 7 Bankruptcy proceeding naming Newsome in efforts to avoid the liability owed for damages Newsome sustained and is addressed in the “USDC-MS proceeding.” Under the statutes/laws governing issues regarding CONFLICT OF INTERESTS, Newsome’s Lawsuit in Southern District Court of Mississippi (Jackson) action (Civil Action 3:10-cv-704) is still LEGALLY/LAWFULLY active despite the CRIMINAL acts of said court to make it appear that the case is closed (when it is NOT)! 12. Newsome is NOT a business entity, but a private citizen (individual) of the United States and is seeking relief of and against Townsend and others in the “USDC-MS proceeding.” II. OBJECTION TO DECEMBER 8, 2015, ORDER ON OBJECTION TO NOVEMBER 4, ORDER ON MOTION (sic) RELIEF FROM SEPTEMBER 30, 2015, FINAL JUDGMENT ON CREDITOR’S (VOGEL NEWSOME) MOTION FOR RELIEF FROM ORDER/JUDGEMENT (sic); MOTION FOR RULE 11 SANCTIONS OF AND AGAINST ROBERT REX McRANEY JR./McRANEY & McRANEY; and REQUEST TO BE ADVISED OF CONFLICT-OF- INTERESTS (DKT. #34); REITERATION FOR RULE 11 SANCTIONS OF AND AGAINST ROBERT REX MCRANEY, JR./McRANEY & McRANEY; REQUEST TO BE ADVISED OF
  • 8. Page 7 of 27 CONFLICT-OF-INTERESTS; and REITERATION FOR MOTION FOR RECUSAL OF JUDGE EDWARD ELLINGTON” Vogel Newsome (“Newsome) further OBJECTS to this Court’s December 8, 2015, “Order on Objection To November 4, 2015, Order on Motion (sic) Relief From September 30, 2015, Final Judgment On Creditor’s (Vogel Newsome) Motion For Relief From Order/Judgement (sic); Motion For Rule 11 Sanctions Of And Against Robert Rex McRaney Jr./McRaney & McRaney; and Request To Be Advised Of Conflict-Of-Interests (DKT. #34); Reiteration For Rule 11 Sanctions Of And Against Robert Rex McRaney, Jr./McRaney & McRaney; Request To Be Advised Of Conflict-Of-Interests; and Reiteration For Motion For Recusal Of Judge Edward Ellington.” In further support thereof, Creditor states: 13. Pursuant to Rule 8 (General Rules of Pleading) of the FRCP, Creditor Newsome’s pleadings in this instant Bankruptcy action specifically sets forth “short and plain statement(s)” of the grounds for relief/claims; however, due to this Court’s/Judge Edward Ellington’s INABILITY to respond in accordance to said Rule to legally/lawfully REBUT the claims, allegations and/or arguments set forth in Creditor Newsome’s pleadings, this Court/Judge Ellington merely CONTINUALLY proceeds on what appears to be a MENTALLY DISTURBED and RABID Judge/Law Clerk THROWING TOGETHER a FRIVOLOUS and BASELESS 8-PAGE rambling of UNSUBSTANTIATED GARBAGE! Further supporting and challenging Judge Edward Ellington’s FITNESS as well as MENTAL/PSYCHOLOGICAL state to preside in this matter; moreover, his INABILITY to understand and interpret the facts, evidence and legal conclusions provided in Creditor Newsome’s pleadings providing in this Bankruptcy action. 14. UNCONTESTED are the facts, evidence and legal conclusions set out PURSUANT to Rule 8 (General Rules of Pleading) of the FRCP regarding this Court’s/Judge Edward Ellington’s LACK OF JURISDICTION! 15. UNCONTESTED are the facts, evidence and legal conclusions set out PURSUANT to Rule 8 (General Rules of Pleading) of the FRCP regarding Creditor Newsome’s pleadings seeking relief from FRIVOLOUS and UNLAWFUL/ILLEGAL Orders and/or PREMATURE “FINAL JUDGMENT” which this Court/Judge Edward Ellington LACKS Jurisdiction to enter! 16. UNCONTESTED are the facts, evidence and legal conclusions set out PURSUANT to Rule 8 (General Rules of Pleading) of the FRCP regarding “MOTION FOR SANCTION(S)” provided by Creditor Newsome in pleading(s)
  • 9. Page 8 of 27 filed with this Court and said OBJECTION(S) for which this instant pleading is filed. 17. UNCONTESTED are the facts, evidence and legal conclusions set out PURSUANT to Rule 8 (General Rules of Pleading) of the FRCP regarding “REITERATION FOR MOTION FOR RECUSAL OF JUDGE EDWARD ELLINGTON” provided by Creditor Newsome in pleading(s) filed with this Court and said OBJECTION(S) for which this instant pleading is filed. PLEASE NOTE: All Creditor Newsome is concerned about doing is PROPERLY “PRESERVING” (which this Court has CONFIRMED has been done – DOCKET 64 at Exhibit “1” at Page 5/Lines 1 thru 5) her legal actions DESPITE of the FRUDULENT and CRIMINAL Acts this Court/Judge Edward Ellington and CONSPIRATORS/CO-CONSPIRATORS are engaging in to DECEIVE the PUBLIC/WORLD! Creditor, Vogel Newsome in good faith submits this instant pleading for the above foregoing reasons and, demands, relief requested herein. Creditor Newsome further reserves the right to amend and/or correct said pleading in accordance with the statutes governing said matters. In the meantime, as Newsome shared in previous filings with this Court as well as the September 18, 2015 hearing, her time is being BETTER SPENT informing the PUBLIC/WORLD as to what their LEGAL/LAWFUL “DUTY” is under such documents as the DECLARATION OF INDEPENDENCE and other governing statutes/laws to REGAIN/RECLAIM the United States of America’s Government out of the hands of such TERRORIST DESPOTISM Government Regimes SPEARHEADED by the likes of the KU KLUX KLAN/WHITE SUPREMACISTS/JEWISH-ZIONISTS and Law Firms as Baker Donelson Bearman Caldwell & Berkowitz. See documents that may be found in SlideShare.net Social Forums shared by Creditor Newsome as the 11/11/15 Declaration Of Independence: http://www.slideshare.net/VogelDenise/111115-declaration-of-independence-legal-lawful-right-to- abolish-despotism-government
  • 10. Page 9 of 27 which appears CONTINUES to have a PROFOUND IMPACT on the United States of America’s STOCK MARKET – report as of 12/11/15: and 12/17/15. The WHITE JEWISH-ZIONISTS release of FALSE and MISLEADING Stock Reports is becoming a REALITY!
  • 11. Page 10 of 27 When “WE THE PEOPLE” realize that the UNITED STATES OF AMERICA’S KU KLUX KLAN/WHITE SUPREMACISTS/JEWISH-ZIONISTS have CLEANED out their FINANCIAL/INVESTMENT Accounts (as it appears WHITE-JEWISH ZIONIST Bernard “Bernie” Madoff, his JEWISH BANK JP Morgan Chase and their JEWISH Law Firm Baker Donelson Bearman Caldwell & Berkowitz did and CREATED FALSE and MISLEADING Portfolios for their clients: http://www.slideshare.net/VogelDenise/bernard-bernie- madoff-ties-relationship-to-jp-morgan-chase-bank-ponzi- scheme, http://www.slideshare.net/VogelDenise/madoff- bernard-wiki-info, http://www.slideshare.net/VogelDenise/bd-secmadoff) and TAX DOLLARS through FINANCING their TERRORIST Cells (as Taliban, ISIS, etc.) , the OVERTHROW and bringing these CRIMINALS to JUSTICE will NOT be a PATTY-CAKE experience! http://www.slideshare.net/VogelDenise/taliban-paid-360-million-us-tax-dollars http://www.slideshare.net/VogelDenise/afghanistan-us-talks-with-taliban http://www.slideshare.net/VogelDenise/taliban-us-paysterrorist2
  • 12. Page 11 of 27 http://www.slideshare.net/VogelDenise/afghanistan-president-hamid-karzi-confirms-united-states- cia-provides-bagsofcash-monthly
  • 13. Page 12 of 27 http://www.slideshare.net/VogelDenise/hillary-clinton-united-states-of-americas-terrorist-roles http://www.slideshare.net/VogelDenise/hillary-clinton-dealing-with-the-united-states-of-americas- stingers – YES, United States of America’s President Barack Obama’s WHITE-JEWISH Banker is NONE other than WHITE-JEWISH Owned JP Morgan Chase Bank/Jamie Dimon:
  • 14. Page 13 of 27 http://www.slideshare.net/VogelDenise/barack-obamas-relationship-with-jp-morgan-chase-bank http://www.slideshare.net/VogelDenise/jamie-dimon-jp-morgan-chase-new-york-times-article http://www.slideshare.net/VogelDenise/leggitt-lancesr-advisortopresidenthhscounselorgovofva
  • 15. Page 14 of 27 TERRORIST CELLS created abroad for purposes of OVERTHROWING Foreign Governments and using WHITE-JEWISH Control over the MEDIA Resources to show the IGNORANCE of OVERTHROWN and/or DESTROYED Governments as the SOVIET Union, Iraq, Iran, etc. Leaders to PROMOTE lies and APPEARANCE of CONFLICTS (when there are NONE) by SNAKES and DECEPTIVE Foreign Government Leaders out to BETRAY the People of their Countries:
  • 16. Page 15 of 27 http://www.slideshare.net/VogelDenise/syria-crisis-united-states-of-america-chemical-weapons- attack ALL are for MEDIA SHOW and RATINGS and TERRORIST Acts of WHITE-Jewish Controlled Governments and IGNORANT Foreign Government Leaders BELIEVING their FORK- TONGUE Lies and BETRAYING their Country and Citizens! NOT learning from PAST MISTAKES and FATAL MISTAKES when the United States of America’s TERRORIST Government Regime and their ALLIES grow WEARY of them:
  • 17. Page 16 of 27 DIVIDE AND CONQUER http://www.slideshare.net/VogelDenise/no-laughing-matter-united-states-allies-plans-to-overthrow- governments-52342682 http://www.slideshare.net/VogelDenise/breaking-up-the-middle-east-united-states-allies-plans-to- overthrow-governments
  • 18. Page 17 of 27 The CHICKENS “WILL RETURN TO ROOST” and what the United States of America’s TERRORIST Government Regime and its RACIST Allies have REAPED on other Foreign Nations they sought to OPPRESS and OVERTHROW has NOW reached SOWING TIME! The time for OPPRESSIVE Foreign Nations to also UNITE TOGETHER and bring the United States of America’s TERRORIST Government Regime and its LAWYERS/ATTORNEYS as Baker Donelson Bearman Caldwell & Berkowitz to JUSTICE and PUT them on TRIAL for their TERRORIST Acts as well as WAR CRIMES, etc. that it appears they have LAUNCHED AGAINST other Foreign Governments/Nations for purposes of gaining ACCESS to their MONIES, LAND/PROPERTY and RESOURCES! Creditor Newsome’s time is also being BETTER SPENT being sure that REJECTED News Articles by the Jackson ADVOCATE regarding this DECEPTIVE “URBAN RENEWAL” Scam to STEAL/ROB Black/African-Americans of their LAND/PROPERTY and to CIRCUMVENT laws as the KU KLUX KLAN ACT:
  • 19. Page 18 of 27 http://www.slideshare.net/VogelDenise/100715-urban-renewal-from-the-eyes-of-community- activist-vogel-denise-newsome are presently being EXPOSED through the filing of this instant pleading (so that the PUBLIC/WORLD has a FRONT-ROW Seat for Battle Action as well as the POSTING of information to EDUCATE and
  • 20. Page 19 of 27 INFORM the Public/World of the United States of America’s GENOCIDE practices: http://www.slideshare.net/VogelDenise/tuskegee-tests http://www.slideshare.net/VogelDenise/guatemala-experiments
  • 21. Page 20 of 27 http://www.slideshare.net/VogelDenise/united-states-woman-speaks-out-about-being- sterilizedgutted-by-government KILLING and BRUTAL MURDER OF BLACK/AFRICAN-AMERICAN MALES as Trayvon Martin by WHITE-JEWISH George Zimmerman and what appears to be his Law Firm’s BAKER DONELSON BEARMAN CALDWELL & BERKOWITZ’ Cover-up, REMAINS a TOP/KEY interest by Foreign Governments:
  • 22. Page 21 of 27 http://www.slideshare.net/VogelDenise/english-040512
  • 23. Page 22 of 27 Creditor Newsome’s time is also better spent advising the PUBLIC/WORLD on HOW to LEGALLY/LAWFULLY OVERTHROW the DESPOTISM Terrorist Government Regimes and the HOUSE NEGROES/UNCLE TOMS placed in Political Office for DECEPTIVE purposes: http://www.slideshare.net/VogelDenise/111615-meeting-with-jackson-mayor-tony-yarber-siemens- baker-donelson-scam http://www.slideshare.net/VogelDenise/siemens-settling-bribery-case-to-cost-siemens-16-billion- nytimes http://www.slideshare.net/VogelDenise/baker-donelson-siemens-scam-project-city-approves- financial-advisory-team-highlighted – i.e. for instance in Jackson, Mississippi sharing with the PUBLIC/WORLD the LEGAL/LAWFUL DUTY to OVERTHROW a DESPOTISM Government and NOT having to WAIT for the NEXT ELECTIONS (State and/or Federal) to address DESPOTISM, POLITICAL CORRUPTION,
  • 24. Page 23 of 27 JUDICIAL CORRUPTION, etc.! The POWER of the Government IS WITH “WE THE PEOPLE” and NOT the KU KLUX KLAN/WHITE SUPREMACISTS/WHITE-JEWISH ZIONISTS whose time of TERRORIST Activities has EXPIRED and EVICTION and OVERTHROW being INEVITABLE! If such a DESPOTISM Terrorist/White Supremacist/White-Zionist Government Regimes want to see Blacks/African-Americans as GORILLAS/MONKEYS/APES, at least they are aware of these PRIMATES’ INEVITABLE OVERTHROW of the Government! SO BE IT! At least they KNOW of the INEVITABLE OVERTHROW!
  • 25. Page 24 of 27 There is yet PLENTY of work to do in the OVERTHROW of the United States of America’s DESPOTISM TERRORIST Government Regime – in which it is GOOD to have a VISION and PLAN to present to the PUBLIC/WORLD of what appears to be their LEGAL/LAWFUL DUTY to OVERTHROW a DESPOTISM Government. . . http://www.slideshare.net/VogelDenise/120815-vision-for-the-overthrow-of-the-despostism- government-of-the-united-states-of-america
  • 26. Page 25 of 27 WHEREFORE, PREMISES CONSIDERED, YES, there are LEGAL and LAWFUL ways to TAKE DOWN such TERRORIST DESPOTISM Government Regimes. Moreover, there are laws governing the PRESERVATION of legal cases as this instant Bankruptcy action and the filing of this pleading is for said purposes. As for the September 18, 2015 Hearing, Creditor Newsome also uses such opportunities to CONTINUE to produce and provide EVIDENCE regarding the JUDICIAL Injustices, POLITICAL Corruption – in which MISSISSIPPI has appeared as the NO. 1 State for CORRUPTION and TAINTED Elections. http://www.slideshare.net/VogelDenise/most-corrupt-mississippi http://www.slideshare.net/VogelDenise/most-corrupt-states
  • 27. Page 26 of 27 While the United States of America’s DESPOTISM Government Regime SPEARHEADED by the likes of the KU KLUX KLAN/WHITE SUPREMACISTS/JEWISH-ZIONIST are wanting a “RACE WAR,” the AMERICAN REVOLUTION has ALREADY been fought and the DECLARATION OF INDEPENDENCE provided to DIRECT and SUPPORT “WE THE PEOPLE’S” LEGAL/LAWFUL DUTY to TAKE BACK their Government from the TERRORISTS that have HIJACKED IT! IN SUMMARY: Creditor Vogel Denise Newsome who is also a COMMUNITY ACTIVIST/CIVIL RIGHTS Activist has better things to do with her time and at the BOTTOM of the LIST is responding to such STUPID/FRIVOLOUS Orders from LUNATICS as it appears to be the case with of this Court’s Judge Edward Ellington. The LAWS provide LEGAL/LAWFUL access to OVERTHROWING and REMOVING such CORRUPT JUDGES from the BENCH and this will be how Creditor Newsome will be spending her time!
  • 28. Page 27 of 27 The December 8, 2015, Order entered by this Court/Judge Edward Ellington IS clearly BASELESS, FRIVOLOUS, full of ERRORS, cannot be UPHELD, supports CONFLICT –OF INTERESTS, criminal acts and much more for purposes of AIDING and ABETTING Judge Edward Ellington’s Legal Counsel Baker Donelson Bearman Caldwell & Berkowitz. Said December 8, 2015, appears to be REDUNDANT and NOT worth the ink and paper written on! Respectfully submitted this 18th day of December, 2015. ___________________________________ Vogel Denise Newsome Post Office Box 31265 Jackson, MS 39286 Phone: (513) 680-2922 or (601) 885-9536 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the forgoing pleading was MAILED via U.S. Mail first-class to: Robert Rex McRaney, Jr. Post Office Box 1397 Clinton, Mississippi 39060 COUNSEL FOR DEBTOR (LADYE M. TOWNSEND) Dated this 18th day of December, 2015. _____________________________________ Vogel Newsome
  • 29. The December 8, 2015, Order entered by this Court/Judge Edward Ellington IS clearly BASELESS, FRIVOLOUS, rull oF ERRORS, ainiwt be UPHELD, supports CONFLICT -OF INTERESTS, criminal acts and much more for purposes of AIDING and ABETTING Judge Edward Ellington's Legal Counsel Baker Donelson Bearman Caldwell & Berkowitz. Said December 8, 2015, appears to be REDUNDANT and NOT worth the ink and paper written on! The undersigned hereby certifies that a true and couect copy o f the forgoing pleading was M A J L E D via U.S. Mail fu'st-class to: Robert Rex McRaney, Jr. Post Office Box 1397 Clinton, Mississippi 39060 COUNSEL FOR DEBTOR (LADYE M . TOVWSEND) Dated this 18" day of December, 2015. Respectfully submitted this 18'^ day of December, 2015. Vogel Denise Newsome Post Office Box 31265 Jackson, N4S 39286 Phone: (513) 680-2922 or (601) 885-9536 CERTIFICATE OF SERVICE Vogel Newsome Page 27 of 27 T