17 USC § 107 Limitations on Exclusive Rights – FAIR USE Here is a copy of the “STATEMENT OF POSITION” provided by Ogletree Deakins Nash Smoak & Stewart on BEHALF of First Heritage Credit LLC in the Equal Employment Opportunity Commission Charge brought by Community Activist Vogel Denise Newsome AGAINST her former Employer. First Heritage Credit’s “Statement of Position” is NOT in COMPLIANCE with the EEOC’s Guidelines – i.e. FATEFULLY FAILING to respond to EACH claim/charge RAISED in Newsome’s EEOC Charge. As a matter of law, FAILURE to DENY and/or RESPOND to EACH of the Claims/Charges raised ARE DEEMED “ADMITTED!” A copy of Newsome’s EEOC Charge against First Heritage Credit/1st Heritage Credit may be found at: https://www.slideshare.net/VogelDenise/notice-of-eeoc-complaint-against-1-st-heritage-credit-llc-filed Please feel free to visit our Website at www.vogeldenisenewsome.net and www.vogeldenisenewsome.com where BOTH are presently in the stage of being set up. We are very happy that we went with a Web Building Program as JOOMLA because OUR GOAL is to get OUTSIDE the WALLS of the United States’ DESPOTISM Government Regime who REPEATEDLY attempts to OBSTRUCT Viewership, Analytics, etc.; however, COMPETITIVE Retro-ACTIVE Responses from us in using other Social Media Forums and SEO Engines, etc. the efforts by SlideShare’s NEW OWNER – MicroSoft – to BLOCK VIEWERSHIP has failed. Our COUNTER ATTACKS are VERY PRODUCTIVE based on the information we are getting from our website(s). https://www.slideshare.net/VogelDenise/02-2017-vogeldenisenewsomenet-website-report LOL!

1. 17 USC § 107 Limitations on Exclusive Rights – FAIR USE
Page 1 of 10
EQUAL EMPLOYMENT OPPORUNITY COMMISSION CHARGE
01/09/17 FIRST HERITAGE CREDIT LLC’S
STATEMENT OF POSITION
VOGEL DENISE NEWSOME vs. FIRST HERITAGE CREDIT
Received 04/02/17
As of 04/02/17, Ogletree Deakins Nash
Smoak & Stewart (“OgleTree Deakins”)
does NOT appear to be on the list of
Tenants – i.e. Merrill Lynch, Neel-
Schaffer, H.C. Bailey Companies, CISCO,
Mississippi Valley Title, Taggart Rimes &
Graham, Seventh Knight
EEOC alleges receipt of First
Heritage Credit’s Response on
01/11/17; however, does NOT provide
Newsome with response UNTIL LATE
March – AFTER Newsome’s
03/29/17 PUBLISHING of Article
“The United States’ FALL:entitled,
Building A Government On The
Shoulders of Great Leaders.” On
04/02/17, Newsome received EEOC’s
Correspondence – BACKDATED to
March 20, 2017, on or about
04/02/11, to make it APPEAR that
it was SENT PRIOR to the
of the 03/29/17PUBLISHING
Article - when it WAS NOT!
Newsome’s mail was CHECKED
EARLIER in the week and PRIOR to
completing the Article; however,
there was NOTHING from the EEOC!
It is IMPORTANT TO US that the PUBLIC/WORLD see HOW the United States’ DESPOT goes
about ENGAGING in MAIL TAMPERING and MAIL FRAUD/OBSTRUCTION OF MAIL, etc. and
turns to the United States Postal Service their CRIMES – i.e. POSTMARKING itto COVER UP
for Mar 20 2017; however, mailing AFTER March 29, 2017?

2. 17 USC § 107 Limitations on Exclusive Rights – FAIR USE
Page 2 of 10
Then ONLY giving Newsome approximately 8 DAYS to RESPOND rather than
the 20 DAYS MANDATORILY required – i.e. MAIL FRAUD/TAMPERING, OBSTRUCTION
OF MAIL, etc. This is WHY Community Activist Newsome in her 03/39/17 Article advised
that UNDER the NEW Government it WILL have its OWN Mailing System!
As of 04/05/17: https://www.slideshare.net/VogelDenise/040517-eeoc-questions-and-answers-for-
respondents-on-eeocs-new-position-statement-procedures
DEFAMATION: First Heritage Credit’s Legal Counsel (Ogletree
Deakins Nash Smoak & Stewart through its STATEMENT DEFAMES
Community Activist Vogel Denise Newsome’s Character (i.e. a/k/a
CHARACTER ASSASSINATION) by FALSIFYING that she was
belligerent, disrespectful and – when Newsome WASinsubordinate
NOT! The Email may be found at PUBLIC NOTIFICATION - Page 375 of
this Link:
SlideShare: https://www.slideshare.net/VogelDenise/notice-of-eeoc-complaint-against-1-
st-heritage-credit-llc-filed
WHITE Woman speaks with
FORKED/LYING TONGUE!
IMPORTANT TO NOTE: First Heritage Credit had a HOUSE NIGGERO by the name of
Vicky Clanton (i.e. also a PREACHER’S Wife) that REQUIRED that her Department Members
provide her with FEEDBACK. On or about FRIDAY, 08/08/14, Clanton called an IMPROMTU
Meeting WITH KNOWLEDGE that Newsome was about to leave for an appointment outside
the office! This LEAVE had PRIOR APPROVAL by Clanton (Branch Manager). Therefore,
Newsome provided her Feedback as Clanton requested on MONDAY, 08/11/14! Newsome’s
FEEDBACK and/or RESPONSE are in COMPLIANCE with First Heritage’s Policies &
as were PREVIOUS Emails and/or Complaints submitted to address concerns!Procedures

3. 17 USC § 107 Limitations on Exclusive Rights – FAIR USE
Page 3 of 10
This is a CLASSIC EXAMPLE of WHY Employees should TAKE
“THEIR” Copy of the Employer’s Handbook and/or Policies &
Procedures HOME and, if they want, KEEP a copy on the Job.
WHY? Because the SURPRISE Element and allege claims used by PROFESSIONAL
RACIST Employers, as First Heritage Credit, who engage in unlawful/illegal EMPLOYMENT
, look to use FRIVOLOUS claims as “AT-WILL,” “INSUBORDINATION,” etc. toViolations
COVER UP and CRIMINAL wrongdoing! The SURPRISE Element is used bytheir CIVIL
WHITE Employers WHO are AWARE they are ACTING in VIOLATION as well asof TITLE VII
OTHER Employment Laws. Therefore, by CATCHING the Employee by SURPRISE and
ADVISING of TERMINATION does NOT give the Employee time to PERSONALLY Collect their
items at times which may INCLUDE the Company Handbook if given. Employers like to
CLEAN OUT Office Space so they can UNLAWFULLY/ILLEGALLY VIEW and REMOVE
documents/property of the Employee they feel will be DAMAGING to them should an EEOC
Charge and/or Lawsuit ARISE!
ALSO, Employees should keep COPIES of Emails and/or Office Correspondence as it
relates to Employer/Employee and Human Resources/Personnel ISSUES. WHY? Because
it IS NOTwhile the Employer may allege that such correspondence is Company Property,
and may be used to SUPPORT WRONGFUL DISCRIMINATORY Termination/ , BREACH of
Employment Terms VOIDING, etc. – i.e. any such DEFENSE! Furthermore, SUPPORT that
while the Employee(s) is FOLLOWING that ONCEthe Company’s Policies & Procedures, the
UNLAWFUL/ILLEGAL Termination occurs WILL use of thethe Employer(s) such IGNORANCE
Laws to DEFAME (as First Heritage and its Lawyers are doingthe Employee’s Character
with Community Activist Vogel Denise Newsome)! HAD Newsome NOT put her EDUCATION,
TRAINING and LEGAL EMPLOYMENT Experiences to work, her CLAIMS may have been
DIFFICULT to PROVE and she would NOT have had the “PRIMA FACIE” EVIDENCE as provided
with her 02/09/15 Equal Employment Opportunity Complaint to REBUT First Heritage Credit’s
“POSITION STATEMENT!”
Suppose Community Activist Vogel Denise Newsome
did NOT have a copy of First Heritage Credit’s
EMPLOYEE HANDBOOK – then most likely you
would BELIEVE the LIES as that DISHED OUT by
First Heritage Credit’s WHITE Jews/Zionists and
WHITE Supremacists Attorneys at the Law Firm of
Ogle Ogletree Deakins Nash Smoak & Stewart.
See EXCERPT beginning at Page 388:
SlideShare:
https://www.slideshare.net/VogelDenise/notice-of-
eeoc-complaint-against-1-st-heritage-credit-llc-filed
So far from our RESEARCH in preparation
to provding a Response by the 04/10/17
DEADLINE provided by the EEOC for
instance, Community Activist Vogel Denise
Newsome has been able to come across
a Legal Pleading to SUPPORT HOW
First Heritage Credit’s Legal Counsel is
for aLAYING the GROUNDWORK
FRIVOLOUS “CONCILIATION” Defense:

4. 17 USC § 107 Limitations on Exclusive Rights – FAIR USE
Page 4 of 10
https://www.slideshare.net/VogelDenise/040317-ogletree-deakins-barking-up-the-wrong-tree-conciliation-defense-fhc
The FIRST Defense that First Heritage Credit and its Legal Counsel (Ogletree Deakins)
with Conspirators/Co-Conspirators as BAKER DONELSON BEARMAN CALDWELL & BERKOWITZ)
CONSPIRED with the Equal Empoloyment Opportunity Commission on was a FRIVOLOUS
claim that Newsome’s 02/09/15 EEOC Charge/Complaint was “UNTIMELY FILED” – when it
WAS NOT!
NOW, here they go attempting to assert a FRIVOLOUS “CONCILIATION” Defense! First
Heritage Credit and its CRIMINAL/RACIST Lawyers are OUT OF LIFELINES and are BARKING
UP THE WRONG TREE in their efforts to use such Defenses!
MORE DELAY TACTICS used by andWHITE Jewish/Zionist
WHITE Supremacist Law Firms to UNDULY Burden and FURTHER
ENGAGE in the Conspiracies against their Employee(s) – i.e. as in this case with
Community Activist Vogel Denise Newsome! IF First Heritage Credit was INTERESTED in
RESOLVING this matter in GOOD-FAITH, do you really think it would have WAITED almost
3 YEARS!
NO! Because First Heritage and its Legal Counsel of
Ogletree Deakins with their CONSPIRATORS-IN-CRIME
(Baker Donelson Bearman Caldwell & Berkowitz) had
“PLACED ALL THEIR ROTTEN EGGS INTO ONE
BASKET” with LIES as the following:
(1) UNTIMELY Filed EEOC Charge.
(2) EXPIRATION of Statute of Limitation to file Lawsuit.
(3) “Prima Facie Evidence”FAILURE to ESTABLISH
(4) MALICIOUSLY attempting to FRAME ANOTHER Company
for a WHITE Jewish/Zionist and WHITE Supremacist
Company’s TITLE VII/EMPLOYMENT Violations to AVOID
Liability and used that as a – i.e.WOULD HAVE DEFENSE
that Newsome’s EEOC’s “Dismissal and Notice of Rights” IS
AGAINST “First Heritage Credit Union” and NOT “First
Heritage Credit LLC.”

5. 17 USC § 107 Limitations on Exclusive Rights – FAIR USE
Page 5 of 10
NO, because they CONSPIRED with OTHERS to cause IRREPARABLE Injury/Harm to
Community Vogel Denise Newsome’s REPUTATION and WANT to PAINT her as a SERIAL
LITIGATOR without TAKING RESPONSIBILITY for their CRIMINAL and CIVIL Wrongdoings!
YES, CRIMINAL Wrongdoings! NOW that it is TIME to ANSWER for their Criminal/Civil
Violations, THEY want to SEEK Confidentiality!
FAILURE by the United States’ DESPOTISM
Government’s Equal Employment Opportunity
Commission to PUBLICLY EXPOSE and REPORT the
andCriminal Civil VIOLATIONS of Newsome’s
Employers – as First Heritage Credit LLC- (as it has DONE
on NUMEROUS occasions for other Employees),
ALLOWED for such UNLAWFUL/ILLEGAL practices
AGAINST Newsome to CONTINUE! Had Community
Activist Vogel Denise Newsome NOT turned to the
Social Media NETWORKS being used by the WHITE
Jewish/Zionist and WHITE Supremacist Employers to
, etc., the PUBLIC/WORLD would NOT beDEFAME her
getting the TRUTH of WHERE the United States’
DESPOTISM Government’s EMPIRES are and the
DOMESTIC/INTERNATIONAL TERRORIST Acts being
CARRIED out by the United States’ DESPOTISM
CORPORATE Regime and its Corporate BRANCHES
People-Of-Color and NATIONS-Of-Color!TARGETING
This is a matter of
PUBLIC/WORLDWIDE
Interests!
The Newsome vs. First Heritage Credit EEOC
Charge/Complaint consist of APPROXIMATELY
381 Pages 310 of the Pagesof which SET
the Claims/ChargesFORTH and the
REMAINING Pages SUPPORTINGare the
setting forth (pursuant to Rule 8 ofEXHIBITS
the Federal Rules of Civil Procedure and IN
COMPLIANCE with the Equal Employment
Opportunity Commission’s PROCEDURES) short
and/or plain STATEMENTS setting forth EACH
claim(s) asserted and the MANDATORILY
REQUIRED documents and/or evidence to support
the claims/charges set forth! https://www.slideshare.net/VogelDenise/notice-of-
eeoc-complaint-against-1-st-heritage-credit-llc-filed

6. 17 USC § 107 Limitations on Exclusive Rights – FAIR USE
Page 6 of 10
https://www.slideshare.net/VogelDenise/eeoc-effective-position-statements-040517-highlighted
The “Statement of Position” provided by First Heritage Credit was NOT provided to AID
the EEOC with the ACCELERATION of its Investigation; however, was provided with INTENT to
DELIBERATELY, WILLFULLY and OBSTRUCT a Federal Investigation!MALICIOUSLY
Community Activist Vogel Denise Newsome’s EEOC Charge AGAINST First Heritage Credit
IS WELL DRAFTED and provide LEGAL Conclusions/Case Laws and DOCUMENTATION to
support the Claims/Charges made. NOW that Newsome’s CLAIMS/CHARGES have gone
UNREFUTED, according to the EEOC’s Procedures, the ACCELERATION of the Investigation
is INEVITABLE with a DEFAULT DECISION in FAVOR of Newsome!
On or about January 9, 2017, First Heritage
Credit’s Legal Counsel Robin Banck Taylor
of Ogletree Deakins Nash Smoak & Stewart
provided an 8-Page document alleged to be
a “statement of position.” The 8-Page
Statement IS NOT in compliance with the
EEOC’s Procedures and/or Federal
Guidelines regarding HOW “Position
Statements” are MANDATORILY Required to
be DRAFTED! Nevertheless, here is Robin
Banck Taylor SWIFTLY attempting to put
forth CONCILIATION Defensea when she
HASN’T CLEARED the FIRST DoHurdle!
you THINK the EEOC NOTIFIED First
Heritage Credit of its FAILURE to meet the
PLEADING REQUIREMENTS for “Position
Statements” submitted?
Ogletree Deakins Nash Smoak & Stewart
has
GONE THEAS FAR AS
SUPREME COURT
OF THE UNITED STATES
to PRESENT their “CONCILIATION” Defense
in a CIVIL LAWSUIT; however, RIGHT OUT OF
THE BLOCKS and WITHOUT CLEARING the
FIRST HURDLE of the PLEADING
REQUIREMENTS for “Position Statements,”
Ogletree Deakins –TOP RANKING Attorney
(Robin Banck Taylor - Office MANAGER
) serving as the MANAGINGSHAREHOLDER
Shareholder in the Jackson, Mississippi Office -
BEGINS CLUTTERING the Investigation File
with FRIVOLOUS UNSUBSTANTIATED and
UNSUPPORTED documentation LOADED
with LUNATIC Ramblings – i.e. leaving a
reasonable mind to QUESTION Taylor’s
FITNESS and MENTAL Capacities as Legal
Counsel for First Heritage Credit!
https://www.slideshare.net/VogelDenise/040317-ogletree-deakins-
barking-up-the-wrong-tree-conciliation-defense-fhc

7. 17 USC § 107 Limitations on Exclusive Rights – FAIR USE
Page 7 of 10
From the AWARDS and ACCOLADES published about Taylor, one is supposed to THINK that
she is SMART, INTELLIGENT, a GOOD Lawyer, etc. – WHEN she is NOT! Based on the Work
Product (“Statement of Position”) Community Activist Vogel Denise Newsome looks forward to
responding to, it DOESN’T support a document prepared by a “CUM LAUDE” Law School
Graduate! Taylor allegedly having OVER 15 Years in Law; therefore she is KNOWLEDGEABLE
of VIOLATIONS of Rule 11 of the FRCP and CONSEQUENCES for placing her SIGNATURE on
such a FRIVOLOUS document as First Heritage Credit’s “Statement of Position!” Keep in mind,
it is reported Taylor HOLDS a B.S. Degree in PSYCHOLOGY!
First Heritage Credit’s “Statement of Position” does NOT meet the MANDATORY Pleading
Requirements of the EEOC’s NEW PROCEDURES implemented addressing “POSITION
STATEMENTS;” NOR does First Heritage Credit response meet the PLEADING Requirements of
Rule 8 of the of Civil Procedure.Federal Rules

8. 17 USC § 107 Limitations on Exclusive Rights – FAIR USE
Page 8 of 10
Here is an EEOC Complaint filed in FEDERAL COURT styled, EEOC vs. Carolina Mattress
Guild. Carolina Mattress Guild’s Legal counsel is Ogletree Deakins Nash Smoak & Stewart –
i.e. the SAME Law Firm operating as Legal Counsel for First Heritage Credit’s Legal Counsel!
This Lawsuit is provided to SUPPORT that Robin Banck Taylor of Ogletree Deakins KNEW
and/or should have KNOWN that the January 9, 2017 “Statement of Position” FAILED to
meet the Pleading REQUIREMENTS and GUIDELINES UNDER the EEOC’s PROCEDURES
addressing “Position Statements” as well as those set forth in Rule 8 of the FRCP!
https://www.slideshare.net/VogelDenise/ogletree-deakins-eeoc-vs-carolina-mattress-guild-highlighted
IT IS IMPORANT FOR THE PUBLIC/WORLD to know that under the Statutes/Laws of the United
States’ DESPOTISM Government Regime that First Heritage Credit’s RESPONSIVE Pleading
(Statement of Position) does NOT Comply with the EEOC’s MANDATORY Procedures
provided for “POSITION STATEMENTS” nor that of Federal Rules of Civil Procedure Rule 81
and/or other applicable laws governing said matters that responses to Complaint shall:
1. State in short and plain terms Respondent’s defense(s) to each
claim asserted and shall admit or deny averments upon which you
rely;
2. If Respondent is without knowledge or information sufficient to
1
Reference Purposes: Rule 9 General Rules of Pleadings – Wright & Miller Federal Practice and Procedure Civil 3d.

9. 17 USC § 107 Limitations on Exclusive Rights – FAIR USE
Page 9 of 10
form a belief as to the truth of an averment, then Respondent shall
so state and this has the effect of denial. However, said denials
shall fairly meet the substance of the averments denied;
3. If Respondent intend in good faith to deny only a part of a
qualification of an averment, then Respondent shall specify so
much of it as is true and material and shall deny only the
remainder; and
4. Be subject to the provisions of Federal Rules of Civil Procedure
Rule 11. Your “failure to comply with Rule 11 may be attacked
by a motion to strike.” “An attorney who willfully violates Rule 11
is subject to possible disciplinary action.”
Attorney’s/Respondent’s signing of pleadings constitutes a
certificate of the following:
a. That the attorney (or party) has conducted a
reasonable inquiry;
b. is satisfiedThat he or she that the paper is
well grounded in fact;
c. That the pleading has a basis in existing law
or that the attorney (or party) has a good
faith argument to amend or reverse existing
law; and
d. That the pleading is not interposed for any
improper purpose, such as harassment,
delay or needless increase of his opponent’s
costs of litigation.
. . . If the pleading or other paper is signed in violation of this Rule, appropriate
disciplinary action shall be imposed by the factfinder on request or on its own
initiative. Disciplinary acts may include an order to pay the other party the amount of
reasonable expenses caused by the violation, including reasonable attorney’s fees.2
As a LAW FIRM, OGLETREE DEAKINS NASH SMOAK & STEWART and/or ROBIN BANCK
TAYLOR knew and/or should have known:
5. That it/she had a duty to familiarize and/or acquaint itself/herself with
the Rules governing responsive pleadings. Because Answers such as
“failure to state a claim,” “lack of subject matter jurisdiction,” provided for
purposes of misrepresentation, delay of proceedings, obstruction of
justice, etc. will be subject to the provisions of Rule 11;3
6. That if answer(s) is not sufficiently definite in nature to give reasonable
notice of the allegations in the Complaint sought to be placed in issue,
then Newsome’s averments may be treated as admitted (i.e. a corporate
defendant’s denial of “each and every allegation” did not give “plain
notice.”).4
7. A denial of knowledge or information requires that First Heritage
Credit/Ogletree Deakins not only lack first-hand knowledge of the
necessary facts involved, but also that First Heritage Credit/Ogletree
Deakins lack information upon which it reasonably could form a personal
belief concerning the truth of the Newsome’s allegations.5
8. Normally, Responder may NOT assert lack of knowledge or information if
the necessary facts or data involved are within your knowledge or
easily brought within their knowledge (i.e. An Answer denying
2
Reference Purposes: Niles Federal Civil Procedure 7.530 Signing of Pleadings, Motions and Other Papers.
3
Reference Purposes: Niles Federal Civil Procedure 7.100 Pleadings Allowed through 7.262 Effect of Failure to Deny.
4
Reference Purposes: Wright & Miller Federal Practice and Procedure Civil 3d § 1261.
5
Reference Purposes: Wright & Miller Federal Practice and Procedure Civil 3d § 1262.

10. 17 USC § 107 Limitations on Exclusive Rights – FAIR USE
Page 10 of 10
information as to the truth or falsity of a matter necessarily within the
knowledge of the party’s managing officers is a sham, and will be
treated as an admission of allegation of the complaint.6)
9. An averment, that Respondent is without knowledge or information
sufficient to form a belief as to matters that are common knowledge or of
which Responder can inform oneself with the slightest effort, will be
treated as patently false and the effect and purpose will be taken as
such to merely delay justice.7
10. If the Answer to the Complaint is not in compliance with the rules and/or
laws governing said matters, the applicable Request to Strike the
Answer may be submitted and request for proper relief (i.e. disciplinary
action against Respondent and/or attorney [if applicable] and costs of
legal fees to defend sham/frivolous filings) will be brought.
While First Heritage Credit may WANT ANOTHER
BITE at the APPLE – i.e. ANSWERING the EEOC
Charge – IS CLOSED NOthat OPPORTUNITY and is
LONGER After approximately THREEAVAILABLE!
(3) Years since Newsome’s UNLAWFUL/ILLEGAL
Termination of Employment and the FRIVOLOUS
01/09/17 LACKING“Statement of Position” -
factual evidence and LACKING Legal Conclusions
to REBUT that produced and SUPPORTED by the
EVIDENCE in Newsome’s EEOC Charge/Complaint –
ALLwas First Heritage could come up with!
KEEP YOUR EYES AND EARS OPEN and LOOK FORWARD TO
COMMUNITY ACTIVIST VOGEL DENISE NEWSOME’S RESPONSE TO
THE FOLLOWING “STATEMENT OF POSITION” FROM FIRST HERITAGE CREDIT LLC:
6
For Reference Purposes: Wright & Miller Federal Practice and Procedure Civil 3d § 1262 and also, Harvey Aluminum (Inc.) v. NLRB, 335 F2d 749, 758 (9th
Cir. 1964).
7
For Reference Purposes: See Reed v. Turner, 2 F.R.D. 12; and Squire v. Levan, 32 F.Supp. 437.