2. IN THE UNITED STATESlSjWlKiWei^fil^
SOUTHERN DISTRICT OF MKftlgSlPPl
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IN R E :
L A D Y E M. T O W N S E N D D A N N Y i MILLER C H A P T E R 7
DEBTOR „ C L C R K CASE NO. 11-00167-ee
BY DEPUTY
O B J E C T I O N TO JANUARY 4, 2016, O R D E R ON O B J E C T I O N TO D E C E M B E R 8, 2015,
O R D E R ON O B J E C T I O N TO N O V E M B E R 4, O R D E R ON MOTION (sic) R E L I E F F R O M
S E P T E M B E R 30, 2015, n N A L J U D G M E N T ON C R E D I T O R ' S ( V O G E L NEWSOME) MOTION
FOR R E L I E F F R O M O R D E R / J U D G E M E N T (sic); MOTION F O R R U L E 11 SANCTIONS O F
AND AGAINST R O B E R T R E X McRANEY JR./McRANEY & McRANEY; and R E Q U E S T TO
BE ADVISED O F C O N F L I C T - O F - I N T E R E S T S (DKT. #34); R E I T E R A T I O N FOR R U L E 11
SANCTIONS O F AND AGAINST R O B E R T R E X McRANEY, JR./McRANEY & McRANEY;
R E Q U E S T TO B E ADVISED O F C O N F L I C T - O F - I N T E R E S T S ; and R E I T E R A T I O N F O R
MOTION F O R R E C U S A L O F J U D G E EDWARD E L L I N G T O N '
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 JANUARY 4. 2016. ORDER ON 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" ("OT01-04-16OrderOnObjection") pursuant to Rule 60 of the Federal Rules
NOTE: Boldface, italics and underline, etc. represents •"emphasis"" added.
Page 1 of 23
3. Page 1 of 23
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 JANUARY 4, 2016, ORDER ON 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 JANUARY 4, 2016, ORDER ON 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” (“OT01-04-16OrderOnObjection”) pursuant to Rule 60 of the Federal Rules
1
NOTE: Boldface, italics and underline, etc. represents “emphasis” added.
4. Page 2 of 23
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 January 4, 2016 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
granted, it lacks “jurisdiction” of the subject matter and must
refrain from an adjudication of rights in connection therewith.
5. Page 3 of 23
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 “OT01-04-16OrderOnObjection” 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.
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).
6. Page 4 of 23
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).
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
7. Page 5 of 23
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.
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
8. Page 6 of 23
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 JANUARY 4, 2016, ORDER ON 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
9. Page 7 of 23
Vogel Newsome (“Newsome) further OBJECTS to this Court’s January 4, 2016, “OBJECTION
TO JANUARY 4, 2016, ORDER ON 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.” 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!
10. Page 8 of 23
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)
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
11. Page 9 of 23
as well as UPDATES to Vogel Denise Newsome’s WEBSITE at
www.vogeldenisenewsome.net
21. Page 19 of 23
which appears CONTINUES to have a PROFOUND IMPACT on the United States of America’s
STOCK MARKET – report as of 01/13/16:
The WHITE JEWISH-ZIONISTS release of FALSE and MISLEADING Stock Reports is becoming
a REALITY! They thought SACRIFICING Jewish BERNIE MADOFF for the PONZI SCAM that it
appears his JEWISH/WHITE SUPREMACIST Counterparts Law Firm Baker
Donelson Bearman Caldwell & Berkowitz and JP MORGAN CHASE was bad!
NO! It is NOW a WHOLE LOT
WORSE and they
WILL NOT be able to COVER-UP their
CRIMES!
22. Page 20 of 23
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
You see, 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:! 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!
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. . .
23. Page 21 of 23
http://www.slideshare.net/VogelDenise/120815-vision-for-the-overthrow-of-the-despostism-
government-of-the-united-states-of-america
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!
24. Page 22 of 23
YOUTUBE: https://youtu.be/viLIo7KObUU
ONEDRIVE: http://1drv.ms/1UoahQO
FILES ANYWHERE:
https://www.filesanywhere.com/fs/v.aspx?v=8b70658759667475ad6c
WHEREFORE, PREMISES CONSIDERED, Creditor Newsome files this instant “OT01-04-
16OrderOnObjection” in good faith and according to Judge Ellington’s statement, “Newsome is hereby
put on notice that this Court will not respond to another Rule 60 motion and/or objection and that this
case will be closed unless an appeal has been filed” and “IT IS FURTHER ORDERED that if Newsome
files another motion and/or objection to this Order, the Court will not rule on the motion and/or objection
and that the case will be closed unless an appeal is filed” that she is being given the ASSURANCE that
her case is going to be PRESERVED and there WILL BE no ruling on the motion and/or objection she
brings.
25. Page 23 of 23
IMPORTANT TO NOTE: Is the showing of the IGNORANCE of this
Court/Judge Edward Ellington in that APPEALS CANNOT be brought from
ORDERS! Creditor Newsome has TIMELY, PROPERLY and
ADEQUATELY filed the MANDATORY MOTIONS/OBJECTIONS to
preserve her case as in this instant filing!
The January 4, 2016, 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 January 4, 2016 Order
IS NOT worth the ink and paper written on!
Respectfully submitted this 14th
day of January, 2016.
___________________________________
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 14th
day of January, 2016.
_____________________________________
Vogel Newsome
26. J I P O R T A N T T O N O T E ; Is the showing of the IGNORANCE of this
Court/Judge Edward Ellington in that APPEALS CA^iNpT be brought from
A D E Q U A T E L Y filed the MANDATORY MOTIONS/OBJECTIONS to
preserve her case as in this instant filing!
The Januan 4. 2016. Order entered bs Court/Judge Edward Ellington IS clearly
BASELESS. FRIVOLOUS, full of ERRORS, cannot be UPHELD, supports CONFLICT -OF
LNTERESTS. criminal acts and much more for purposes of AIDING and ABETTING Judge Edward
Ellington's Legal Counsel Baker Donelson Bearman Caldwell & Berkowitz. Said Januar} 4. 2016 Order
IS NOT worth the ink and paper written onl
The undersigned hereb> certifies that a true and correct copf the forgoing pleading was
MAILED via U.S. Mail first-class to:
Robert Rex McRaney, Jr.
Post Office Box 1397
Clinton. Mississippi 39060
C O U N S E L E O R D E B T O R ( L A D Y E M . T O U N S E N D )
Dated this 14'" day of January-, 2016.
ORDERS! Creditor Newsome has T I M E L Y , P R O P E R L Y and
RespectfulK submitted this 14 day of January, 2016.
Post Office Box 31265
Jackson. MS 39286
Phone: (513) 680-2922 or (601) 885-9536
CERTinCATE OF SERVICE
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