This document lists 43 questions presented for review relating to lawsuits involving the petitioner Vogel Denise Newsome. The questions cover issues such as whether extraordinary circumstances exist warranting relief, whether judges and justices should have recused themselves due to conflicts of interest, whether the petitioner's right to a jury trial was violated, and whether various parties including Baker Donelson Bearman Caldwell & Berkowitz and government officials engaged in criminal, retaliatory, or conspiratorial acts against the petitioner. The petitioner seeks review of lower court rulings and requests relief including injunctive action.

2. I. QUESTIONS PRESENTED FOR REVIEW
1. Whether EXTRAORDINARY and/or EXCEP-
TIONAL circumstances warrants the granting
of the Petition(s) sought.
2. Whether Supreme Court of United States Jus-
tices are required to RECUSE themselves in
this lawsuit. Whether Conflict-Of-Interest ex-
ist with Justices and/or Administrative Staff of
this Court in this lawsuit.
3. Should United States District Court Judge for
the Southern District of Mississippi (Jackson
Division) [“USDC-Jackson, MS”], the Honora-
ble Tom S. Lee, who it appears has a business
and personal relationship with Defendant(s) in
the lower court action and appears have finan-
cial and/or personal interests in this lawsuit,
be disqualified from presiding in cases in
which Baker Donelson Bearman Caldwell &
Berkowitz, its PARTNERING firms as Phelps
Dunbar LLP are used as FRONTS to
shield/mask/hide the role it is playing in law-
suits and/or legal actions involving Vogel Den-
ise Newsome (“Newsome”)?
4. Whether Judge Tom S. Lee has jurisdic-
tion/legal authority to preside over lower court
action where “Affidavit of Disqualification” has
been filed against him. See APPENDIX
(“APPX”) “5” and “Request for Conflict of In-
terest Information, Notice of Opposition to
Magistrate Judge Assignment; and Notice of
Address” was filed; however, Judge Lee RE-
i

3. FUSED to address ALL issues raised in plead-
ings. See APPENDIX “6” - Appendix Chart
(“APPX CHART”) No. “12” 1 Whether Judge
Tom S. Lee submitted issues raised and in
dispute to a JURY as timely demand-
ed/requested.
5. Whether Judge Tom S. Lee owe a specific duty
to Newsome to recuse himself from United
States District Court – Southern District of
Mississippi (Jackson Division) action.
6. Whether Newsome is entitled to know of “Con-
flict of Interest” that exist between factfind-
er(s)/judges/justices and/or opposing par-
ties/counsel.
7. Whether Judges/Justices owe a specific duty to
Newsome to recuse themselves when “conflict
of interest” exists. Whether Judges/Justices
remained on the bench in legal actions where
Newsome is a party with knowledge there was
a “conflict of interest” due to their relationship
with opposing parties and/or their coun-
sel/counsel’s law firm.
8. Whether judges/justices assigned cases involv-
ing Newsome and supporting “THIRD-
PARTIES’” (i.e. such as opposing law firm(s)
as Baker Donelson Bearman Caldwell &
Berkowitz, their employees and/or clients) in-
1 In accordance with the Rules of the Supreme Court of the United
States and in good faith to mitigate costs to prepare an Appendix with the
amount of VOLUMINOUS documents referenced, Newsome has provided the
LINKS where supporting documents may be found supporting this pleading.
Newsome has prepared at APPENDIX “6” an APPENDIX CHART (“APPX
CHT”) containing the documents to be included in the JOINT APPENDIX in
this matter.
ii

4. terests had a duty to recuse themselves from
lawsuits – i.e. as Judge Tom S. Lee [see APPX
CHT No. “7” – Recusal Orders executed be-
cause of relationship to Baker Donelson
Bearman Caldwell & Berkowitz - provided and
incorporated herein by reference] – in which
knowledge of CONFLICT OF INTEREST EX-
ISTED. Whether judges/justices are allowed to
discriminate in their compliance with laws
governing recusal [see APPX CHT No. “8” –
Docket Sheet (Newsome v. Entergy - wherein
Baker Donelson Bearman Caldwell & Berko-
witz appears as counsel of record - provided
and incorporated herein by reference]. Wheth-
er judges/justices should be IMMEDIATELY
removed from the bench and/or the applicable
legal actions initiated against judges/justices
for removal when record evidence supports
judges/justices failure to recuse. How does said
failure of judges/judges to recuse themselves
affect the public and/or Constitutional rights
of citizen(s)?
9. Whether Newsome’s Complaint and her sub-
sequent pleadings in the lower court meet the
PLEADING Requirements of Rule 8 of the
Federal Rules of Civil Procedure.
10. Whether Newsome’s Complaint can be dis-
missed WITH prejudice upon Motion to Dis-
miss for 42 § 1983 claims that are NOT the
basis of her claims and when § 1983 claims
were NEVER raised in her Complaint.
11. Whether Newsome’s Complaint is governed by
CONTINUING TORT – statute of limitations
– when civil wrongs/violations of Defend-
iii

5. ants/Respondents are ONGOING and contin-
ues to date.
12. Whether Newsome is entitled to injunctive re-
lief as a direct and proximate cause of the ir-
reparable injuries/harm sustained and contin-
ues to date. Injunctive relief commanding
and/or preventing the unlawful/illegal acts of
Respondents.
13. Whether Newsome, as a matter of Constitu-
tional right, is entitled to JURY trial(s) when
requested. Whether Newsome has been de-
prived of Constitutional right to jury trial(s).
14. Whether Newsome timely, properly and/or ad-
equately DEMANDED jury trial on issues.
15. Whether Newsome WAIVED her right to have
issues tried before jury.
16. Whether Judge Tom S. Lee possessed
knowledge that Newsome timely, properly and
adequately demanded JURY on ALL triable
issues. Whether Judge Tom S. Lee possessed
knowledge that he infringed upon Newsome’s
Constitutional Rights. Whether Judge Tom S.
Lee acts are arbitrary and/or capricious.
17. Whether the United States District Court –
Southern District of Mississippi (Jackson Divi-
sion) entered a decision in conflict with the de-
cision of another federal district and/or federal
circuit court of appeals on the same important
matter; has decided in important federal ques-
tion in a way that conflicts with a decision by a
federal court of last resort; and/or has taken a
far departure from the accepted and usual
iv

6. course of judicial proceedings, or sanctioned
such a departure, as to call for an exercise of
the Supreme Court of the United States’ su-
pervisory power and/or original jurisdiction.
18. Whether United States District Court –
Southern District of Mississippi (Jackson Divi-
sion) has decided an important question of
federal law that has not been, but should be,
settled by this Court; and/or has decided an
important federal question in a way that con-
flicts with relevant decisions of the Supreme
Court of the United States.
19. Whether the lower court has decided an im-
portant federal question in a way that conflicts
with the decision of another federal court of
last resort or of a United States court of ap-
peals.
20. Whether lower court decision(s) raise ques-
tion(s) as to the validity of the federal statute
or treaty; raise a question statute statute/law
relied upon is repugnant to the Constitution,
laws or treaties of the United States; or ad-
dress the contention that a right, privilege or
immunity is “set up or claimed under the Con-
stitution or statutes of, or any commission
held or authority exercised under, the United
States.”
21. Whether the Supreme Court of the United
States’ decision in Citizens United v Federal
Election Commission, 558 U.S. 50 (2010), have
provide courts with a license and/or defense to
engage in criminal acts – i.e. provide arbi-
trary/capricious decisions for purposes of cov-
ering up criminal/civil wrongs leveled against
v

7. citizens/litigants – for purposes of protecting
TOP/BIG/KEY Financial Campaign Contribu-
tors. Whether said Court NOTIFIED parties
in the Citizens United matter and/or the
PUBLIC that a CONFLICT-OF-INTEREST
existed in its handing of said decision. Wheth-
er the Supreme Court of United States’ DE-
LIBERATE FAILURE to RECUSE and/or
NOTIFY of Conflict-Of-Interest in the han-
dling of Citizens United v. Federal Election
Commission, renders its decision NULL/VOID
and its acts ARBITRARY/ CAPRICIOUS.
22. Whether Newsome has been deprived equal
protection of the laws, equal privileges and
immunities of the laws, and due process of
laws secured under the United States of Amer-
ica’s Constitution.
23. Whether Newsome is a victim of “Pattern-of-
Practices,” “Pattern-of-Abuse,” “Pattern-of-
Injustices” and/or “PATTERN” of unlaw-
ful/illegal practices as a direct and proximate
result of her engagement in protected activi-
ties.
24. Whether Newsome is a victim of “Criminal
Stalking.”
25. Whether Newsome is a victim of Government
“BULLYING.” Whether the United States
Government/Courts allow parties opposing
Newsome in legal matters (judicial and admin-
istrative) to use their “political” and “financial
wealth” for purposes of BULLYING Newsome.
Whether said BULLYING is for purposes of
intimidation, coercion, threats, bribery,
blackmail, etc. to force Newsome to abandon
vi

8. protected rights and/or deprive Newsome
equal protection of the laws, equal privileges
and immunities of the laws and due process of
laws.
26. Whether United States of America Govern-
ment Officials and Newsome’s former employ-
er(s) have engaged in criminal/civil wrongs
leveled against her for purposes of BLACK-
LISTING. Whether the United States Gov-
ernment Agencies/Courts have placed infor-
mation on the INTERNET regarding New-
some that it knew and/or should have known
was false, misleading and/or malicious.
27. Whether Government agencies, their employ-
ees and others have engaged in TERRORIST
ACTS.
28. Whether the United States citizens/public
and/or Foreign Nations, their leaders and citi-
zens are entitled to know of the crimes and
civil injustices of the United States of Ameri-
ca’s Government, its officials/employees and
co-conspirators leveled against African/Black-
Americans and/or people of color.
29. Whether extraordinary circumstances exist to
warrant granting of this petition.
30. Whether conspiracy(s) leveled against New-
some exist. Whether United States Govern-
ment Officials’/Courts’ failure and “neglect to
prevent” has created a “threat to the public” in
allowing criminal(s) to remain at large in the
general population.
vii

9. 31. Whether citizens of the United States have the
right to exercise First Amendment Rights and
Rights secured/guaranteed under the United
States Constitution and/or Rights secured un-
der the laws of the United States without fear
of reprisal.
32. Whether United States Government Agencies
and their Officials/Employees have the right to
retaliate against Newsome for exercising
rights protected and secured under the laws of
the United States and United States Constitu-
tion.
33. Whether opposing parties, their insurance
providers, special interest groups, lobbyists,
and their representatives have legal authority
to retaliate against Newsome for her engage-
ment in protected activities. Whether oppos-
ing parties and their conspirators/co-
conspirators are allowed to stalk Newsome
from job-to-job/employer-to-employer and
state-to-state for purposes of terminating her
employment, blacklisting, etc. in retaliation
for Newsome having exercised and/or or en-
gagement in protected activities.
34. What role (if any) has the law firm Baker Do-
nelson Bearman Caldwell & Berkowitz, its
employees, clients and others played in the
criminal/civil wrongs and conspiracies leveled
against Newsome?
35. What relationship (if any) does the law firm
Baker Donelson Bearman Caldwell & Berko-
witz, its employees and clients have to United
States of America President Barack Obama
and his Administration?
viii

10. 36. What relationship (if any) does the law firm
Baker Donelson Bearman Caldwell & Berko-
witz, its employees and clients have to past
Presidents of the United States of America
and their Administration?
37. What relationship (if any) does the law firm
Baker Donelson Bearman Caldwell & Berko-
witz, its employees and clients have to offi-
cials/employees in the United States of Ameri-
ca Senate and United States of America House
of Representatives?
38. What relationship (if any) does the law firm
Baker Donelson Bearman Caldwell & Berko-
witz, its employees and clients have in the ap-
pointment of judges/justices to the courts?
39. What role (if any) did the law firm Baker Do-
nelson Bearman Caldwell & Berkowitz, its
employees and clients have in the handling of
criminal/civil complaints Newsome filed with
the United States Department of Justice – i.e.
based on relationship and KEY position(s)
held with the Commission on Civil Rights
[Chairman, etc.] which serve as a national
clearinghouse for information in respect to
discrimination or denial of equal protection of
the laws; submitting reports, findings and rec-
ommendations to the President and Congress;
and issuing public service announcements to
discourage discrimination or denial of equal
protection of the laws . . . served as Chief
Counsel to the U.S. House Judiciary Commit-
tee's Subcommittee on the Constitution, which
responsibilities included advising the Chair-
man and Republican Members of the Judiciary
ix

11. Committee on legislation and Congressional
oversight implicating civil and constitutional
rights, Congressional authority, separation of
powers, proposed constitutional amendments
and oversight of the Civil Rights Division of
the Department of Justice and the U.S. Com-
mission on Civil Rights [see for instance AP-
PENDIX DOCUMENTS CHART (“APPX
CHT”) No. “9” – Baker Doneslon information
regarding Bradley S. Clanton]
40. What role (if any) did Baker Donelson Bear-
man Caldwell & Berkowitz, its employees, its
clients and the United States Department of
Justice play in the COVER-UP of crimi-
nal/civil violations leveled against Newsome
reported on or about September 17, 2004 in
“Petitioner's Petition Seeking Interven-
tion/Participation of the United States De-
partment of Justice” - i.e. styled "VOGEL
DENISE NEWSOME vs. ENTERGY SER-
VICES, INC." [see APPIX “8”] in which New-
some timely, properly and adequately reported
the criminal/civil violations of Baker Donelson
Bearman Caldwell & Berkowitz, Judge G.
Thomas Porteous Jr. and others – to no avail.
41. Whether the IMPEACHMENT of Judge G.
Thomas Porteous, Jr. (i.e. having role as pre-
siding judge in lawsuit involving Newsome) on
or about December 8, 2010 [see APPX CHT
No. “10” – Article “Senate Removes Federal
Judge in Impeachment Conviction” incorpo-
rated herein by reference], is perti-
nent/relevant to this instant lawsuit.
42. What role (if any) did Baker Donelson Bear-
man Caldwell & Berkowitz, its employees, its
x

12. clients, others and the United States Depart-
ment of Justice play in the COVER-UP of
criminal/civil violations leveled against New-
some reported on or about September 24, 2004
in “Request for Department of Justice's Inter-
vention/ Participation in this Case” - i.e. refer-
encing "Newsome v. Mitchell McNutt & Sams
P.A." [See APPX CHT No. “11”] in which New-
some timely, properly and adequately reported
the criminal/civil violations of Mitchell McNutt
& Sams – to no avail.
43. Whether the INDICTMENT of Judge Bobby
DeLaughter [i.e. having a role as presiding
judge in lawsuit involving Newsome] on or
about January 6, 2009, and his pleading
GUILTY on or about July 30, 2009, is perti-
nent and/or relevant to this instant lawsuit.
44. Whether Baker Donelson Bearman Caldwell &
Berkowitz, its employees and clients have an
interest in the outcome of this lawsuit. If so,
whether the Supreme Court of the United
States is aware of said knowledge and/or in-
formation.
45. Whether attorneys and their client(s) are al-
lowed to engage in criminal and civil wrongs
for purposes of obstructing the administration
of justice.
46. Whether the EXTRAORDINARY and EX-
CEPTIONAL circumstances surrounding this
lawsuit supports the establishment of special
court(s) to litigate matters. Whether the
SPECIAL relationships of Judges/Justices to
opposing party(s) in litigation involving New-
some warrant the creation of special court(s) to
xi

13. afford Newsome rights secured and guaran-
teed under the United States Constitution and
laws of the United States – i.e. equal protec-
tion of the laws, equal privileges and immuni-
ties of the laws and due process of laws.
47. Whether attorneys and their client(s) are al-
lowed to engage in criminal and civil wrongs
for purposes of obstructing the administration
of justice.
48. Whether the EXTRAORDINARY and EX-
CEPTIONAL circumstances surrounding this
lawsuit supports the establishment of special
court(s) to litigate matters. Whether the
SPECIAL relationships of Judges/Justices to
opposing party(s) in litigation involving New-
some warrant the creation of special court(s) to
afford Newsome rights secured and guaran-
teed under the United States Constitution and
laws of the United States – i.e. equal protec-
tion of the laws, equal privileges and immuni-
ties of the laws and due process of laws.
xii

14. II. 2LIST OF PARTIES
All parties appear in the caption of the case on the
cover page and the following is the contact information for
each of their counsel/representative of record:
Honorable Tom S. Lee – Judge
J. T. Noblin – Clerk
USDC-Southern District Mississippi (Jackson)
501 E. Court Street – Suite 2.500
Jackson, Mississippi 39201
PHELPS DUNBAR LLP
c/o W. Thomas Siler, Jr., Esq.
Jason T. Marsh, Esq.
4270 I-55 North
Jackson, Mississippi 39211-6391
Post Office Box 16114
Jackson, Mississippi 39236-6114
At all times relevant to this instant action, Respond-
ent Does 1 through 100 served in respective positions with
their employer and/or in their individual capacity. New-
some is ignorant of the true names and capacities of Does 1
through 100, inclusive, and therefore sue these Respond-
ents by such fictitious names. Newsome is informed and
believes and thereon alleges that Respondent Does so
named (and/or to be named) is responsible and/or partici-
2 BOLDFACE, ITALICS, UNDERLINE, CAPS, etc. of text in this Peti-
tion is for purposes of emphasis.
xiii

15. pated in the conspiracy(s)3 against Newsome and in such
manner is responsible for the injuries and damages suf-
fered by Newsome as set forth in this instant pleading.
Newsome will amend Petition(s) for: ORIGINAL WRIT –
WRIT OF MANDAMUS – WRIT OF PROHIBITION – WRIT OF CON-
SPIRACY – WRIT OF EXIGI FACIAS - WRIT OF INJUNCTION -
WRIT OF MANDAMUS - WRIT OF REVIEW - WRIT OF SUPER-
SEDEAS - WRIT OF SUPERVISORY CONTROL - WRIT OF SECURI-
TATE PACIS - EXTRATERRITORIAL WRITS (“OW-WOM, ET AL”)
to state the true names and capacities of Respondents Does
1 through 100, inclusive, when they have been identified
and/or ascertained. Due to the extraordinary circumstanc-
es and scope of CONSPIRACIES leveled against Newsome
at the time of the filing of this “OW-WOM, ET AL,” she is
ignorant of the names and capacities of Respondent Does –
i.e. believing that during the course of litigation of this mat-
ter and/or investigation by this Court into this matter, the
identity(s) of Respondent Does may become known. By en-
gaging in the conduct described in this “OW-WOM, ET AL”
Respondent Does acted under the course and scope of their
employment with their respective employer as well as may
have acted within their individual capacity. By engaging in
the discriminatory conduct described in this “OW-WOM, ET
AL,” Respondent Does exceeded the authority vested in
them as an employee of their respective employer and
committed acts of a personal nature, personal bias and/or
for personal and financial interest and gain.
3 Respondent (conspirator) becomes the agent of the other conspirator
(s), and any act done by one of the combination is regarded under the law as the
act of both or all. In other words, what one does, if there is this combination,
becomes the act of both or all of them, no matter which individual may have
done it. This is true as to each member of the conspiracy, even those whose
involvement was limited to a minor role in the unlawful transaction, and it
makes no difference whether or not such individual shared in the profits of the
actions. (Am. Jur. Pleading and Practice Forms, Conspiracy § 9).
xiv

16. III. TABLE OF CONTENTS
I. QUESTIONS PRESENTED FOR REVIEW ..........................i
II. LIST OF PARTIES .............................................................. xiii
III. TABLE OF CONTENTS ...................................................... xv
IV. INDEX TO APPENDICES ................................................. xvi
V. TABLE OF AUTHORITIES ............................................ xxiii
VI. CONCISE STATEMENT OF JURISDICTION ................ 1
VII. CONSTITUTIONAL PROVISIONS, TREATIES,
STATUTES, ORDINANCES and REGULATIONS
INVOLVED IN CASE ........................................................................ 6
VIII. CONCISE STATEMENT OF THE CASE ...................... 7
IX. REASONS FOR GRANTING THE PETITION .............. 12
X. CONCLUSION and RELIEF SOUGHT ........................... 79
XI. CERTIFICATE OF SERVICE ............................................ 80
XII. APPENDIX ............................................................................... 1
NOTICE OF FILING ........................................................................ 12
OF AN “ORIGINAL” ACTION/APPEAL IN THE ...................... 12
SUPREME COURT OF THE UNITED STATES ...................... 12
WHEREFORE, PREMISES CONSIDERED, please docket
this instant NOTICE OF FILING OF AN “ORIGINAL”
ACTION/APPEAL IN THE SUPREME COURT OF THE
UNITED STATES. ............................................................................ 20
PLAINTIFF’S REQUEST FOR CONFLICT OF INTEREST
INFORMATION, NOTICE OF OPPOSITION TO
MAGISTRATE JUDGE ASSIGNMENT; AND .......................... 21
NOTICE OF ADDRESS .................................................................. 21
VOGEL DENISE NEWSOME’S AFFIDAVIT OF ..................... 22
xv

17. DISQUALIFICATION OF JUDGE TOM S. LEE ..................... 22
IV. INDEX TO APPENDICES
In compliance with the Rules of the Supreme Court
of the United States and in good faith of mitigating costs
because Appendix is VOLUMINOUS, the documents that is
to be included in the JOINT APPENDIX are provided at
APPENDIX “6” – Appendix Chart may be found at the fol-
lowing link as well:
https://secure.filesanywhere.com/fs/v.aspx?v=
8a72648b595e7377b06e
APPX DESCRIPTION
1 08/20/12 - Judgment DISMISSING Newsome’s
Complaint WITH prejudice
2 08/20/12 - Order DENYING Newsome’s Motion to
Disqualification and DEMAND for Jury Trial
3 08/20/12 - Memorandum Opinion GRANTING
Named Defendants’ Motion to Dismiss for “failure
to state a claim”
4 09/20/12 – Notice of Filing of an “ORIGINAL” Ac-
tion/Appeal in the Supreme Court of the United
States
5 Affidavit of DISQUALIFICATION [ONLY] and
Link for: OBJECTION(S) To August 2, 2012 Or-
der Of Judge Tom S. Lee; Motion For DISQUAL-
IFICATION; AND DEMAND FOR JURY TRIAL
xvi

18. (“OBJECTION(S) TO 08/02/12 ORDER”)
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b595e75bc719a
APPENDIX “6” – APPENDIX CHART CONTAINS THE FOLLOW-
ING:
NO.
6 DOCKET SHEET – Newsome v. Page Kruger &
Holland P.A., et al
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b595f6d7d6b9b
7 Recusal Orders by Tom S. Lee
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b595f6ea56c9c
8 Docket Sheet – Newsome v. Entergy
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b595f71b3b26a
9 Bradley S. Clanton – Baker Donelson Information
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b595f72ae9ca5
10 Judge G. Thomas Porteous Impeachment Articles
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b595f76ae9ca5
11 09/24/04 - Request for Department of Justice's In-
tervention/ Participation in this Case
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59606eb2a1aa
12 05/15/12 - Request for Conflict of Interest Infor-
mation, Notice of Opposition to Magistrate Judge
xvii

19. Assignment; and Notice of Address
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596070b8a6af
13 08/15/12 - OBJECTION(S) To August 2, 2012 Or-
der Of Judge Tom S. Lee; Motion For DISQUAL-
IFICATION; AND DEMAND FOR JURY TRIAL
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596075b96e97
14 07/17/12 - Motion to Strike Motion To Dismiss
and Memorandum In Support Of Motion To Dis-
miss; Motion for Rule 11 Sanctions of and Against
Defendants; and Motion for Default Judgment
(Jury Trial Demanded in this Action)
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59616dae9ca5
15 07/17/12 – Cover Letter to Court Filing
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59616ebca99b
16 07/30/12 - Motion to Strike Motion To Stay All
Proceedings Pending A ruling On Defendants’
Motion To Dismiss and Memorandum In Support
Of Motion To Stay All Proceedings Pending A
Ruling On Defendants’ Motion To Dismiss; Mo-
tion for Rule 11 Sanctions of and Against Defend-
ants; and Motion for Default Judgment (Jury Tri-
al Demanded in this Action)
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59616fb1a0a9
17 08/02/12 – Order GRANTING Motion to Stay
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596170afaf67
xviii

20. 18 08/14/12 - Motion to Strike Defendants’ Response
In Opposition To Plaintiff’s Motion To Strike Mo-
tion To Dismiss and Memorandum In Support Of
Motion To Dismiss; Motion To Strike Defendants’
Response In Opposition To Plaintiff’s Motion For
Rule 11 Sanctions Of And Against Defendants;
and Motion To Strike Defendants’ Response In
Opposition To Plaintiff’s Motion For Default
Judgment; Plaintiff’s Motion for Rule 11 Sanc-
tions of and Against Defendants; and Motion for
Default Judgment (Jury Trial Demanded in this
Action)
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b5961717d6c9b
19 Baker Donelson - Listing of Government Posi-
tions
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59617275ae6d
20 Baker Donelson – Listing of Government Posi-
tions (09/11/04)
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b5961747aa0a2
21 Baker Donelson’s Website Listing of Government
Positions
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596176b3a06b
22 07/18/11 – Newsome’s Letter to Supreme Court of
United States
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59626db3b36a
23 Conduct or Bias of Law Clerk or Other Judicial
Support Personnel As Warranting Recusal of
xix

21. FEDERAL Judge or Magistrate
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59626fb19fa8
24 DISQUALIFICATION of Supreme Court Justic-
es: The Certiorari Conundrum
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596270769c9e
25 HOOD vs. HOFFMAN-LAROCHE, LTD, District
of Columbia District Court, Case No. 1:06-cv-
01484
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596271bcaa69
26 Phelps Dunbar and Page Kruger & Holland Cli-
ent Listings:
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596272b19fa8
27 W. Lee Rawls Information
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596273bdac6a
28 President Barack Obama’s “Secret Kill List” Arti-
cle
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596275b8a7af
29 David Addington Information
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59636db6a4ad
30 28 USC § 1651
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59636eb2b169
xx

22. 31 Morrow v. District of Columbia
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596370a66ca8
32 Platt v. Minnesota Min. & Mfg. Co.
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596372b0af67
33 De Beers Consol. Mines v. U.S.
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596374aead67
34 Google Search Information Regarding Vogel
Newsome
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596375a76eaa
35 Adams v. U.S. ex rel. McCann
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596376bcab6a
36 Ex parte Milwaukee R. Co.
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59646ea66d9d
37 Platt v. Minnesota Min. & Mfg. Co.
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596471bead6c
38 Liljeberg v. Health Services Acquisition Corp.
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596474769c9e
39 COMPLAINT – Newsome v. Page Kruger & Hol-
land et al.
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596476759b9d
xxi

23. 40 Hare v. City of Corinth, Miss.
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59656fbba968
41 05/16/06 – TERMINATION Email (Page Kruger
& Holland)
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596571769c9e
42 Salinas v. U.S
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596573aa72a2
43 Porter v. Lee
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596574b5b46c
44 Heckler v. Ringer
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596576b96e99
45 U.S. ex rel. McLennan v. Wilbur
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59666fa8709f
46 U.S. v. Hoffman
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596671b0af67
47 La Buy v. Howes Leather Company
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59676d79b197
48 Fisher v. District Court of Sixteenth Judicial
Dist. of Montana, in and for Rosebud County
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
xxii

24. 2648b59676ea5a56c
V. TABLE OF AUTHORITIES
Adams v. U.S. ex rel. McCann, 63 S.Ct. 236 (1942) .................. 47
Albert v. R.P. Farnsworth & Co.,
176 F 2d 198 (5th Cir. 1949) ........................................................ 55
Aman v. Cort Furniture Rental Corp.,
85 F.3d 1074, 1081-82 (3rd Cir. 1996) ....................................... 26
Anderson v. McLaughlin, 263 F.2d 723 (1959)........................... 38
Andrade v. Chojnacki, 338 F.3d 448 (5th Cir. 2003) .................. 52
Archibeque v. Wylie, 16 F.3d 415,
1994 WL 41272, *3 (10th Cir.(N.M.)) ........................................... 56
Bagley v. Byrd, 534 U.S. 1301,
122 S.Ct. 419, 419-420, 151 L.Ed. 2d 370 (2001) ............. 41, 66
Baylis v. Travellers’ Ins. Co., 113 US 316,
28 L Ed 989, 5 S Ct 494 ............................................................... 54
Benjamin J. Shipman, Handbook of
Common-Law Pleading § 341, at 542
(Henry Winthorp Ballantine ed., 3d ed. 1923) ....................... 75
Bennett v. Schmidt, 153 F3d 516 (7th Cir. 1998) ....................... 53
Brown v. Gilmore, 533 U.S. 1301,
122 S.Ct. 1, 2-3, 150 L.Ed. 2d 782 (2001) ................................ 64
xxiii

25. Bryant v. Military Department of Mississippi,
597 F.3d 678 (5th Cir. Miss. 2010) ............................................. 61
Chessman v. Teets, 354 U.S. 156,
77 S.Ct. 1127, 1 L.Ed.2d 1253 (1957) ....................................... 44
Citizens United v Federal Election Commission,
558 U.S. 50 (2010) ........................................................................... v
Conduct or Bias of Law Clerk or
Other Judicial Support Personnel As
Warranting Recusal of FEDERAL Judge
or Magistrate.......................................................................xix, 16, 4
Connor v. Coleman, 440 U.S. 612, 624,
99 S.Ct. 1523, 59 L.Ed. 2d 619 (1979) .......................... 40, 65, 70
Cox v. C. H. Masland & Sons, Inc.,
607 F 2d 138 (5th Cir. 1979) ........................................................ 55
Davis v. Board of School Comm’rs,
517 F2d 1044 (5th Cir. 1975) ....................................................... 51
De Beers Consol. Mines v. U.S., 65 S.Ct. 1130,
325 U.S. 212, 89 L.Ed. 1566 (1945) ........................................... 39
DISQUALIFICATION of Supreme
Court Justices: The Certiorari Conundrum ............................ 17
Estate of Cole by Pardue v. Fromm,
94 F.3d 254, 260 (7th Cir.1996) ................................................. 56
Ex parte Fahey, 332 U.S. 258, 260,
67 S.Ct. 1558, 91 L.Ed. 2041 (1947) .............................. 36, 41, 66
Ex parte Harding, 219 U.S. 363, 374;
31 S.Ct. 324, 55 L.Ed. 252 (1911) ........................................ 41, 67
Ex parte Hung Hang, 108 U.S. 552, 553,
xxiv

26. 2 S.Ct. 863, 27 L.Ed. 811 (1883) .................................... 40, 65, 69
Ex parte Milwaukee R. Co., 72 U.S. 188 (1866) ......................... 48
Ex parte Siebold, 100 U.S. 371, 374,
25 L.Ed. 717 (1879) ........................................................... 40, 65, 69
Ex parte United States, 242 U.S. 27, 52,
37 S.Ct. 72, 61 L.Ed. 129 (1916) .................................... 40, 65, 70
Ex parte Young, 209 U.S. 123, 165,
28 S.Ct. 441, 52 L.Ed. 714 (1908) .................................... 1, 42, 67
Fisher v. District Court of Sixteenth
Judicial Dist. of Montana, in and for
Rosebud County, 96 S.Ct. 943 (1976) ....................................... 77
Gasperini v. Center for Humanities, Inc.,
518 U.S. 415, 116 S.Ct. 2211,
135 L.Ed.2d 659 (1996) (quoting Byrd v.
Blue Ridge Rural Elec. Cooperative, Inc.,
356 U.S. 525, 537, 78 S.Ct. 893, 901,
2 L.Ed.2d 953 (1958)) ................................................................... 57
Greason v. Kemp, 891 F.2d 829, 835 (11th Cir.1990) ............... 56
Hall v. Doering, 185 FRD 639 (1999) ........................................... 48
Hare v. City of Corinth, Miss., 949 F.Supp. 456
(N.D.Miss.E.Div.,1996) ................................................................ 55
Heckler v. Ringer, 104 S.Ct. 2013 (1984) .................................... 74
Hendrix v. City of Yazoo City, Miss.,
911 F.2d 1102 (5th Cir. Miss. 1990) ........................................... 59
Hodges v. Easton, 106 US 408, 16 Otto 408,
27 L Ed 169, 1 S Ct 307 ............................................................... 54
In re Aetna Casualty & Surety Co.,
xxv

27. 919 F2d 1136 (6th Cir. 1990) ....................................................... 51
In re McDonald, 489 U.S. 180, 109 S.Ct. 993 (1989)................. 43
In re Michael Sindram, 498 U.S. 177, 179,
111 S.Ct. 596, 112 L.Ed. 2d 599 (1991) .............................. 41, 66
In re Murchison, 75 S.Ct. 623 (1955) ............................................ 52
Ir re Parmalat Sec. Litig., 375 F.Supp. 2d 278 (2005) .............. 53
Kirk v. Simpson, 35 F.3d 566,
1994 WL 443461, *1 (6th Cir.(Tenn.)) ...................................... 56
La Buy v. Howes Leather Company,
77 S.Ct. 309 (U.S.,1957)............................................................... 76
Liljeberg v. Health Services Acquisition Corp.,
486 US 847, 100 L Ed 2d 855, 108 S Ct 2194 (1988) ............ 49
Lyon v. Mutual Ben. Health & Acci. Asso.,
305 US 484, 83 L Ed 303, 59 S Ct 297,
reh den (1939) 306 US 667 .......................................................... 54
Macklin v. Spector Freight Systems, Inc.,
478 F.2d 979 (1973) ...................................................................... 59
Marbury v. Madison, 5 U.S. (1 Cranch) 137, 147,
2 L.Ed. 60 (1803) ........................................................... 4, 40, 65, 69
McDonnell Douglas Corp. v. Green,
411 U.S. 792, 801 (1973) .............................................................. 26
MCullough v. Cosgrave, 309 U.S. 634, 635,
60 S.Ct. 703, 84 L.Ed. 992 (1940) .................................. 40, 65, 70
Miller v. Schoenen, 75 F.3d 1305, 1311 (8th Cir.1996) ............ 56
Mongelli v. Mongelli, 849 F.Supp. 215 (1994) ............................ 47
xxvi

28. Morrow v. District of Columbia, 417 F.Ed 728, 135 U.S.
App.Dc. 160 on remand 259 A.2d 592 (1969) .......................... 37
Parliament Ins. Co. v. Hanson,
676 F.2d 1069 (5th Cir. 1982) ...................................................... 52
Pennsylvania v. Wheeling Belmont Bridge Co.,
59 U.S. 421, 431, 15 L.Ed. 435 (1885) .......................... 40, 65, 69
Platt v. Minnesota Min. & Mfg. Co.,
84 S.Ct. 769, 376 U.S. 240, 11 L.Ed.2d 674 (1964) .......... 38, 48
Porter v. Lee, 66 S.Ct. 1096 (U.S.Ky.,1946) ................................ 73
Potashnick v. Port City Const. Co., 609 F.2d 1101 (1980) ....... 22
Randolph v. Lambert, 926 So.2d 941 (Miss.App.,2006) ........... 60
Reeside v. Walker, 52 U.S. 272 (1850) ......................................... 74
Roche v. Evaporated Milk Ass’n, 319 U.S.21, 25,
63 S.Ct. 938, 941, 87 L.Ed. 1185 ................................................ 39
Sable v. General Motors Corp., 90 F.3d 171 (1996) ................... 46
Salinas v. U.S., 118 S.Ct. 469 (1997) ............................................ 70
Stevens v. Lake, 615 So.2d 1177 (Miss.,1993) ............................ 60
Supervisors v. U.S., 85 U.S. 71 (1873) ......................................... 74
U.S. ex rel. McLennan v. Wilbur, 51 S.Ct. 502 (1931) .............. 74
U.S. v. Comstock, 130 S.Ct. 1949 (U.S.,2010) ............................ 77
U.S. v. Denedo, 129 S.Ct. 2213 ...................................................... 36
U.S. v. Hoffman, 71 U.S. 158 (1866) ............................................. 75
xxvii

29. U.S. v. International Broth. Of Teamsters,
Chauffeurs, Warehousemen and Helpers of
America, AFL-CIO, 911 F.Supp. 743 (1996) ........................... 46
U.S. v. New York Tel. Co., 98 S.Ct. 364,
434 U.S. 159, 54 L.Ed.2d 376 ..................................................... 46
U.S. v. Oregon State Medical Soc., 72 S.Ct. 690 (1952) ........... 72
U.S. v. Schaffer, 586 F.3d 414 (C.A.6.Ohio,2009) ...................... 71
United States v. Brown, 539 F2d 467 (5th Cir. 1976) ................ 50
United States v. IBM Corp.,
475 F.Supp. 1372 affd 618 F2d 923 (2nd Cir. 1980) ............... 50
Wagner, Original Jurisdiction of
National Supreme Courts,
33 St. John’s L. Rev. 217 (1959) ..................................... 40, 65, 69
Walden's Lessee v. Craig's Heirs,
39 U.S. 147 (U.S.Ky.,1840) ......................................................... 72
Wayman v. Southard, 23 U.S. 1 (U.S.Ky.,1825) ........................ 72
Weber v. Henderson, 275 F.Supp.2d 616 (2003) ........................ 43
Will v. United States, 389 U.S. 90, 95,
88 S.Ct. 269, 19 L.Ed. 305 (1967) ........................................ 41, 66
Winters v. AmSouth Bank,
964 So.2d 595 (Miss.App.,2007) ................................................. 60
Wisconsin Right to Life, Inc. v.
Federal Election Comm’n., 542 U.S. 1305,
125 S.Ct. 2, 159 L.Ed. 2d 805, 807 (2004).......................... 37, 64
Wisconsin v. Pelican Ins. Co., 127 US 265,
32 L Ed 239, 8 S Ct. 1370 (1888) (ovrld in part
on other grounds by Milwaukee County v
xxviii

30. M.E. White Co. (1935) 296 US 268,
80 L Ed 220, 56 S. Ct. 229)) ........................................................ 78
Woodard v. Atlantic C.L. R. , 57 F 2d 1019 (5th Cir. 1932). ..... 55
WW, Inc. v. Rainbow Casino-Vicksburg
Partnership, L.P., 2011 WL 4037024 (Miss. 2011) ................ 61
Zuber v. Allen, 90 S.Ct. 314 (1969) ............................................... 76
Statutes
28 U.S.C. § 455 ...................................................................... 22, 23, 24
28 U.S.C. § 1251 .................................................................................. 3
28 U.S.C. § 1257 ...................................................................... 3, 77, 78
28 U.S.C. § 1651 .............................................................. 35, 40, 64, 65
42 U.S.C.A. § 1981 ............................................................................ 60
28 U. S. C. § 2403 ............................................................................ 5, 6
80th Congress House Report No. 308 ............................................ 40
Vol. 22 Moore’s Federal Practice, § 400.04
Supervisory Authority of Supreme Court
Over Inferior Federal Courts ....................................................... 5
§ 402.02 Article III Jurisdiction and Its Limitations .................. 4
___ , § 520.02 Considerations Governing Issuance Of
Extraordinary Writ ....................................................................... 64
Vol. 23 Moore’s Federal Practice, § 520.02[2]
(Matthew Bender 3d ed.) ................................................. 41, 66, 70
80th Congress House Report No. 308 ............................................ 40
Other Authorities
Am. Jur. Pleading and Practice Forms,
Conspiracy § 9 ......................................................................... xiv, 70
xxix

31. Article III, § 2, United States Constitution................................... 4
H.R.Rep.No.93-1453, 93d Cong., 2d Sess. (1974),
Reprinted in 1974 U.S.Code Cong. & Admin.
News, pp. 6351, 6352-54 .............................................................. 23
Vol. 23 Moore’s Federal Practice, § 520.02
Considerations Governing Issuance Of
Extraordinary Writ ....................................................................... 64
Rules
Rule 14.1(e)(v) ...................................................................................... 6
Supreme Court of United States Rule 20 ...................................... 3
U.S. Supreme Court Rule 29(b) ....................................................... 5
United States Supreme Court Rule 17(1) ...................................... 3
United States Supreme Court Rule 20 .......................................... 3
United States Supreme Court Rule 29(b) ...................................... 5
xxx

32. VI. CONCISE STATEMENT OF JURISDICTION
Ex parte Young, 209 U.S. 123, 165, 28
S.Ct. 441, 52 L.Ed. 714 (1908) - [HN1]
The Supreme Court of the United States
will not take jurisdiction if it should not;
but it is equally true that it must take
jurisdiction if it should. The judiciary
cannot, as the legislature may, avoid a
measure because it approaches the con-
fines of the Constitution. The court
cannot pass it by because it is doubtful.
With whatever doubts, with whatever
difficulties, a case may be attended, the
court must decide it, if it is brought be-
fore it. The court has no more right to
decline the exercise of jurisdiction,
which is given, than to usurp that which
is not given. The one or the other would
be treason to the Constitution. Ques-
tions may occur which the court would
gladly avoid, but the court cannot avoid
them. All the court can do is to exercise
its best judgment, and conscientiously
perform its duty.
This is a matter that is birthed out of the United
States District Court – Southern District of Mississippi
(Jackson Division) denial of Newsome’s Affidavit of Dis-
qualification and DEMAND for JURY Trial on ALL issues
triable by jury. Because of the EXTRAORDINARY and
EXCEPTIONAL circumstances surrounding this matter,
Newsome seeks the Supreme Court of the United States’
(“U.S. Supreme Court”) Original Jurisdiction through Ex-
traordinary Writ(s) Newsome believes that the role of a sit-
ting United States President (Barack H. Obama), his legal

33. Page 2 of 80
counsel/advisor Baker Donelson Bearman Caldwell &
Berkowitz (“Baker Donelson”), his Administration as well
as his SPECIAL INTEREST Groups’, Lobbyists’, etc. role in
the lower courts’ actions (which are clearly prohibited by
law) supports the extraordinary and exceptional circum-
stances which exist warranting the relief sought through
Extraordinary Writ(s) and/or applicable action the U.S. Su-
preme Court deems appropriate. In further support of said
Court’s Original Jurisdiction, Newsome states:
a. On or about May 15, 2012, Newsome’s Com-
plaint (i.e. with TIMELY JURY DEMAND)
styled, Vogel Denise Newsome v. Page Kruger
& Holland P.A., et al., Civil Action No. 3:12-cv-
00342 was filed in the United States District
Court – Southern District of Mississippi (Jack-
son Division). See APPX CHT No. “6” – Dock-
et Sheet at No. 1 incorporated herein by refer-
ence as if set forth in full herein.
b. On or about May 15, 2012, a TIMELY plead-
ing entitled, “Request for Conflict of Interest
Information, Notice of Opposition to Magis-
trate Judge Assignment; and Notice of Ad-
dress.” See APPX CHT No. “12” incorporated
by reference as if set forth in full herein. Low-
er Court FAILED to address the ALL issues
raised therein.
c. On or about August 15, 2012, Newsome’s
pleading entitled, “OBJECTION(S) To August
2, 2012 Order Of Judge Tom S. Lee; Motion
For DISQUALIFICATION; AND DEMAND
FOR JURY TRIAL” was filed in the lower
court. See APPX CHT No. “13” incorporated
herein by reference as if set forth in full here-
in.

34. Page 3 of 80
d. Because of the EXTRAORDINARY and EX-
CEPTIONAL circumstances surrounding this
action, pursuant to Rule 17 – Procedure in an
Original Action - of the U.S. Supreme Court,
“A petition for an extraordinary writ in aid of
the Court’s appellate jurisdiction shall be filed
as provided in Rule 20” of this Court.
e. Pursuant to U.S. Supreme Court Rule 20 –
Procedure on a Petition for an Extraordinary
Writ – issuance by the Court of an extraordi-
nary writ is authorized by 28 USC § 1651(a).
f. The jurisdiction of the U.S. Supreme Court is
invoked under 28 U.S.C. § 1257(a).
g. The jurisdiction of the U.S. Supreme Court is
invoked under 28 U.S.C. § 1251 – Original Ju-
risdiction:
(a) The Supreme Court shall have
original and exclusive jurisdiction
of all controversies between two
or more states. . . .
h. Jurisdiction is invoked under U.S. Supreme
Court Rule 17(1) – Procedure in an Original
Action:
This Rule applies only to an ac-
tion invoking the Court's original
jurisdiction under Article III of
the Constitution of the United
States. See also 28 U. S. C. §1251
and U. S. Const., Amdt. 11. A pe-
tition for an extraordinary writ in
aid of the Court's appellate juris-

35. Page 4 of 80
diction shall be filed as provided
in Rule 20.
i. The jurisdiction of this Court is further in-
voked pursuant to Article III, § 2, United
States Constitution - - Section 2: The judicial
Power shall extend to all Cases, in Law and
Equity, arising under this Constitution, the
Laws of the United States, and Treaties made,
or which shall be made, under their Authority
...
§ 402.02 Article III Jurisdiction and Its Limi-
tations
[1] – Original Jurisdiction of Supreme Court
Under Article III
[a] Nature of Original Jurisdiction:
The Supreme Court is generally a source of
appellate review, but it can act as a trial
court in certain instances. Original juris-
diction means the following, as Justice
Marshall explained in Marbury v. Madison;
5 U.S. (1 Cranch) 137, 174, 2 L.Ed. 60
(1803):
[The Court has] the power to
hear and decide a lawsuit in the
first instance . . . [A]ppellate ju-
risdiction means the authority
to review the judgment of an-
other court which has already
heard the lawsuit in the first
instance. Trial courts are
courts that exercise original ju-
risdiction; courts of appeals. . .

36. Page 5 of 80
exercise appellate jurisdiction.
Id.
Article III of the U.S. Constitution pre-
scribes the Supreme Court’s original ju-
risdiction (See U.S. Constitution, Article
III, § 2 cl. 2). Under the first clause of
Section 2 of Article III, federal courts
have jurisdiction over the following: [A]ll
Cases, in Law and Equity, arising under
this Constitution, the Laws of the United
States, and Treaties made, or which shall
be made, under their Authority.
j. Vol. 22 Moore’s Federal Practice, § 400.04 Su-
pervisory Authority of Supreme Court Over
Inferior Federal Courts
[1] SUPREME COURT HAS EXTENSIVE RULEMAK-
ING POWER: The Supreme Court has powers
beyond its duty to entertain cases within its
original and appellate jurisdiction. The Court
has extensive power to prescribe rules of prac-
tice and procedure for civil actions. . . The Su-
preme Court, of course, has the power to
promulgate rules governing practice and pro-
cedure before itself, and has done so.
k. Pursuant the U.S. Supreme Court Rule 29(b),
28 USC § 2403(a) may apply.4
4 U.S. Supreme Court Rule 29(b): In any proceeding in this Court in
which the constitutionality of an Act of Congress is drawn into question, and
neither the United States nor any federal department, office, agency, officer, or
employee is a party, the initial document filed in this Court shall recite that 28
U. S. C. § 2403(a) may apply and shall be served on the Solicitor General of the
United States, Room 5614, Department of Justice, 950 Pennsylvania Ave., N.
W., Washington, DC 20530-0001. In such a proceeding from any court of the
United States, as defined by 28 U. S. C. § 451, the initial document also shall
state whether that court, pursuant to 28 U. S. C. § 2403(a), certified to the At-

37. Page 6 of 80
l. The following statute may further apply: 28
USC §2403 - Intervention by United States or
a State; Constitutional Question: (a) In any
action, suit or proceeding in a court of the
United States to which the United States or
any agency, officer or employee thereof is not a
party, wherein the constitutionality of any Act
of Congress affecting the public interest is
drawn in question, the court shall certify such
fact to the Attorney General, and shall permit
the United States to intervene for presentation
of evidence, if evidence is otherwise admissible
in the case, and for argument on the question
of constitutionality. The United States shall,
subject to the applicable provisions of law,
have all the rights of a party and be subject to
all liabilities of a party as to court costs to the
extent necessary for a proper presentation of
the facts and law relating to the question of
constitutionality.
VII. CONSTITUTIONAL PROVISIONS, TREATIES,
STATUTES, ORDINANCES and REGULATIONS
INVOLVED IN CASE
CONSTITUTION:
a. United States Constitution
b. United States Constitution –
Amendments 1, 7, 13 through 15
c. Article III, § 2, United States
Constitution
torney General the fact that the constitutionality of an Act of Congress was
drawn into question. See Rule 14.1(e)(v).

38. Page 7 of 80
STATUTES:
d. 28 USC § 144 -Bias or prejudice of
judge
e. 28 USC § 455 - Disqualification of
justice, judge, or magistrate judge
f. 28 USC § 1651 - Writs
g. 28 USC § 1915 - Proceedings in
forma pauperis
h. 28 USC § 1257 - State courts; certi-
orari
i. 42 USC § 1983 - Civil action for
deprivation of rights
j. 42 USC § 1985 - Conspiracy to in-
terfere with civil rights
k. 42 USC § 1986 - Action for neglect
to prevent 5
VIII. CONCISE STATEMENT OF THE CASE
(1) On or about May 15, 2012, Newsome’s Com-
plaint styled, Vogel Denise Newsome v. Page
Kruger & Holland P.A., et al., Civil Action No.
3:12-cv-00342 was filed in the United States
District Court – Southern District of Missis-
sippi (Jackson Division). See APPX CHT No.
5 Every person who, having knowledge that any of the wrongs con-
spired to be done, and mentioned in section 1985 of this title, are about to be
committed, and having power to prevent or aid in preventing the commission of
the same, neglects or refuses so to do, if such wrongful act be committed, shall
be liable to the party injured, or his legal representatives, for all damages
caused by such wrongful act, which such person by reasonable diligence could
have prevented; and such damages may be recovered in an action on the case;
and any number of persons guilty of such wrongful neglect or refusal may be
joined as defendants in the action; . . .

39. Page 8 of 80
“6” – Docket Sheet at No. 1 incorporated here-
in by reference as if set forth in full herein.
(2) On or about May 15, 2012, the lower court
filed Newsom’e pleading entitled, “Request for
Conflict of Interest Information, Notice of Op-
position to Magistrate Judge Assignment; and
Notice of Address” See APPX CHT No. “12” in-
corporated herein by reference as if set forth in
full herein.
(3) On or about July 5, 2012, lower court Defend-
ants (Page Kruger & Holland P.A., Thomas Y.
Page, Louis G. Baine III, Linda Thomas
[“Named Defendants”]) submitted for filing
their pleadings entitled, “Motion To Dismiss”
and “Memorandum In Support Of Motion To
Dismiss.” See APPX CHT No. "6” at Docket
Nos. 5 and 6.
(4) On or about July 16, 2012, in FURTHER
ABUSE of the lower court’s electronic filing
system Named Defendants filed pleadings en-
titled, “Motion to Stay All Proceedings Pend-
ing a Ruling on Defendants’ Motion to Dis-
miss” and “Memorandum in Support of Motion
to Stay All Proceedings Pending a Ruling on
Defendants’ Motion to Dismiss.” See APPX
CHT No. “6” – Doc. Nos. 9 and 10 respectively.
(5) On or about July 17, 2012, Newsome’s plead-
ing entitled, “Motion to Strike Motion To Dis-
miss and Memorandum In Support Of Motion
To Dismiss; Motion for Rule 11 Sanctions of
and Against Defendants; and Motion for De-
fault Judgment (Jury Trial Demanded in this
Action)” was filed with the lower court. See

40. Page 9 of 80
APPX CHT No. “14” incorporated herein by
reference as if set forth in full herein.
(6) On or about July 17, 2012, the lower court
filed a copy of Newsome’s cover letter which
addresses the PUBLIC/GLOBAL/INTER-
NATIONAL interests in documents posted in
SOCIAL Forums by her. See APPX CHT No.
“15” incorporated herein by reference as if set
forth in full herein.
(7) On or about July 30, 2012, Newsome’s plead-
ing entitled, Motion to Strike Motion To Stay
All Proceedings Pending A ruling On Defend-
ants’ Motion To Dismiss and Memorandum In
Support Of Motion To Stay All Proceedings
Pending A Ruling On Defendants’ Motion To
Dismiss; Motion for Rule 11 Sanctions of and
Against Defendants; and Motion for Default
Judgment (Jury Trial Demanded in this Ac-
tion) was filed in the lower court. See APPX
CHT No. “16” incorporated by reference as if
set forth in full herein.
(8) On or about August 2, 2012, Judge Tom S. Lee
entered Order GRANTING Named Defend-
ants’ Motion to Stay and DENYING New-
some’s Motion to Strike the Motion to Stay –
i.e. in which Newsome TIMELY demanded a
JURY TRIAL on issues raised. See APPX
CHT No. “17.”
(9) On or about August 14, 2012, Newsome’s
pleading entitled, Motion to Strike Defend-
ants’ Response In Opposition To Plaintiff’s
Motion To Strike Motion To Dismiss and
Memorandum In Support Of Motion To Dis-
miss; Motion To Strike Defendants’ Response

41. Page 10 of 80
In Opposition To Plaintiff’s Motion For Rule
11 Sanctions Of And Against Defendants; and
Motion To Strike Defendants’ Response In
Opposition To Plaintiff’s Motion For Default
Judgment; Plaintiff’s Motion for Rule 11 Sanc-
tions of and Against Defendants; and Motion
for Default Judgment (Jury Trial Demanded
in this Action) was filed in the lower court.
See APPX CHT No. “18” incorporated herein
by reference as if set forth in full herein.
(10) On or about August 15, 2012, Newsome’s
pleading entitled, “OBJECTION(S) To August
2, 2012 Order Of Judge Tom S. Lee; Motion
For DISQUALIFICATION; AND DEMAND
FOR JURY TRIAL” was filed in the lower
court. See APPX CHT No. “5” incorporated
herein by reference as if set forth in full here-
in.
(11) On or about August 20, 2012, Judge Tom S.
Lee entered ORDER DENYING Newsome’s
Motion to Disqualification and DEMAND for
Jury Trial. See APPX “2.”
(12) On or about August 20, 2012, Judge Tom S.
Lee entered Memorandum Opinion GRANT-
ING Named Defendants’ Motion to Dismiss for
“failure to state a claim” - defense based on
42 USC § 1983 claims when NO such claim(s)
under § 1983 is raised at all in Newsome’s
Complaint [EMPHASIS ADDED] - and
DENYING Newsome’s Motion to Strike Mo-
tion to Dismiss. See APPX “3.”
(13) On or about August 20, 2012, Judge Tom S.
Lee entered Judgment DISMISSING New-

42. Page 11 of 80
some’s Complaint WITH prejudice. See APPX
“1.”
(14) On or about September 20, 2012, Newsome’s
pleading entitled; “Notice of Filing of an
“ORIGINAL” Action/Appeal in the Supreme
Court of the United States” was filed in the
lower court. See APPX “4” incorporated herein
by reference as if set forth in full herein.
This is a matter that involves a sitting United States of
America President (Barack H. Obama)/his Administra-
tion/his Legal Counsel (Baker Donelson Bearman Caldwell
& Berkowitz) and their SPECIAL Interest Groups who all
have interests (i.e. financial/personal) in the outcome of this
lawsuit. This is a matter of EXTRAORDINARY and EX-
CEPTIONAL circumstances in which Newsome is not
aware whether the Supreme Court of the United States has
seen anything like it. In preservation of rights secured to
Newsome under the United States of America Constitution,
Laws of the United States of America (“United States”) and
other governing statutes/laws, she submits her Petition(s)
for: ORIGINAL WRIT – WRIT OF MANDAMUS – WRIT OF PRO-
HIBITION – WRIT OF CONSPIRACY – WRIT OF EXIGI FACIAS -
WRIT OF INJUNCTION - WRIT OF MANDAMUS - WRIT OF RE-
VIEW - WRIT OF SUPERSEDEAS - WRIT OF SUPERVISORY CON-
TROL - WRIT OF SECURITATE PACIS - EXTRATERRITORIAL
WRITS (hereinafter, “OW-WOM, ET AL”) and states the fol-
lowing in support thereof:
a. Also see facts set forth at Concise State-
ment of Jurisdiction above of this instant
pleading.

43. Page 12 of 80
IX. REASONS FOR GRANTING THE PETITION
A. CONFLICT OF INTEREST REQUEST:
Prior to addressing the reasons for granting the
“OW-WOM, ET AL,” Newsome, in the interest of justice as
well as for PUBLIC/WORLDWIDE interest, Newsome re-
quest that the U.S. Supreme Court Jus-
tice(s)/Administration advise her of whether or not “CON-
FLICT OF INTEREST” exists in the handling of this mat-
ter.
Newsome has obtained information which will sup-
port that Respondents engage in conspiracies with THIRD-
Parties - i.e. for instance, Baker Donelson Bearman Cald-
well & Berkowitz [“Baker Donelson”] who advertises its
SPECIAL relationships/ties to “highly distinguished indi-
viduals, people who have served as:”
 Chief of Staff to the President of the
United States
 United States Secretary of State
 United States Senate Majority Lead-
er
 Members of the United States Sen-
ate
 Members of the United States House
of Representatives
 Director of the Office of Foreign As-
sets Control for United States
 Department of Treasury
 Director of the Administrative Office
of the United States

44. Page 13 of 80
 Chief Counsel, Acting Director, and
Acting Deputy Director of United
States Citizenship & Immigration
Services within the United States
Department of Homeland Security
 Majority and Minority Staff Director
of the Senate Committee on Appro-
priations
 Member of United States President’s
Domestic Policy Council
 Counselor to the Deputy Secretary
for the United States Department of
HHS
 Chief of Staff of the Supreme Court
of the United States
 Administrative Assistant to the
Chief Justice of the United States
 Deputy under Secretary of Interna-
tional Trade for the United States
Department of Commerce
 Ambassador to Japan
 Ambassador to Turkey
 Ambassador to Saudi Arabia
 Ambassador to the Sultanate of
Oman
 Governor of Tennessee
 Governor of Mississippi
 Deputy Governor and Chief of Staff
for the Governor of Tennessee

45. Page 14 of 80
 Commissioner of Finance & Admin-
istration (Chief Operating Officer) -
State of Tennessee
 Special Counselor to the Governor of
Virginia
 United States Circuit Court of Ap-
peals Judge
 United States District Court Judges
 United States Attorneys
 Presidents of State and Local Bar
Associations
EMPHASIS ADDED in that this information is pertinent
to establish - “though not parties to original action . . .are
in position to frustrate implementation of court order or
proper administration of justice” - the CONSPIRACY and
PATTERN-OF-CRIMINAL/CIVIL wrongs leveled against
Newsome out of which this instant relief is sought. This
information was originally located at:
http://www.martindale.com/Baker-Donelson-
Bearman-Caldwell/law-firm-307399.htm
See APPX CHT No. “19” attached hereto and incorporated
by reference as if set forth in full herein. It is such infor-
mation which had been posted for several years. See AP-
PENDIX “20” of listing pulled approximately September 11,
2004. However, Baker Donelson moved SWIFTLY for
DAMAGE-CONTROL purposes and SCRUBBED this in-
formation from the Internet. It is a GOOD THING NEW-
SOME RETAINED HARD COPIES so that the PUB-
LIC/WORLD can see the COVER-UP and COWARDLY tac-
tics of one of the most Powerful Leaders (Barack
Obama)/Countries (United States) attempting to
HIDE/MASK their CRIMES/CIVIL WRONGS leveled
against Newsome, members of her class and/or citizens of

46. Page 15 of 80
the United States of America. From research, Baker Do-
nelson’s LISTING of GOVERNMENT positions
held/controlled may also be found on its website. See APPX
CHT No. “21.”
Newsome hereby DEMANDS that this Court advise
her of any/all CONFLICTS-Of-Interest that exist. CON-
FLICTS are MANDATORILY required to be made KNOWN
to Newsome as a matter of statutes/laws governing said
matters. It is a matter of PUBLIC/GLOBAL/ INTERNA-
TIONAL interests in that this Court is the HIGHEST
Court of the ONCE MOST powerful Country (United States
of America) in the World. The HIGHEST Court in which it
appears one has to be either CATHOLIC or JEWISH to be
appointed to the Bench – i.e. DISCIMINATORY and UN-
CONSTITUTIONAL practices in themselves. The United
States of America in which its CONGRESS (at the time of
this filing) consist of approximately an 100% ALL WHITE
Senate and approximately 90% ALL WHITE House of Rep-
resentatives as recent as the YEAR 2012!
The record evidence of this Court will support that
Newsome on or about July 18, 2011, demanded that the
Justices of the U.S. Supreme Court STEP DOWN, be RE-
MOVED and/or IMPEACHED:
PLEASE TAKE NOTICE: . . .Newsome's
REQUEST that ALL Justices of the United
States Supreme Court be IMMEDIATELY
REMOVED from the BENCH (by FRIDAY,
July 22, 2011) - i.e. IMPEACHED, or in ac-
cordance with the applicable laws governing
REMOVAL and/or IMPEACHMENT! While
such request(s) may be UNPRECEDENT it
is one of URGENT and NATIONAL SECU-
RITY; as well as in PUBLIC/WORLDWIDE
Interest that the Supreme Court of the Unit-
ed States be PURGED of such CRIMINALS

47. Page 16 of 80
so that JUSTICE may be rendered UNBIAS
and IMPARTIALLY - i.e. rather than
TAINTED with the likes of this Court's pre-
sent Judicial Panel.
PLEASE TAKE NOTICE: That the PUB-
LIC/WORLD would be better served and the
United States may be SPARED further EM-
BARRASSMENT (sic) and HUMILIA-
TION/DISGRACE/DISHONOR if the Justic-
es of this Court and those involved in the
CORRUPTION, COVER-UP of Criminal Civ-
il wrongs leveled against Newsome STEP
DOWN IMMEDIATELY!
See APPX CHT No. “22” attached hereto and incorporated
by reference as if set forth in full herein.
It appears this Court is FULLY AWARE and is al-
lowing its RELATIONSHIPS with Baker Donelson Bear-
man Caldwell & Berkowitz to CONTROL and MANIPU-
LATE “Supreme Court DECISIONS” through CRIMINAL
acts and practices. Moreover, the Justices and the Staff of
this Court are WILLING PARTICIPANTS in Baker Donel-
son’s CONSPIRACIES and CRIMINAL activities, and,
therefore, present CONFLICTS-Of-Interest warranting
RECUSAL. See APPX CHT No. “23” – Conduct or Bias of
Law Clerk or Other Judicial Support Personnel As War-
ranting Recusal of FEDERAL Judge or Magistrate (i.e.
which INCLUDE Justice(s) of the U.S. Supreme Court, at-
tached hereto and incorporated by reference as if set forth
in full herein. The Justices of this Court having
KNOWLEDGE that it is Baker Donelson’s ACCESS and
CONTROL of the EXECUTIVE Branch/White
House/United States of America Presidents and LEGISLA-
TIVE Branch/Congress/United States Senators as their Le-
gal Counsel/Advisor that led to their NOMINATION and
APPOINTMENT of Justices Baker Donelson wanted on

48. Page 17 of 80
this Court’s Bench for purposes of PROMOTING its and its
clients’ PERSONAL/BUSINESS!
During Newsome’s research on said matter(s), she
came across an article in the Minnesota Law Review enti-
tled, “DISQUALIFICATION of Supreme Court Justices:
The Certiorari Conundrum,” in which for instance, provide
an example:
. . .the recent nomination of Stephen
Breyer to the Supreme Court of the
United States raised the question of
his participation as a “name” in a
Lloyd’s of London insurance syndicate.
During the confirmation hearings,
Justice Breyer pledged that he would
not participate in any cases that im-
plicated Lloyd’s financial interests. As
a member of the Court, he has de-
clined to sit on cases involving Lloyd’s
either directly or indirectly. Other
nominees in less controversial circum-
stances have made similar disqualifi-
cation commitments. Since 1992,
there have been OVER 350 cases, peti-
tions, motions or applications in which
one or more Supreme Court Justices
“took NO part. . .”
at Page 659 See APPENDIX “24” – attached hereto and in-
corporated by reference as if set forth in full herein. Never-
theless, when Newsome comes before this Court, its Justic-
es CLEARLY having KNOWLEDGE of the CONFLICTS-
Of-Interest that exist FAIL to recuse themselves and pro-
ceed on to ENGAGE in CRIMINAL wrongdoing and ful-
filling their ROLES in Conspiracies to DEPRIVE Newsome
EQUAL protection of the laws, immunities and privileges

49. Page 18 of 80
and DUE PROCESS of laws secured/guaranteed under the
United States Constitution.
While Baker Donelson’s name may not appear as Le-
gal Counsel in this Lawsuit, PROVISIONS have been made
to add them and their Client(s) as a party when applicable
and upon receipt of DISCOVERY evidence which will pro-
vide additional evidence as to the ROLE it has played and
is playing in the CONSPIRACIES leveled against New-
some– and their INTERESTS in this instant lawsuit. Sable
v. General Motors Corp., 90 F.3d 171 (1996); U.S. v. New
York Tel. Co., 98 S.Ct. 364, 434 U.S. 159, 54 L.Ed.2d 376
and Mongelli v. Mongelli, 849 F.Supp. 215 (1994)
Under All Writs Act, federal courts
has authority to issue commands as
necessary to effectuate orders it has
previously issued and extends to per-
sons who were not parties to original
action but are in position to frustrate
implementation of court order.
Furthermore, Newsome’s RESEARCH has yielded infor-
mation wherein Baker Donelson engages in “TAG-TEAM
Litigation” – i.e. lawsuits in which Baker Donelson COW-
ARDLY SHIELDS/HIDES its role in lawsuits involving
Newsome by relying upon what are known as “FRONTING
Firms” wherein it SHARE Clients and interests of these
other Law Firms and SHARE in the expenses and PROF-
ITS from representation of clients for purposes of REMAIN-
ING UNDETECTED! In this instant “OW-WOM, ET AL”
the “FRONTING” law firm being used by Baker Donelson is
Phelps Dunbar LLP. For instance, see HOOD vs. HOFF-
MAN-LAROCHE, LTD, District of Columbia District Court,
Case No. 1:06-cv-01484 – APPENDIX “25” attached hereto
and incorporated by reference as if set forth in full herein –
where Baker Donelson TAG-TEAMS with Law Firms as
Butler Snow O’Mara Stevens & Cannada PLLC (“Butler

50. Page 19 of 80
Snow”) and Phelps Dunbar LLP (“Phelps Dunbar”). Of
course, like Baker Donelson, their associating law firms en-
joy sharing their CLIENT LISTINGS with the PUBLIC.
See for instance APPX CHT No. “26” – Phelp Dunbars List-
ing and that of Page Kruger & Holland attached hereto and
incorporated by reference as if set forth in full herein. List-
ing such clients as those provided in document at the fol-
lowing link:
https://secure.filesanywhere.com/fs/v.a
spx?v=8a72648b596272b19fa8
Information that is relevant in that it provides information
to further support RECUSAL and CONFLICT-OF-
INTEREST requests of Newsome. SUBSTANTIAL EVI-
DENCE is apparent through lawsuits in which Newsome
engages. For instance:
In Newsome vs. Mitchell
McNutt & Sams, Butler Snow at-
tempted to enter that lawsuit WITH-
OUT making an appearance. New-
some TIMELY, PROPERLY and AD-
EQUATELY objected to these CRIM-
INAL and CIVIL violations! To date
that lawsuit sits DORMANT as the
CRIMINAL CONSPIRACIES leveled
against Newsome ESCALATES!
Newsome believes that Baker Donel-
son is involved and merely using But-
ler Snow as a FRONTING Firm to
HIDE/SHIELD its ROLE and person-
al, business and financial INTER-
ESTS in lawsuit. This case is just sit-
ting DORMANT as Baker Donelson
and its CONSPIRATORS and
BRIBED/TAINTED and CORRUPT
Judge(s) OBSTRUCT the administra-
tion of justice and CONTINUE to en-

51. Page 20 of 80
gage in CRIMINAL and CIVIL viola-
tions leveled against Newsome.
www.slideshare.net/VogelDenise/0519
12-docket-sheet-mms
A lawsuit in which one of Phelp
Dunbar’s Employees (F. Keith Ball)
has been assigned as the Magistrate
Judge:www.slideshare.net/VogelDenis
e/071812-fax-to-phelps-dunbar-w-
thomas-siler-jr-jason-t-marsh This is a
lawsuit in which it appears Baker Do-
nelson had Magistrate Ball ABUSE
his Authority and WITHOUT Juris-
diction, etc. enter a NULL/VOID Or-
der STAYING the lawsuit. Now it ap-
pears a matter which may also have to
be brought before this Court as an
ORIGINAL action pursuant to Rules
17 and 20 of the Supreme Court of the
United States and other statutes/laws
governing said matters.
In Newsome vs. Page Kruger &
Holland, et al., Phelps Dunbar has ap-
peared as counsel and is acting as the
FRONTING Firm for Baker Donelson
and their personal, business and fi-
nancial INTERESTS. Judge Tom S.
Lee is assigned this matter. Judge
Lee appears on Baker Donelson’s
LISTING of Judges:
www.slideshare.net/VogelDenise/bake
r-donelson-ties-to-judgesjustices-as-
of120911-11566964

52. Page 21 of 80
As well as Baker Donelson appearing
on Judge Lee’s List of Law Firms RE-
QUIRING his recusal:
www.slideshare.net/VogelDenise/lee-
judge-recusal-orders-11574531
For instance, Newsome TIME-
LY, PROPERLY and ADEQUATELY
made her OBJECTIONS KNOWN in
the lower court. However, it appears
that as recent as August 20, 2012,
Judge Tom S. Lee too has ABUSED
his authority, USURPED jurisdiction
over this lawsuit in which he lacks
and, as a matter of law, is required to
RECUSE himself. Nevertheless,
Judge Tom S. Lee is ADAMANT about
staying in the lawsuit for CRIMINAL
intent and the FULFILLMENT of his
ROLE in the CONSPIRACIES leveled
against Newsome that CONTINUES
to date. A matter which is now being
brought before this Court as an ORIG-
INAL action pursuant to Rules 17 and
20 of the Supreme Court of the United
States and other statutes/laws govern-
ing said matters.
It appears this instant “OW-
WOM, ET AL” is before this Court be-
cause of the CONSPIRACIES and
CRIMINAL acts of Baker Donelson
and TOP/KEY Clients (i.e. as LIBER-
TY MUTUAL INSURANCE COMPA-
NY). It appears Baker Donelson
CONTROLS and RUN the entire JU-
DICIAL system. Moreover, engage in
CRIMINAL activities for purposes of

53. Page 22 of 80
obtaining decisions in their favor and
that of PARTNERING law firms as
PHELPS DUNBAR and their clients
(i.e. in this instant lawsuit Judge Tom
S. Lee, Named Defendants, etc.).
Wherefore, Newsome believes this request is made in
good faith in that the record evidence will support that in
approximately a one-year period, Judges and/or their Aides
associated in legal matters regarding Newsome have been
“INDICTED” and/or “IMPEACHED” – i.e for instance
Judge John Andrew West’s (Judge in the Hamilton County
Court of Common Pleas matter former Bailiff, Damon Rid-
ley, was found GUILTY for attempted bribery for taking
monies for purposes of getting cases dismissed as Judge
West and opposing parties in that action are attempting to
do without legal authority and cause).6 Furthermore, two
6 Potashnick v. Port City Const. Co., 609 F.2d 1101 (1980) - [n.4] A
judge faced with a potential ground for disqualification ought to consider how
his participation in a given case looks to the average person on the street; use of
the word “might” in statute was intended to indicate that disqualification
should follow if reasonable man, were he to know all the circumstances, would
harbor doubts about judge's impartiality. 28 U.S.C.A. § 455(a).
Our first ground for reversal results from the trial court
judge's failure to disqualify himself from participation in the proceeding before
him. . . . The parties do not allege that the judge exhibited any actual bias or
prejudice in the case; they assert only that under the circumstances his impar-
tiality might reasonably be questioned.
. . . The Applicable Statute
At the time this lawsuit was instituted, the . . . statute relating to judi-
cial disqualification provided:
*1108 Any justice or judge . . . shall
disqualify himself in any case in which he
has a substantial interest, . . . as to render it
improper, in his opinion, for him to sit on the
trial, appeal, or other proceeding therein.
28 U.S.C. § 455 (1970). While the case was pending, but prior to the
commencement of trial, 28 U.S.C. § 455 was amended to bring the statutory
grounds for disqualification of judges into conformity with the recently adopted

54. Page 23 of 80
other Judges (i.e. Judge Bobby DeLaughter was INDICTED
and pled GUILTY and Judge G. Thomas Porteous as of ap-
proximately December 8, 2010, has been IMPEACHED ac-
cording to proceedings before the United States Senate)
have been prosecuted for their unlawful/illegal practices.
All acts in which the United States Department of Justice
was fully aware of and clearly having knowledge of NEXUS
and/or relationship of Judge(s) in matters involving New-
some because she reported concerns of criminal/civil wrongs
by Judge(s) and/or their conspirators/co-conspirators (i.e. as
Baker Donelson). To no avail.
Court records will support for instance that New-
some had concerns regarding “conflict of interest” and re-
quested RECUSAL of Judge Tom S. Lee and Magistrate
Judge in Newsome vs. Melody Crews, et al; USDC South-
ern District of Mississippi (Jackson); Case No. 3:07-cv-
00099 (see Docket Nos. 110, 104 and 160) due to relation-
ship to opposing parties and/or their attorneys/attorneys’
law firms. To no avail. Then Newsome finds that Judge
Tom S. Lee (i.e. judge assigned her lawsuits) recused him-
self based upon his relationship to Baker Donelson; never-
theless FAILED to RECUSE in matters involving New-
some:
“Pursuant to 28 U.S.C. §455(a), the under-
signed is compelled to disqualify himself in
the above styled and numbered proceedings
for the reason that the law firm of Baker,
Donelson, Bearman, Caldwell & Berkowitz,
canon of the Code of Judicial Conduct [FN2] relating to disqualification of judges
for bias, prejudice, or conflict of interest. See H.R.Rep.No.93-1453, 93d Cong.,
2d Sess. (1974), Reprinted in 1974 U.S.Code Cong. & Admin.News, pp. 6351,
6352-54 (hereinafter cited as 1974 U.S.Code Cong. & Admin.News). . . .
FN2. Canon 3C of the Code of Judicial Conduct was
adopted by the Judicial Conference of the United
States in April, 1973.

55. Page 24 of 80
PC, counsel for the defendants, is on the
recusal list of the undersigned United States
district judge.
Accordingly, the undersigned does
hereby recuse himself in this cause.”
information which is of PUBLIC record and can be found
on the INTERNET and/or in court records for instance in
Joni B. Tyler, et al. vs. JPF1, LLC, et al.; Civil Action No.
3:09-cv-338 TSL-FKB (Recusal Order dated March 25,
2010); and Joyce Walker vs. Captain D’s LLC, et al., Civil
Action No. 3:09-cv-679 TSL-JCS (Recusal Order dated No-
vember 13, 2009); however, Judge Lee failed to recuse him-
self when presiding over said lawsuit with KNOWLEDGE
that Baker Donelson was and its client(s) were involved.
See APPX CHT No. “7” - Recusal Orders attached hereto
and incorporated by reference.
In the Newsome vs. Spring Lake Apartments, et al.
matter, Newsome TIMELY had this case PULLED and
submitted to the United States of America Congress for
handling. However, it appears that Baker Donelson is AL-
SO legal counsel for the LEGISLATIVE Branch/Congress
as well. See APPX CHT No. “19.” What a MESS!
Newsome further believes that a reasonable per-
son/mind may conclude that the assignments to the U.S.
Supreme Court of Justices Sonia Sotomayor and Elena Ka-
gen were recommended for appointment for vacancies
which arose with this Court by United States President
Barack Obama appears to have been done under the DI-
RECTION, LEADERSHIP and GUIDANCE of Baker Do-
nelson; therefore, leaving Newsome and/or a reasonable
person/mind with valid concerns whether the Justices of
this Court can remain impartial in deciding this matter.
Why are such FACTS and EVIDENCE relevant?

56. Page 25 of 80
MATTER OF PUBLIC IMPORTANCE: It
goes to the VALIDITY of U.S. Supreme
Court’s Decisions regarding the Health
Care Reform Bill (a/k/a ObamaCare) as
well as its decision in Citizens United v
Federal Election Commission, 558 U.S. 50
(2010) - in that these decisions as well as
any/all other decisions by the U.S. Supreme
Court may be NULL/VOID and properly
CHALLENGED due to such CRIMINAL
and UNETHICAL violations of the Justices
and the Administration of said Court.
Furthermore, it is FACTUAL evidence to
support just how TAINTED and CORRUPT
the JUDICIAL system has become and the
CONSTITUTIONAL and LEGAL rights of
Americans have been HEAVILY
BREACHED and/or COMPROMISED!
The Extraordinary Writs that Newsome seek to bring
will further provide additional facts, evidence and legal
conclusions to support matters such as the following which
are of PUBLIC/GLOBAL/INTERNATIONAL interests – i.e.
matters which will EXPOSE CRIMINAL Acts WORSE than
the U.S. President Richard Nixon “WATERGATE Scandal!”

57. Page 26 of 80
Conducting a Thorough Investigation7
Because discrimination often is subtle,
and there rarely is a “smoking gun,” [Fn.
45 - See Aman v. Cort Furniture Rental
Corp., 85 F.3d 1074, 1081-82 (3rd Cir.
1996)(“It has become easier to coat vari-
ous forms of discrimination with the ap-
pearance of propriety, or to ascribe some
other less odious intention to what is in
reality discriminatory behavior. In other
words, while discriminatory conduct per-
sists, violators have learned not to leave
the proverbial ‘smoking gun’ behind.”); cf.
McDonnell Douglas Corp. v. Green, 411
U.S. 792, 801 (1973). . .] determining
whether race played a role in the deci-
sionmaking requires examination of all of
the surrounding facts and circumstances.
The presence or absence of any one piece
of evidence often will not be determina-
tive. Sources of information can include
witness statements, including considera-
tion of their credibility; documents; direct
observation; and statistical evidence such
as EEO-1 data, among others . . .
Yes ObamaFraudGate is WORSE than the Richard Nixon
matter and it appears that President Barack Obama’s Le-
gal Counsel Baker Donelson is RIGHT-IN-THE-THICK of
the CRIMINAL and FRAUDULENT acts that have been
PERPETRATED on the Citizens of the United States of
America as well as those committed against Citizens of
Foreign Nations. It is time to FOLLOW the SMOKING
7
Taken from EEOC’s Compliance Manual Section 15: Race and Color Dis-
crimination

58. Page 27 of 80
GUN TRAIL left by Baker Donelson and its CONSPIRA-
TORS/CO-CONSPIRATORS:
(a) President Barack Obama “Birther Issue”
– i.e in which Baker Donelson advertises
position as Chief Counsel, Acting Direc-
tor, and Acting Deputy Director of United
States Citizenship & Immigration Ser-
vices within the United States Depart-
ment of Homeland Security
http://www.slideshare.net/VogelDenise/
devine-robert-chowobamagotcolb
http://www.slideshare.net/VogelDenise/
devine-robertbio-infocolb
WHAT DOES THIS
MEAN? That the last FOUR years of
President Barack Obama may have to be
ERASED from the HISTORY BOOKS.
ALL those bills that he allegedly signed
into law are VOID – MEANINGLESS!
That’s just HOW SCANDALOUS and
SERIOUS these criminal acts of Re-
spondents and their Conspirators/ Co-
Conspirators are.
(b) Alleged Killing/Murder of Osama Bin
Laden;
(c) United States Of America’s EXECUTIVE
Branch, LEGISLATIVE Branch and JU-
DICIAL Branch (U.S. Supreme Court) role
in the CRIMINAL acts, CORRUPTION and
COVER-UP of the September 11, 2001

59. Page 28 of 80
“DOMESTIC” Terrorist Attacks carried out
by CORRUPT Government Officials and
their counsel/advisor Baker Donelson and
its Conspirators/Coconspirators;
(d) Role United States of America President
Barack Obama and his Administration
with the advice of their Legal Coun-
sel/Advisor Baker Donelson appears to
have played in the recent attacks and
KILLING/MURDER of U.S. Ambassador
to Libya (Christopher Stevens) and three
others in that attack – i.e. and the at-
tempts by President Barack Obama and
Baker Donelson to COVER-UP their
crimes through the SPREADING and
PROMOTION of the “Muhammad Movie.”
(e) “Pattern-Of-Criminal/Murderous Sprees”
for this Court’s, the United States of
America’s CONGRESS and United States
of America’s WHITE HOUSE to act on
Complaints filed by Newsome in efforts of
COVERING UP Corrupt Government Of-
ficials and their Lawyers/Attorneys and
their CONSPIRATORS criminal and civil
violations leveled against Newsome as
well as other citizens here and abroad!
For instance, after Newsome’s October
2010 filing entitled, “Emergency Motion
to Stay; Emergency Motion for Enlarge-
ment of Time and Other Relief The Su-
preme Court of the United States Deems
Appropriate To Correct The Legal
Wrongs/Injustices Reported Herein,” in
the Stor-All Alfred v. Newsome matter, it
appears President Barack Obama, his
Administration (i.e. which includes Secre-

60. Page 29 of 80
tary of State Hillary Clinton) and their
Legal Counsel/Advisor Baker Donelson
moved SWIFTLY it appears to “CLEAN
HOUSE” of those individuals they be-
lieved to be a THREAT and EXPENDA-
BLE – i.e for instance:
On or about December 5, 2010
– W. Lee Rawls (Employee of
Baker Donelson, Chief of
Staff/Senior Counsel to Feder-
al Bureau of Investigation
Robert Mueller) – See APPX
CHT No. “27” W. Lee Rawls
information. Approximately
EIGHT days later;
(ii) On or about December 13,
2010 – Richard Holbrooke
(Special Envoy to Pakistan
and Afghanistan) who just co-
incidentally was in a meeting
with Secretary of State Hilla-
ry Clinton when this meeting
ENDED on a DEATH NOTE –
Approximately EIGHTEEN
days later;
http://www.slideshare.net/
Vo-
gelDenise/holbrookerichard
-deathmeeting-with-
hillary-clinton
(iii) On or about December 31,
2010 – John Wheeler III (U.S.
Military Expert who served
THREE Republican Presi-

61. Page 30 of 80
dents) who was
KILLED/MURDERED and
body dumped in a Waste
Landfill – Approximately
FOUR Months later;
http://www.slideshare.net
/VogelDenise/wheeler-
john-parsons-iii
(iv) On or about May 1, 2011, al-
leged KILLING/MURDER of
Osama Bin Laden; however,
NO PROOF to support
death/killing has been made
PUBLIC as required under
the Freedom of Information
Act (“FOIA”); however, this
instant lawsuit by Newsome
will provide the PUB-
LIC/WORLD with the long
sought after information re-
quested – Approximately ONE
Month later;
(v) On or about June 4, 2011,
Lawrence Eagleburger (Em-
ployee of Baker Donelson,
Secretary of State to U.S.
President George H.W. Bush,
Under Secretary of State to
U.S. President Ronald
Reagan, Member on the Board
of Directors for Halliburton) –
Approximately TWO Months
later;

62. Page 31 of 80
http://www.slideshare.net/
VogelDenise/lawrence-
eagleburger-wikipedia-
information
(vi) On or about August 6, 2011,
the KILLING/MURDER of
U.S. Navy Seals. It appears
members in the same Seal 6
Unit allegedly used to
kill/murder Osama Bin Laden.
Most likely Navy Seals
killed/murdered to SILENCE
them.
http://www.slideshare.net
/VogelDenise/navy-seal-
helicopter-down-080611
http://www.slideshare.net
/VogelDenise/navy-seal-
helicopter-shot-down-
080611
Who is the SECRETARY of
Navy? None other than
BAKER DONELSON’S em-
ployee Raymond Mabus;
http://www.slideshare.ne
t/VogelDenise/mabus-
raymondemploy-ties
http://www.slideshare.ne
t/VogelDenise/baker-
donelson-wikipedia-
information-
withraymondmabusinfo

63. Page 32 of 80
http://www.slideshare.ne
t/VogelDenise/baker-
donelson-wikipedia-info-
11566741
(vii) Now the recent killing/murder
of U.S. Ambassador to Libya
Christopher Stevens for what
appears to be a COVER-UP by
Secretary of State Hillary
Clinton, President Barack
Obama and their Legal Coun-
sel/Advisor Baker Donelson
for purposes of covering up
Hillary Clinton’s Interview
admitting to U.S. Wars being
implemented and the LEAV-
ING of U.S. STINGERS and
then LAUGHING about it:
http://www.slideshare.net
/VogelDenise/082112-
hillary-clinton-dealing-
with-the-united-states-of-
americas-stingers
http://youtu.be/6Yxrsfhs
MDc or
https://secure.filesanywh
ere.com/fs/v.aspx?v=8a71
648d60616ea970a0
for Middle Eastern Nations to
deal with and threatening
Sanctions if they don’t like it.
Secretary Hillary Clinton

64. Page 33 of 80
ADMITTING that she PER-
SONALLY sought to have
U.S. Ambassador Christopher
Stevens put in this position
and then despite “URGENT”
demands from Stevens regard-
ing the need for INCREASED
SECURITY, it appears Presi-
dent Barack Obama, Secre-
tary Hillary Clinton, their Le-
gal Counsel Baker Donelson
used such security request(s)
by Ambassador Stevens to
DISTRACT and OBSTRUCT
the EXPOSURE of their
CRIMINAL Acts and have
him placed on President
Barack Obama’s “SECRET
KILL LIST!” APPX CHT No.
“28” – Secret Kill List Article
attached hereto and incorpo-
rated by reference as if set
forth in full herein.
http://www.slideshare.net/
VogelDenise/obama-secret-
kill-list-13166139
These are only a FEW facts and EVIDENCE to support
that had this Court as well as the United States of Ameri-
ca’s CONGRESS and DEPARTMENT OF JUSTICE acted
on Newsome’s Complaints submitted for filing, such
WHITE SUPREMACIST/RACIST/TERRORIST Groups as
Baker Donelson, the September 11, 2001 attacks may have
been PREVENTED – i.e. in that according to INTERNET
postings regarding Newsome, this Court and other Gov-
ernment Branches began posting Newsome’s QUEST for
JUSTICE on the INTERNET for purposes of BLACKLIST-

65. Page 34 of 80
ING/BLACKBALLING her and to make her appear as a
LUNATIC, SERIAL LITIGATOR, CRAZY, PARANOID, etc.
The RECORD EVIDENCE of the U.S. Supreme
Court will further support that even PRIOR to the Septem-
ber 11, 2001 Attacks on the World Trade Center, through
Newsome’s pleadings involving Newsome vs. Entergy mat-
ter (in which Baker Donelson is opposing counsel), this
Court as well as other Courts and other Government Agen-
cies were TIMELY, PROPERLY and ADEQUATELY placed
on NOTICE of Baker Donelson’s HABITUAL criminal and
civil violations. Nevertheless, did NOTHING! Therefore,
as a DIRECT and PROXIMATE result Citizens of the Unit-
ed States of America as well as Foreign Nations and their
Citizens have suffered because this Court as well as other
United States Government Agencies (as CONGRESS and
the WHITE HOUSE) “DELIBERATELY” FAILED to act
because of their role in the CONSPIRACIES that led to the
September 11, 2001 World Trade Center Attacks and the
UNWARRANTED Wars in the Middle East.
IMPORTANT TO NOTE: A reasonable mind may
want to know exactly what are some of the positions Baker
Donelson’s employees held during the September 11, 2001
Attacks (911 Attacks). Well Newsome believes that it is of
PUBLIC/GLOBAL/INTERNATIONAL interest to EXPOSE
and share FACTS that while many were not far off as to
former U.S. Vice President Richard “Dick” Cheney’s RUN-
NING/CONTROLLING of the White House, it is of PUB-
LIC/GLOBAL/INTERNATIONAL interest to make known
that Baker Donelson’s employee David Addington (served
as Legal Counsel and Chief of Staff to U.S. Vice President
Dick Cheney) WAS WELL ROOTED in the White House
and appears to be the MASTERMIND behind the PLAN-
NING, ORCHESTRATING and CARRYING out of the 911
Attacks and the PUSH for the WARS in the Middle East.
David Addington according to some sources as “being the
MOST POWERFUL man you’ve NEVER heard of.” See

66. Page 35 of 80
APPIX “29” - Addington Articles attached hereto and incor-
porated by reference as if set forth in full herein.
As a matter of law, Newsome is required to make the
above concerns PUBLIC and to request DISCLOSURE by
the U.S. Supreme Court as to whether or not “Conflicts-of-
Interest” exists with its Justices and/or Court Administra-
tion in the handling of this instant action. Moreover, the
PUBLIC/WORLD has the right to know whether or not the
Supreme Court of the United States is being used to keep
the TRUTH behind ObamaFraudGate, the 9/11 attacks,
and other TERRORIST acts of CORRUPT government offi-
cials and their lawyers (i.e. as Baker Donelson) from COM-
ING-TO-LIGHT and being EXPOSED!
B. ALL WRITS ACT
This instant “OW-WOM, ET AL” has been brought
pursuant to 28 USC § 1651 and seeks any/all applicable re-
lief in accordance with the statutes/laws governing said
matters:
28 USC § 1651 Writs:
(a) The Supreme Court and all
courts established by Act of Congress
may issue ALL writs necessary or ap-
propriate in aid of their respective ju-
risdictions and agreeable to the usages
and principles of law.
Section 376 provided:
“. . . The Supreme Court. . .
shall have power to issue ALL writs
NOT specifically provided for by stat-
ute, which may be NECESSARY for
the exercise of their respective juris-

67. Page 36 of 80
dictions, and agreeable to the usages
and principles of law.”
See APPX CHT No. “30” attached hereto and
incorporated by reference as if set forth in full
herein (remaining phrase hereafter “attached
hereto . . .”).
Ex parte Fahey, 67 S.Ct. 1558 (1947) -
Supreme Court of the United States has
power to issue extraordinary writs . .
.but such remedies should be resorted to
only where appeal is clearly inadequate,
and they are reserved for really ex-
traordinary causes.
Black’s Law Dictionary (8th Edition):
All Writs Act – A federal statute that
gives the U.S. Supreme Court and all
courts established by Congress the pow-
er to issue writs in aid of their jurisdic-
tion and in conformity with the usages
and principles of law.
Black’s Law Dictionary – Second Pocket
Edition:
Writ: A court’s written order, in
the name of a state or other competent
legal authority, commanding the ad-
dressee to do or refrain from doing some
specified act.
Extraordinary Writ: A writ is-
sued by a court exercising unusual or
discretionary power.
U.S. v. Denedo, 129 S.Ct. 2213
(U.S.,2009) - Under the All Writs Act, a

68. Page 37 of 80
court's power to issue any form of relief,
extraordinary or otherwise, is contin-
gent on that court's subject-matter ju-
risdiction over the case or controversy.
28 U.S.C.A. § 1651(a).
Wisconsin Right to Life, Inc. v. Federal
Election Com'n, 125 S.Ct. 2 (U.S.,2004) -
Authority granted to courts under the
All Writs Act is to be used sparingly and
only in the most critical and exigent cir-
cumstances. (Per Chief Justice
Rehnquist, sitting as single Justice.) 28
U.S.C.A. § 1651(a).
. . .Authority granted to courts
under the All Writs Act is appropriately
exercised only: (1) when necessary or
appropriate in aid of court's jurisdiction;
and (2) when legal rights at issue are
indisputably clear. (Per Chief Justice
Rehnquist, sitting as single Justice.) 28
U.S.C.A. § 1651(a).
This instant action has been brought seeking the fil-
ing of ORIGINAL ACTION and issuance of EXTRAORDI-
NARY WRITS because of the extraordinary circumstances
sustained by the facts, evidence and legal conclusions pro-
vided in this “OW-WOM, ET AL” and the supporting Ap-
pendix – for purposes of confining the inferior courts and
Administrative Agency(s) addressed, to the lawful exercise
of their prescribed jurisdiction and to compel them to exer-
cise authority MANDATORILY required and GOVERNED
by statutes/laws.
Morrow v. District of Columbia, 417
F.Ed 728, 135 U.S. App.Dc. 160 on re-
mand 259 A.2d 592 (1969) – Among the
factors to be considered in determining

69. Page 38 of 80
whether prerogative writs should issue
are whether the matter is of “PUBLIC
IMPORTANCE,” whether the policy
against piecemeal appeals would be
frustrated, whether there has been a
WILLFUL disregard of legislative poli-
cy, or of rules of the higher court, and
whether refusal to issue the writ may
work a serious hardship on the parties.
See APPX CHT No. “31.”
Platt v. Minnesota Min. & Mfg. Co., 84
S.Ct. 769, 376 U.S. 240, 11 L.Ed.2d 674
(1964) – Extraordinary writs are re-
served for really extraordinary causes,
and then only to confine an inferior
court to a lawful exercise of its pre-
scribed jurisdiction or compel it to exer-
cise its authority when it is duty to do
so.
See APPX CHT No. “32.”
Newsome seeks any and all applicable relief KNOWN to
the U.S. Supreme Court to correct the injustic-
es/miscarriages of justice addressed herein and in the sup-
porting Appendix. Newsome believes that the record evi-
dence will further support Orders entered by Judge Tom S.
Lee with KNOWLEDGE that he LACKED jurisdiction to
act in legal action/lawsuit.
Anderson v. McLaughlin, 263 F.2d 723
(1959) – (n.2) Authority conferred by
statute authorizing courts to issue ALL
writs necessary is NOT confined to is-
suance of writs in aid of jurisdiction al-
ready acquired by appeal but extends to

70. Page 39 of 80
those cases which are within court’s ap-
pellate jurisdiction although NO appeal
has yet been perfected. 28 U.S.C.A. §
1651. Roche v. Evaporated Milk Ass’n,
319 U.S.21, 25, 63 S.Ct. 938, 941, 87
L.Ed. 1185.
(n. 3) Extraordinary writs author-
ized to be issued by courts established
by Act of Congress should be issued only
under unique and compelling circum-
stances.
De Beers Consol. Mines v. U.S., 65 S.Ct.
1130, 325 U.S. 212, 89 L.Ed. 1566
(1945) - . . . petitioners applied to this
court for certiorari under § 262. That
section provides in part: “The Supreme
Court. . . shall have power to issue all
writs not specifically provided for by
statute, which may be necessary for the
exercise of their respective jurisdictions,
and agreeable to the usages and princi-
ples of law.”
. . . When Congress withholds in-
terlocutory reviews, § 262 can, of course
be availed to correct a mere error in the
exercise of conceded judicial power. But
when a court has no judicial power to do
what it purports to do – when its action
is not mere error or usurpation of power
– the situation falls precisely within the
allowable use of § 262. We proceed,
therefore, to inquire whether the . . .
Court is empowered to enter the order
under attack.
See APPX CHT No. “33.”

71. Page 40 of 80
Also see, 80th Congress
House Report No. 308.
Newsome believes that this “OW-WOM, ET AL”
meets the REQUIRED prerequisites in that:
(1) the writ(s) will be in aid of the
Court’s appellate jurisdiction –
[28 U.S.C. § 1651(a)] “The U.S.
Supreme Court has a continuing
power to issue extraordinary
writs in aid of either its original
jurisdiction8 including as a part of
jurisdiction(s) the exercise of gen-
eral supervisory control over the
court system – state or federal.”9
(2) exceptional circumstances war-
rant the exercise of the Court’s
discretionary powers - While
there need NOT be a laundry list
8 See Ex parte Hung Hang, 108 U.S. 552, 553, 2 S.Ct. 863, 27 L.Ed. 811
(1883) (Court has authority to issue writ); Pennsylvania v. Wheeling Belmont
Bridge Co., 59 U.S. 421, 431, 15 L.Ed. 435 (1885) (“act of congress cannot have
the effect and operation to annul the decision of the court already rendered); Ex
parte Siebold, 100 U.S. 371, 374, 25 L.Ed. 717 (1879) (“Having this general
power to issue the writ, the court may issue it in the exercise of original juris-
diction where it has original jurisdiction. . . “); see also Wagner, Original Juris-
diction of National Supreme Courts, 33 St. John’s L. Rev. 217 (1959); cf. Mar-
bury v. Madison, 5 U.S. (1 Cranch) 137, 147, 2 L.Ed. 60 (1803) (“The term ‘ap-
pellate jurisdiction’ is to be taken in its larger sense, and implies in its nature
the right of superintending the inferior tribunals.”).
9See e.g., Connor v. Coleman, 440 U.S. 612, 624, 99 S.Ct. 1523, 59
L.Ed. 2d 619 (1979) (“When a lower. . .court refuses to give effect to, or miscon-
strues our mandate, its actions are controlled by this Court. . .”); MCullough v.
Cosgrave, 309 U.S. 634, 635, 60 S.Ct. 703, 84 L.Ed. 992 (1940) (Court directed .
. . Court judge to vacate order and retry cases expediently); Ex parte United
States, 242 U.S. 27, 52, 37 S.Ct. 72, 61 L.Ed. 129 (1916) (mandamus proper
remedy for enforcing . . . when. . . Court that passed it has defeated its execu-
tion). - - Vol. 23 Moore’s Federal Practice, § 520.02[2] (Matthew Bender 3d ed.).

72. Page 41 of 80
of “exceptional circumstances,”
the U.S. Supreme Court has re-
peatedly asserted that the per-
emptory writs are drastic and ex-
traordinary remedies that must
be reserved for only truly ex-
traordinary cases (as the extraor-
dinary circumstances in this in-
stant lawsuit).10
(3) adequate relief cannot be had in
any other form - Newsome seeks
to bring, the writ sought in that it
is permissible and warranted as a
matter of law - Ex parte Har-
ding, 219 U.S. 363, 374; 31 S.Ct.
324, 55 L.Ed. 252 (1911) (writ on-
ly applicable to exceptional cases)
– and is sustained by facts, evi-
dence and legal conclusions of the
good-faith acts of Newsome to
seek adequate relief through ap-
propriate legal recourse – i.e. due
to no avail because of the con-
spiracy(s) leveled against her.
10 See Bagley v. Byrd, 534 U.S. 1301, 122 S.Ct. 419, 419-420, 151 L.Ed.
2d 370 (2001) (Stevens, J., in chambers) (Court will deny applications for stay of
lower-court proceedings pending Court’s disposition of . . . petition unless appli-
cation demonstrates that denial of stay will either cause irreparable harm or
affect Supreme Court’s jurisdiction to act on . . . petition); In re Michael Sin-
dram, 498 U.S. 177, 179, 111 S.Ct. 596, 112 L.Ed. 2d 599 (1991) (petitioner
“identifies no ‘drastic’ circumstances to justify extraordinary relief” as required
by Sup. Ct. R. 20.1); Will v. United States, 389 U.S. 90, 95, 88 S.Ct. 269, 19
L.Ed. 305 (1967) (“only exceptional circumstances amounting to a judicial
‘usurpation of power’ will justify the invocation of this extraordinary remedy”);
Ex parte Fahey, 332 U.S. 258, 260, 67 S.Ct. 1558, 91 L.Ed. 2041 (1947) (“These
remedies should be resorted to only where appeal is a clearly inadequate reme-
dy.”).

73. Page 42 of 80
(4) adequate relief cannot be had in
any other court below – the rec-
ord evidence, facts and legal con-
clusions will support a PATTERN
of unlawful/illegal acts leveled
against Newsome (i.e. moreover,
CONSPIRACIES). The record ev-
idence will further support efforts
by lower courts to “CLOSE
DOORS OF COURT(S) to New-
some.” Thus, warranting and
supporting the relief Newsome
seeks through bringing Extraor-
dinary Writ. [Ex parte Young,
209 U.S. 123, 165, 28 S.Ct. 441,
52 L.Ed. 714 (1908) (remedies at
law not inadequate).
as well as for reasons known to this Court to deter/prevent
the criminal/civil wrongs addressed herein.
It is of PUBLIC/WORLDWIDE interest for citizens to
see just how the courts in the United States of America op-
erate and then move to COVER-UP the CORRUPTION of
the United States Government/Government Officials, BIG
corporations, BIG law firms, BIG insurance companies,
SPECIAL INTEREST groups, their lobbyists, etc. who en-
gage in criminal/civil wrongs leveled against citizens such
as Newsome who OPPOSE such unlawful/illegal/unethical
practices as that raised and addressed in this instant plead-
ing and supporting Appendix. In fact, it is IMPORTANT
for the PUBLIC/WORLD to see just how far the United
States Government, WHITE employers, their lawyers, their
insurance companies, etc. will go to POST FALSE, MALI-
CIOUS and MISLEADING information known to be re-
ceived through criminal acts on the INTERNET for purpos-
es of destroying citizens’ (i.e. such as Newsome) lives. See

74. Page 43 of 80
APPX CHT No. “34” – Google Information regarding New-
some attached hereto and incorporated by reference as if
set forth in full herein. Furthermore, how the Government
and WHITE employers engage in criminal/civil wrongs
against citizens (i.e. such as Newsome) to see that the
“DOORS OF THE COURTS” are closed to citizens who
have VALID and MERITABLE claims by either engaging
and/or condoning the criminal acts of judges/justices who
AID and ABET in the COVER-UP of CORRUPTION and
CRIMINAL behavior. In Newsome’s case, the United
States Government and White employers with their attor-
neys/lawyers (Baker Donelson) CONSPIRED to place in-
formation on the INTERNET they knew to be FALSE, MA-
LICIOUS and MISLEADING and obtained through
BRIBES, BLACKMAIL, EXTORTION, COERCION, etc. for
purposes of having Newsome BLACKLIST-
ED/BLACKBALLED and creating situation to see that
Newsome is NEVER employable in EFFORTS of keeping
the CRIMINAL/TERRORIST/RACIST/WHITE SUPREM-
ACIST practices of Baker Donelson and its clients (as New-
some’s WHITE Racist employers) OUT of the
eyes/knowledge of CITIZENS and/or PUBLIC/WORLD.
Weber v. Henderson, 275 F.Supp.2d 616
(2003) – Postal employee who filed fif-
teen lawsuits in nine years against
United States Postal Service (USPS),
stemming from his removal from full-
service carrier duty, failed to raise
claims in any action relating to events
at issue that were neither meritless nor
frivolous, and thus any further pro se
pleadings submitted by employee on
same basis would be PROPERLY re-
viewed under ALL WRITS ACT . . .
In re McDonald, 489 U.S. 180,
109 S.Ct. 993 (1989) Jessie McDonald

75. Page 44 of 80
may well have abused his right to file
petitions in this Court without payment
of the docketing fee; the Court's order
documents that fact. I do not agree,
however, that he poses such a threat to
the orderly administration of justice
that we should embark on the unprece-
dented and dangerous course the Court
charts today. . . . I am most concerned,
however, that if, as I fear, we continue
on the course we chart today, we will
end by closing our doors to a litigant
with a meritorious claim. It is rare, but
it does happen on occasion that we
grant review and even decide in favor of
a litigant who previously had presented
multiple unsuccessful*188 petitions on
the same issue. See, e.g., Chessman v.
Teets, 354 U.S. 156, 77 S.Ct. 1127, 1
L.Ed.2d 1253 (1957); see id., at 173-177,
77 S.Ct. at 1136-1138 (Douglas, J., dis-
senting).
"Petitioner is no stranger to us.
Since 1971, he has made 73 separate fil-
ings with the Court, not including this
petition, which is his eighth so far this
Term. These include 4 appeals, 33 peti-
tions for certiorari, 99 petitions for ex-
traordinary writs, 7 applications for
stay and other injunctive relief, and 10
petitions for rehearing." Id. pp. 994-
995.
"But paupers filing pro se peti-
tions are not subject to the financial
considerations - filing fees and attor-
ney's fees - that deter other litigants
from filing frivolous petitions." Id. p.
996.

76. Page 45 of 80
The Supreme Court (even after
all of McDonald's filings) did not close
the door to McDonald. A litigant who is
identified as filing 73 separate filings in
a one-year period; however, ruled, "Peti-
tioner remains free under the present
order to file in forma pauperis requests
for relief other than an extraordinary
writ, if he qualifies under the Court's
Rule 46 and does not similarly abuse
that privilege." Id. p. 996.
Newsome believes that a reasonable mind may conclude,
that based upon the facts, evidence and legal conclusions
provided in this instant pleading and supporting Appendix,
that the role the Respondents, United States Government
Agencies/Officials, courts, WHITE employers, etc. played in
the posting of PROTECTED ACTIVITIES involving New-
some on the INTERNET – see APPX CHT No. “34” - was
posted for unlawful/illegal/unethical/malicious/willful in-
tent to subject Newsome to irreparable injuries/harm. Mat-
ters in which Judge Tom S. Lee was CLEARLY involved
and played a KEY/MAJOR role in conspiracies leveled
against Newsome!
Newsome believes that the record will sustain that
the facts, evidence and legal conclusions set forth in in this
instant pleading, and their supporting Appendix will sus-
tain the RELIEF sought under the “All Writs Act” and will
sustain that there “are persons/parties, though not parties
to original action” - such as: (a) United States President
Barack Obama and members of his Administration, law-
yers, advisors, etc.; (b) Baker, Donelson, Bearman, Caldwell
& Berkowitz, PC (“Baker Donelson”) their client(s) (i.e.
such as LIBERTY MUTUAL INSURANCE COMPANY,
J.P. Morgan Chase Bank, etc.); (c) and others that may be
identified through FACTUAL inquiries/INVESTIGATIONS
that engaged in CONSPIRACIES and criminal/civil wrongs

77. Page 46 of 80
leveled against Newsome and citizens here in the United
States of America and abroad – that RELY upon their
DOMINENT/ PROMINENT positions to INFLUENCE and
FRUSTRATE the implementation of the laws, OBSTRUCT
the administration of justice, and implementation of Orders
issued by this Court.
Sable v. General Motors Corp., 90 F.3d
171 (1996) – Power conferred by All
Writs Act extends, under appropriate
circumstances, to persons who, though
not parties to original action . . . are in
position to frustrate implementation of
court order or proper administration of
justice.
U.S. v. New York Tel. Co., 98 S.Ct. 364,
434 U.S. 159, 54 L.Ed.2d 376 – Power
conferred by this section extends, under
appropriate circumstances, to persons
who though not parties to original ac-
tion . . . are in position to frustrate im-
plementation of court order or proper
administration of justice and encom-
passes even those who have not taken
any affirmative action to hinder justice.
See APPX CHT Nos. “19” – “21” incorporated by reference
as if set forth in full herein.
U.S. v. International Broth. Of Team-
sters, Chauffeurs, Warehousemen and
Helpers of America, AFL-CIO, 911
F.Supp. 743 (1996) – Important feature
of All Writs Act is its grant of authority
to enjoin and bind nonparties to action
when needed to preserve court’s ability

78. Page 47 of 80
to reach or enforce its decision in case
over which it has proper jurisdiction.
Mongelli v. Mongelli, 849 F.Supp. 215
(1994) - Under All Writs Act, federal
courts has authority to issue commands
as necessary to effectuate orders it has
previously issued and extends to per-
sons who were not parties to original ac-
tion but are in position to frustrate im-
plementation of court order.
Moreover, it is of PUBLIC IMPORTANCE for the CITI-
ZENS/WORLD to see the Terrorist/White Suprema-
cist/Racist Regime that appear to be running the United
States Government – Baker Donelson Bearman Caldwell &
Berkowitz - and the positions it holds/held in the Govern-
ment for purposes of exposing how ONE law firm has been
ALLOWED to infiltrate the United States Government for
purposes of PROMOTING its RACIST/DISCRIMINATORY
ideas over their victims such as Newsome, other citizens
and Foreign Countries/Leaders.
http://www.slideshare.net/VogelDenise/bd-oilfield-patents
As a matter of law the U.S. Supreme Court has a
DUTY to correct the miscarriage of justices made known to
it through any/all legal means known to it. Newsome need
NOT be specific because this Court has VAST legal re-
sources and KNOWLEDGE and/or the TOOLS TO OBTAIN
SUCH KNOWLEDGE on how to handle the EXTRAOR-
DINRY, EXCEPTION and CRITICAL/EXIGENT circum-
stances brought to its attention by Newsome.
Adams v. U.S. ex rel. McCann, 63 S.Ct.
236 (1942) - Unless appropriately con-
fined by Congress, a federal court may
avail itself of all auxiliary writs as aids

79. Page 48 of 80
in performance of its duties, when the
use of such historic aids is calculated in
its sound judgment to achieve the ends
of justice entrusted to it.
See APPX CHT No. “35”
Ex parte Milwaukee R. Co., 72 U.S. 188
(1866) - Where a case is properly in the
Supreme Court . . ., the Supreme Court
has a right under Judiciary Act § 14, 28
U.S.C.A. § 1651, to issue any writ which
may be necessary to render their . . . ju-
risdiction effectual.
See APPX CHT No. “36.”
Platt v. Minnesota Min. & Mfg. Co., 84
S.Ct. 769 (1964) - Extraordinary writs
are reserved for really extraordinary
causes, and then only to confine an infe-
rior court to a lawful exercise of its pre-
scribed jurisdiction or to compel it to ex-
ercise its authority when it is its duty to
do so. 28 U.S.C.A. § 1651(a).
See APPX CHT No. “37.”
C. MANDATORY DUTY TO RECUSE:
This instant action is brought before this Court to
have the lower court Judge Tom S. Lee ANSWER ALL
claims/issue raised in Newsome’s Recusal pleadings:
RECUSAL statute is meant to
SHIELD litigants from biased and
prejudiced judges. . . Hall v. Doering,
185 FRD 639 (1999). - - Purpose of 28

80. Page 49 of 80
USCS § 455(b)(1) is to ENSURE delib-
erate, UNBIASED factfinding. id.
With respect to DISQUALIFICATION
of federal judges, 28 USCS § 455(c) re-
quires federal judges to STAY in-
formed of any PERSONAL or FINAN-
CIAL interest they may have in cases
in which they preside, notwithstand-
ing size and complexity of litigation.
Liljeberg v. Health Services Acquisi-
tion Corp., 486 US 847, 100 L Ed 2d
855, 108 S Ct 2194 (1988).
Goal of 28 USCS § 455(a), which DIS-
QUALIFIES judge from acting in pro-
ceeding in which is IMPARTIALITY
might reasonably be QUESTIONED,
is to AVOID even APPEARANCE of
PARTIALITY; if it would appear to
reasonable person that judge has
knowledge of facts which would give
him INTEREST in litigation, then
APPEARANCE of PARTIALITY is
created even though no actual partial-
ity exists because the judge does not
recall the facts, actually has no inter-
est in the case, or is pure in heart and
incorruptible. Liljeberg v. Health Ser-
vices Acquisition Corp., 486 US 847,
100 L Ed 2d 855, 108 S Ct 2194
(1988). – See APPX CHT No. “38.”
RECUSAL statute, 28 USCS 455(a)
and (b), requires mandatory disquali-
fication of judge in any proceeding in
which his impartiality might reasona-
bly be QUESTIONED or where he has

81. Page 50 of 80
PERSONAL BIAS or PREJUDICE
concerning party. United States v.
Brown, 539 F2d 467 (5th Cir. 1976)
28 USCS §§ 144, 455 give life to DUE
PROCESS requirement of FAIR trial
BEFORE FAIR tribunal, and claim of
bias and prejudice that survives rigid
scrutiny under §§ 144, 455 will neces-
sarily pass constitutional muster.
United States v. IBM Corp., 475
F.Supp. 1372 affd 618 F2d 923 (2nd
Cir. 1980)
The record evidence in the in the lower court action
will support that Newsome TIMELY, PROPERLY and AD-
EQUATELY submitted the required pleadings warranting
the RECUSAL of Judge Tom S. Lee. Moreover, that New-
some NEVER consented, NOR waived recusal issue and
REPEATEDLY provided pleadings in support of said de-
fense for RECUSAL.
The record evidence will support that Newsome has
sustained irreparable injury/harm which CONTINUES to
date to from the role that Judge Tom S. Lee is playing in
the CONSPIRACIES leveled against Newsome.
The record evidence will support that although New-
some pursuant to Rule 8 of the Federal Rules of Federal
Procedure set forth in NUMBERED paragraphs SHORT
(i.e. some warranting additional comments for clarity) and
PLAIN statements with supporting EXHIBITS/Evidence
and Legal Conclusions, the lower court record is VOID of
address ALL ISSUES raised in the May 15, 2012 – 17 Pag-
es and 4 Numbered Paragraphs:
Request for Conflict of Interest Infor-
mation, Notice of Opposition to Magis-

82. Page 51 of 80
trate Judge Assignment; and Notice of
Address – See APPX CHT No. “12” at
Doc. No. 2.
28 USCS § 455 is self-enforcing on
part of judge; it may be asserted by
party by motion in trial court, through
assignment of error on appeal, by in-
terlocutory appeal, or by mandamus.
Davis v. Board of School Comm’rs, 517
F2d 1044 (5th Cir. 1975)
Court will consider petition for writ of
mandamus following District Court’s
denial of motion to disqualify based on
conflict of interest and appearance of
partiality. In re Aetna Casualty &
Surety Co., 919 F2d 1136 (6th Cir.
1990)
as well as is VOID of Judge Tom S. Lee’s ANSWER as to
each claim/issue raised in Newsome’s – 35 Pages and 79
Numbered Paragraphs with JURY DEMAND noted in the:
OBJECTION(S) To August 2, 2012 Or-
der Of Judge Tom S. Lee; Motion For
DISQUALIFICATION; AND DEMAND
FOR JURY TRIAL (“OBJECTION(S)
TO 08/02/12 ORDER”)
and CLEARLY FAILS to address the ISSUES/CLAIMS
raised in Newsome’s supporting AFFIDAVIT OF DIS-
QUALIFICATION which was 6 pages and contained ap-
proximately 21 Numbered paragraphs:
VOGEL DENISE NEWSOME’S AFFI-
DAVIT OF DISQUALIFICATION OF
JUDGE TOM S. LEE - See APPX “5.”

83. Page 52 of 80
The statutes/laws are clear governing Judge Tom S. Lee’s
MANDATORY requirement to recuse himself from lawsuit;
however, he is determined to place himself above the law
and OBSINATE/PIGHEADED in duty to stand as the
GATEKEEPER and fulfill his ROLE and OBLIGATIONS
in the ONGOING conspiracies leveled against Newsome.
This Court has found in Murchison:
In re Murchison, 75 S.Ct. 623 (1955) - No
man can be a judge in his own case, and no
man is permitted to try cases where he has
an interest in the outcome. . .
The interest which will disqualify a man
from trying a case depends on circumstances
and relationships.
The record evidence will not only support Judge Lee’s role
in conspiracies leveled against Newsome but FINANCIAL
and PERSONAL interests in the outcome this lawsuit and
others in which he is UNLAWFULLY presiding over.
Andrade v. Chojnacki, 338 F.3d 448
(5th Cir. 2003) - Judge abuses his or
her discretion in denying recusal
where reasonable person, cognizant of
relevant circumstances surrounding
judge's failure to recuse, would harbor
legitimate doubts about that judge's
impartiality. 28 U.S.C.A. § 455.
Parliament Ins. Co. v. Hanson, 676
F.2d 1069 (5th Cir. 1982) - Statutory
provision governing disqualification of
federal judges imposes a reasonable
man standard in determining whether
a judge should recuse himself. 28
U.S.C.A. § 455(a).

84. Page 53 of 80
D. JURY TRIAL DEMANDED:
Plaintiff’s use of twelve pages to set
out claim that could have been stated
in six pages did not justify dismissal
under Rule 8(a), where complaint was
intelligible and gave defendants notice
of claim for relief, even though com-
plaint could have been improved.
Bennett v. Schmidt, 153 F3d 516 (7th
Cir. 1998).
Defendants’ motion to dismiss under
Fed. R. Civ. P. 8(a)(2) and (e)(1), as-
serting that, at 368 pages and 1,249
paragraphs, plaintiff’s complaint was
too long and confusing, was DENIED
because although plaintiffs’ was
lengthy, it did NOT overwhelm de-
fendants’ ability to understand or to
mount defense. Ir re Parmalat Sec.
Litig., 375 F.Supp. 2d 278 (2005).
The record evidence will support Judge Tom S. Lee’s
KNOWLEDGE of Newsome’s TIMELY demand for JURY
Trial through his masked attack noting her “143-page com-
plaint.” – See APPX CHT No. “39” – which he DELIBER-
ATELY steers clear of noting the 25 SUPPORTING Exhib-
its accompanying it. Moreover, Newsome’s REPEAT de-
mand for JURY Trial:
Paragraph Page Paragraph Page
¶ 56 21 ¶ 178 75
¶ 99 39 ¶ 200
¶ 103 41 ¶ 218 87
¶ 108 43 ¶ 239 95

85. Page 54 of 80
¶ 120 49 ¶ 262 109
¶ 141 62 ¶ 299 116
¶ 170 71 ¶¶ 310 thru 312 136
See APPX CHT No. “39” incorporated by reference as if
set forth in full herein.
The lower court record will sustain Newsome’s RE-
PEATEDLY REITERATING “JURY” Demand and did NOT
waive right to have issues presented to jury and allow
Judge Tom S. Lee and/or lower court to decide ISSUES in
DISPUTE! The Supreme Court of the United States’ deci-
sions and that of the FIFTH Circuit Court of Appeals are
clear on litigants’ rights to have matters tried by JURY and
NOT by the court as Judge Tom S. Lee has attempted to do
in his ROLE in the conspiracies leveled against Newsome:
Constitutional right to trial by jury in suits
at common law will be scrupulously safe-
guarded by Supreme Court. Lyon v. Mutu-
al Ben. Health & Acci. Asso., 305 US 484,
83 L Ed 303, 59 S Ct 297, reh den (1939)
306 US 667
In absence of waiver of right to trial by ju-
ry, it is VIOLATION of Seventh Amend-
ment for federal court to substitute itself
for jury, pass upon effect of evidence, find
facts involved in case, and render judg-
ment. Baylis v. Travellers’ Ins. Co., 113 US
316, 28 L Ed 989, 5 S Ct 494.
Trial by jury is fundamental guaranty of
rights and liberties of people, and every
reasonable presumption should be indulged
against its waiver. Hodges v. Easton, 106
US 408, 16 Otto 408, 27 L Ed 169, 1 S Ct
307

86. Page 55 of 80
Court should not take case from jury where
evidence is conflicting or different conclu-
sions may be drawn from undisputed facts.
Woodard v. Atlantic C.L. R. , 57 F 2d 1019
(5th Cir. 1932).
Upon motion for jury trial, court should
grant same in absence of compelling rea-
sons to contrary, even though time for de-
manding jury trial has expired. Albert v.
R.P. Farnsworth & Co., 176 F 2d 198 (5th
Cir. 1949)
Right to jury trial in civil cases under Sev-
enth Amendment may be waived by failure
to make timely demand for it; however,
although judge is not required to allow
UNTIMELY request for jury trial, court
should grant trial in absence of strong and
compelling reasons to contrary. Cox v. C.
H. Masland & Sons, Inc., 607 F 2d 138 (5th
Cir. 1979)
Because of the DISPUTED issues raised in Newsome’s
Complaint and her subsequent pleadings (i.e. which are to
be resolved through a jury trial), she has been deprived
DUE PROCESS, equal PROTECTION of the laws and priv-
ileges and immunities secured/guaranteed under the Con-
stitution of the United States and other governing stat-
utes/laws of the United States of America:
Hare v. City of Corinth, Miss., 949
F.Supp. 456 (N.D.Miss.E.Div.,1996) -
Essential characteristic of federal sys-
tem is the manner in which, in civil
common-law actions, it assigns trial
functions between judge and jury and,

87. Page 56 of 80
under the influence if not the com-
mand of Seventh Amendment, assigns
decisions of disputed questions of fact
to jury. U.S.C.A. Const.Amend. 7.
[22] [23] As already noted by the
court in this case, this court has de-
termined that there remain genuine
issues of material fact as to whether
the actions of the . . . defendants
amount to deliberate indifference in
this case. These same defendants now
argue to the court that “[t]his court
made [its previous] holding based up-
on a set of undisputed facts leaving
only a legal question to be decided. If
this court cannot determine after dili-
gent research and the benefit of hind-
sight whether the defendants' actions
were deliberately indifferent based
upon a set of undisputed facts, then
the defendants should certainly could
not in July, 1989, . . . The ultimate
factual determination of whether or
not these defendants were deliberately
indifferent is itself a disputed question
of fact. See, e.g., Estate of Cole by
Pardue v. Fromm, 94 F.3d 254, 260
(7th Cir.1996); Miller v. Schoenen, 75
F.3d 1305, 1311 (8th Cir.1996); Kirk v.
Simpson, 35 F.3d 566, 1994 WL
443461, *1 (6th Cir.(Tenn.)); Archibe-
que v. Wylie, 16 F.3d 415, 1994 WL
41272, *3 (10th Cir.(N.M.)); Greason v.
Kemp, 891 F.2d 829, 835 (11th
Cir.1990). Its determination is the re-
sponsibility of the jury in this case,
and does not rest with this court as it
is a determination of fact:

88. Page 57 of 80
The federal system is an inde-
pendent system for administering jus-
tice to litigants who properly invoke
its jurisdiction. An essential character-
istic of that system is the manner in
which, in civil common-law actions, it
distributes trial functions between
judge and jury and, under the influ-
ence—if not the command—of the
Seventh Amendment, assigns the de-
cisions of disputed questions of fact to
the jury. - See APPX CHT No. “40” –
incorporated by reference as if set
forth in full herein.
Gasperini v. Center for Humanities,
Inc., 518 U.S. 415, 116 S.Ct. 2211, 135
L.Ed.2d 659 (1996) (quoting Byrd v.
Blue Ridge Rural Elec. Cooperative,
Inc., 356 U.S. 525, 537, 78 S.Ct. 893,
901, 2 L.Ed.2d 953 (1958)). This court
is nevertheless fully capable of making
findings of fact as well as conclusions
of law if the parties wish to waive
their right to a jury trial in this case.
That it is not this court's place to
make this factual determination at the
summary judgment stage lends no de-
cisive weight to the determination of
whether the defendants are actually
entitled to the protection of qualified
immunity. There remain genuine is-
sues of material fact as to whether the
actions of the . . .defendants were ob-
jectively reasonable in light of existing
law. As such, an award of summary
judgment on the issue is inappropri-

89. Page 58 of 80
ate. The defendants are not entitled to
the entry of a judgment as a matter of
law.
E. STATUTE OF LIMITATION FOR CONTINUING TORT
ACTIONS:
It is UNDISPUTED that the Named Defendants in
the lower court action sought DISMISSAL of Newsome’s
Complaint asserting 42 USC § 1983 Claims when it is
CLEAR Newsome’s Complaint does NOT allege and NEI-
THER assert any such § 1983 claims at all. – See APPEN-
DICES “14,” “16,” “18” and “39” incorporated by reference
as if set forth in full herein.
Newsome’s Complaint is premised on § 1981 claims
and other supporting statutes/laws governing said matters.
While the lower court/Judge Tom S. Lee wants to as-
sert that Newsome may have erred in the application of the
SIX-year statute of limitations to the claims/issues raised
in her Complaint, it is UNDISPUTED that Newsome’s
Complaint claims and provide supporting documentation of
the ONGOING civil rights violations leveled against her
and the ONGOING conspiracies which CONTINUES to
date by Respondents and those with whom they CON-
SPIRE and, therefore, are governed by the “CONTINUING
TORT” claims and, therefore, tolls any alleged statute of
limitations claimed to have expired. While it appears that
Judge Tom S. Lee mocks the “143-page complaint” and as-
serts that her claims are BARRED by the FOUR-year stat-
ute of limitation, this Court will find that through DECEP-
TIVE and FRAUDULENT practices in his role of fulfilling
conspiracy duties, it is CLEAR he CRAFTILY steers clear
of addressing the TIMELY defense of Newsome supporting
that CONTINUING TORT claims in which the statute of

90. Page 59 of 80
limitation begins AFTER each/every OVERT act committed
until desisted – i.e. which to date CONTINUES and has
NOT stopped:
¶5 Pg. 21 ¶198-199 Pg. 87
¶(xii) Pg. 22 ¶l Pg. 89
¶105 Pg. 41 ¶214-216 Pg. 94
¶¶106, 107 Pg. 43 ¶217 Pg. 95
¶110 Pg. 47 ¶l Pg. 96
¶117 Pg. 48 ¶ 233-235 Pg. 108
¶119 Pg. 49 ¶237, 238 Pg. 109
¶ (xii) Pg. 51 ¶m Pg. 111
¶136 Pg. 60 ¶245 Pg. 112
¶138-139 Pg. 61 ¶253, 259 Pg. 114
¶140 Pg. 62 ¶260 Pg. 115
¶(xii) Pg. 63 ¶261 Pg. 116
¶165 Pg. 70 ¶l Pg. 117
¶170 Pg. 71 ¶278 Pg. 121
¶175 Pg. 73 ¶1 Pg. 122
¶176 Pg. 74 ¶292 Pg. 127
¶177 Pg. 75 ¶296 Pg. 127
¶(xii), (xvii) Pg. 77 ¶297 Pg. 130
¶188 Pg. 82 ¶298 Pg. 130
¶197 Pg. 85 ¶1 Pg. 131
Macklin v. Spector Freight Systems,
Inc., 478 F.2d 979 (1973) - [18] Where
continuing violations were alleged,
complaint under statute providing
that all persons within United States
shall have same right to make and en-
force contracts as is enjoyed by white
citizens was not barred by limitation.
42 U.S.C.A. § 1981
Hendrix v. City of Yazoo City, Miss.,
911 F.2d 1102 (5th Cir. Miss. 1990) - In
case in which original violation oc-
curred outside statute of limitations,

91. Page 60 of 80
but is closely related to other viola-
tions that are not time barred, recov-
ery may be had for all violations, on
theory that they are part of one, con-
tinuing violation.
Stevens v. Lake, 615 So.2d 1177
(Miss.,1993) - “Continuing injury” doc-
trine did not enable surviving busi-
ness partners to avoid bar of six-year
statute of limitations applicable to le-
gal . . . action alleging attorneys' neg-
ligent failure to record trust prepared
for now-deceased partner, even though
surviving partners continued to sus-
tain losses each year after alleged neg-
ligence; attorneys' alleged act of negli-
gence occurred entirely in year that
was more than six years before mal-
practice suit was filed. Code 1972, §
15-1-49. [NOTE: In Newsome’s law-
suit it is UNDISPUTED of PKH’s
and/or Named Defendants’ role and/or
interest in the Newsome vs. Spring
Lake Apartments matter.]
Winters v. AmSouth Bank, 964 So.2d
595 (Miss.App.,2007) - A “continuing
tort” sufficient to toll a statute of limi-
tations is occasioned by continual un-
lawful acts, not by continual ill effects
from an original violation.
Randolph v. Lambert, 926 So.2d 941
(Miss.App.,2006) - If the claim is a
continuing tort, the statute of limita-
tions does not begin to run until the
date of the last injury.

92. Page 61 of 80
WW, Inc. v. Rainbow Casino-
Vicksburg Partnership, L.P., 2011 WL
4037024 (Miss. 2011) - Where a tort
involves a continuing or repeated inju-
ry, the cause of action accrues at, and
limitations begin to run from, the date
of the last injury, or when the tortious
acts cease.
Bryant v. Military Department of Mis-
sissippi, 597 F.3d 678 (5th Cir. Miss.
2010) - Under Mississippi law, a “con-
tinuing tort,” for which the statute of
limitations is tolled, is one inflicted
over a period of time, it involves a
wrongful conduct that is repeated un-
til desisted, and each day creates a
separate cause of action.
Therefore, it is left up to the JURY and not the lower
court/Judge Tom S. Lee to decide.
TACIT AGREEMENT - Occurs when two
or more persons pursue by their acts
the same object by the same means.
One person performing one part and
the other another part, so that upon
completion they have obtained the ob-
ject pursued. Regardless whether
each person knew of the details or
what part each was to perform, the
end results being they obtained the ob-
ject pursued. Agreement is implied or
inferred from actions or statements.
The record evidence will support the TAG-TEAM litigation
of Respondents and their role in CONSPIRACIES leveled

93. Page 62 of 80
against Newsome which appears to be SPEARHEADED by
Baker Donelson and have NOT ceased. Furthermore, how
through said conspiracies, they STALK Newsome from job-
to-job and state-to-state contacting her employers (i.e. as in
this matter with Page Kruger & Holland) and advise of her
participation in PROTECTED activities for purposes of
having her employment terminated and employers as Page
Kruger & Holland P.A. and its employees are more than
happy to oblige in fulfilling ROLE in CONSPIRACIES! -
See APPX CHT No. “41” and/or APPX CHT No. “39”at Ex-
hibit “VI.”
It is UNDISPUTED the role that Baker Donelson is
playing in the prosecution of lawsuits brought by Newsome
and/or in which Newsome is a party. Moreover, it is UN-
DISPUTED (though timely raised) of Baker Donelson’s in-
terests in the lower court action and now this instant Su-
preme Court of the United States action.
F. REASONS FOR GRANTING PETITION(S):
Newsome herein incorporates the issues/arguments
raised above in this “OW-WOM, ET AL” as well as set forth
in her lower court pleadings – i.e. information which is pro-
vided in the supporting Appendix to this instant action. In
further support thereof, Newsome states:
a. USDC-Jackson, MS has entered a decision
in conflict with the decision of another dis-
trict court on the same important matter;
has decided an important federal question
in a way that conflicts with a decision by a
federal court; or has so far departed from
the accepted and usual course of judicial
proceedings, or sanctioned such a depar-
ture, as to call for an exercise of the U.S.
Supreme Court’s supervisory power; and

94. Page 63 of 80
b. USDC-Jackson, MS has FAILED to decide
an important question of federal law that
has not been, but should be, settled by this
Court; or has decided an important federal
question in a way that conflicts with rele-
vant decisions of this Court.
c. To compel the USDC-Jackson, MS to do
something that it has refused to do. More-
over, to force the lower court to comply
with this Court’s mandate and previous
rulings/decisions by this Court on said is-
sues and those which may be newly pre-
sented through these extraordinary writs.
d. To issue mandate to compel matters be
presented to JURY.
e. To prohibit the USDC-Jackson, MS from
doing something that it will otherwise do.
f. PREREQUISITES: (i) Writ(s) Will Be In Aid
Of The Court’s Original and/or Appellate
Jurisdiction; (ii) Exceptional Circumstanc-
es Warrant the Exercise of the Court’s Dis-
cretionary Powers; (iii) Adequate Relief
Cannot Be Obtained In Any Other Form or
From Any Other Court; and (iv) for Other
Reasons Known to this Court.
Newsome believes her OW-WOM,
ET AL and supporting Appendix sustains
that there are extraordinary and excep-
tional circumstances which exist and meet
the prerequisites required to support grant-
ing of relief sought herein - Vol. 23 Moore’s

95. Page 64 of 80
Federal Practice, § 520.02 Considerations
Governing Issuance Of Extraordinary Writ:
[1] PREREQUISITES TO GRANTING EXTRAOR-
DINARY WRIT: Supreme Court Rule 20 spec-
ifies that the issuance of an extraordinary
writ “is not a matter of right, but of discre-
tion sparingly exercised.11
The Rule then sets forth four pre-
requisites to the granting of extraordinary
writ. It must be shown:
(5) the writ will be in aid of the
Court’s appellate jurisdiction:
Newsome believes that Extraordinary
Writ(s) sought will be in aid of the U.S. Su-
preme Court’s original and/or appellate ju-
risdiction – 28 U.S.C. § 1651(a) provides
that the “Supreme Court and all courts es-
tablished by Act of Congress may issue all
writs necessary or appropriate in aid of
their respective jurisdictions and agreeable
to the usages and principles of law.” The
statute does not purport to restrict this
Court to issuing writs solely in the aid of
its appellate jurisdiction. This Court has
chosen to limit the application of its Rule
11 See Wisconsin Right to Life, Inc. v. Federal Election Comm’n., 542
U.S. 1305, 125 S.Ct. 2, 159 L.Ed. 2d 805, 807 (2004) (Rehnquist, C.J., in cham-
bers) (Supreme Court will issue extraordinary writ only in most critical and
exigent circumstances, only when necessary or appropriate in aid of Court’s
jurisdiction, and only when legal rights at issue are indisputably clear); Brown
v. Gilmore, 533 U.S. 1301, 122 S.Ct. 1, 2-3, 150 L.Ed. 2d 782 (2001) (Rehnquist,
C.J., in chambers) (under All Writs Act, 28 U.S.C. § 1651, injunction against
implementation of presumptively valid state statute pending Court’s disposi-
tion of certiorari petition is appropriate only if legal rights at issue are indis-
putably clear).

96. Page 65 of 80
20 to situations in which the writs are in
aid to the Court’s appellate jurisdiction,
and thereby has left the matter of the ex-
traordinary writs in aid of the Court’s orig-
inal jurisdiction unregulated so far as this
Court’s Rules are concerned. Thus, the
U.S. Supreme Court has a continuing pow-
er to issue extraordinary writs in aid of ei-
ther its original jurisdiction12 including as
a part of jurisdiction(s) the exercise of gen-
eral supervisory control over the court sys-
tem – state or federal: 13
(6) exceptional circumstances war-
rant the exercise of the Court’s
discretionary powers:
Newsome believes that “exception-
al circumstances” as set forth herein and in
the lower court records, warrant the exer-
cise of the U.S. Supreme Court’s discre-
12 See Ex parte Hung Hang, 108 U.S. 552, 553, 2 S.Ct. 863, 27 L.Ed.
811 (1883) (Court has authority to issue writ); Pennsylvania v. Wheeling Bel-
mont Bridge Co., 59 U.S. 421, 431, 15 L.Ed. 435 (1885) (“act of congress cannot
have the effect and operation to annul the decision of the court already ren-
dered); Ex parte Siebold, 100 U.S. 371, 374, 25 L.Ed. 717 (1879) (“Having this
general power to issue the writ, the court may issue it in the exercise of original
jurisdiction where it has original jurisdiction. . . “); see also Wagner, Original
Jurisdiction of National Supreme Courts, 33 St. John’s L. Rev. 217 (1959); cf.
Marbury v. Madison, 5 U.S. (1 Cranch) 137, 147, 2 L.Ed. 60 (1803) (“The term
‘appellate jurisdiction’ is to be taken in its larger sense, and implies in its na-
ture the right of superintending the inferior tribunals.”).
13See e.g., Connor v. Coleman, 440 U.S. 612, 624, 99 S.Ct. 1523, 59
L.Ed. 2d 619 (1979) (“When a lower. . .court refuses to give effect to, or miscon-
strues our mandate, its actions are controlled by this Court. . .”); MCullough v.
Cosgrave, 309 U.S. 634, 635, 60 S.Ct. 703, 84 L.Ed. 992 (1940) (Court directed .
. . Court judge to vacate order and retry cases expediently); Ex parte United
States, 242 U.S. 27, 52, 37 S.Ct. 72, 61 L.Ed. 129 (1916) (mandamus proper
remedy for enforcing . . . when. . . Court that passed it has defeated its execu-
tion). - - Vol. 23 Moore’s Federal Practice, § 520.02[2] (Matthew Bender 3d ed.).

97. Page 66 of 80
tionary powers.” While there need not be a
laundry list of “exceptional circumstances,”
this Court has repeatedly asserted that the
peremptory writs are drastic and extraor-
dinary remedies that must be reserved for
only truly extraordinary cases.14 In this in-
stant action, the “ORIGINAL” jurisdiction
of this Court is also sought because of the
MULTIPLE parties involved and the
MULTIPLE jurisdictions – i.e. DIVERSITY
of parties and states involved.
(7) adequate relief cannot be had in
any other form; and
Newsome believes that the record
evidence as well as the Extraordinary
Writ(s) she seeks to bring before this Court
will support: PATTERN-OF-PRACTICE,
PATTERN-OF-ABUSE, PATTERN-OF-
OBSTRUCTION OF JUSTICE, PATTERN-
OF-DEPRIVATION OF RIGHTS, PAT-
TERN-OF-CORRUPTION, and many un-
lawful/illegal PATTERN-OF-INJUSTICES
leveled against Newsome will support that
she has in GOOD FAITH sought relief
14 See Bagley v. Byrd, 534 U.S. 1301, 122 S.Ct. 419, 419-420, 151 L.Ed.
2d 370 (2001) (Stevens, J., in chambers) (Court will deny applications for stay of
lower-court proceedings pending Court’s disposition of . . . petition unless appli-
cation demonstrates that denial of stay will either cause irreparable harm or
affect Supreme Court’s jurisdiction to act on . . . petition); In re Michael Sin-
dram, 498 U.S. 177, 179, 111 S.Ct. 596, 112 L.Ed. 2d 599 (1991) (petitioner
“identifies no ‘drastic’ circumstances to justify extraordinary relief” as required
by Sup. Ct. R. 20.1); Will v. United States, 389 U.S. 90, 95, 88 S.Ct. 269, 19
L.Ed. 305 (1967) (“only exceptional circumstances amounting to a judicial
‘usurpation of power’ will justify the invocation of this extraordinary remedy”);
Ex parte Fahey, 332 U.S. 258, 260, 67 S.Ct. 1558, 91 L.Ed. 2041 (1947) (“These
remedies should be resorted to only where appeal is a clearly inadequate reme-
dy.”).

98. Page 67 of 80
through the appropriate administrative
and/or judicial remedies prior to bringing
this matter before this Court. Because of
the EXCEPTIONAL circumstances set
forth herein and in the supporting Appen-
dix as well as the lower court records which
supports this action, Newsome seeks to
bring, the writ(s) sought in that it is per-
missible and warranted as a matter of law -
Ex parte Harding, 219 U.S. 363, 374; 31
S.Ct. 324, 55 L.Ed. 252 (1911) (writ only
applicable to exceptional cases) – and is
sustained by facts, evidence and legal con-
clusions.
(8) adequate relief cannot be had in
any other court below:
Newsome believes that the record
evidence will support that without this
Court’s intervention through Extraordinary
Writ(s) sought, that “adequate relief cannot
be had from any other court.” Moreover,
the record evidence supports efforts by low-
er courts to “CLOSE DOORS OF
COURT(S) to Newsome.” Further support-
ing that because of the PATTERN of crimi-
nal/civil wrongs as well as CONSPIRA-
CIES leveled against Newsome; adequate
relief cannot be had in any other Court and
requires the intervention of the U.S. Su-
preme Court’s original jurisdiction for the
resolution. Thus, warranting and support-
ing the relief Newsome seeks through
bringing these Extraordinary Writ(s). [Ex
parte Young, 209 U.S. 123, 165, 28 S.Ct.
441, 52 L.Ed. 714 (1908) (remedies at law
not inadequate). Furthermore, the “ORIG-

99. Page 68 of 80
INAL” jurisdiction of this Court is also
sought because of the MULTIPLE parties
involved and the MULTIPLE jurisdictions
– i.e. DIVERSITY of parties and states in-
volved – sustaining that this matter CAN-
NOT be had in any single court below be-
cause said single court would LACK juris-
diction over parties/litigants because of the
DIVERSITY of jurisdictions involved;
wherein the “ORIGINAL” jurisdiction of
this Court encompasses and allow for its
JURISDICTION over multiple par-
ties/litigants who reside in different states.
Therefore requiring this Court’s jurisdic-
tion and exercise of supervisory powers and
any/all powers governing said Writ(s)
sought.
g. Newsome believes it is of PUBLIC/
WORLDWIDE interest that the Extraordi-
nary Writ(s) sought herein be granted.
h. Newsome believes there are questions of
public importance involved. Furthermore,
questions are of such a nature that it is pe-
culiarly appropriate that such action by the
U.S. Supreme Court should be taken.
i. As a matter of statutes/laws governing
“OW-WOM, ET AL,” Newsome is entitled
to the following Writs and any/all Writ(s) in
accordance with the statutes/laws govern-
ing said matters – i.e. For purposes of miti-
gating costs/damages and the expedition of
this matter, Newsome incorporates herein
by reference the facts, evidence and legal
conclusions set forth in her lower court
pleadings:

100. Page 69 of 80
July 17, 2012 pleading:
https://secure.filesanywhere.com/f
s/v.aspx?v=8a72648b59616dae9ca
5
July 30, 2012 pleading:
https://secure.filesanywhere.com/f
s/v.aspx?v=8a72648b59616fb1a0a
9
August 14, 2012 pleading:
https://secure.filesanywhere.com/f
s/v.aspx?v=8a72648b5961717d6c9
b
August 15, 2012 pleading:
https://secure.filesanywhere.com/f
s/v.aspx?v=8a72648b596075b96e9
7
(1) Original Writ - A writ commencing
an action and directing the defend-
ant to appear and answer.
Thus, the U.S. Supreme
Court has a continuing power to is-
sue extraordinary writs in aid of ei-
ther its original jurisdiction15 in-
15 See Ex parte Hung Hang, 108 U.S. 552, 553, 2 S.Ct. 863, 27 L.Ed.
811 (1883) (Court has authority to issue writ); Pennsylvania v. Wheeling Bel-
mont Bridge Co., 59 U.S. 421, 431, 15 L.Ed. 435 (1885) (“act of congress cannot
have the effect and operation to annul the decision of the court already ren-
dered); Ex parte Siebold, 100 U.S. 371, 374, 25 L.Ed. 717 (1879) (“Having this
general power to issue the writ, the court may issue it in the exercise of original
jurisdiction where it has original jurisdiction. . . “); see also Wagner, Original
Jurisdiction of National Supreme Courts, 33 St. John’s L. Rev. 217 (1959); cf.
Marbury v. Madison, 5 U.S. (1 Cranch) 137, 147, 2 L.Ed. 60 (1803) (“The term

101. Page 70 of 80
cluding as a part of jurisdiction(s)
the exercise of general supervisory
control over the court system –
state or federal. 16
(2) Writ of Conspiracy17 - A writ
against one who conspired to injure
the plaintiff. . .
Salinas v. U.S., 118 S.Ct.
469 (1997) - Conspiracy may
exist and be punished
whether or not substantive
crime ensues, for conspiracy
is distinct evil, dangerous to
public, and so punishable in
itself.
It is possible for person to
conspire for commission of
crime by third person.
‘appellate jurisdiction’ is to be taken in its larger sense, and implies in its na-
ture the right of superintending the inferior tribunals.”).
16See e.g., Connor v. Coleman, 440 U.S. 612, 624, 99 S.Ct. 1523, 59
L.Ed. 2d 619 (1979) (“When a lower. . .court refuses to give effect to, or miscon-
strues our mandate, its actions are controlled by this Court. . .”); MCullough v.
Cosgrave, 309 U.S. 634, 635, 60 S.Ct. 703, 84 L.Ed. 992 (1940) (Court directed .
. . Court judge to vacate order and retry cases expediently); Ex parte United
States, 242 U.S. 27, 52, 37 S.Ct. 72, 61 L.Ed. 129 (1916) (mandamus proper
remedy for enforcing . . . when. . . Court that passed it has defeated its execu-
tion). - - Vol. 23 Moore’s Federal Practice, § 520.02[2] (Matthew Bender 3d ed.).
17 Respondent (conspirator) becomes the agent of the other conspirator
(s), and any act done by one of the combination is regarded under the law as the
act of both or all. In other words, what one does, if there is this combination,
becomes the act of both or all of them, no matter which individual may have
done it. This is true as to each member of the conspiracy, even those whose
involvement was limited to a minor role in the unlawful transaction, and it
makes no difference whether or not such individual shared in the profits of the
actions. (Am. Jur. Pleading and Practice Forms, Conspiracy § 9).

102. Page 71 of 80
See APPX CHT No. “42.”
U.S. v. Schaffer, 586 F.3d
414 (C.A.6.Ohio,2009) - Be-
cause the illegality of an
agreement to commit an un-
lawful act, as the basis of a
conspiracy charge, does not
depend upon the achieve-
ment of its ends, it is irrele-
vant that it may be objec-
tively impossible for the con-
spirators to commit the sub-
stantive offense; indeed, it is
the mutual understanding or
agreement itself that is
criminal, and whether the
object of the scheme actually
is, as the parties believe it to
be, unlawful is irrelevant.
(3) Writ of Exigi Facias - That you
cause to be demanded. Exigent:
Requiring IMMEDIATE action or
aid; URGENT.
Black's Law Dictionary -
Scire Facias: A writ requir-
ing the person against whom
it is issued to appear and
show cause why some matter
of record should not be an-
nulled or vacated, or why a
dormant judgment against
that person should not be
revived.

103. Page 72 of 80
Wayman v. Southard, 23
U.S. 1 (U.S.Ky.,1825) - Un-
der Judiciary Act . . . provid-
ing that court shall have
power to issue writs of scire
facias . . . and all other writs
not specially provided by
statute which may be neces-
sary for the exercise of their
jurisdiction, the general
term “writs” is NOT re-
strained to original process
or to process anterior to
judgment.
Walden's Lessee v. Craig's
Heirs, 39 U.S. 147
(U.S.Ky.,1840) - Demurrers
to writs of scire facias raise
only questions of law on
facts stated in writ.
(4) Writ of Injunction - A court order
commanding or preventing an ac-
tion. - - To get an injunction, the
complainant MUST show that
there is no plain, adequate, and
complete remedy at law and that
an IRREPARABLE injury will re-
sult unless the relief is granted.
U.S. v. Oregon State Medical
Soc., 72 S.Ct. 690 (1952) -
Notwithstanding that in-
junctive relief is MANDA-
TORY in form, such relief is
to undo existing conditions,

104. Page 73 of 80
because otherwise they are
likely to continue.
Porter v. Lee, 66 S.Ct. 1096
(U.S.Ky.,1946) - Where a de-
fendant with notice in an in-
junction proceeding contem-
plates the acts sought to be
enjoined, the court may by
MANATORY injunction re-
store the status quo.
See APPX CHT No. “43.”
(5) Writ of Mandamus: A writ issued
by a superior court to COMPEL a
lower court or a government officer
to PERFORM MANDATORY and
purely MINISTERIAL duties
CORRECTLY.
“Alternative Mandamus: A
mandamus issued upon the
FIRST application of relief,
commanding the defendant
either to PERFORM the act
DEMANDED or to APPEAR
before the court at a speci-
fied time to SHOW CAUSE
for not performing it.”
“Peremptory Mandamus: An
ABSOLUTE and UNQUAL-
IFIED command to the de-
fendant to DO the act in
question.”

105. Page 74 of 80
Heckler v. Ringer, 104 S.Ct.
2013 (1984) - Common-law
writ of mandamus is intend-
ed to provide a remedy for a
plaintiff only if he has ex-
hausted all of the avenues of
relief and only if the defend-
ant owes him a clear nondis-
cretionary duty. 28 U.S.C.A.
§ 1361.
See APPX CHT No. “44.”
U.S. ex rel. McLennan v.
Wilbur, 51 S.Ct. 502 (1931) -
Writ of mandamus will issue
only where duty to be per-
formed is ministerial and ob-
ligation to act peremptory
and plainly defined.
See APPX CHT No. “45.”
Supervisors v. U.S., 85 U.S.
71 (1873) - The office of a
writ of mandamus is not to
create duties but to compel
the discharge of those al-
ready existing.
Reeside v. Walker, 52 U.S.
272 (1850) - A mandamus is
only to compel performance
of some ministerial, as well
as legal duty.
(6) Writ of Prohibition: (1) A law or
order that FORBIDS a certain ac-

106. Page 75 of 80
tion. (2) An extraordinary writ is-
sued by an appellate court to pre-
vent a lower court from exceeding
its jurisdiction or to prevent a non-
judicial officer or entity from exer-
cising a power.
“Prohibition is a kind of
common-law injunction to
prevent an unlawful as-
sumption of jurisdiction . . .
It is a common-law injunc-
tion against governmental
usurpation, as where one is
called coram non judice (be-
fore a judge unauthorized to
take cognizance of the af-
fair), to answer in a tribunal
that has no legal cognizance
of the cause. It arrests the
proceedings of any tribunal,
board, or person exercising
judicial functions in a man-
ner or by means not within
its jurisdiction or discretion.
Benjamin J. Shipman,
Handbook of Common-Law
Pleading § 341, at 542 (Hen-
ry Winthorp Ballantine ed.,
3d ed. 1923).”
U.S. v. Hoffman, 71 U.S. 158
(1866) - The “writ of prohibi-
tion” is one which commands
person to whom it is directed
not to do something which
by relator's suggestion, court
is informed he is about to do;

107. Page 76 of 80
and if thing be already done,
writ of prohibition could not
undo it, for such would re-
quire affirmative act; and
only effect of writ of prohibi-
tion is to suspend all action,
and to prevent any further
proceeding in prohibited di-
rection.
See APPX CHT No. “46.”
(7) Writ of Review - A general form of
process issuing from an appellate
court to BRING UP FOR REVIEW
the RECORD of the proceedings in
the court below.
Zuber v. Allen, 90 S.Ct. 314
(1969) - When action is tak-
en on a record administra-
tive department cannot then
present testimony in court to
remedy the gaps in the rec-
ord, any more than argu-
ments of counsel on review
can substitute for an agen-
cy's failure to make findings
or give reasons.
La Buy v. Howes Leather
Company, 77 S.Ct. 309
(U.S.,1957) - Where subject
concerns enforcement of
rules which by law it is duty
of Supreme Court to formu-
late and put in force, man-
damus should issue to pre-

108. Page 77 of 80
vent such action thereunder
as is so palpably improper as
to place it beyond the scope
of the rule invoked.
See APPX CHT No. “47.”
(8) Writ of Supersedeas - A writ that
SUSPENDS a judgment creditor’s
power to levy execution, usu. pend-
ing appeal.
(9) Writ of SUPERVISORY CON-
TROL: A writ issued to CORRECT
an ERRONEOUS ruling made by a
lower court EITHER when there is
NO appeal or when an appeal
CANNOT provide adequate relief
and the ruling WILL RESULT in
GROSS INJUSTICE.
Fisher v. District Court of
Sixteenth Judicial Dist. of
Montana, in and for Rosebud
County, 96 S.Ct. 943 (1976) -
Writ of supervisory control is
available only in original
proceeding in . . .Supreme
Court and, although it may
issue in broad range of cir-
cumstances, it is not equiva-
lent to an appeal. 28
U.S.C.A. § 1257(3).
See APPX CHT No. “48.”
U.S. v. Comstock, 130 S.Ct.
1949 (U.S.,2010) - At com-

109. Page 78 of 80
mon law, one who takes
charge of a third person is
under a duty to exercise rea-
sonable care to control that
person to prevent him from
causing reasonably foreseea-
ble bodily harm to others.
(10) Writ of Securitate Pacis: A writ for
someone FEARING bodily harm
from another, as when the person
has been THREATENED with VI-
OLENCE.
(11) Extraterritorial Writs: Beyond the
geographic limits of a particular ju-
risdiction.
Corporation created by a
state is citizen of that state
within meaning of Constitu-
tion and United States stat-
ute investing Supreme Court
with original jurisdiction of
controversies between state
and citizens of other states.
Wisconsin v. Pelican Ins.
Co., 127 US 265, 32 L Ed
239, 8 S Ct. 1370 (1888) (ov-
rld in part on other grounds
by Milwaukee County v M.E.
White Co. (1935) 296 US
268, 80 L Ed 220, 56 S. Ct.
229)).

110. Page 79 of 80
X. CONCLUSION and RELIEF SOUGHT
For the above foregoing reasons provided in this in-
stant Petition(s) for: ORIGINAL WRIT – WRIT OF MANDAMUS
– WRIT OF PROHIBITION – WRIT OF CONSPIRACY – WRIT OF
EXIGI FACIAS - WRIT OF INJUNCTION - WRIT OF MANDAMUS -
WRIT OF REVIEW - WRIT OF SUPERSEDEAS - WRIT OF SUPERVI-
SORY CONTROL - WRIT OF SECURITATE PACIS - EXTRATERRI-
TORIAL WRITS and supporting Appendix, the relief sought
herein, as a matter of law, is to be GRANTED.

111. Page 80 of 80
XI. CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and cor-
rect copy of the forgoing pleading was MAILED via U.S.
Mail first-class to:
Honorable Tom S. Lee – Judge
J. T. Noblin – Clerk
USDC-Southern District MS (Jackson)
501 E. Court Street – Suite 2.500
Jackson, Mississippi 39201
PHELPS DUNBAR LLP
c/o W. Thomas Siler, Jr., Esq.
Jason T. Marsh, Esq.
Post Office Box 16114
Jackson, Mississippi 39236-6114
Solicitor General of the United States18
United States Department of Justice
950 Pennsylvania Avenue, N.W. – Room
5614
Washington, D.C. 20530
Barack H. Obama – U.S. President19
Executive Office of the President
1600 Pennsylvania Avenue, NW
Washington, DC 20500-0005
18 USPS Delivery Confirmation No. 03113260000101213679
19 USPS Delivery Confirmation No. 23061570000105859707

112. XII. APPENDIX
In compliance with the Rules of the Supreme Court
of the United States and in good faith of mitigating costs
because Appendix is VOLUMINOUS, the documents that is
to be included in the JOINT APPENDIX are provided at
APPENDIX “6” – Appendix Chart may be found at the fol-
lowing link as well:
https://secure.filesanywhere.com/fs/v.aspx?v=
8a72648b595e7377b06e
APPX DESCRIPTION
1 08/20/12 - Judgment DISMISSING Newsome’s
Complaint WITH prejudice
2 08/20/12 - Order DENYING Newsome’s Motion to
Disqualification and DEMAND for Jury Trial
3 08/20/12 - Memorandum Opinion GRANTING
Named Defendants’ Motion to Dismiss for “failure
to state a claim”
4 09/20/12 – Notice of Filing of an “ORIGINAL” Ac-
tion/Appeal in the Supreme Court of the United
States
5 Affidavit of DISQUALIFICATION [ONLY] and
Link for: OBJECTION(S) To August 2, 2012 Or-
der Of Judge Tom S. Lee; Motion For DISQUAL-
IFICATION; AND DEMAND FOR JURY TRIAL
(“OBJECTION(S) TO 08/02/12 ORDER”)
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b595e75bc719a

113. APPENDIX “6” – APPENDIX CHART CONTAINS THE FOLLOW-
ING:
NO.
6 DOCKET SHEET – Newsome v. Page Kruger &
Holland P.A., et al
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b595f6d7d6b9b
7 Recusal Orders by Tom S. Lee
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b595f6ea56c9c
8 Docket Sheet – Newsome v. Entergy
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b595f71b3b26a
9 Bradley S. Clanton – Baker Donelson Information
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b595f72ae9ca5
10 Judge G. Thomas Porteous Impeachment Articles
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b595f76ae9ca5
11 09/24/04 - Request for Department of Justice's In-
tervention/ Participation in this Case
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59606eb2a1aa
12 05/15/12 - Request for Conflict of Interest Infor-
mation, Notice of Opposition to Magistrate Judge
Assignment; and Notice of Address
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596070b8a6af

114. 13 08/15/12 - OBJECTION(S) To August 2, 2012 Or-
der Of Judge Tom S. Lee; Motion For DISQUAL-
IFICATION; AND DEMAND FOR JURY TRIAL
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596075b96e97
14 07/17/12 - Motion to Strike Motion To Dismiss
and Memorandum In Support Of Motion To Dis-
miss; Motion for Rule 11 Sanctions of and Against
Defendants; and Motion for Default Judgment
(Jury Trial Demanded in this Action)
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59616dae9ca5
15 07/17/12 – Cover Letter to Court Filing
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59616ebca99b
16 07/30/12 - Motion to Strike Motion To Stay All
Proceedings Pending A ruling On Defendants’
Motion To Dismiss and Memorandum In Support
Of Motion To Stay All Proceedings Pending A
Ruling On Defendants’ Motion To Dismiss; Mo-
tion for Rule 11 Sanctions of and Against Defend-
ants; and Motion for Default Judgment (Jury Tri-
al Demanded in this Action)
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59616fb1a0a9
17 08/02/12 – Order GRANTING Motion to Stay
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596170afaf67
18 08/14/12 - Motion to Strike Defendants’ Response
In Opposition To Plaintiff’s Motion To Strike Mo-
tion To Dismiss and Memorandum In Support Of
Motion To Dismiss; Motion To Strike Defendants’
Response In Opposition To Plaintiff’s Motion For
Rule 11 Sanctions Of And Against Defendants;

115. and Motion To Strike Defendants’ Response In
Opposition To Plaintiff’s Motion For Default
Judgment; Plaintiff’s Motion for Rule 11 Sanc-
tions of and Against Defendants; and Motion for
Default Judgment (Jury Trial Demanded in this
Action)
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b5961717d6c9b
19 Baker Donelson - Listing of Government Posi-
tions
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59617275ae6d
20 Baker Donelson – Listing of Government Posi-
tions (09/11/04)
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b5961747aa0a2
21 Baker Donelson’s Website Listing of Government
Positions
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596176b3a06b
22 07/18/11 – Newsome’s Letter to Supreme Court of
United States
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59626db3b36a
23 Conduct or Bias of Law Clerk or Other Judicial
Support Personnel As Warranting Recusal of
FEDERAL Judge or Magistrate
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59626fb19fa8
24 DISQUALIFICATION of Supreme Court Justic-
es: The Certiorari Conundrum

116. https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596270769c9e
25 HOOD vs. HOFFMAN-LAROCHE, LTD, District
of Columbia District Court, Case No. 1:06-cv-
01484
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596271bcaa69
26 Phelps Dunbar and Page Kruger & Holland Cli-
ent Listings:
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596272b19fa8
27 W. Lee Rawls Information
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596273bdac6a
28 President Barack Obama’s “Secret Kill List” Arti-
cle
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596275b8a7af
29 David Addington Information
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59636db6a4ad
30 28 USC § 1651
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59636eb2b169
31 Morrow v. District of Columbia
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596370a66ca8
32 Platt v. Minnesota Min. & Mfg. Co.
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596372b0af67

117. 33 De Beers Consol. Mines v. U.S.
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596374aead67
34 Google Search Information Regarding Vogel
Newsome
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596375a76eaa
35 Adams v. U.S. ex rel. McCann
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596376bcab6a
36 Ex parte Milwaukee R. Co.
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59646ea66d9d
37 Platt v. Minnesota Min. & Mfg. Co.
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596471bead6c
38 Liljeberg v. Health Services Acquisition Corp.
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596474769c9e
39 COMPLAINT – Newsome v. Page Kruger & Hol-
land et al.
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596476759b9d
40 Hare v. City of Corinth, Miss.
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59656fbba968
41 05/16/06 – TERMINATION Email (Page Kruger
& Holland)
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596571769c9e

118. 42 Salinas v. U.S
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596573aa72a2
43 Porter v. Lee
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596574b5b46c
44 Heckler v. Ringer
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596576b96e99
45 U.S. ex rel. McLennan v. Wilbur
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59666fa8709f
46 U.S. v. Hoffman
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b596671b0af67
47 La Buy v. Howes Leather Company
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59676d79b197
48 Fisher v. District Court of Sixteenth Judicial
Dist. of Montana, in and for Rosebud County
https://secure.filesanywhere.com/fs/v.aspx?v=8a7
2648b59676ea5a56c

119. APPX “1”
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF MISSISSIPPI
JACKSON DIVISION
VOGEL NEWSOME PLAINTIFF
VS. CIVIL ACTION NO. 3:12CV342TSL-MTP
PAGE KRUGER &
HOLLAND, P.A., ET AL. DEFENDANTS
JUDGMENT
In accordance with the memorandum opinion and
order entered this date, it is hereby ORDERED AND AD-
JUDGED that the complaint in this action is dismissed
with prejudice.
SO ORDERED AND ADJUDGED this 20th day of
August, 2012.
/s/ Tom S. Lee______________
UNITED STATES DISTRICT JUDGE

120. APPX “2”
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF MISSISSIPPI
JACKSON DIVISION
VOGEL NEWSOME PLAINTIFF
VS. CIVIL ACTION NO. 3:12CV342TSL-MTP
PAGE KRUGER &
HOLLAND, P.A., ET AL. DEFENDANTS
ORDER
It is hereby ordered that plaintiff’s motion to recuse,
styled as a motion for conflict of interest information, is de-
nied. See Andrade v. Chojnacki, 338 F.3d 448, 454 (5th Cir.
2003) (internal citations and quotations omitted) (“[a] judge
abuses his discretion in denying recusal where a reasonable
man, cognizant of the relevant circumstances surrounding
[the] judge's failure to recuse, would harbor legitimate
doubts about that judge's impartiality.”); and United States
v. Randall, 440 Fed. Appx. 283, 286 (5th Cir. Sept. 1, 2011)
(internal citations and quotations omitted) (“As a general
rule, for purposes of recusal, a judge's ‘personal knowledge’
of evidentiary facts means ‘extrajudicial,’ so facts learned

121. by a judge in his or her judicial capacity regarding the par-
ties before the court, whether learned in the same or a re-
lated proceeding, cannot be the basis for disqualification[,]”
thus, “[m]ere prior knowledge of some facts concerning a
litigant ... is not in itself necessarily sufficient to require
disqualification.”).
SO ORDERED this the 20th day of August, 2012.
/s/ Tom S. Lee________
UNITED STATES DISTRICT JUDGE

122. APPX “3”
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF MISSISSIPPI
JACKSON DIVISION
VOGEL NEWSOME PLAINTIFF
VS. CIVIL ACTION NO. 3:12CV342TSL-MTP
PAGE KRUGER &
HOLLAND, P.A., ET AL. DEFENDANTS
MEMORANDUM OPINION AND ORDER
This cause is before the court on the motion of de-
fendants Page Kruger & Holland, P.A. (PKH), Thomas Y.
Page, Louis G. Baine, III, and Linda Thomas to dismiss for
failure to state a claim upon which relief may be granted
pursuant to Rule 12(b)(6) of the Federal Rules of Civil Pro-
cedure. In response to the motion, pro se plaintiff Vogel
Newsome has filed a motion to strike defendants’ motion to
dismiss by which she not only objects to the filing of de-
fendants’ motion and memorandum of authorities, but also
sets forward a substantive response to the motion.20 Hav-
20 Within the text of her motion to strike, plaintiff also purports to seek
Rule 11 sanctions and default judgment against these defendants. Plaintiff is
clearly not entitled to either, and those putative motions are denied.

123. ing considered the parties’ submissions, the court concludes
that defendants’ motion to dismiss is well taken and should
be granted and that plaintiff’s motion to strike should be
denied.
On May 15, 2012, plaintiff instituted this action
against her former employer, Page Kruger & Holland, P.A.,
and several of the shareholders and/or employees of the law
firm. Her 143-page complaint purports to set out fourteen
claims against defendants relating to the termination of her
employment. According to the complaint, plaintiff began
her employment with PKH on January 2, 2005, as tempo-
rary legal secretary and was hired as a full-time employee
on January 31, 2005. On March 15, 2006, she filed a law-
suit against a Jackson-area apartment complex, charging
that she had been unlawfully evicted. Two months later, on
May 15, 2006, PKH terminated Newsome’s employment.
Her current complaint avers that her termination was not
only racially motivated, but was also in retaliation for her

124. previous lawsuit. Specifically, the complaint purports to
state claims for:
Count I - 42 U.S.C. § 1981: Equal Rights Under The
Law Against Defendants;
Count II -42 U.S.C. § 1985: Conspiracy to Interfere
with Civil Rights and 42 U.S.C. § 1981: Equal Rights
Under the Law Against Defendant(s);
Count III- 42 U.S.C. § 1986; Action For Neglect to
Prevent and 42 U.S.C. § 1981: Equal Rights under
the Law Against Defendant(s);
Count IV - Negligent Interference with Employment
and 42 U.S.C. § 1981: Equal Rights Under the Law
Against Defendant(s);
Count V- Discrimination in Employment and 42
U.S.C. § 1981: Equal Rights Under the Law Against
Defendant(s);
Count II [sic]- Retaliation and 42 U.S.C. § 1981:
Equal Rights Under the Law Against Defendant(s);
Count IIIII [sic] -Breach of Express Employment
Agreement 42 U.S.C. § 1981: Equal Rights Under the
Law Against Defendant(s);
Count VIII- Breach of Covenant of Good Faith and
Fair Dealing 42 U.S.C. § 1981: Equal Rights Under
the Law Against Defendant(s);
Count IX- Negligent Infliction of Emotional Distress
42 U.S.C. § 1981: Equal Rights Under the Law
Against Defendant(s);
Count X- Fraud Against and 42 U.S.C. § 1981: Equal
Rights Under the Law Against Defendant(s);
Count XI- Negligent Interference with Employment -
Malicious Conspiracy to Cause Discharge from Em-
ployment and 42 U.S.C. § 1981: Equal Rights Under
the Law Against Defendant(s);
Count IVII [sic]- Violation of the Fourteenth
Amendment of the U.S. Constitution- Due Process

125. and 42 U.S.C. § 1981: Equal Rights Under the Law
Against Defendant(s);
and
Count VII - Violation of the Fourteenth Amendment-
Equal
Protection and 42 U.S.C. § 1981: Equal Rights Under
the
Law Against Defendant(s).
Defendants urge that, accepting as true the facts as
pled in the complaint, all of plaintiff’s claims are barred by
the statute of limitations and thus, subject to dismissal un-
der Rule 12(b)(6). See Jones v. Alcoa, Inc., 339 F.3d 359,
366 (5th Cir. 2003) (“A statute of limitations may support
dismissal under Rule 12(b)(6) where it is evident from the
plaintiff's pleadings that the action is barred and the plead-
ings fail to raise some basis for tolling or the like.”). They
reason that Newsome’s various claims necessarily accrued,
if at all, on May 15, 2006, the day she was terminated, and
are subject to statute of limitations of less than six years,
such that her complaint, filed six years after her termina-
tion, is untimely.
For her part, plaintiff does not dispute that her
claims arose on May 15, 2006, the date PK&H terminated

126. her employment.21 Rather, she takes the position that since
all of her claims are founded, at least in part, on § 1981,
they are all subject to the six-year statute of limitations ap-
plicable to claims under § 1981, and that consequently, her
complaint is timely, as it was filed May 15, 2012, one day
before expiration of the six-year limitations period.22 Plain-
tiff’s position is without merit.
In support of her argument, plaintiff relies on Tru-
villion v. Kings Daughters Hospital, 614 F.2d 520 (5th Cir.
1980), in which the court held that a § 1981 claim by an
employee against his employer was governed by Mississip-
pi’s six-year catch-all statute of limitation, Miss. Code § 15-
1-49, rather than the three-year statute of limitations gov-
21 Indeed, plaintiff points out in her response to defendants’ motion
that in a May 16, 2006 email to defendants, which was appended to her com-
plaint, she advised that she believed that she had been unlawfully terminated.
See Piotrowski v. City of Houston, 237 F.3d 567, 576 (citing Russell v. Bd. of
Trustees, 968 F.2d 489, 493 (5th Cir. 1992))(quoting Helton v. Clements, 832
F.2d 332, 335 (5th Cir. 1987)), cert. denied, 507 U.S. 914 (1993) (“Under federal
law, the [limitations] period begins to run ‘the moment the plaintiff becomes
aware that he has suffered an injury or has sufficient information to know that
he has been injured.’”).
22 As the court understands it, plaintiff’s position is that Count I of her
complaint relies solely on § 1981, and the remaining twelve claims are a hybrid
of § 1981 and other causes of action, and that since all thirteen claims are based
in part on § 1981, then they are all subject to the limitations period that gov-
erns § 1981 claims.

127. erning unwritten contracts. However, while Mississippi’s
catch-all statute of limitations was six years at the time
Truvillion was decided, the statute was amended effective
July 1, 1989, to shorten the period of limitations to three
years, Owens-Illinois, Inc. v. Edwards, 573 So. 2d 704, 705
(Miss. 1990), and thus, at the time of plaintiff’s termina-
tion, the limitations period applicable to § 1981 claims was
three years. Accordingly, accepting for the sake of argu-
ment plaintiff’s assertion that each count of her complaint
is brought under § 1981, it follows that all her claims are
time-barred as they were filed well over three years after
the claims accrued.23
Alternatively, were the limitations period(s) applica-
ble to plaintiff’s various claims determined by reference to
23 The court notes that, as defendants point out, there is a possibility
that plaintiff’s § 1981 claims are subject to the four-year limitation period set
forth in 28 U.S.C. § 1658. Fonteneaux v. Shell Oil Co., 289 Fed. Appx. 695, 698
(5th Cir., July 30, 2008) (“Because Section 1981 does not contain a statute of
limitations, traditionally the most analogous state statute of limitations has
been applied. Jones v. R.R. Donnelley & Sons Co., 541 U.S. 369, 371, 124 S. Ct.
1836, 158 L. Ed. 2d 645 (2004). [However,] [a]fter enactment of the 1991 Civil
Rights Bill by Congress, a four-year statute of limitations [set forth in 28 U.S.C.
§ 1658] applies “if the plaintiff's claim against the defendant was made possi-
ble” by the 1991 or later statute.”). Because, in the case at bar, plaintiff’s
claims would be barred even under the four-year statute of limitation, the court
will not endeavor to determine whether plaintiff’s claims were made possible by
the 1991 statute.

128. the non- § 1981 aspect of her claims, all her claims would
still be time-barred. See Green v. Vu, 393 Fed. Appx. 225,
226 (5th Cir. Aug. 27, 2010) (forum state’s general personal
injury statute of limitation applies to actions brought pur-
suant to § 1985(3)); 42 U.S.C. § 1986 (establishing one-year
statute of limitation); James v. Sadler, 909 F.2d 834, 836
(5th Cir. 1990) (finding in § 1983 suit asserting claims for
alleged violations of the constitution that “the three year
residual period provided by Section 15–1–49, Miss. Code
Ann. applies”); Miss. Code Ann. § 15-1-29 (providing one-
year limitations period for actions based on unwritten con-
tract of employment); Rankin v. Am. Gen. Fin., Inc., 912 So.
2d 725 (Miss. 2005) (holding that breach of implied cove-
nant of good faith and fair dealing, negligent misrepresen-
tation, fraudulent misrepresentation and negligence are
subject to three-year limitations period under Miss. Code
Ann. § 15-1-49).
Accordingly, based on the foregoing, it is ordered that
defendants’ motion to dismiss for failure to state a claim is

129. granted. It is further ordered that plaintiff’s motion to
strike the motion to dismiss is denied as to all aspects of
relief requested thereby.
A separate judgment will be entered in accordance
with Rule 58 of the Federal Rules of Civil Procedure.
SO ORDERED this 20th day of August, 2012.
_/s/ Tom S. Lee____________________
UNITED STATES DISTRICT JUDGE

130. APPX “4”
IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT – JACKSON DIVISION
VOGEL DENISE NEWSOME PLAINTIFF
V. CIVIL ACTION NO. 3:12-cv-00342
PAGE KRUGER &
HOLLAND P.A., ET AL. DEFENDANTS
NOTICE OF FILING
OF AN “ORIGINAL” ACTION/APPEAL IN THE
SUPREME COURT OF THE UNITED STATES 24
Notice is hereby given that Vogel Denise Newsome
(“Newsome”), Plaintiff in the above entitled action, WITH-
OUT waiving here rights to a JURY TRIAL and REITER-
ATING Objection(s) to Judge Tom S. Lee’s presiding over
this lawsuit and hereby submits this, her, Notice of Filing
of an “ORIGINAL” Action/Appeal in the Supreme Court of
the United States (“NOF-OA-US SCT”) seeking to bring an
ORGINAL Action to the Supreme Court of the United
States from the JUDGMENT of this Court entered on or
24 NOTE: Boldface, caps, small-caps, italics, highlights and underline
represents “emphasis” added.

131. about August 20, 2012 – See EXHIBIT “A” – Judgment at-
tached hereto and incorporated by reference.
This ORIGINAL Action is taken pursuant to Rule
applying to an action which invokes the Supreme Court of
the United States ORIGINAL jurisdiction under Article III
of the Constitution of the United States and any/all appli-
cable statutes/laws governing said matters. In that New-
some may also seek for EXTRAORDINARY Writ(s) under
the “All Writs Act” pursuant to 28 § 1651(a) and any/all ap-
plicable statutes/laws, this instant filing is hereby served
for purposes of PRESERVING any/all rights and protec-
tions Newsome may have under the laws of the United
States of America. Therefore, in support thereof and in
good faith in aiding this Court in the filing of this instant
pleading, Newsome provides at EXHIBIT “B” a copy of the
Supreme Court of the United States Rules as well as states
the following the following in support thereof:
1. This instant NOF-OA-US SCT is submit-
ted in good faith and is not submitted for
purposes of delay, harassment, hindering

132. proceedings, embarrassment, obstructing
the administration of justice, vexatious lit-
igation, increasing the cost of litigation,
etc. and is filed to protect and preserve the
rights of Newsome secured/guaranteed un-
der the United States Constitution and
other laws of the United States of America.
2. Rule 17 (Procedure in an Original Action)
of the Rules of the Supreme Court of the
United States (“US SCt”) provides for the
filing under said court’s original jurisdic-
tion in that Newsome’s legal action:
(a) Involve sitting United States Dis-
trict Court/Article III Judge(s) – i.e.
as Judge Tom S. Lee;
(b) Involve parties of diverse/multiple
jurisdictions that are NOT within
the lower courts’ jurisdiction;
(c) Seeks to bring parties to this ac-
tion, a sitting United States of
America President (Barack Hus-
sein Obama II), his legal coun-
sel/advisor Baker Donelson Bear-
man Caldwell & Berkowitz as well
as members of his Administration,
member of the United States of
America’s Congress that appear
may have an interest in the out-
come of this litigation and appears
are presently engaging in unlaw-
ful/illegal practices in the OB-
STRUCTION of justice and judicial
proceedings, etc.;

133. (d) Involve matters of extraordinary,
exceptional and public importance;
(e) Will address matters protected un-
der the Constitution of the United
Stats and other laws of the United
States of America; and
(f) Addresses legal violations known
to this Court as well as the Su-
preme Court of the United States
in which the laws are clear are to
be corrected.
3. In accordance with Rule 17 (4) of the Rules
of the Supreme Court of the United States,
Newsome’s ORIGINAL Action will be
placed on the docket when the “Motion for
Leave to File” and the “Initial Pleading”
are filed with the Clerk. The Docket FEE
pursuant to the Rule 38(a) of the Supreme
Court is to be PAID upon receipt of said
pleadings. See EXHIBIT “B” at Rule 17 at-
tached hereto and incorporated by refer-
ence as if set forth in full herein.
4. To the extent that the Supreme Court of
the United States may want to view New-
some’s ORIGINAL Action as an EX-
TRAORDINARY Writ under the “All Writs
Act,” pursuant to 28 U.S.C. § 1651 and
any/all applicable statutes/laws governing
said matters, this instant pleading is sub-
mitted to support NOF-OA-US SCT is in
accordance with the laws of the United
States of America.

134. 5. This Court, Named Defendants (Page Kru-
ger & Holland P.A., Thomas Y. Page, Louis
G. Baine III, and Linda Thomas) and
their Counsel (Phelps Dunbar/W. Thomas
Siler, Jr./Jason T. Marsh) are fully aware
of the matter Newsome has pending before
the Supreme Court of the United States
and said court’s efforts to STALL proceed-
ings as they try and get United States of
America President Barack Obama through
the November 2012 Elections as well as
keep the TRUTH about his origin of birth
and matters of the 9/11 DOMESTIC Ter-
rorist attacks orchestrated by TERRORIST
Regimes as Baker Donelson and their al-
lies from coming to the LIGHT! In fact,
Newsome having received as recent as
September 8, 2012, correspondence dated
June 18, 2012 in response to her August
25, 2012 submittal. See EXHIBIT “D” -
Copy of August 31, 2012 Supreme Court’s
Postage of Mailing and June 18, 2012 let-
ter – attached hereto and incorporated by
reference as if set forth in full herein.
6. As the UPRISING and REVOLUTIONS
continue to INCREASE, of course New-
some is SMILING – it appears the
“CHICKENS are COMING HOME to
ROOST!” The uprising/revolutions having
NOTHING to do with a VIDEO that has
been circulating for MONTHS; so if the
MEDIA wants to MISLEAD/DECEIVE the
people to think that it is over some LUNA-
TIC’S/WHITE RACIST’S (Pastor Terry
Jones) video, and have with WILLFUL and
MALICIOUS intent spread this video for
purposes of MASKING/HIDING from the

135. Public/World the TRUTH behind the UP-
RISINGS/REVOLUTIONS. As a CHRIS-
TIAN, Newsome can validly state that the
actions of this lunatic Terry Jones and the
United States of America’s RACIST Gov-
ernment Leaders to attack the Muslim
Faith/Values are NOT that of TRUE Chris-
tians because Christians are NOT insecure
in their beliefs and values and are CHRIST
did NOT promote such RACIST practices.
However, such RACIST organizations as
the Ku Klux Klan (i.e. in which the likes of
Baker Donelson, United States Congress,
etc.) use their positions and powers to
DISTORT and PROMOTE their RACIST
Agendas. Newsome just SMILES because
there are MANY media sources and the
PUBLIC that are NOT buying this LIE!!
Newsome taking advantage of ALL of this
FREE TIME she has on her hand. 
7. Newsome through this instant filing also
DEMANDS that this Court advise her of
any/all –CONFLICTS-OF-INTERESTS
known to its Judge(s) and Judicial Offi-
cial(s) warranting DISQUALIFICA-
TION/RECUSAL.
8. Newsome further REITERATES that un-
der the Constitution of the United States,
she is ENTITLED to a JURY Trial on the
issues that Judge Tom S. Lee USURPED
and/or ABUSED authority and rendered a
ruling on in which he with KNOWLEDGE
that he LACKED jurisdiction to act.
9. Newsome believes that the record evidence
will support this Court’s UNLAW-

136. FUL/ILLEGAL and UNETHICAL practic-
es in the role it is playing in the CON-
SPIRACIES leveled against Newsome.
Moreover, this Court’s KNOWLEDGE of
the role that Baker Donelson Bearman
Caldwell & Berkowitz (i.e. Legal Counsel
for Federal Judges/Judge Tom S. Lee, etc.,
the President of the United States of Amer-
ica (Barack Obama), Members of the Unit-
ed States Congress as well as Justices of
the Supreme Court of the United States,
etc.); however, did with WILLFUL and
MALICIOUS intent withhold perti-
nent/relevant information from Newsome.
Moreover, this Court’s KNOWLEDGE of
the “TAG-TEAM” Litigation – i.e. in which
Baker Donelson uses such firms as Named
Defendants’ Legal Counsel (Phelps Dun-
bar) to MASK/SHIELD their ROLE and
INTEREST in litigation involving New-
some. Pertinent/Relevant facts which have
been timely, properly and adequately
raised through Newsome’s pleadings in
this lawsuit. For instance, as recent as
Newsome’s July 25, 2012 pleading entitled,
“MOTION TO STRIKE MOTION TO STAY ALL
PROCEEDINGS PENDING A RULING ON DE-
FENDANTS’ MOTION TO DISMISS and MEMO-
RANDUM IN SUPPORT OF MOTION TO STAY
ALL PROCEEDINGS PENDING A RULING ON
DEFENDANTS’ MOTION TO DISMISS; Motion
for Rule 11 Sanctions of and Against De-
fendants; and Motion for Default Judg-
ment (Jury Trial Demanded in this Action)
– Doc No. 19, she states at approximately
27, Paragraph 49 (a):

137. . . .In fact, there is EVI-
DENCE of how Phelps Dun-
bar and Baker Donelson
TEAM UP and/or engage
JOINTLY in legal actions on
behalf of their clients. . .
For instance, Newsome’s RESEARCH has
yielded information wherein Baker Donel-
son engages in “TAG-TEAM Litigation” –
i.e. lawsuits in which Baker Donelson may
SHARE Clients also represented by other
Law Firms and SHARE in the expenses
and representation of clients. For in-
stance, see HOOD vs. HOFFMAN-
LAROCHE, LTD, District of Columbia Dis-
trict Court, Case No. 1:06-cv-01484 – EX-
HIBIT “C” attached hereto and incorpo-
rated by reference as if set forth in full
herein – where Baker Donelson TAG-
TEAMS with Law Firms as Butler Snow
O’Mara Stevens & Cannada PLLC (“Butler
Snow”) and Phelps Dunbar LLP (“Phelps
Dunbar”). Of course, like Baker Donelson,
their associating law firms enjoy sharing
their CLIENT LISTINGS with the PUB-
LIC.
While Phelps Dunbar is presently repre-
senting the Named Defendants (Page Kru-
ger & Holland P.A., Thomas Y. Page, Louis
G. Baine III, and Linda Thomas) in this
instant lawsuit, Butler Snow attempted to
UNLAWFULLY/ILLEGALLY enter the
lawsuit WITHOUT making an appearance
before this Court styled Newsome vs.
Mitchell McNutt & Sams (3:10-cv-0074).

138. WHEREFORE, PREMISES CONSIDERED, please
docket this instant NOTICE OF FILING OF AN “ORIGI-
NAL” ACTION/APPEAL IN THE SUPREME COURT OF
THE UNITED STATES.
Respectfully submitted this 15TH day of September,
2012.
___________________________________
Vogel Newsome, PLAINTIFF - PRO SE
Post Office Box 14731
Cincinnati, Ohio 45250
Phone: (513) 680-2922 or (601) 885-9536

139. APPX “5”
AFFIDAVIT ONLY PROVIDED IN THIS APPENDIX:
IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT – JACKSON DIVISION
VOGEL DENISE NEWSOME PLAINTIFF
V. CIVIL ACTION NO. _____________________________
APAGE KRUGER & HOLLAND , P.A.;
a Mississippi Corporation;
THOMAS Y. PAGE, in his official and
individual capacity; LOUIS G. BAINE, III,
in his official and individual capacity;
LINDA THOMAS, in her official and
individual capacity; and DOES 1-100,
in their official and individual capacities DEFENDANTS
PLAINTIFF’S REQUEST FOR CONFLICT OF INTEREST
INFORMATION, NOTICE OF OPPOSITION TO MAGIS-
TRATE JUDGE ASSIGNMENT; AND
NOTICE OF ADDRESS
For Pleading see:
https://secure.filesanywhere.com/fs/v.aspx?v=8a72648b595e
75bc719a

140. IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT – JACKSON DIVISION
VOGEL DENISE NEWSOME PLAINTIFF
V. CIVIL ACTION NO. 3:12-cv-00342
PAGE KRUGER &
HOLLAND P.A., ET AL. DEFENDANTS
VOGEL DENISE NEWSOME’S AFFIDAVIT OF
DISQUALIFICATION OF JUDGE TOM S. LEE 25
STATE OF OHIO )
) SS
COUNTY OF HAMILTON )
I, Vogel Denise Newsome (“Newsome”), being first duly
sworn, deposes and states:
1. Newsome is the Plaintiff in the above-
entitled action.
2. Newsome has personal knowledge as to
the claims and facts set forth in the Mo-
tions and Memorandum Brief in which
this Affidavit supports. Moreover, giving
rise to the lawsuit filed in this action.
25 NOTE: Boldface, caps, small-caps, italics, highlights and underline
represents “emphasis” added.

141. 3. Newsome is competent to testify to the
matters set forth in the Complaint and
her subsequent pleadings filed.
4. Newsome is informed and believe, and
based on such information and belief, al-
lege that the Honorable Tom S. Lee, the
Judge before whom the above-entitled
lawsuit is pending, has a personal bias
and/or prejudice against her and is in fa-
vor of Defendants Page Kruger & Holland
P.A., Thomas Y. Page, Louis G. Baine III,
Linda Thomas and their Legal Coun-
sel/Attorneys Phelps Dunbar LLP/W.
Thomas Siler, Jr./Jason T. Marsh.
5. Judge Tom S. Lee has a personal bias
and/or prejudice against me and is there-
fore disqualified to act in the above-
numbered and entitled cause under the
provisions of 28 U.S.C.A. § 455 based on
the reasons set forth in the OBJEC-
TION(S) To August 2, 2012 Order Of
Judge Tom S. Lee; Motion For DISQUAL-
IFICATION; AND DEMAND FOR JURY
TRIAL (“OBJECTION(S) TO 08/02/12
ORDER”) in which this Affidavit sup-
ports.
6. On or about May 12, 2012, Newsome
TIMELY and PROPERLY submitted for
filing her pleading entitled, Request for
Conflict of Interest Information, Notice of
Opposition to Magistrate Judge Assign-
ment; and Notice of Address (Doc. No.
2)/EXHIBIT “D” of the pleading to which
this Affidavit supports.

142. 7. The facts and the reasons for the belief
that such bias and/or prejudice exists are
as follows:
a) Judge Tom S. Lee’s bias and prejudice
towards Newsome.
b) Newsome has been and continues to
suffer irreparable injury harm as a di-
rect and proximate result of Judge Tom
S. Lee’s criminal/civil violations leveled
against her.
c) Judge Tom S. Lee’s acts are arbitrary
and MALICIOUS for purposes of caus-
ing Newsome injury/harm.
d) Judge Tom S. Lee’s is proceeding in this
lawsuit with KNOWLEDGE that he
lacks jurisdiction to preside over Law-
suit. Therefore, any and all claims to
Judge Lee may assert for Judicial IM-
MUNITY is NULL/VOID!
e) Appearance of impropriety.
f) Conflict of Interest exists.
g) Newsome has been deprived life, liberty
and pursuit of happiness.
h) Judge Tom S. Lee has a DU-
TY/OBLIGATION to make KNOWN
any/all conflicts of interest which pre-
cludes him from presiding over this
Lawsuit.

143. i) Newsome believes that further legal ac-
tions and the issuance of subpoena for
Judge Tom S. Lee will yield further evi-
dence of his DELIBERATE, WILLFUL
and MALICIOUS intent to destroy the
integrity of this Court and the judicial
process for purposes of providing his
CONSPIRATORS/CO-
CONSPIRATORS with an un-
due/unlawful/illegal advantage in Law-
suit.
j) Judge Tom S. Lee has substituted him-
self for the JURY which Newsome has
timely, properly and adequately DE-
MANDED and entered Order which has
deprived Newsome rights afford-
ed/secured and guaranteed under Rule
38 of the Federal Rules of Civil Proce-
dure, Seventh Amendment of the Unit-
ed States Constitution and other laws
of the United States governing rights to
Jury Trial.
k) Newsome did NOT waive her right to
JURY Trial and has REPEATEDLY as-
serted in her filings with this Court to
have claims/issues so triable decided by
a JURY – i.e. not Judge Tom S. Lee/this
Court. Newsome has NOT and does
NOT waive her RIGHT to Jury Trial on
triable issues/claims.
l) Judge Lee’s direct and personal finan-
cial/pecuniary interest in the outcome of
this Lawsuit.

144. m) Judge Tom S. Lee’s determination to
deprive Newsome of life, liberty, pursuit
of happiness and property, etc. and/or
rights secured/guaranteed under the
United States Constitution and other
laws of the United States governing
disqualification.
n) For the SAME reasons KNOWN and
giving rise to Judge Lee’s
RECUSAL/DISQUALIFICATIONS in
KKLM vs. Marsh USA, Joni B. Tyler
vs. JPF1 and Joyce Walker vs. Captain
D’s LLC, etc. - See EXHIBIT “F” of
“OBJECTION(S) TO 08/02/12 ORDER”
in which this Affidavit supports – in
that it appears that Baker Donelson
has and is playing a MAJOR/KEY role
in the running and controlling of this
lawsuit; however, has relied upon its
CONSPIRATOR Law Firm Phelps
Dunbar LLP to act as a “FRONT” to
shield/mask their criminal/civil wrongs
from Newsome as well as the PUBLIC-
AT-LARGE!
o) Baker Donelson is Legal Coun-
sel/Attorneys for Federal Judges Asso-
ciation. See EXHIBIT “S” “OBJEC-
TION(S) TO 08/02/12 ORDER” in which
this Affidavit supports.
p) Baker Donelson played a MAJOR/KEY
role in having Judge Tom S. Lee ap-
pointed to the Judicial Bench.
q) Baker Donelson and Named Defend-
ants’ Counsel/Attorneys Phelps Dunbar

145. SHARE/SWAP attorneys. See EXHIB-
IT “T” “OBJECTION(S) TO 08/02/12
ORDER” in which this Affidavit sup-
ports. Moreover, SHARE Clients. In-
formation they are attempting to
SHIELD/HIDE from Newsome as well
as the PUBLIC-AT-LARGE!
r) Judge Tom S. Lee has been named in
other legal proceedings brought by
Newsome before the United States of
America Congress, etc. addressing his
unlawful/illegal and judicial miscon-
duct.
s) Judge Tom S. Lee is in a position in
which he is usurping powers in which
he lacks jurisdiction and/or is prohibit-
ed to assert and attempting to perform
dual roles as investigator and adjudica-
tor – i.e. encroaching upon the duties
and/or responsibilities of the Jury DE-
MANDED by Newsome in this Lawsuit.
t) Judge Tom S. Lee’s August 2, 2012 Or-
der staying proceedings is an “ABUSE”
of discretion and an act carried out by
him to fulfill his ROLE in conspiracies
leveled against Newsome.
u) Judge Toms S. Lee appears, is a mate-
rial witness to this instant Lawsuit.
v) Judge Tom S. Lee has PERSONAL
knowledge and an interest in disputed
evidentiary facts.

146. w) Judge Tom S. Lee has a finan-
cial/pecuniary interest in this Lawsuit.
x) Judge Tom S. Lee’s decisions are rooted
and grounded in extrajudicial matters.
y) Judge Tom S. Lee’s August 2, 2012 Or-
der was executed for purposes of com-
mitting FRAUD upon this Court, pur-
poses of delay, harassment, obstructing
justice, increasing costs of litigation,
embarrassment, sham/frivolousness,
unduly burdensome practices, providing
opposing parties (Defendants) with an
undue/unlawful/illegal advantage in
lawsuit, and other reasons known to
Judge Tom S. Lee in the fulfillment of
his role in conspiracies leveled against
Newsome.
z) The integrity of this Court has been
compromised.
aa) Objection(s)/Reasons set forth in “OB-
JECTION(S) TO 08/02/12 ORDER.”
bb) Newsome is presently engaging in Con-
gressional and/or further legal proceed-
ings in which a reasonable person
knowing the following facts and evi-
dence regarding the Governmental po-
sitions held/controlled by Baker Donel-
son Bearman Caldwell & Berkowitz
(“Baker Donelson”):
 Chief of Staff to the Presi-
dent of the United States

147.  United States Secretary of
State
 United States Senate Ma-
jority Leader
 Members of the United
States Senate
 Members of the United
States House of Repre-
sentatives
 Director of the Office of
Foreign Assets Control for
United States
 Department of Treasury
 Director of the Administra-
tive Office of the United
States
 Chief Counsel, Acting Di-
rector, and Acting Deputy
Director of United States
Citizenship & Immigration
Services within the United
States Department of
Homeland Security
 Majority and Minority
Staff Director of the Senate
Committee on Appropria-
tions
 Member of United States
President’s Domestic Poli-
cy Council
 Counselor to the Deputy
Secretary for the United
States Department of HHS

148.  Chief of Staff of the Su-
preme Court of the United
States
 Administrative Assistant
to the Chief Justice of the
United States
 Deputy under Secretary of
International Trade for the
United States Department
of Commerce
 Ambassador to Japan
 Ambassador to Turkey
 Ambassador to Saudi Ara-
bia
 Ambassador to the Sultan-
ate of Oman
 Governor of Tennessee
 Governor of Mississippi
 Deputy Governor and
Chief of Staff for the Gov-
ernor of Tennessee
 Commissioner of Finance
& Administration (Chief
Operating Officer) - State
of Tennessee
 Special Counselor to the
Governor of Virginia
 United States Circuit
Court of Appeals Judge
 United States District
Court Judges
 United States Attorneys

149.  Presidents of State and Lo-
cal Bar Associations
8. The “OBJECTION(S) TO 08/02/12 OR-
DER” to which this Affidavit supports
and this Affidavit is being filed in good
faith and is NOT imposed for purposes of
delay, harassment, hindering proceed-
ings, embarrassment, obstructing the
administration of justice, vexatious litiga-
tion, 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.
9. Newsome OBJECTS to the appointment
of this matter to Judge Tom Stewart Lee
and believes that he is to RECUSE and/or
DISQUALIFY himself from this lawsuit
for the reasons set forth in her previous
pleadings and this instant filing to which
this Affidavit supports.
10. Newsome OPPOSES and OBJECTS to
this Court’s allowing parties to abuse this
Court’s Electronic Filing System.
11. Newsome will be prejudiced by this
Court’s allowing the sham and frivolous
Motion to Dismiss and supporting Memo-
randum In Support of Motion To Dismiss
to remain a part of the record in that they
have been filed in violation of the stat-
utes/laws governing said matters.
12. There are genuine issues of material fact
which precludes the filing of Motion to

150. Stay and the supporting Memorandum
Brief; wherein resulting in Newsome’s
Motion to Strike and Motion for Default
Judgment as well as other relief set forth
in the Motions to which the Affidavit pro-
vided in support thereof.
13. All facts and/or claim set forth in the
Complaint are to be deemed as TRUE and
to date remain UNCONTESTED!
14. On or about June 6, 2012, Newsome time-
ly, properly and adequately notified
“Named Defendants” – Page Kruger &
Holland, Thomas Y. Page, Louis G. Baine
III and Linda Thomas [hereinafter
“Named Defendants”] – of the conse-
quences (i.e. that she will file Motion to
Strike and/or Motion for Default Judg-
ment) should they fail to comply with the
statutes and laws governing said matters.
15. Newsome believes that based upon the
facts, evidence and legal conclusions pro-
vided in the Complaint and her subse-
quent pleading, that a reasonable mind
may conclude that Named Defendants
and/or their Counsel (Phelps Dunbar/W.
Thomas Siler, Jr./Jason T. Marsh) did
knowingly and willing submit Motion to
Dismiss and Memorandum Briefs with
fraudulent intent – i.e. purposes of com-
mitting fraud upon this Court.
16. Newsome believes that the record evi-
dence will sustain that Judge Tom S. Lee,
“Named Defendants” and their Coun-

151. sel/Attorneys are before this Court with
DIRTY HANDS!
17. Newsome believes that it is important for
this Court to be fully aware as to what is
going on in matters outside this lawsuit
so that this Court can better understand
the unlawful/illegal acts of Judge Tom S.
Lee, Named Defendants and/or their
Counsel. Moreover, see through their
HIDDEN MOTIVES and AGENDAS!
18. The allegations set forth in the “OBJEC-
TION(S) TO 08/02/12 ORDER” to which
this Affidavit supports can be supported
by factual evidence in the record of
“Named Defendants” as well as pleading
in this lawsuit.
19. Newsome believes that when this Court
allows the UNLAWFUL/ILLEGAL prac-
tices as that in the submittal of Motion to
Stay and supporting Memorandum Brief,
it sends a message that such criminal and
unethical practices are accepted – i.e. all
you have to do is have BIG MONEY and
be a BIG LAW FIRM with influences in
HIGH PLACES.
20. Newsome believes that a reasonable per-
son/mind provided with the facts, evi-
dence and legal conclusions provided re-
garding disputed issues/claims regarding
Motion to Stay will reach a decision con-
trary to Judge Tom S. Lee. Therefore,
Newsome has timely, properly and ade-
quately DEMANDED a JURY Trial!

152. 21. Pursuant to Rule 26 of the Federal Rules
of Civil Procedure governing “INITIAL
DISCLOSURE,” the Named Defendants
have failed to provide Newsome with the
MANDATORY disclosure information
and Judge Tom S. Lee is CONSPIRING
with them to keep this information from
Newsome. Moreover, the PUBLIC-AT-
LARGE who may have an interest in this
lawsuit.
FURTHER, AFFIANT SAYETH NAUGHT,
Dated this 13th day of August, 2012.
___________________________
VOGEL DENISE NEWSOME,
Affiant
Subscribed and sworn to before me on the 13th day of Au-
gust, 2012.
____________________________________
NOTARY PUBLIC
Commission Expires: