Pretrial Conference Memorandum State of Maine v. Dorothy LaFortune Dorothy LaFortune's home was foreclosed and a Writ of Possession issued.  LaFortune contends that the foreclosure and writ were unlawful.  In Barb's opinion, the bureaucrats of the City of Biddeford goofed and LaFortune was not trespassing.  Where the foreclosure and writ were unlawful, the charge of criminal trespass must be dismissed.  These are, at least, some of the issues to be decided. These are some of the witnesses and documents from which LaFortune will glean, respectively, testimonial and documentary evidence at trial. The home addresses of the witnesses have been redacted out of concern for privacy.


 

STATE OF MAINE                                                                                     SUPERIOR COURT York, ss.                                                                               Location: Alfred Docket No. CR-03-1979  State of Maine Plaintiff v. Dorothy LaFortune Defendant  _______________________________________________  UPDATED PRETRIAL MEMORANDUM OF DEFENDANT

Through her successor counsel, Defendant submits this updated pretrial memorandum. Uncontroverted Facts    NOTE More uncontroverted facts have been discerned since writing this memorandum. On 10 April 2002, the City of Biddeford published the pending sale of its tax liens on LaFortune’s Graham Street property. The newspaper advertisement set forth 5 June 2002 as the date on which the sealed bids would be opened, reviewed, and awarded.  On 22 May 2002, without notice to LaFortune as required by 36 M.R.S.A. 943 and notwithstanding the publicly announced date for bidding, City Manager Bruce Benway ["Benway"] and Tax Collector Gayle Doyon ["Doyon"] prematurely both conducted a sealed-bid sale of the tax liens on the subject property and opened the bids. On 4 June 2002, the Biddeford City Council voted to accept a bid from Tim Q. Ly ["Ly"] and authorized the purchase by Tim Q. Ly of the tax lien on the subject property. On 21 June 2002, the City of Biddeford, through Benway and Doyon, delivered a Municipal Quitclaim Deed to Ly "to release the City of Biddeford’s interest, if any, arising from matured tax liens dated . . . Meaning and intending to convey to the grantee, the Grantor’s tax acquired interest." The consideration given by Ly in exchange for the deed was $80,000, a sum more than $50,000 in excess of the amount of the City’s monetary interest in the liens. On or around 24 June 2002, LaFortune challenged the validity of both the tax taking and the sale of the subject property, by initiating suit in York Superior Court against the City of Biddeford. During or around the week between 30 July 2002 and 7 August 2002, Ly, seeking possession of the subject property, initiated a forcible entry and detainer ["FED"] action against LaFortune in York District Court, which had "exclusive original jurisdiction of all actions of forcible entry and detainer to recover the possession of real property."  On 15 May 2003, Ly sought a Writ of Possession, and on 3 June 2003, over LaFortune’s opposition, the court issued the first Writ of Possession to Ly.  LaFortune had been denied a full and fair adjudication.  During June 2003, LaFortune appealed the ruling of the York Superior Court in Ly v. LaFortune to the Maine Supreme Judicial Court. Superior Court had also denied Lafortune's motion for a stay and issued a Writ of Possession, but her request for a stay of the Writ of Possession was granted by a single justice of the SJC. Ly v. LaFortune, 2003 Me. 119, ¶3. SJC Justice Levy then affirmed the lower-court decisions on 14 October 2003. 2003 Me. 119.  On 4 November 2003, a second Writ of Possession issued from Biddeford District Court giving the sheriffs the authority to remove LaFortune from her property on Graham Street in Biddeford.  On 12 November 2003, the Writ of Possession was again served on LaFortune. On 14 November 2003, Ly sought the assistance of the Biddeford police to enforce the writ and on 19 November 2003, a SWAT time forcibly removed LaFortune from her home on Graham Street. On or around 20 July 2004, LaFortune appealed the ruling of the York Superior Court in LaFortune v. City of Biddeford to the Maine Supreme Judicial Court, which has not yet disposed of the case. At no time since 24 June 2002 has LaFortune been given an opportunity to present evidence of her claims and defenses in her action against the Biddeford. At no time since 24 June 2002, when she filed LaFortune v. City of Biddeford, has LaFortune been given the opportunity that in York Superior Court "a trial bearing on the aspects of the merits of the action," that is, to determine whether she had superior title to the real property on Graham Street. LaFortune was similarly precluded in Ly v. LaFortune from defending her title during the trial in Biddeford District Court.On or around 20 July 2004, LaFortune appealed the ruling of the York Superior Court in LaFortune v. City of Biddeford to the Maine Supreme Judicial Court, which has not yet disposed of the case.  At no time since 24 June 2002, when she filed LaFortune v. City of Biddeford, has LaFortune been given the opportunity that in York Superior Court "a trial bearing on the aspects of the merits of the action," that is, to determine whether she had superior title to the real property on Graham Street.  LaFortune was similarly precluded in Ly v. LaFortune from defending her title during the trial in Biddeford District Court. Contested Issues of Fact      NOTE Five of these issues of fact address the  elements of the crime charged: criminal trespass   Whether the defendant had license or privilege to remain in 22 Graham Street in Biddeford on 11/14/03, the day that a SWAT team forcibly removed her from her home; specifically whether the defendant had the superior title to the real property  Whether the District Court order(s) are lawful Whether the Superior Court order(s) are lawful Whether the Supreme Court order(s) are lawful Whether the defendant acted in defiance of a lawful order Where the more than $50,000-plus surplus went Whether the statutes as to the procedure for tax liens and foreclosure were followed Contested Issues of Law Whether collateral estoppel may be used offensively by the prosecution. Whether audio and/or video and/or audiovideo tapes may be used by the prosecution. Whether the City of Biddeford waived its right to ownership when it sent tax bills to Ruel ["LaFortune "] after there was an automatic foreclosure on the property. Whether the City of Biddeford’s failure to discharge, in accordance with the statute, active liens and notice of automatic foreclosure caused the successive liens and notices of impending automatic foreclosure to be invalid and unlawful. Whether the City contributed to Ruel-LaFortune’s arrearages by encumbrancing her property to the extent that there was an ever-growing cloud on the title, such that the property could not be sold. Whether the City of Biddeford’s failure to record a Notice of Impending Automatic Foreclosure was a violation of 36 M.R.S.A. §943 and thus caused its sale of the property Tim Q. Ly unlawful. Whether the City of Biddeford foreclosed, in accordance with the statutes, on the property prior selling the property to Tim Q. Ly. Whether the City of Biddeford waived its right to ownership when it sent tax bills to Ruel ["LaFortune "] after it sold the property to Tim Q. Ly (circa June 2002). Whether a city waives its absolute ownership when it sends a tax bill to the mortgagor – i.e., the owner of the property prior to the foreclosure -- on a date after the foreclosure but before a sale of the property to a third-party. Whether the City of Biddeford waived its right to ownership -- or had foreclosed on Tim Q. Ly -- when it sent a tax bill to Ruel-LaFortune after it sold the property to Tim Q. Ly and accepted payment from her in May 2003. Whether the City of Biddeford waived its absolute ownership each and every time it failed to sell the property and continued to send her tax bills.  Whether the City of Biddeford waived its absolute ownership when the City failed to follow the foreclosure procedures of §§ 942 and 943. Whether the Writ of Possession was a lawful or unlawful order. Whether Ruel-LaFortune acted in defiance of a lawful order when she did not remove herself from Graham Street on or about 14 November 2003. List of Potential Witnesses   For reasons of privacy, the home addresses of the percipient witnesses have been redacted. A City Councilor (name as-yet unknown) Atty. Harry Center, of Smith Elliott Smith & Garmey and Attorney for the City, home address needed if will not consent to service at office Atty. Jens-Peter W. Bergen, 79 Portland Road, Kennebunk, ME 04043, 207-985-6789, home:  Atty. Roger S. Elliott (counsel for Saco & Biddeford Savings Bank),  Smith Elliott Smith & Garmey, 199 Main Street, P.O. Box 1179, Saco, ME 04072 207-774-3199; home:  Atty., real estate, Smith Elliott Smith & Garmey, 199 Main St., Saco, ME 04072, 207-282-1527, home address needed if will not consent to service at office Bruce Benway (former city manager), home address needed if will not consent to service at office Bruce Haskell, home:  Candice Gagne,  City Assessor, Frank W. Yattaw, 205 Main St., Biddeford, ME 04005, 207-284-9003, home address needed if will not consent to service at office  City Attorney Aaron Burns, 205 Main Street, Biddeford, ME 207-284-9307, home address needed if will not consent to service at office City Attorney Keith Jacques, 205 Main Street, Biddeford, ME, 207-284-9307, home address needed if will not consent to service at office  City Clerk Clarma Matherne, 205 Main Street, Biddeford, ME 207-284-9307 City Code Enforcement Officer, Richard Lambert City Council members City Councilor (former), former mayor, James Grattelo,  home:  City Councilor Rosemarie Sheltra,  home: City Manager & Treasurer, Edward R. Clifford, 205 Main St., Biddeford, ME 04005, 207-284-9313, home address needed if will not consent to service at office City Planner, Greg Tansley, 205 Main St., Biddeford, ME 04005, 207-284-9115, home address needed if will not consent to service at office City Police Chief Roger Beaupre, 39 Alfred Street, Biddeford, ME 04005; home:  City Tax Collector Gayle Doyon, home:  City Tax Collector (former), Robert L. Mathieu (deceased) City Tax Collector (former, circa 1993) Rene F. Camire, CMA, home: Donna Dion (former mayor), last known address:  Dorothy LaFortune (to be determined; likely not) Fred & Arlene Dolgon, Fred Hendrickson,  home: Fred W. Turner, CCIM, CPM, RPA, The Masiello Group, Commercial Division, 1465 Post Rd., Wells, ME 04090; home: Marge S. Poirier, home:  Mark Lawrence, D.A., York County Courthouse, P.O. Box 399, 45 Kennebunk Road, Alfred, ME 04002-0399, home:  Philip Castora, former city councilor, former ward representative, P.O. Box 187, Biddeford, ME 04005 Rep. Henry L. Joy, P.O. Box 103, Island Falls, ME 04747, home:  Robert Ruel (ex-husband),  home: Saco & Biddeford Savings Institution, Mark Jones, bank loan officer, 252 Main Street, P.O. Box 557, Saco, ME 04072 Saco & Biddeford Savings Institution, Kevin Savage, Pres. and CEO, 252 Main Street, P.O. Box 557, Saco, ME 04072 Tim Q. Ly, home:  William Zafirson, HAZA Auctioneer home: Defendant reserves the right to update this list of witnesses. Defendant will also continue searching for home addresses of the potential and percipient witnesses and will update accordingly. List of Potential Exhibits to Be Used at Trial   This list has been made more specific over the last 10 days since it was filed and served. And more documents have been added to those to be potentially used at trial since this list was filed and served. Abstract of Divorce, Book 5891 and Page 110, dated 11/21/94 Affidavit in Support of Notice of Lien Claim dated 15 May 2002 by Phil Castora Advertisements by Bruce Haskell City of Biddeford's receipt of money from Tim Q. Ly City Council order where bids opened privately in May 2002 City council tapes; Meetings televised and archived at public access Complaint against the City of Biddeford regarding title to real estate, filed in superior court which was pending Complaint for Foreclosure (SBSI v. DR) dated 11/2/94 Computer list of all delinquent taxpayers Correspondence from Center to Mayor Grattelo and councilors re Quitclaim Deed to bank Correspondence from bank to DFL alone Correspondence from bank to DFL and ex Correspondence from city Correspondence to bank from DFL alone Correspondence to bank from DFL and ex Correspondence to city Court orders Deed from bank to city Document 2002.51, dated 4 June 2002, published by the Board of City Council Foreclosure papers Handwritten letter dated 19 July 2002 by Tim Q. Ly to tenant Handwritten letter dated 22 February 1999 from Marge S. Poirier to LaFortune regarding ownership Judgment of Foreclosure and Sale (1995) for $75,345.44 Letter to DLF from Doyon re Tax Lien Certificate  Letter dated 10/ /1991 from the tax collector stating that an Abstract of Divorce is insufficient for transfer of title in the Tax Assessor's Office Letter dated 1993 from Harry Canter and re Abstract of Divorce WAS sufficient for transfer of title in the records at city hall Letter dated 14 January 1993 from Rene F. Camire, CMA, City of Biddeford re Abstract of Divorce Judgment insufficient to transfer title of transfer of real estate from Robert and Dorothy Ruel to the name of Dorothy Ruel alone. Letter dated 1 February 1993 from Rene F. Camire, CMA, City of Biddeford re tax bill for 1993-1994 to be changed to be in the name of Dorothy Ruel Letter dated 29 January 2001 from real estate agent regarding sale of Graham Street Letter dated 14 November 2003 of Jens-Peter Bergen to Deputy Chief Bruce N. Audie Letter dated 14 October 2003 from the Joys to the Governor Lis Pendens by Dorothy LaFortune List by Benway of taxes owed by LaFortune on 12 April 2002 in the amount of $11,450  Loan documentation, on refinancing Memo from city councilor to DLF when they came out of executive session Minutes of City Council meeting of 4 June 2002 Newspaper articles about the LaFortune cases Newspaper publication of time bids to be opened on 5 June 2002 Pleadings and exhibits filed in LaFortune v. City of Biddeford in District, Superior and Supreme Judicial courts Pleadings and exhibits filed in Ly v. LaFortune in District, Superior and Supreme Judicial courts Pleadings and exhibits filed in State v. LaFortune in District and Superior courts Promissory Note dated 12/5/91 and signed by Dorothy L. Ruel Quit claim deed given to Tim Q. Ly Return for Just Cause, dated 3/10/95 Sec. 2-118. Procedural policy for disposition of foreclosed property Statutes (M.R.S.A.) regarding procedure and processes Tape of city council meeting Tape of meeting with Roger Eliot. Given to DLF by Atty. Elliott Tape of meeting with the Chief of Police of Biddeford  Tape of television show, "What Price Justice?" Tax bills sent LaFortune by the City of Biddeford for the Graham Street property Taxes: receipt and money order for taxes paid in May 2003 Title search (all documents found in rundown) of 22 Graham Street, Biddeford, Maine Deed to Robert Ruel and Dorothy Ruel dated 08/26/74 in Book 2050, Page 427. Mortgage for $20,200 to Sun Federal Savings and Loan Association of Portland dated 08/26/74 in Book 2050, Page 429. Discharged Book 2193, Page 313. Mortgage for $26,500 to Sun Federal Savings and Loan Association of Portland dated 03/08/77 in Book 2171, Page 853. Discharged Book 4315, Page 079?? Municipal Lien Certificate dated 06/25/81 in the amount of $35.60 plus interest of $.32 and $17.53 in costs in Book 2810, Page 137. Discharged Book 2838, Page 025. Mortgage on two Biddeford and Saco properties for $72,500 to Maine National Bank dated 06/06/84 in Book 3307, Page 058. Discharged Book 4387, Page 199. Mortgage from Robert Ruel and Dorothy Ruel for $45,000 to Saco & Biddeford Savings Institution dated 11/19/86 in Book 4088, Page 173. Discharged Book 5906, Page 108 on 12/5/91. Municipal Lien Certificate dated 06/22/88 in the amount of $1321.75 plus interest of $65.53 and $28 in costs in Book 4743, Page 238. Discharged Book ?? Junior Mortgage (ARM, Adjustable Rate Mortgage) for $18,000 to Saco & Biddeford Savings Institution dated 03/29/89 in Book 5022, Page 117. Discharged Book 5906, Page 108 on 12/5/91. Municipal Lien Certificate dated 06/18/90 in the amount of $1480.36 plus interest of $79.81 and $28 in costs in Book 5434, Page 080. Discharged Book 5927, Page 156?? Municipal Lien Certificate dated 06/21/91 in the amount of $1552.60 plus interest of $64.57 and $28 in costs in Book 5748, Page 248. Discharged Book 5927, Page 169?? Abstract of Divorce Judgment Regarding Real Estate dated 11/21/91 in Book 5891, Page 110. Property transferred to Dorothy Ruel. Divorce judgment, 10/8/91. Mortgage for $71,500 from Dorothy Ruel to Saco & Biddeford Savings Institution dated 12/05/91 in Book 5906, Page 109. Discharged ?? Municipal Lien Certificate dated 06/23/92 in the amount of $790.16 plus interest of $10.91 and $34.29 in costs in Book 6138, Page 150. Discharged Book 6906, Page 010?? Municipal Lien Certificate -- Sewer Charges (38 M.R.S.A. 1208) dated 10/01/92 in the amount of $155.08 plus interest of $8.77 and $33.58 in costs in Book 6271, Page 019. Discharged Book 7031, Page 260?? Municipal Lien Certificate (§§942, 943) dated 05/21/93 in the amount of $1613.60 plus interest of $73.61 and $34.29 in costs in Book 6591, Page 241. Discharged Book 7331, Page 073?? Municipal Lien Certificate – Sewer Charges (38 M.R.S.A. 1208) dated 09/24/93 in the amount of $101.25 plus interest of $7.48 and $33.58 in costs in Book 6735, Page 055. Discharged Book 7404, Page 064??   A. Municipal Lien Certificate (allegedly tax lien) – not found in Registry – allegedly dated 6/22/94 and recorded in Book 7096, Page 004. Date Paid: 6/21/02. Discharged 6/24/02 and recorded on 7/8/02 both at Book 1177111771, Page 292, and at Book 11771, Page 293. Municipal Lien Certificate (§§942, 943) dated 06/22/94 in the amount of $1729 plus interest of $64.42 and $34.29 in costs in Book 7098, Page 004. Discharged Book ?? Municipal Lien Certificate – Sewer Charges (38 M.R.S.A. 1208) dated 07/27/94 in the amount of $247.50 plus interest of $20.91 and $33.58 in costs in Book 7206, Page 124. Discharged ??   A. Judgment of Foreclosure and Sale, BID-94-CV-323, Saco and Biddeford Savings Bank v. Dorothy Ruel, dated 2/13/95 and recorded at Book 7390, page 271, on 4/21/95. [Appears it did not show up at Registry.] Municipal Lien Certificate (§§942, 943) dated 06/23/95 in the amount of $1729 plus interest of $65.37 and $34.52 in costs in Book 7459, Page 048. Discharged 6/24/02 and recorded on 7/8/02 both at Book 1177111771, Page 292, and at Book 11771, Page 294. Municipal Lien Certificate – Sewer Charges (38 M.R.S.A. 1208) dated 09/27/95 in the amount of $346.50 plus interest of $24.81 and $40.04 in costs in Book 7582, Page 141. Discharged ?? Final Order and Judgment of Quiet Title (14 M.R.S.A. §2401) dated 03/13/96 in Book 7747, Page 310. I don’t know why Dorothy filed this. Municipal Lien Certificate (§§942, 943) dated 06/27/96 in the amount of $1559.25 plus interest of $67.05 and $34.52 in costs in Book 7893, Page 088. Discharged 6/24/02 and recorded on 7/8/02 both at Book 1177111771, Page 292, and at Book 11771, Page 295.  Municipal Lien Certificate – Sewer Charges (38 M.R.S.A. 1208) dated 09/27/96 in the amount of $216 plus interest of $18.95 and $40.04 in costs in Book 8009, Page 261. Discharged ?? Deed to John G. DellaJacova dated 02/26/97 in Book 8173, Page 002.  Municipal Lien Certificate in name of Dorothy Ruel dated 06/30/97 in the amount of $1559.25 plus interest of $67.51 and $34.52 in costs in Book 8327, Page 349. Discharged 6/24/02 and recorded on 7/8/02 both at Book 1177111771, Page 292, and at Book 11771, Page 296. Notice of Impending Automatic Foreclosure (§943) undated notary signature but recorded on 02/02/98 (referring to #22 above) in Book 8622, Page 006, setting a foreclosure date of 12/29/97. Deed to Dorothy Ruel dated 02/26/97 in Book 8649, Page 212, recorded 2/23/98. Notice of Impending Automatic Foreclosure in name of John G. DellaJacova dated 04/09/98 (referring to #23 above) in Book 8732, Page 069 setting a foreclosure date of 03/27/98. Municipal Lien Certificate in name of John G. DellaJacova dated 06/15/98 in the amount of $1559.25 plus interest of $71.32 and $34.77 in costs in Book 8858, Page 229. Discharged 6/24/02 and recorded on 7/8/02 both at Book 1177111771, Page 292, and at Book 11771, Page 297. Notice of Impending Automatic Foreclosure (§943) in name of Dorothy Ruel, undated notary signature, but recorded on 12/31/98 (referring to #25 above) in Book 9240, Page 327 setting a foreclosure date of 12/30/98. Municipal Lien Certificate (§§942, 943) in name of Dorothy Ruel dated 06/08/99 in the amount of $1666.17 plus interest of $74.59 and $34.98 in costs in Book 9515, Page 039. Discharged 6/24/02 and recorded on 7/8/02 both at Book 1177111771, Page 292, and at Book 11771, Page 298. Municipal Lien Certificate – Sewer Charges (error §§942, 943) dated 06/08/99 in the amount of $203.95 plus interest added to the tax and $34.98 in costs in Book 9515, Page 141. Discharged?? Notice of Impending Automatic Foreclosure (§943) – Sewer -- in name of Dorothy Ruel dated 11/1/99 and recorded on 12/16/99 (referring to Municipal Lien Certificate for Sewer Charges not found in the title) in Book 9825, Page 163, setting a foreclosure date of 12/15/99. Notice of Impending Automatic Foreclosure (§943) in name of Dorothy Ruel, undated notary signature and recorded on 12/16/99 (referring to #28 above. However, #28 above was recorded on 06/17/98 and not 06/15/98) in Book 9825, Page 237, setting a foreclosure date of 12/15/99. Municipal Lien Certificate – Sewer Charges (error §§942, 943) dated 06/06/00 in the amount of $351.26 plus interest rolled into the tax and $34.98 in costs in Book 10060, Page 125. Discharged?? Municipal Lien Certificate (§§942, 943) dated 06/06/00 in the amount of $1648.35 plus interest of $69.10 and $34.77 in costs in Book 10061, Page 213. Discharged 6/24/02 and recorded on 7/8/02 both at Book 1177111771, Page 292, and at Book 11771, Page 299. Notice of Impending Automatic Foreclosure dated 10/24/00 (referring to #31 above) and recorded on 12/26/00 in Book 10370, Page 235, and setting a foreclosure date of 12/08/00. Notice of Impending Automatic Foreclosure – Sewer (§943) -- dated 10/24/00 (referring to #32 above) and recorded on 12/26/00 in Book 10370, Page 257, and setting a foreclosure date of 12/08/00. Municipal Lien Certificate – Sewer Charges -- dated 06/06/01 in the amount of $564.13 plus interest of $53.60 and $34.74 in costs, and recorded in 6/7/01 in Book 10698, Page 200.  Municipal Lien Certificate dated 06/06/01 in the amount of $1630.53 plus interest of $70.60 and $34.74 in costs, and recorded on 6/07/01 in Book 10699, Page 214.  Notice of Lien Claim dated 05/15/02 in the amount of $85,000 to Castora Detective Bureau in Book 11628, Page 051.  Municipal Lien Certificate dated 06/10/01 in the amount of $1523.78 plus interest of $72.97 and $34.94 in costs, and recorded on 6/10/92 in Book 11695, Page 199.  Municipal Quitclaim Deed dated 06/21/02 to Tim Q. Ly for $80.000 in Book 11748, Page 252. Mortgage to Fleet National Bank in the maximum amount of $105,000 dated 08/19/02 in Book 11991, Page 043. Discharge of Lien Mortgage Certificate. Date of Lien. 06/10/02 (referring to #42 above). Dated Paid 06/24/02 and recorded on 12/5/02 in Book 12256, Page 221. Mortgage to Countrywide Home Loans, Inc. in the maximum amount of $53,300 dated 07/21/04 in Book 14167, Page 745. Subordination Agreement dated 07/14/04 from Fleet in Book 14167, Page 767. Title search (all documents found in rundown) of Dance Studio building in Saco, Maine Transcript of city council meeting Writ of Possession dated 3 June 2003 Writ of Possession dated 4 November 2003 Defendant reserves the right to update this list of documents.

Respectfully submitted, Dorothy LaFortune,  By her attorneys, _____________________________________ Barbara C. Johnson, Esq., Mass. B.B.O.  6 Appletree Lane Andover, MA 01810-4102  978-474-0833   Local Counsel,  _________________________________________ Thomas A. Grossman, Esq., Maine B.B.O.  Grossman & Grossman, PC 40 Babcock Street P.O. Box 2011 Brookline, MA 02446 617-975-0005  16 September 2004 CERTIFICATE OF SERVICE I, Barbara C. Johnson, hereby certify that I caused to be emailed on 9September 2004 and served by first-class mail on 10 September 2004 a true and accurate copy of this document on District Attorney Mark W. Lawrence, York County Courthouse, P.O. Box 399, 45 Kennebunk Road, Alfred, Maine 04002-0399. __________________________________ Barbara C. Johnson 10 September 2004

 

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Sylvia #26, Grandparents #30, Meuse #34, Linnehan Related #38, Smith/Pocahontas #42, Linnehan Related #46, Smith/Pocahontas #50, Smith/Pocahontas #54, Smith/Pocahontas #58, Smith/Pocahontas #62, Smith & Judges #66, Linn. Dom. Rel. #70, Linn.Child-support #74, Fraud-5-Lawyers #78, StupidButFamous #82, 1st Amendment/Bar #85, Bogus contempt, coming #89, Petition for Discipline #90, Count 3: Answer Interwoven #94, Restraining Order #98, Hearse at Lawyers Weekly #102, Bar Board:Star Chamber #106 Motions filed at Bar Board #110 Reply Appeal Immunity #114 The Younger Doctrine #117 Fed QuasiJudicial Immunity #121 Opp. to Dismiss by FOX TV #125 F4J London Parade Pics #129 Letter- Editor Lawyers Wkly #133-Barb v, BBO: App Brief #137 Smith-o-dipiano-recons-dism #141 Smith o-sj-Boston-memo mp1 #145 m-partial-recon-cc-wiretap #149 reply-o-dism-jdp-ccs-2d-mal #153 barb-v-bbo-crane-defamation ------------------------------------------------------- #157 strike-appearance-ag-for-BC-ABC ------------------------------------------------------- #161 m-str-docs-obc-record-appendix #165 m-declaration of-practice-of-law #169 o-impound-supp-appendix-record #173 show-cause-brief for hear'g-1st-Cir #177 motions-vacate-reverse-dismiss #181 five-motions-and-oppositions-sjc	#3,   Meuse #7,   Recusing Judge #11, Meuse #15, Linnehan & Brown #19, Linnehan & Brown #23, Robyn Sylvia, Aff. #27, Meuse #31, Linnehan & Brown #35, Smith/Pocahontas #39, Linnehan & Brown #43, Linnehan Related #47, Smith/Pocahontas #51, Smith/Pocahontas #55, Smith/Pocahontas #59, Smith/Pocahontas #63, King HarrySmith #67, Meuse Kidnapping #71, Smith/Judges/A-G #75, LaidbackPocahontas #79, Fraud-StupidButFamous #83, 1st Amendment/Bar #86, Proposed Findings/Bar #90, Answer to Petition Discipline #91, Motion for Attorney Fees #95, Court Commits Crimes #99, Opposition to Attorney Fees #103 Appeal Judicial Immunity #107 Barb v. BBO et al (State) #111 Complaint - Sec 1983 #115 TOC-Proposed Findings #118 Opposition to Motion Strike #122 Barb v. BBO -- immunity #126 Meuse- re- Bivens Claims #130 LaFortune-Opp to Preclude #134 Memorial Butch Bailey  #138 o-city-recons-denial-dismiss #142 Smith surreply-Boston-facts #146 Smithsupp-m-partial-recon-cc #150 Barb-appeal-recommend-BB #154a announcement-of-disbarment #154 opp-recommendation-disbarment #158 m-dismis-by-bbo in Barb v BBO --------------------------------------------------- #162 m-recuse-SJC Justice-spina #166 claims-USDC-Local Rule-83.6(2)(D) #170 m-decl-practice-of-law-full-panel-sjc #174 reply-unauthorized-practice-laws-jc #178 motion-dismiss-disbarment-violation #182 app-for-further-app-review-Rule27-1	#4,  Meuse #8,  Meuse #12, Linnehan & Brown #16, Meuse #20, Linnehan & Brown #24, Sylvia c. Sylvia #28, Deleted #32, Linnehan & Brown #36, Smith/Pocahontas #40, Smith.Pocahontas #44, Linnehan Related #48, Smith/Pocahontas #52, Smith/Pocahontas #56, Judge Contempt #60, King HarrySmith  #64, Linnehan Related #68, GAL Fees #72, Brown & Linnehan #76, Fraud-LaidbackLawyer #80, 1st Amendment/Bar #84, Sano case/Bar #87, Senior citizen,Gordon #90, Count 1: Answer Interwoven #92 Immunity-DMA-Elderly #96, Jarasitis: Judas to Justice #100, Motion for Jury Trial #104 Judicial Accountability Art. #108 Preliminary Injunction #112 Smith'sOpposition to Det. #115a-Proposed Findings-Divorce #119 Barb v. BBO--Prop Findings #123 Meuse-Opp-to-STF-Dism. #127 Meuse- Fake FBI Docs #131 LaFortune-Mot-to-Dismiss #135 Smith's dipiano-mot-dism  #139 mal-pros-garden-variety #143 Smith's o-recon-sj-qual-iy #147 Reply-to-offs-o-partl-recon #151 barb-ussct-petition-writ-cert ---------------------------------------------- #155 petition-for-rehearing-spina #159 app-brief-and-letter-to-clerk #159a app-brief-surprises #163 m-jury trial for contempt #167 combined-correct-docket-order-toc #171 appeal-judgment-of-contempt-sjc #175 nonlawyer-representing-parties #179 reply-apps-disbarm't-contempt #183 -scotus-petition-for-writ-certiorari
#1, Drano Series (640-pixel monitor) #3, Drano Series (640-pixel monitor) #5, Drano Series (640-pixel monitor) #7, Drano Series (640-pixel monitor) #9, Drano Series (640-pixel monitor) #11, Drano Series (640-pixel monitor) #13, Drano Series (640-pixel monitor) #15, Drano Series (640-pixel monitor) #17, Drano Series (640-pixel monitor) #19, Drano Series (640-pixel monitor) #21, Drano Series (640-pixel monitor) #23, Drano Series (640-pixel monitor) #25, Drano Series (640-pixel monitor) #27, Drano Series (640-pixel monitor) #29, Drano Series (640-pixel monitor) #31, Drano Series (640-pixel monitor) #33, Drano  (Not available in 640 pixels)		#2, Drano Series (640-pixel monitor) #4, Drano Series (640-pixel monitor) #6, Drano Series (640-pixel monitor) #8, Drano Series (640-pixel monitor) #10, Drano Series (640-pixel monitor) #12, Drano Series (640-pixel monitor) #14, Drano Series (640-pixel monitor) #16, Drano Series (640-pixel monitor) #18, Drano Series (640-pixel monitor) #20, Drano Series (640-pixel monitor) #22, Drano Series (640-pixel monitor) #24, Drano Series (640-pixel monitor) #26, Drano Series (640-pixel monitor) #28 #30, Drano Series (640-pixel monitor) #32, Drano Series (640-pixel monitor) #34, Drano Series (640-pixel monitor)

Barbara C. Johnson, Attorney at Law 6 Appletree Lane, Andover, Massachusetts 01810-4102 Phone 978-474-0833