#160, Drano Series

Barb's Motion for Leave to File Brief in Excess of 50 Pages
(filed in the Clerk's Office for the
Full Panel of the Massachusetts Supreme Judicial Court)

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NOTE that Drano ##159, 160, and 161 were sent to the
Massachusetts Supreme Judicial Court for the Commonwealth, where the full panel (minus the judge who sat in the single-justice) will hear the case.
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NOTE that Drano ##162, 163, and 164 were sent to the
Massachusetts Supreme Judicial Court for Suffolk County, where every month a different SJC justice is assigned to sit as a  judge  in the single-justice session.
Amongst the many types of cases heard by a "Single Justice" are petitions invoking the "SUPERINTENDENCY" of the SJC and
Board Discipline cases.

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People have written me, "What can I do to help you?"
It is unlikely anything will help the inevitable,
however, anything is worth trying. 
The "anything" might be letters to the Court:

Supreme Judicial Court
John Adams Courthouse
One Pemberton Square
Boston , MA 02108

__________________________________________
Supreme Judicial Court
Justices
(click on names and see photos and profiles)
Send letters by snail mail or email of both.
Snail mail address above.
Email addresses below.

Chief Justice Margaret H. Marshall chiefjustice.marshall@sjc.state.ma.us margaret.marshall@sjc.state.ma.us
Justice John M. Greaney john.greaney@sjc.state.ma.us	Justice Roderick L. Ireland roderick.ireland@sjc.state.ma.us
Justice Francis X. Spina francis.spina@sjc.state.ma.us	Justice Judith A. Cowin judith.cowin@sjc.state.ma.us
Justice Martha B. Sosman martha.sosman@sjc.state.ma.us	Justice Robert J. Cordy robert.cordy@sjc.state.ma.us
Keep the letters going to the Court. I was there on October 6th to file my appeal.   One of the clerks said the letter file was a few inches thick. Whether the judges will ever read them is unknown, but they are sure to know that they are there.  I'll inquire as to whether a "reader" has been assigned. Let's also try emails.  The judges' secretaries will certainly let them know how many are coming in.

COMMONWEALTH OF MASSACHUSETTS

SUPREME JUDICIAL COURT

for the Commonwealth

Docket No. SJC-09820

IN RE BARBARA C. JOHNSON

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JOHNSON’S MOTION FOR LEAVE TO FILE BRIEF

IN EXCESS OF 50 PAGES

Now comes Barbara C. Johnson, Esq., [“Johnson”] and moves this Honorable Court for leave to file a brief in excess of 50 pages, specifically, 16 pages over the limit.

As grounds, Johnson states that, as Assistant Bar Counsel Susan Strauss Weisberg argued to Judge Francis X. Spina, “this case is complex.” This case is also a “three-fer”: it contains three counts and each count involves distinct underlying matters. Specifically a juvenile court action, a family court action, a district court action, and a de minimus fee dispute with an Internet client. As a result, Johnson had to set out multiple, independent sets of facts and legal issues—some unique, some first impression, and some of constitutional import. And because this is a Board Discipline case, she also had to argue professional conduct rules and canons.

WHEREFORE, Johnson prays this motion be allowed.

Respectfully submitted,

Barbara C. Johnson
4 October 2006 Barbara C. Johnson, Esq., Pro Se
6 Appletree Lane
Andover, MA 01810-4102
978-474-0833
BBO #549972

CERTIFICATE OF SERVICE

I, Barbara C. Johnson, hereby certify that on 6 October 2006 I served a true and accurate copy of the within pleading to the opposing OBC counsel, 99 High Street, Boston, MA 02110 by first-class mail.

Barbara C. Johnson

6 October 2006 Barbara C. Johnson, Esq., Pro Se