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A Multi-faceted Motion: (1) to Vacate ..., (2) to Reverse ..., (3) to Hold ..., (4) to Dismiss ..., and (5) to Vacate Judgments of Disbarment and Contempt on Grounds of Being Both Devoid  of Evidence and Replete with Egregious Irregularities in Process ~~~~~~~~~~~~~~~~

COMMONWEALTH OF MASSACHUSETTS Supreme Judicial Court for the Commonwealth   No. SJC-2006-09820   No. SJC-2006-09866 IN RE BARBARA C. JOHNSON ____________________________ JOHNSON’S MOTION (1) TO VACATE ORDER ALLOWING APPELLEE A THIRD EXTENSION TO OVER FOUR MONTHS  TO FILE  BRIEF, (2) TO REVERSE FORTHWITH THE DENIAL OF JOHNSON’S MOTION FOR A STAY OF DISBARMENT, (3) TO HOLD  OBC AND BBO IN DEFAULT, (4) TO DISMISS THE PETITION FOR DISCIPLINE AGAINST JOHNSON, AND (5) TO VACATE JUDGMENTS OF DISBARMENT AND CONTEMPT ON GROUNDS OF BEING BOTH DEVOID  OF EVIDENCE AND REPLETE WITH EGREGIOUS IRREGULARITIES IN PROCESS

Now comes Barbara C. Johnson, Esq., [“Johnson”] and moves this Court (1) to vacate order allowing the OBC and the BBO a third extension to file their appellee brief, resulting in giving them over four months to file the “red brief,” (2) to hold the OBC and the BBO in default for failure to file brief timely, (3) to dismiss the joint\[1]/ OBC/BBO petition for discipline against Johnson, and (4)  to vacate the judgments of disbarment and contempt, both judgments issued by Justice Francis X. Spina.   As grounds, Johnson states that not only is the disciplinary  action devoid of evidence but the process, too, has been full of egregious irregularities, including but not limited to the process in this Court.   In support, Johnson states that this Court has written:                  The grounds upon which bar counsel may          petition the single justice for disciplinary          action against an attorney include:   ·        misuse or loss of client funds, ·        neglect of client interests, ·        fraudulent conduct, ·        sanction in another jurisdiction, ·        conviction of a crime and ·        misrepresentation to the court.   “Practice and Procedure Single Justice,” published at http://www.sjccountyclerk.com/singjusprpr.html.   No evidence of any such charges was found, despite the malicious buckshot approach taken by the OBC and the BBO.   Disbarment or any other sanction is inappropriate.               The so-called trial had no witnesses.  Johnson’s trial subpoenas were quashed.  All Johnson’s evidence for her defense was precluded by the now-deceased M. Ellen Carpenter and the special hearing officer, Herbert Phillips.   No authenticated documentary evidence was proffered.  Documents that Johnson had never seen were accepted into evidence.  The OBC/BBO’s 12-volume set of the appendix was never supplied Johnson.  Not even a Table of Contents was supplied her.  The guaranteed public trial never took place.  Phillips ordered the public to leave based on the fallacious reason that Johnson had violated an order commanding Johnson not to use real names for certain individuals on a list.  That the OBC prosecutor admitted there was no such list was ignored.  Phillips, with the help of Assistant General Counsel Carol Wagner, conducted a Kangaroo Court.  Johnson’s motion for a new and real trial was denied summarily.\[2]/   In further support, Johnson states after Judge Spina denied her motion to stay the judgment of disbarment, she filed a motion to stay in this Court.  If the appeal to this Court were intended to be real, i.e., were this Court neutral and the possibility existed that Judge Spina’s judgment would be reversed, the motion to stay the judgment should have been allowed . . .  at the very least, so that Johnson’s clients would not be harmed and damaged by their counsel of choice being forced—by imprisonment—to withdraw prior to the conclusion of their cases.   The denial by the full court of the motion to stay confirmed that the final decision had been predetermined by this Court.   The motion to stay affected not only Johnson’s livelihood but also the property of Johnson’s clients.  By the denial of that motion, Johnson and her clients have been egregiously harmed and damaged without due process and without equal protection.   In further support, Johnson re-iterates her argument in her MOTION TO VACATE ORDER ALLOWING BAR COUNSEL’S MOTION TO STAY AND CONSOLIDATE AND TO FILE CONSOLIDATED BRIEF ON APPEAL [Paper #15], where she stated (1) that she was not given the opportunity to oppose Bar Counsel‘s motion,\[3]/  (2)  that it is discriminatory to act on Bar Counsel’s motions immediately but to delay acting on Johnson’s motion long enough to give Bar Counsel time to oppose, \[4]/   (3) that the lack of time standards for motions in this type of action deprives the respondent of due process and the equal protection of the laws.                  The complained-of acts were again repeated on Monday, 22 January 2007.  It went down as follows:   1.         On 10 November 2006, Weisberg filed the MOTION FOR STAY AND CONSOLIDATE AND TO FILE CONSOLIDATED BRIEF ON APPEAL [Paper #13].   Over Johnson’s opposition [Paper #14], Clerk Susan Mellen allowed the motion and ruled:   Bar Counsel may file one 50 page brief addressing issues raised in both SJC-9820 and SJC-9866.  Appellee's brief is due 30 days after the filing of appellant's brief in SJC-9866. The  cases will be paired for argument.  Notice sent.   2.         It was then that Johnson filed Paper #15, cited supra, the motion to vacate Clerk Mellen’s order.  At that time, Johnson was unaware that Mellen had made the decision.     3.         Weisberg opposed Johnson’s motion [Paper #18].  Johnson replied [Paper #19].    4.         Even though, as she stated in her motion to vacate, Johnson had a right to read the OBC/BBO arguments in Appellee-OBC/BBO’s brief for SJC-06-09820 and possibly use those arguments against them when writing her brief for her appeal of the unjustifiable Judgment of Contempt, SJC-06-0986, Clerk Susan Mellen intentionally disregarded Johnson’s right to fundamental fairness and allowed the Siamese twins, the OBC and the BBO, a second extension, to January 22d, Monday [Paper #13].   (Clerk Mellen allowed the first extension on 27 October 2006 [Paper #11].)    5.         On Friday, 19 January 2007, Weisberg [whom Mellen deems an employee of the BBO, as shown at http://www.ma-appellatecourts.org/display- attorney.php? ano=26570798] filed another motion to continue the briefing due date from January 22d to February 14th [Paper #23].  Weisberg had had several weeks to file a motion to continue.  Instead, anticipating that Clerk Susan Mellen would allow her motion forthwith—as Mellen had done repeatedly in the past—Weisberg waited until the last possible moment to make it impossible for Johnson to oppose the third request for an extension of the briefing schedule without making a special trip to Boston to deliver her opposition in hand.    6.        Because Johnson had pointed out the discrimination on a class-of-one theory in Paper #15, Mellen clearly hesitated and did not allow Weisberg’s Paper #23 on Friday the 19th. 7.         Johnson received Paper #23 on Saturday, January 20th.  8.         Johnson phoned the clerk’s office at around 2:30 Monday afternoon and learned that the OBC/BBO brief had not yet been filed. She was told, Weisberg has until 5:00 to file, call back then. 9.         Johnson phoned at 4:55. Clerk Mellen told her the red brief had not been filed and the motion to extend had not decided. Mellen would, however, be accepting the brief for filing when it arrived. Johnson said she was unaware that a motion to extend time acted automatically as a continuation without being allowed. Johnson asked whether she should call back at 5:00. Mellen told her to do what she wanted and hung up on Johnson. 10.       At 4:59, Johnson called the office again.  Mellen told her the motion [Paper #23] had been allowed by the Court.  Johnson asked who in the Court.  She said it was she who allowed it; the Court had given her the authority to decide such motions.  So in the last few minutes, literally, of the business day, Mellen, smelling that Johnson would oppose a late filing of the red brief, granted Weisberg a third extension to file a red brief in opposition to Johnson’s blue brief, which was filed on 6 October 2006.   NOTE:  Had Johnson sought a 3½ -month extension, it would have been considered frivolous and sanctions would have been imposed—likely, at the very least, dismissal of the appeal.  But Mellen, with intentional discrimination against Johnson, allowed OBC/BBO Weisberg over 4 months to file an opposition brief. 11.       At 6:00 P.M. on Friday, 22 January 2007, Mellen emailed Johnson notice of the allowance of Weisberg’s untimely filed motion [Paper #23].   Exhibit A attached.   12.       On Tuesday, 23 January 2007, SJC Clerk Mellen emphasized to Johnson that when she acted on the motions, she was acting “at the direction of the Court.”     Given that not only is the disciplinary action devoid of evidence but the process, too, is replete with egregious irregularities, the prejudice to Johnson is irreversible, . . . and the discrimination against Johnson is startling, if not “merely” political, and certainly unacceptable.       In any civil action in any court of the commonwealth in which one or more of the parties at the time of             commencement of the proceeding is sixty-five years of             age or older or during the pendency of the proceeding             attains the age of sixty-five, the court shall, upon motion             of such person, advance the proceeding for speedy trial             so that it may be heard and determined with as little            delay as possible. G.L. c. 231, §59F (speedy trial for persons sixty-five years of age or older).   Where Johnson is 72 years of age, the repeated allowance of motions to extend time for filing, which resulted in unnecessary delay without a showing of good cause, is sanctionable.   Cf. Christopher W. v. Portsmouth School Committee, 877 F.2d 1089, 1089, 1098 (1st Cir. (R.I.),1989) (where appellees failed both to file a timely brief and to establish “good cause” for the tardiness, taxation of appellate costs was appropriate notwithstanding appellees prevailing in the appeal), citing  Fed.R.App.P. 26(b) and Hoffman v. Alside, Inc., 596 F.2d 822 (8th Cir.1979) (taxing costs against party for failure to file timely brief).  Here, for the delay alone in filing the appellee brief, the appropriate sanction would be to reverse forthwith the denial of Johnson’s motion to stay.  For denying Johnson the ability to use the appellee brief as a source of potential admissions and errors of fact and law against the appellee(s) in her appeal of the judgment of contempt, the sanction against the OBC and BBO must be considerably more severe.   For example, the Clerk’s immediate allowance of their motions, which deprived Johnson of the ability to oppose those motions, is indicative of the internal institutional bias against Johnson.   The institutional bias arose, Johnson assumes, out of politically-motivated retaliation, where Johnson ran for statewide elective office on a platform of court reform and the abolishment of judicial and the quasi-judicial immunities and focused during a statewide televised debate on the need for judicial accountability.  “Accountability.  Accountability.  Accountability,” she explicitly demanded. Given that it is unlikely that the Clerk would take such discriminatory and prejudicial action on her own, i.e., without being ordered by the Court to find against Johnson in every instance unreasonably and prejudicially, the above-described process is, at the very least, circumstantial evidence that this Court has predetermined the disciplinary case against Johnson.  Added to the conflict of interest and the appearance of impropriety detailed in her two appellate briefs, which are incorporated in entirety by reference as if set forth herein and which are presently before this Court, as well as detailed in her motions entered as Papers ## 10, 12, 16 (reply), 15, and 19 (reply), the Joint Petition for Discipline against Johnson must be dismissed. Wherefore, Johnson prays (1) that the order allowing the OBC and the BBO a third extension be vacated, making the appellee brief untimely filed—whenever it arrives, (2) that the denial of Johnson’s motion for a stay of disbarment be reversed forthwith, (3) that the OBC and BBO be adjudged in default for failing to file timely the appellee brief, (4) that the Petition for Discipline against Johnson be dismissed, and (5) that the single-justice judgments of disbarment and contempt be vacated. Johnson seeks an emergency hearing before the full Court, with the exception of Justice Spina.                               Respectfully submitted,          24 January 2007                 Barbara C. Johnson, Esq., Pro Se                                            6 Appletree Lane                                           Andover, MA 01810-4102                                            978-474-0833                                BBO #549972 (pending appeal)             CERTIFICATE OF SERVICE I, Barbara C. Johnson, hereby certify that on 25 January 2007 I served a true and accurate copy of the within pleading to the opposing OBC counsel, 99 High Street., Boston, MA 02110.   24 January 2007                                                    Barbara C. Johnson [1]    Identifying the Petition for Discipline as emanating from the Office of Bar Counsel [OBC] has been an error.  Before the petition issued, it allegedly had to be, and was, approved by a member of the Board of Bar Overseers [BBO], in this case, Elizabeth Mulvey.  That is highly irregular.  A party does not write a Complaint and need to seek approval of an adjudicator before filing the Complaint.  A court will act on a motion to dismiss after the Complaint is filed if it insufficiently states a claim. [2]    Given that the BBO is not a court of record, Johnson was entitled to a trial de novo in the single-justice session or even in this Court before the full panel.  Ex parte Gladhill,  8 Metcalf (Mass.) 168, 171 (1844) (Shaw, C.J.).   See also Black's Law Dictionary, 4th Ed., 425, 426. [3]   Johnson was literally editing her opposition to Bar Counsel’s motion when she received in an email the notice that Bar Counsel’s motion had been allowed.  She had begun drafting the opposition within 24 hours of having received the motion by first-class mail.  Giving Johnson only 24 hours-give-or take-a-few to oppose a motion and giving Bar Counsel a week or more to oppose a motion is discriminatory. (Johnson herein invokes discrimination of a class-of-one theory.  See Rule 27 Petition for Hearing of BD-2006-039, in Appendix, Petition, pp. 12-13.) [4]  On 27 October 2006, too, Bar Counsel filed a motion to file a limited supplemental appendix [Paper #10].   That was allowed the same day.  Johnson was not even given opportunity to receive the motion, never to oppose the motion.   If that is not bias, what is?  The prosecuting Assistant Bar Counsel has not bothered identify those documents which will be in the limited supplemental appendix.

                                               Exhibit A
 

Subject:	SJC-09820 - Notice of Docket Entry
From:	SJCCommClerk@sjc.state.ma.us
Date:	Mon, 22 Jan 2007 18:00:00 -0500
To:	barbaracjohnson@att.net (Barbara C. Johnson)

   Supreme Judicial Court for the Commonwealth of Massachusetts

                      John Adams Courthouse

One Pemberton Square, Suite 1400, Boston, Massachusetts 02108-1724

             Telephone 617-557-1020, Fax 617-557-1145

RE:      No. SJC-09820

    IN THE MATTER OF BARBARA C. JOHNSON

                       NOTICE OF DOCKET ENTRY

    Please take note that the following entry was made on the

docket of the above-referenced case:

January 19, 2007:  MOTION to extend to 2/14/07 filing of brief of

Bar Counsel by Susan A. Strauss Weisberg, Ass't Bar Counsel.

ALLOWED.  Notice to counsel.

                               Susan Mellen, Clerk

Dated: January 22, 2007

To:  Susan A. Strauss Weisberg, Ass't Bar Counsel

     Barbara C. Johnson

----------------------------------------------------------------------

This e-mail notice is being sent to you as part of a pilot program

being conducted by the SJC Full Court Clerk's office.  Under the 

program, notices will be sent by e-mail to those whose e-mail 

addresses have been provided to the Clerk's office.  During the pilot

program, a copy of the notice will also be sent to you by regular 

mail.  If you have any comments about this e-mail notification, 

please let us know.  If you would prefer not to receive such e-mail

notices, please notify us at the above e-mail address.  Thank you. 

 

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