Employee Engagement in Criminal/Civil Wrongs and Bankruptcy

This is a CLASSIC EXAMPLE of an Employee’s ENGAGEMENT in CRIMINAL/CIVIL wrongs
with Baker Donelson Bearman Caldwell & Berkowitz (Legal Counsel for President Barack
Obama, Congress, Supreme Court, etc.) such as RACE DISCRIMINATION, LYING DURING
FEDERAL INVESTIGATIONS, etc. Then when they are SUED in their INDIVIDUAL
CAPACITIES as Ladye Margaret Townsend, they want to go and file BANKRUPTCY in
attempts to get out of PAYING for their CRIMINAL/CIVIL VIOLATIONS!
Now if Vogel Denise Newsome is NOT ALLOWING the FIRST ALLEGED Black-American
President Barack Obama’s CRIMINAL/CIVIL wrongs not to be EXPOSED, WHY would
Ladye Margaret Townsend and her attorney Robert Rex McRaney Jr. think that Newsome
would SPARE them the EXPOSURE they RIGHTFULLY DESERVE!

I N T H E U N I T E D S T A T E S B A T ^ ^ ^ C ^ T C Y C O U R T
S O U T H E R N D I S T R I C T O F ' M I S S I S S I P P I
i U U L |t4 AH 9 : 5 C
IN R E : j - ^ , , , , ,
L A D Y E M . T O W N S E N D < ~ C H A P T E R 7
DEBTOR B Y D E P U W C A S E N O . 11-00167-ee
C R E D I T O R ' S ( V O G E L N E W S O M E ) M O T I O N F O R R E L I E F F R O M O R D E R / J U D G E M E N T ;
M O T I O N F O R R U L E 11 S A N C T I O N S O F AND A G A I N S T R O B E R T R E X M C R A N E Y
J R . / M C R A N E Y & M C R A N E Y ; AND R E Q U E S T T O B E A D V I S E D O F C O N F L I C T - O F
I N T E R E S T S ^
COMES N O W Creditor Vogel Newsome ("Newsome") without waiving her rights, without
submitting to the jurisdiction of this Court, without waiving the defenses and claims set forth in her:
(a) "Creditor's Opposition/Response to Notice of Chapter 7
Bankruptcy Case, Meeting of Creditors, & Deadlines and
Motion to be Dismissed, from Action " - Docket 10 - and
(b) "Creditor Vogel Newsome's Opposition/Response to 5/11/11
Discharge of Debtor; Request for Findings of Fact and
Conclusions of Law; and Vacating of Discharge of Debtor" -
Docket 20 -
and files this her "Creditor's (Vogel Newsome) Motion for Relief From. Order/Judgment; Motion for Rule
11 Sanctions of and Against Robert Rex McRaney Jr./McRaney & McRaney; and Request To Be Advised
Of Conflict-Of Interests" ("CMFRFO/J") pursuant to Rule 60 of the Federal Rules of Civil Procedure
("FRCP"), FRCP Rule 11; FRCP Rule 12(G) - consohdation of matters - and odier statutes/laws
governing said matters. In support thereof, Newsome states the following:
L L A C K O F J U R I S D I C T I O N :
There is authority that dismissal of a bankruptcy case does not
mandate dismissal of all pending adversary proceedings.
However, i f an entity joined as a party in an adversary
proceeding raised the defense that the court lacks jurisdiction
over the subject matter and that defense is sustained, the court
' NOTE: Boldface, italics and underline, etc. represents "emphasis" added.
Page I of 2 ^

of 28
IN THE UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF MISSISSIPPI
IN RE:
LADYE M. TOWNSEND CHAPTER 7
DEBTOR CASE NO. 11-00167-ee
CREDITOR’S (VOGEL NEWSOME) MOTION FOR RELIEF FROM ORDER/JUDGEMENT;
MOTION FOR RULE 11 SANCTIONS OF AND AGAINST ROBERT REX MCRANEY
JR./MCRANEY & MCRANEY; AND REQUEST TO BE ADVISED OF CONFLICT-OF
INTERESTS1
COMES NOW Creditor Vogel Newsome (“Newsome”) without waiving her rights, without
submitting to the jurisdiction of this Court, without waiving the defenses and claims set forth in her:
(a) “Creditor’s Opposition/Response to Notice of Chapter 7
Motion to be Dismissed from Action” – Docket 10 – and
(b) “Creditor Vogel Newsome’s Opposition/Response to 5/11/11
Conclusions of Law; and Vacating of Discharge of Debtor” –
Docket 20 -
and files this her “Creditor’s (Vogel Newsome) Motion for Relief From Order/Judgment; Motion for Rule
11 Sanctions of and Against Robert Rex McRaney Jr./McRaney & McRaney; and Request To Be Advised
Of Conflict-Of Interests” (“CMFRFO/J”) pursuant to Rule 60 of the Federal Rules of Civil Procedure
(“FRCP”), FRCP Rule 11; FRCP Rule 12(G) – consolidation of matters – and other statutes/laws
governing said matters. In support thereof, Newsome states the following:
I. LACK OF JURISDICTION:
There is authority that dismissal of a bankruptcy case does not
mandate dismissal of all pending adversary proceedings.
However, if an entity joined as a party in an adversary
proceeding raised the defense that the court lacks jurisdiction
over the subject matter and that defense is sustained, the court
1
NOTE: Boldface, italics and underline, etc. represents “emphasis” added.

of 28
must dismiss such entity from the adversary proceeding.
Fed.R.Bankr.P. 7019(1).
Mississippi Case: Rice v. McMullen, 43 So.2d 195 (Miss. 1949)
- A court must have jurisdiction of the subject matter and of the
person of the parties, to give validity to its final judgments,
orders and decrees, and legislature cannot under the Constitution
dispense with notice, actual or constructive.
Illinois Cent. R. Co. v. Mississippi Public Service Commission,
135 F.Supp. 304 (S.D.Miss.Jackson.Div.,1955) - “Judicial
power” is the legal right, ability and authority to hear and decide
a justifiable issue or controversy, and such power is ordinarily
vested in a court of justice.
U.S. Supreme Court Case: U.S. v. O'Grady, 89 U.S. 641(1874)
- “Jurisdiction” is the power to hear and determine a cause.
In re N.L.R.B., 58 S.Ct. 1001 (1938) - “Jurisdiction” means, in
one sense, the power to hear and determine the controversy
presented, but a court has “jurisdiction,” in another sense, to
determine whether such power is conferred upon it in the
circumstances disclosed, and if it finds such power is not
granted, it lacks “jurisdiction” of the subject matter and must
refrain from an adjudication of rights in connection therewith.
Other Court Cases: In re Jahelka, 2010 WL 5558990 (Bankr.,
2010) - Subject matter jurisdiction is threshold question in every
case.
In re AE Liquidation, Inc., 435 B.R. 894 (2010) - A motion to
dismiss for lack of subject matter jurisdiction challenges the
power of the federal court to hear a claim or case. Fed.Rules
Civ.Proc.Rule 12(b)(1), 28 U.S.C.A.
Issue of court's subject matter jurisdiction can be raised
in any manner, including on motion of one of the parties or by
the court sua sponte. Fed.Rules Civ.Proc.Rule 12(b)(1), 28
U.S.C.A.
1. Newsome DOES NOT waive her defense to the jurisdictional issue which arises
in this matter. Therefore, Newsome does not submit to the jurisdiction of this
Court. While the laws are clear that Newsome cannot waive jurisdictional rights,
she believes it is necessary to provide information regarding decisions of court(s)
on said issue(s):
In re Kirkland, 600 F.3d 310 (4th
Cir. 2010) - Subject matter
jurisdiction cannot be forfeited or waived, and can be raised by
party, or by court sua sponte, at any time prior to final judgment.
2. This instant “CMFRFO/J” is submitted in good faith and has not been submitted
for purposes of delay, harassment, hindering proceedings, embarrassment,
obstructing the administration of justice, vexatious litigation, increasing the cost

of 28
of litigation, etc. and is filed to protect and preserve the rights of Newsome
secured/guaranteed under the United States Constitution and other laws of
the United States.
3. For the purposes of expedition, saving of time and minimize costs associated
with litigation, Newsome consolidate her motions/pleadings herein pursuant to
FRCP Rule 12(G) which states:
FRCP Rule 12(g) Joining Motions.
Right to Join. A motion under this rule may be joined
with any other motion allowed by this rule.
4. Townsend’s Title 11 – Chapter 7 Bankruptcy – proceeding is merely acts in
FURTHERANCE of PATTERN-OF-ABUSE (i.e. for instance, under
CRIMINAL LAWS may be known as “Engaging in a PATTERN of CORRUPT
ACTIVITY”, etc.) to engage in criminal/civil wrongs and efforts to engage/solicit
this Court to cover up such legal injustices. Now it appears from this Court’s
June 27, 2014 Order relying upon a PROPOSED Order provided by Counsel for
Debtor Townsend (Robert Rex McRaney, Jr.) that a Motion to Dismiss –which
has NOT been served on Newsome – was filed with this Court. Service of
process providing Newsome with a copy of the Debtor Townsend’s Motion to
Dismiss has NOT been completed.
In re Spencer, 137 B.R. 506 (1992) - All courts possess inherent
power to protect their jurisdiction and process from abuse. In re
Higginbotham, 111 B.R. 955 (1990).
5. Newsome’s December 3, 2010, filing of the lawsuit – United States District
Court; Southern District of Mississippi (Jackson Division); Civil Action 3:10-cv-
704 - protected her rights and secured District Court with jurisdiction and any
such actions as that brought by Townsend on or about January 18, 2011.
Newsome’s December 3, 2010, lawsuit filed in this action secured District Court
with jurisdiction to hear any such bankruptcy Townsend may attempt to assert in
that Chapter 7 Bankruptcy filing arises out of the relief Newsome seeks through
this instant lawsuit. Therefore, it appears that Townsend has “HIT-A-BRICK-
WALL” in her efforts to try and run and hide from the liability Newsome seeks of
and against her for the legal wrongs addressed in Complaint. As a matter of
law, Newsome is to be dismissed from Townsend’s Bankruptcy action or matter
involving Newsome transferred the United States District Court for purposes of
keeping legal matters combined.
Matter of Wood, 825 F.2d 90 (5th
Cir. Miss. 1987) - If
proceeding involves right created by federal bankruptcy law, or
is one which would only arise in bankruptcy, it is core
proceeding, but if proceeding does not invoke substantive right
created by federal bankruptcy law and is one that could exist
outside of bankruptcy, it is noncore proceeding, though it may be
related to bankruptcy because of its potential effect on debtor's
estate. 28 U.S.C.A. § 157.
In re OCA, Inc., 551 F.3d 359 (5th
Cir. 2008) - Bankruptcy
court's adjudicative authority is constrained if the adversary
proceeding is non-core.

of 28
6. As a matter of law, the United States District Court – Southern District of
Mississippi (Jackson Division) on December 3, 2010, FIRST retained
jurisdiction over this matter.
Jurisdiction is the power to decide; it must be conferred,
not assumed. Matter of Chicago, Rock Island and Pacific R.
Co., 794 F.2d 1182 (7th
Cir. 1986). All bankruptcy jurisdiction is
given in the first instance to the United States district courts.
Acolyte Elec. Corp. v. City of New York, 69 B.R. 155 (Bankr.
E.D. N.Y. 1986), ordered aff’d, 1987 1987 WL 47763 (E.D.
N.Y. 1987); In re Double TRL, Inc., 65 B.R. 993 (Bankr. E.D.
N.Y. 1986).
The district courts are granted jurisdiction over
bankruptcy cases, that is cases under the Bankruptcy Code and
over three categories of bankruptcy proceedings: (1) civil
proceedings arising under Title 11; (2) civil proceedings arising
in a case under Title 11; and (3) civil proceedings related to
cases under Title 11. 28 U.S.C. § 1334(b). As used in this
statute, the phrase “arising under Title 11” is meant, not to
distinguish between different matters, but to identify collectively
a broad range of matters subject to the bankruptcy jurisdiction of
federal courts. Matter of Wood, 825 F.2d 90 (5th
Cir. 1987).
On or about December 16, 2010, Newsome served Debtor (Ladye M. Townsend
[“Townsend”]) with the required: (a) “Notice of Lawsuit and Request to Waive
Service of Summons;” and (b) “Waiver of the Service of Summons” which was
accompanied by Notification Accompanying Waiver of Service of Summons.
According to United States Postal Service information, Townsend received these
documents on or about December 27, 2010.
7. PLEASE BE ADVISED: There are FOREIGN/INTERNATIONAL Interest in
the Legal proceedings involving Vogel Newsome because it EXPOSES the
CORRUPTION in the United States of America’s JUDICIAL System and
SUPPORTS the RACIST/DISCRIMINATORY handling of lawsuits and
SPECIAL FAVORS given to Terrorist/White Supremacist Regimes as the Law
Firm of Baker Donelson Bearman Caldwell & Berkowitz. You see
Foreign/International Nations have LAWYERS/ATTORNEYS as well and they
can see for themselves THE LEGAL ARGUMENTS and EVIDENCE that
Newsome is presenting in Legal matters involving her and HOW the JUDICIAL
SYSTEM is TAINTED and DETERMINED to COVER-UP Criminal/Civil
wrongs made known to it – i.e. for instance look at the interest the one of Judge
Tom S. Lee’s (United States District Court – Southern District of Mississippi
(Jackson))

of 28
NOTE: Information taken from Newsome’s SLIDESHARE Social Forum -
www.SlideShare.net/VogelDenise
8. PLEASE BE ADVISED: Under the statutes/laws governing said matters that the
Southern District Court of Mississippi (Jackson) action (Civil Action 3:10-cv-
704) is STILL very VIABLE and ACTIVE regardless of the APPEARANCE said
Court may want the Public/World to think in displaying it as being
CLOSED/DISMISSED – i.e. it is NOT.
In fact, during the MAY 14, 2014 hearing held by this Court before Judge
Edward Ellington, this REPEATEDLY seem to be an issue that was
CLEARIFIED by Newsome that “DUE TO THE CONFLICT OF INTEREST”
present, any/all RULINGS by the District Court in that Lawsuit is NULL/VOID
and Newsome is in the process of having it addressed and seeing that the proper
actions –i.e. PROSECUTIONS, IMPEACHMENTS, etc. are initiated.
During said May 14, 2014 hearing, this Court attempted to convince/persuade
Newsome that the Southern District Court of Mississippi (Jackson) action (Civil
Action 3:10-cv-704) was a CLOSED/DISMISSED/RESOLVED matter.
However, Newsome NOTIFIED the Court of the statutes/laws governing said
matters which PRECLUDES the acts of Judge Louis Guirola in that lawsuit.

of 28
FACTS and EVIDENCE of the CONFLICT-OF-INTERESTS that precludes
Judge Guirola from acting and NEITHER is Newsome required to ENGAGE in
the CRIMINAL Acts of said Court/Judge in which the PROPER pleading(s) have
been submitted and will be UPDATED to support the INVESTIGATION(S)
requested. It is PLEASANT to state that said issues are
PROPERLY/ADEQUATELY and TIMELY PRESERVED. Thus, allowing
Newsome to CONTINUE in her QUESTS to EXPOSE what former United
States of America’s President John Fitzgerald Kennedy announced:
“There’s a PLOT in this country to ENSLAVE
every man, woman and child. BEFORE I leave
this HIGH and NOBLE office, I INTEND to
EXPOSE the PLOT!”
Then approximately seven (7) days later, President Kennedy is assassinated to
SILENCE him!
President Kennedy was nice in using the term “PLOT;” however, Newsome is
going to call it what it is “CONSPIRACY(S)!” So let us move on!

of 28
9. Newsome believes given the facts, evidence and legal conclusions not only in
this Bankruptcy matter, but that in the United States District Court, that
Townsend’s Title 7 Bankruptcy proceeding naming Newsome under “Creditors
Holding Unsecured Nonpriority Claims” has been submitted: in bad faith, for
purposes of harassment, for delay, for vexatious litigation, for purposes of
increasing the costs of litigation, for embarrassment, for false and frivolous
reasons in attempts to provide her with a defense to Newsome’s Civil lawsuit
filed in the United States District Court – Southern District of Mississippi
(Jackson Division) [“USDC-MS proceeding”]on or about December 3, 2010;
and other willful, malicious and wanton reasons known to Townsend for the
filing of this Chapter 7 Bankruptcy proceeding. Therefore, supporting the
dismissal of Newsome from Townsend’s Chapter 7 Bankruptcy proceeding:
A district court may transfer a bankruptcy case or
proceeding to a district court . . .in the interest of justice or for
the convenience of the parties. 28 § 1412. In contrast with the
general venue transfer statutes, this provision allows transfer to
any district, not only to districts in which venue would have been
proper had the case been brought in that district.
In determining whether to transfer a bankruptcy case, the
court should consider the following factors: (1) the proximity of
creditors to the court; (2) the proximity of the debtor to the court;
(3) the proximity of the witnesses necessary to the administration
of the estate; (4) the location of the assets; (5) economic
administration of the estate; (6) the necessity of ancillary
administration if liquidation should result. See In re
Commonwealth Oil Refining Co., 596 F.2d 1239, 1247 (5th
Cir.
1979), cert. denied, 444 U.S. 1045 (1980) (construing former 28
U.S.C. § 1475, substantially similar to present § 1412O.
Newsome does not believe that based upon the willful, malicious and wanton
acts of Townsend and the filing of this FRIVOLOUS Chapter 7 Bankruptcy
proceeding as a defense to Newsome’s “USDC-MS proceeding,” that a transfer
of this case is warranted or even qualifies for transfer. Therefore, in the
interest of justice and expedition of this case, Newsome timely, properly and
adequately requested to be dismissed as a “Creditor” from Townsend’s Chapter 7
Bankruptcy action in that this Court lacks jurisdiction over Newsome to proceed;
furthermore, that this Court(if it insist on entertaining Townsend’s Bankruptcy
action), in the interest of justice and convenience of parties transfer matter
regarding Newsome to the United States District Court – Southern District of
Mississippi (Jackson Division) for consolidation of cases and convenience to
parties. Townsend’s filing of the Chapter 7 Bankruptcy action clearly supports
that she would not be prejudiced by the transfer of this matter in that it will
remain in SAME venue; however, JURISDICTION of the United States District
Court – i.e. NOT Bankruptcy Court.
Time, Inc. v. Manning, 366 F.2d 690 (5th
Cir. 1966) - Both
jurisdiction and venue are designed to test fairness to defendant
and degree of inconvenience caused him by requiring him to
litigate in a particular court, but jurisdiction is relatively more
concerned with fairness and venue more with inconvenience.

of 28
10. It appears that Townsend and her counsel are attempting to get this Court to
usurp jurisdiction over this matter, the laws clearly prohibits such practices.
Brown v. Pyle, 310 F.2d 95 (5th
Cir. Miss. 1962) - “Jurisdiction”
is the power to hear and determine a cause-the power to
adjudicate; it is not to be confused with venue.
11. While Newsome does not claim to have knowledge of Chapter 7 Bankruptcy
laws, it is clear that Townsend did not bring this instant Chapter 7 Bankruptcy
proceeding as an “ENTITY,” “BUSINESS” for “ESTATE ADMINISTRATOR.”
Therefore, Newsome believes the laws support her concerns as to the motives for
the Chapter 7 Bankruptcy filing and this Bankruptcy Court’s jurisdiction over
this matter.
12. Newsome further believes that Townsend’s Chapter 7 Bankruptcy proceeding
filed with this Court in her INDIVIDUAL capacity was filed as a DEFENSE to
Newsome’s “USDC-MS proceeding” and therefore, may be precluded by law
given the facts, evidence and laws governing said matters.
In re SemCrude, L.P., 428 B.R. 82 (2010) - As general rule,
subject matter jurisdiction of court is based on state of facts that
existed at time cause of action was filed.
13. Newsome further believes that a “FEDERAL” court judgment on her “USDC-
MS proceeding” may preclude Townsend from bringing Chapter 7 Bankruptcy
proceeding naming Newsome in efforts to avoid the liability owed for damages
Newsome sustained and is addressed in the “USDC-MS proceeding.” Under the
statutes/laws governing issues regarding CONFLICT OF INTERESTS,
Newsome’s Lawsuit in Southern District Court of Mississippi (Jackson) action
(Civil Action 3:10-cv-704) is still LEGALLY/LAWFULLY active despite the
CRIMINAL acts of said court to make it appear that the case is closed (when it is
NOT)!
14. Newsome is NOT a business entity, but a private citizen (individual) of the
United States and is seeking relief of and against Townsend and others in the
“USDC-MS proceeding.”
II. MOTION FOR RELIEF FROM JUNE 27, 2014 CHAPTER 7 BANKRUPTCY ORDER
Vogel Newsome (“Newsome) further moves this Court for “Relief From the June 27, 2014
Order” pursuant to Rule 60 of the Federal Rules of Civil Procedure (“FRCP”) entered in that Counsel for
Debtor – Robert Rex McRaney, Jr./McRaney & McRaney – obtained said ruling as a direct and
proximate result of engaging in “FRAUD UPON THE COURT!” Moreover, that said Order is to be
VACATED in that it was INDUCED and/or PROCURED through FRAUDULENT and CRIMINAL Acts.
Not only that, this Court executed a PROPOSED Order to support a Motion to Dismiss that WAS
NEVER served on Newsome. A PROPOSED Order it appears was produced by Opposing Counsel

of 28
Robert Rex McRaney, Jr. via ELECTRONIC Filing; however, the Motion to Dismiss to which said
proposed Order supports was NEVER served on Creditor Newsome. Moreover, to date (July 14, 2014) -
at the time of this filing – Creditor Newsome has NOT been served with the Motion to Dismiss and thus,
having NO KNOWLEDGE prior to the June 27, 2014 PROPOSED Order executed by this Court that a
Motion to Dismiss by Debtor Townsend had been filed. Debtor Townsend’s Counsel Robert Rex
McRaney, Jr./McRaney & McRaney having KNOWLEDGE and UPDATED information regarding
Newsome’s CURRENT/PRESENT mailing address; nevertheless, made a WILLFUL, CONSCIENCE
and MALICIOUS decision to WITHHOLD service of Motion to Dismiss on Creditor Newsome having
KNOWLEDGE it would be CONTESTED if it was served on Newsome.

of 28
Rule 60. Relief from a Judgment or Order
(b) GROUNDS FOR RELIEF FROM A FINAL JUDGMENT, ORDER, OR
PROCEEDING. On motion and just terms, the court may relieve a party or its
legal representative from a final judgment, order, or proceeding for the following
reasons:
(1) mistake, inadvertence, surprise, or excusable neglect; . . .
(3) fraud (whether previously called intrinsic or extrinsic),
misrepresentation, or misconduct by an opposing party; . . .
(6) any other reason that justifies relief.
(c) TIMING AND EFFECT OF THE MOTION.
(1) Timing. A motion under Rule 60(b) must be made within a
reasonable time—and for reasons (1), (2), and (3) no more than a
year after the entry of the . . . order or the date of the
proceeding.
(d) OTHER POWERS TO GRANT RELIEF. This rule does not limit a court's
power to:
(1) entertain an independent action to relieve a party from a judgment,
order, or proceeding;
(3) set aside a judgment for fraud on the court. . . .
Fraud, whether intrinsic or extrinsic, misrepresentation, or other
misconduct of an adverse party are express grounds for relief by
motion under amended subdivision (b). There is no sound reason
for their exclusion. The incorporation of fraud and the like
within the scope of the rule also removes confusion as to the
proper procedure. It has been held that relief from a judgment
obtained by extrinsic fraud could be secured by motion within a
“reasonable time,” which might be after the time stated in the
rule had run. Fiske v. Buder (C.C.A.8th, 1942) 125 F.(2d) 841;
see also inferentially Bucy v. Nevada Construction Co.
(C.C.A.9th, 1942) 125 F.(2d) 213.. . .. The amendment settles
this problem by making fraud an express ground for relief by
motion; and under the saving clause, fraud may be urged as a
basis for relief by independent action insofar as established
doctrine permits. See Moore and Rogers, Federal Relief from
Civil Judgments (1946) 55 Yale L.J. 623, 653–659; 3 Moore's
Federal Practice (1938) 3267 et seq. And the rule expressly does
not limit the power of the court, when fraud has been
perpetrated upon it, to give relief under the saving clause. As an
illustration of this situation, see Hazel-Atlas Glass Co. v.
Hartford Empire Co. (1944) 322 U.S. 238.

of 28
However the Ninth Circuit Court of Appeals in the case of
Pumphrey v. K.W. Thompson Tool Co., 62 F.3d 1128, 1131 (9th
Cir. 1995) held that a lawyer’s failure to disclose . . . constituted
fraud upon the court.
In further support of said motion,
15. FACT: This Court has before it UNCONTESTED pleadings:
(a) “Creditor’s Opposition/Response to Notice of Chapter 7 Bankruptcy
Case, Meeting of Creditors, & Deadlines and Motion to be
Dismissed from Action” – Docket 10 – and
Discharge of Debtor; Request for Findings of Fact and Conclusions
of Law; and Vacating of Discharge of Debtor” – Docket 20 -
of Vogel Newsome.
16. On or about May 14, 2014, this Court held a hearing:

of 28
during said hearing, Judge Edward Ellington advised Newsome of additional
information that the Court needed. Newsome advised the Court/Judge Ellington
of her notation(s) of the Court’s requests and her proceeding to comply with said
request(s). Furthermore, Newsome advised the Court/Judge Ellington of the
JURISDICTION issue wherein it appears Judge Ellington wanted to remain
and/or appear to be oblivious to such CRITICAL/CRUCIAL facts. Moreover, at
said hearing Newsome REITERATED reliance upon said claims and defenses set
forth in her pleadings before the Court.
17. The BODY Language, ACTION as well as CONDUCT of Judge Ellington were
clear that he was DESPERATELY working to AID Counsel for Debtor
Townsend – Robert Rex McRaney, Jr. – in the defense of the SHALLACKING
being rendered by Newsome. Counsel McRaney had NO excuse for FAILURE
to provide a REBUTTAL to Newsome’s pleadings – i.e. at Docket Nos. 10 and 20
of this instant Bankruptcy action. Judge Ellington’s CODED EYEYING of
Opposing Counsel confirmed to Newsome that this Court/Ellington having
KNOWLEDGE that Newsome’s arguments were SOUND and SUBSTANTIATED
by statutes/laws governing said matters and went UNCONTESTED! Thus,
warranting rulings in favor of the relief sought therein.
18. At the end of the May 14, 2014 Bankruptcy Hearing in this instant Bankruptcy
action, this Court, Counsel for Townsend (McRaney) and Newsome UPDATED
Address information for Newsome:
Post Office Box 31265
Jackson, MS 39286
and Newsome advising that the Cincinnati, Ohio mailing address (P.O. Box
14731 – Cincinnati, OH 45250) is also good. McRaney also providing
Newsome with his contact information (2 Business Cards):

of 28
19. TO DATE (July 14, 2014), Newsome has NOT been served with the Motion to
Dismiss that this Court’s June 27, 2014 addresses. The EVIDENCE supports that
Newsome provided this Court and Counsel for Debtor (McRaney) with
UPDATED mailing address and RECEIVED this Court’s June 27, 2014
PROPOSED Order created by Counsel for Debtor Robert Rex McRaney, Jr.
20. Creditor Vogel Newsome is PRO SE and is NOT an attorney and DOES NOT
receive NOTICE(s) of filing(s) with this Court ELECTRONICALLY as Counsel
for Debtor Townsend – McRaney. Furthermore, Newsome DOES NOT have
available to her – because of PRO SE/NON-Attorney Status – the ability to
submit filings ELECTRONICALLY through this Court’s Electronic Filing
System.
21. With that being said, the BURDEN OF PROOF is on Counsel for Debtor
Townsend to PROVE by EVIDENCE that he SERVED Newsome with the
Motion to Dismiss pursuant to Rule 5 of the Federal Rules of Civil Procedure and
or other statutes/laws governing said matters:
Rule 5. Serving and Filing Pleadings and Other Papers
(b) Service: How Made.
(1) Serving an Attorney. If a party is represented by an attorney,
service under this rule must be made on the attorney unless the
court orders service on the party.
(2) Service in General. A paper is served under this rule by: . . .
(C) mailing it to the person's last known address—in
which event service is complete upon mailing; . .
(d) Filing.
(1) Required Filings; Certificate of Service. Any paper after the complaint that
is required to be served—together with a certificate of service—must be filed
within a reasonable time after service. . . .
22. With TWO VALID addresses provided to Opposing Counsel Robert Rex
McRaney, Jr. and Creditor Newsome NOT receiving Motion to Dismiss, it
warrants further INVESTIGATION(S) as well as PROOF from Counsel
McRaney that Service has been completed in the handling of the Motion to
Dismiss he based his PROPOSED supporting Order upon.

of 28
23. Such FRAUDULENT and CRIMINAL Acts by Debtor Townsend’s Counsel
Robert Rex McRaney, Jr./McRaney & McRaney is PREJUDICIAL and has
caused Creditor Newsome rights SECURED under the Constitution –i.e.
providing her with information so that she can CONTEST (if desired – Newsome
would have contested Motion to Dismiss had she been served). The Constitution
MANDATORILY requires that Creditor Newsome be provided with a copy of
the Debtor Townsend’s Motion to Dismiss to which the PROPOSED Order of
June 27, 2014 was executed upon.
24. Creditor Newsome is CONFIDENT that Counsel for Debtor Townsend
(McRaney) will NOT be able to provide any PROOF/EVIDENCE of mailing(s)
of the Motion to Dismiss ELECTRONICALLY filed, it appears from the
proposed Order signed, because NO such mailing(s) was initiated as
MANDATORILY required by the statute/laws governing said matters.
25. A reasonable mind may conclude that this Court submitted its ruling to Creditor
Newsome at the mailing address (Post Office Box 31265 – Jackson, MS 39286)
provided and Newsome’s RECEIPT is CONFIRMED through this filing;
that most UNLIKE this Court Counsel McRaney did NOT serve Newsome with
the Motion to Dismiss for purposes of ENGAGING in FRAUD UPON THE
COURT and for purposes of obtaining an UNDUE and ILLEGAL advantage in
this instant Bankruptcy action in which he is taking a HEAVY SHELLACKING!
Moreover, the ROLE that it now appears to Creditor Newsome that Counsel
McRaney is FULFILLING in the CHAIN CONSPIRACIES leveled against
Newsome.
It appears it may come down to Creditor Newsome doing further research to
determine WHEN Counsel for Debtor Townsend (McRaney) FILED the Motion
to Dismiss and WHEN (what date) the Lawsuit in the Anna Louise Inn Scandal
was FILED – and HOW SERVICE OF PROCESS (if any) in said scandal was
handled (if at all) – The Anna Louise Inn Lawsuit is an action brought AGAINST
Newsome which is being POSTED in Social Forums for PUBLIC/WORLD
interests:

of 28
26. The Anna Louise Inn Lawsuit was filed AGAINST Newsome on or about MAY
28, 2014!
So WHEN did Counsel for Debtor Townsend file the Motion to Dismiss and
how CLOSE (proximity date range - if at all) is said filing with the Lawsuit in
the Anna Louise Inn matter? Such information which is RELEVANT and
PERTINENT in that it NOW appears that the CRIMINAL Acts of Counsel
Robert Rex McRaney, Jr./McRaney & McRaney’ WITHHOLDING of service fo
the Motion to Dismiss may be a DIRECT and PROXIMATE result of his
ROLE(S) in the CHAIN CONSPIRACIES targeting Creditor Newsome - - For
instance:
(a) On or about May 14, 2014, this Court held a Hearing regarding Newsome’s
pleadings (Docket Nos. 10 and 20).
(b) On or about May 28, 2014, a Lawsuit was brought AGAINST Newsome in
the Anna Louise Inn matter.
(c) SO WHEN did Counsel for Debtor Townsend (McRaney)
file the Motion to Dismiss?

of 28
27. On or about JUNE 27, 2014, the court in the Anna Louise Inn Matter set for
hearing Newsome’s Motion to Dismiss.
Then ON-THE-SAME-DATE (June 27, 2014), it appears that this Court’s
Judge Ellington EXECUTED the proposed Order provided by Opposing Counsel
Robert Rex McRaney, Jr.
NOW let us look at WHEN this Court EXECUTED the proposed Order
submitted by Counsel for Debtor Townsend (McRaney).

of 28
28. This is IMPORTANT/RELEVANT information because the ANNA LOUISE
SCANDAL is DIRECTLY LINKED to the Scandals and CRIMINAL Activities
of United States of America President Barack Obama and his Legal Counsel
Baker Donelson Bearman Caldwell & Berkowitz – i.e. who has an office located
Jackson, Mississippi –
and BAKER DONELSON is LEGAL COUNSEL to the Federal Judges and/or
its Judges/Justices as Judge Edward Ellington as well as it appears may have
played a KEY/MAJOR role in Judge Ellington’s APPOINTMENT to the Bench.

of 28
29. In Newsome’s May 22, 2011 pleading entitled, “Creditor Vogel Newsome’s
Opposition/Response to 5/11/11 Discharge of Debtor; Request for Findings of
Fact and Conclusions of Law; and Vacating of Discharge of Debtor” – Docket
20 – she advised this Court that she had “BIGGER FISH TO FRY” which entails
United States of America’s President Barack Obama and his Legal Counsel
Baker Donelson Bearman Caldwell & Berkowitz! See at Docket 20, Pages 4 thru
9.

of 28
30. Yes, with CRIMINAL LAWYERS as Baker Donelson Bearman Caldwell &
Berkowitz at the HELM OF THE SHIP in their ATTACKS leveled AGAINST
Newsome, Newsome is getting JOY on EXPOSING what President John F.
Kennedy sought to EXPOSE! It may have cost President Kennedy his life;
however, he was a President UNLIKE President Barack Obama that appears
WOULD NOT compromise with the likes of Baker Donelson Bearman Caldwell
& Berkowitz its TERRORIST/RACIST Regime.
31. Newsome believes there are sufficient, facts, evidence and legal conclusions in
the “USDC-MS proceeding” to support that Townsend’s and her legal counsel’s
(Robert Rex McRaney, Jr.) credibility is lacking. Moreover, that Townsend and
McRaney have a PATTERN-OF-PRACTICE to: (a) provide false and
misleading information; (b) obstruct justice and/or the administration of justice;
and (c) engage in civil/criminal violations for willful, malicious and wanton
intent.
Thigpen v. Kennedy, 238 So.2d 744 (Miss.,1970) - It is duty of
the chancellor to apply “unclean hands” doctrine of its own
motion when it becomes evident that the facts of case are such
they call for application of the doctrine.
32. Newsome believes that based upon the facts, evidence and legal conclusions
provided herein, that Townsend comes before this Court with “UNCLEAN
HANDS” and is AIDED and ABETTED by her attorney (McRaney). The
unlawful/illegal acts of Townsend and McRaney are for purposes of causing
Newsome further injury and harm. Moreover, efforts to preclude Newsome from
recovering from injuries/harm caused by Townsend’s unlawful/illegal actions
addressed in “USDC-MS proceeding.”

of 28
Positive Black Talk Inc. v. Cash Money Records, Inc., 394 F.3d
357 (5th
Cir. 2004) - The “unclean hands doctrine” is used to
defeat an undeserving plaintiff's claim for equitable relief against
a defendant that he has injured.
33. Townsend and her counsel (Robert Rex McRaney, Jr. [“McRaney”]) do not come
before this Bankruptcy Court in good faith and clean hands. In fact, this instant
Bankruptcy proceeding has been brought in bad faith and with dirty hands for
purposes of causing needless delay, embarrassment to this Court, increasing the
costs of litigation, harassment of Newsome, intimidation, coercion, obstructing
the administration of justice, committing fraud on this Court and other reasons
known to Townsend and her counsel (McRaney).
In re Stoball's Will, 50 So.2d 635 (Miss.,1951) - He who comes
into an equity court must come with clean hands, and one cannot
use processes of that court when his conduct with respect to
transaction in question has been characterized by wilful inequity,
illegality, and fraud.
34. McRaney is an attorney whose area of SPECIALTY/practice entails,
“BANKRUPTCY” law. Therefore, a reasonable may conclude that McRaney
knew and/or should have known that in the filing of Townsend’s Chapter 7
Bankruptcy action, was done with intent to commit fraud and deceive this Court.
NOW we have Opposing Counsel McRaney’s handling of the Motion to Dismiss
to SUBSTANTIATE such FRUDULENT acts upon this Court as well as the
OBSTRUCTION of the Administration of Justice and other CRIMINAL Acts
known and/or should be known to him as well as this Court. McRaney practicing
before this Court with “DIRTY HANDS!”
Other Court Case: Because Bankruptcy Court is a court of
equity, a person seeking relief in Bankruptcy Court must come
into court in good faith and with clean hands. In re Quality
Trading Co., Inc., Bkrtcy.D.Hawaii 1984, 36 B.R. 265,
reconsideration denied 39 B.R. 42.
Mississippi Cases: Vasser v. Bibleway M.B. Church, 2010 WL
5093741 (Miss. App. 2010) - One seeking relief in equity must
come with clean hands or face refusal by the court to aid in
securing any right or granting any remedy. Community Bank of
Mississippi v. Stuckey, 2010 WL 4983102 (Miss. 2010); Whalen
v. Bistes, 45 So.3d 290 (Miss.App.,2010).
Lane v. Lane, 850 So.2d 122 (Miss.App.,2002) - The court may
apply the unclean hands doctrine sua sponte where it is shown
applicable.
35. Even if Townsend may want to assert she relied upon the counsel of McRaney,
such defense must also fail. Townsend has a history and pattern of engaging in
criminal acts for purposes of obstructing justice. Furthermore, Townsend has an
employment history in law as a Legal Secretary/Assistant. Therefore, a

of 28
reasonable mind may conclude the necessary tools to determine whether the
advice given her was lawful or whether she knowingly, deliberately and
intentionally encouraged McRaney to file the Chapter 7 Bankruptcy proceeding
with knowledge that she may have been committing fraud on the United States
Bankruptcy Court – Southern District of Mississippi. Townsend’s PATTERN of
CRIMINAL ACTS are also well documented in “USDC-MS proceeding.”
Creditors could not defeat claim that they filed involuntary
Chapter 7 petition in bad faith by asserting that they relied on
advice of counsel; advice of counsel defense is only available to
those who place good faith reliance on that advice after full
disclosure of material facts, but creditors had intentionally
deceived bankruptcy attorney by building a "Chinese wall"
around him so that he would not know key facts regarding events
surrounding the petition filing. In re Landmark Distributors,
Inc., Bkrtcy.D.N.J. 1995, 189 B.R. 290.
36. Newsome further request through this instant filing that should the United States
Bankruptcy Court find that Debtor’s counsel (Robert Rex McRaney, Jr.) has
engaged in criminal/fraudulent practices that it initiate the applicable
proceedings to have him disciplined – i.e. sanctioned and/or disbarred – if
permissible under the laws governing said matters. Newsome believes that the
appropriate disciplinary actions against McRaney is necessary to DETER and
DISCOURAGE future abuse of the laws as an attorney/officer of the Court.
In re Tbyrd Enterprises LLC, 354 Fed.Appx. 837 (5th
Cir. 2009)
- Bankruptcy court had jurisdiction to impose sanctions under
the Federal Rules of Bankruptcy Procedure against debtor's
owner and debtor's counsel for filing a bad faith petition, since
the imposition of sanctions on litigants in a bankruptcy case was
a matter arising in such a case within meaning of the statute
granting bankruptcy judges authority to hear and determine
matters arising in a bankruptcy case. 28 U.S.C.A. § 157(b)(1);
Fed.Rules Bankr.Proc.Rule 9011, 11 U.S.C.A.
In re Pratt, 524 F.3d 580 (5th
Cir. 2008) - Because Rule 9011 of
the Federal Rules of Bankruptcy Procedure is substantially
identical to Federal Rule of Civil Procedure 11, the Court of
Appeals may refer to Rule 11 jurisprudence when considering
sanctions under Rule 9011. Fed.Rules Bankr.Proc.Rule 9011, 11
U.S.C.A.; Fed.Rules Civ.Proc.Rule 11, 28 U.S.C.A.
In re First City Bancorporation of Texas Inc., 282 F.3d 864 (5th
Cir. 2002) - Sanctions imposed by the bankruptcy court must be
chosen to employ the least possible power to the end proposed;
in other words, the court must use the least restrictive sanction
necessary to deter the inappropriate behavior.

of 28
WHEREFORE, Opposing Counsel Robert Rex McRaney, Jr. did KNOWINGLY and
WILLINGLY commit FRAUD UPON THE COURT in the handling of the Motion to Dismiss and
ENGAGED in a PATTERN-OF-CRIMINAL Acts through the use of this Court’s Electronic Filing
System which WARRANTS the proper INVESTIGATIONS and PROSECUTION(S) for criminal/civil
wrongs McRaney engaged in.
III. MOTION FOR SANCTION(S):
Pursuant to Federal Rule of Civil Procedure Rule 12(G) and Rule 11, Creditor Vogel Newsome
(“Newsome”) moves this Court, for the above foregoing reasons and those known to this Court for the
ISSUANCE of Sanctions of and AGAINST Opposing Counsel Robert Rex McRaney, Jr./McRaney &
McRaney in accordance with the Statutes/Laws governing said matters. In support thereof, Newsome
states the following:
Rule 11. Signing Pleadings, Motions, and Other Papers; Representations to
the Court; Sanctions
(a) Signature. Every pleading, written motion, and other paper must be signed by
at least one attorney of record in the attorney's name—or by a party personally if
the party is unrepresented. The paper must state the signer's address, e-mail
address, and telephone number. Unless a rule or statute specifically states
otherwise, a pleading need not be verified or accompanied by an affidavit. The
court must strike an unsigned paper unless the omission is promptly corrected
after being called to the attorney's or party's attention.
(b) Representations to the Court. By presenting to the court a pleading, written
motion, or other paper—whether by signing, filing, submitting, or later
advocating it—an attorney or unrepresented party certifies that to the best of the
person's knowledge, information, and belief, formed after an inquiry reasonable
under the circumstances:
(1) it is not being presented for any improper purpose, such as to harass, cause
unnecessary delay, or needlessly increase the cost of litigation;. . .
Sanctions.
(1) In General. If, after notice and a reasonable opportunity to respond, the
court determines that Rule 11(b) has been violated, the court may impose an
appropriate sanction on any attorney, law firm, or party that violated the rule or is
responsible for the violation. Absent exceptional circumstances, a law firm

of 28
must be held jointly responsible for a violation committed by its partner,
associate, or employee.
(2) Motion for Sanctions. A motion for sanctions must be made separately from
any other motion and must describe the specific conduct that allegedly violates
Rule 11(b). The motion must be served under Rule 5, but it must not be filed or
be presented to the court if the challenged paper, claim, defense, contention, or
denial is withdrawn or appropriately corrected within 21 days after service or
within another time the court sets. If warranted, the court may award to the
prevailing party the reasonable expenses, including attorney's fees, incurred for
the motion.
(3) On the Court's Initiative. On its own, the court may order an attorney, law
firm, or party to show cause why conduct specifically described in the order has
not violated Rule 11(b).
(4) Nature of a Sanction. A sanction imposed under this rule must be limited to
what suffices to deter repetition of the conduct or comparable conduct by others
similarly situated. The sanction may include nonmonetary directives; an order to
pay a penalty into court; or, if imposed on motion and warranted for effective
deterrence, an order directing payment to the movant of part or all of the
reasonable attorney's fees and other expenses directly resulting from the
violation.
(5) Limitations on Monetary Sanctions. The court must not impose a monetary
sanction:
(A) against a represented party for violating Rule 11(b)(2); or
(B) on its own, unless it issued the show-cause order under Rule 11(c)(3) before
voluntary dismissal or settlement of the claims made by or against the party that
is, or whose attorneys are, to be sanctioned.
(6) Requirements for an Order. An order imposing a sanction must describe
the sanctioned conduct and explain the basis for the sanction.
A. RULES OF CIVIL PROCEDURE – RULE 11 SANCTIONS:
Skidmore Energy, Inc. v. KPMG, 455 F.3d 564, 569-570 (2006)
– Under the “snapshot” rule, sanctions based on a frivolous
pleading were proper because the lack of legal and evidentiary
support for the pleading at the time it was filed. The . . .court
found the claims lacked both legal and factual support and
imposed more than $500,000 in sanctions against plaintiffs and
their counsel, based on defendants’ reasonable expenses incurred
in litigating against the claims. . . . This test focuses on the
instant when the signature is placed on the document, and the
state of mind of the signer at the time. The test ensures the Rule
11 liability is assessed only for violation existing at the moment
of filing. The . . . court had clearly concluded that the pleadings
were frivolous when filed. The fact that they continued to lack

of 28
evidentiary support throughout the proceedings only underscored
the violation.
(n. 4) Both client and attorney have duty to conduct
reasonable inquiry into facts or law before filing lawsuit;
(n. 5) In lawsuit addressing ongoing dispute . . .court did
not abuse its discretion in awarding Rule 11 sanctions against
plaintiffs; rather than sanctioning them for legally frivolous
nature of pleadings, it sanctioned them for . . .factually
groundless allegations in their complaint; and
(n. 7) Fifth Circuit's “snapshot” rule/test ensures that
Rule 11 liability is assessed only for a violation existing at
moment of filing.
37. This Court, upon the use of the U.S. Fifth Circuit Court of Appeals’
“SNAPSHOT Rule” Debtor Ladye M. Townsend’s and her Legal Counsel Robert
Rex McRaney, Jr.’s Motion to Dismiss will find the evidence LACKING to
support dismissal. Moreover, that the CRIMINAL ACTS and PATTERN-OF-
CRMINAL acts of Debtor and her Counsel supports the Bankruptcy action
brought and the listing of Vogel Newsome (an INDIVIDUAL and NOT a
Business Entity) is frivolous and a sham submitted with WILLFUL,
MALICIOUS and WANTON acts to commit fraud upon this Court.
Furthermore, that said pleadings brought by Debtor and her Counsel clearly
lacked legal standing and evidentiary support at the time they were filed.
Therefore, supporting and sustaining the sanction relief Newsome seeks through
this instant filing.
38. Newsome believes that a reasonable mind may conclude that in using the
“SNAPSHOT Rule” as well as COUNSEL Robert Rex McRaney Jr.’s
DELIBERABTE, WILLFUL and MALICIOUS acts in failing to provide
Newsome with a copy of the Motion to Dismiss to which the JUNE 27, 2014
Order is issued were for purposes of fraud, deceit, misrepresentation,
harassment, embarrassment, obstructing justice, delaying proceedings,
increasing the costs of litigation, violating the Rules of the Court and
Federal Rules of Civil Procedures and other reasons known to him.
39. Newsome further believes that the record evidence will support that Debtor
Townsend and her Counsel (McRaney) have established a “PATTERN-OF-
ABUSE” and “PATTERN-OF-ENGAGING-IN-CRIMINAL ACTS” to further
support Rule 11 Sanctions as well as this Court’s reporting of said CRIMINAL
acts to the appropriate agency/entity for prosecution, sanction and disbarment (if
applicable).
40. Rule 11 of the Federal Rules of Civil Procedure are CLEAR of the
MANDATORY requirements for such FRAUDULENT and CRIMINAL acts of
Counsel for Debtor Townsend (Robert Rex McRaney, Jr./McRaney &
McRaney).
41. Newsome believes that the record evidence will support that Rule 11 liability is
deemed appropriate at this time to deter and discourage Counsel for Debtor
Townsend – Robert Rex McRaney, Jr./McRaney & McRaney) from coming
before this Court with fraudulent intent, criminal intent and other willful,
malicious and wanton unethical behavior known to them.

of 28
42. Opposing Counsel Robert Rex McRaney, Jr./McRaney & McRaney KNEW that
he/it was ENGAGING in FRAUDULENT practices UPON THIS COURT in the
submittal of the Motion to Dismiss granted through the June 27, 2014 Order
ATTACHED to his/its PROPOSED Order dismissing action. Moreover, that
FAILURE to provide Creditor Newsome with Motion to Dismiss with
KNOWLEDGE that she is PRO SE and is NOT an attorney further SOLIDIFIES
the FRAUDULENT practices INITATED upon this Court and WILLFUL,
MALICIOUS and WANTON acts to ENGAGE this Court in his/its CRIMINAL
ACTS!
Mercury Air Group, Inc. v. Mansour, 237 F.3d 542 (C.A.5.
2001) - Under Rule 11, an attorney must have made a reasonable
inquiry into the facts and law of a case at the time which he or
she affixes his or her signature on any papers to the court.
Fed.Rules Civ.Proc.Rule 11, 28 U.S.C.A.
Walker v. City of Bogalusa, 168 F.3d 237 (C.A.5.1999) - A
signatory violates Rule 11 if he fails to conduct a reasonable
inquiry into the law and facts underlying his motion, or if he
makes a motion to delay, harass or increase the costs of
litigation. Fed.Rules Civ.Proc.Rule 11, 28 U.S.C.A.
Prior to Opposing Counsel Robert Rex McRaney, Jr. AFFIXING his signature to
the PROPOSED Order supporting the Motion to Dismiss, he KNEW that he did
NOT and NEITHER was he intending to provide Creditor Newsome with a copy
of the Motion to Dismiss. In so ENGAGING in such CRIMINAL acts, a
REASONABLE mind may conclude that the CRIMINAL and FRAUDULENT
acts by Counsel Robert Rex McRaney, Jr./McRaney & McRaney was done with
FORETHOUGHT, MALICE and FRAUDULENT intent, etc.
43. The nature and/or area of BANKRUPTCY is within the “LEGAL FIELD and
EXPERTISE” – of Opposing Counsel Robert Rex McRaney, Jr./McRaney &
McRaney. Therefore, supporting KNOWLEDGE that his/its handling of the
Motion to Dismiss this Court executed a PROPOSED Order from Opposing
Counsel on was provided with WILLFUL and MALICIOUS intent to commit
FRAUD UPON THE COURT and to get this Court to ERR on relying upon an
OFFICER OF THE COURT who took an OATH; nevertheless, TOOK A FAR
DEPARTURE from said Oath for purposes of obtaining an
UNDUE/UNLAWFUL/ILLEGAL advantage in this instant Bankruptcy action.
44. During the May 14, 2014 hearing before Judge Ellington, this Court wanted
Creditor Newsome to believe that her Civil Lawsuit in United States District
Court; Southern District of Mississippi (Jackson Division); Civil Action 3:10-cv-
704 was NO LONGER viable; however, Newsome CORRECTED and
INFORMED this Court with Opposing Counsel Robert Rex
McRaney, Jr./McRaney & McRaney present that such
ASSERTION was in ERROR and that the United States District
Court action is ALIVE and WELL despite HOW that Court
wants it to appear to the PUBLIC/WORLD! Thus, allowing

of 28
Creditor Newsome to continue to PURSUE other
CRIMINAL/CIVIL prosecution in other matters.
Marlin v. Moody Nat. Bank, N.A., 533 F.3d 374 (5th
Cir. 2008) -
“Snapshot rule” ensures that Rule 11 liability is assessed only
for violation existing at moment of filing.
Nevertheless, in this instant matter, Creditor Newsome wants to REITERATE
that the United States District Court; Southern District of Mississippi (Jackson
Division); Civil Action 3:10-cv-704, due to the CONFLICT-OF-
INTERESTS of Judge Louis Guirola, Jr. is ALIVE and WELL
and BEAUTIFULLY Stayed while she pursues OTHER Legal
Resources available to her – i.e. just CONTINUE to WATCH
CAPITOL HILL in Washington, D.C.
45. After the May 14, 2014 Bankruptcy Hearing, Opposing Counsel Robert Rex
McRaney, Jr. advised Creditor Newsome of Debtor Townsend’s financial
situation which led her to have to file for Bankruptcy. McRaney it appears
advising Newsome of such for purposes of obtaining sympathy from her;
however, Newsome advised McRaney, that he would not be getting any
sympathy from her and that Debtor Townsend was fully aware of her actions and
the Civil Lawsuit was a direct and proximate result of her ENGAGEMENT in
Criminal/Civil wrongs – i.e. LYING during Federal Investigation(s) in which
Newsome has documentation supporting same. Moreover, it was obvious that
Creditor Newsome had become VERY UPSET that Opposing Counsel McRaney
was requesting she let Debtor Townsend off the hook because of her financial
situation – i.e. NOT A CHANCE!
Information PERTINENT and RELEVANT for the purposes of SHOWING the
STATE of MIND – i.e. Criminal Intent – of Opposing Counsel McRaney and his
KNOWLEDGE that Creditor Newsome would provide a DEFENSE for any
pleading filed. Therefore, realizing that he FAILED to provide a REBUTTAL
pleading to Creditor’s:
(a) “Creditor’s Opposition/Response to Notice of Chapter 7
Motion to be Dismissed from Action” – Docket 10 – and
Conclusions of Law; and Vacating of Discharge of Debtor”
– Docket 20.
It appears from the June 27, 2014 Order of this Court, that Opposing Counsel
Robert Rex McRaney, Jr./McRaney & McRaney did KNOWINGLY and WITH
MALICIOUS intent submit a Motion to Dismiss and a PROPOSED Order that it
UNLAWFULLY/ILLEGALLY withheld from Creditor Newsome for purposes
of obtaining an UNLAWFUL/ILLEGAL advantage in this Bankruptcy action
with KNOWLEDGE that Creditor Newsome would provide a REBUTTAL to the
Motion to Dismiss. In so doing, Creditor Newsome has been

INJURED/HARMED and DEPRIVED for Consritutional and Civil Rights to
CONTEST the Motion to Dismiss because Opposing Coimsel McRaney
WITHHELD service and may have PERJURED himself and/or LIED,
FALSIFIED and/or MISREPRESENTED to this Court that Creditor Newsome
had been served - i.e. which can be CONFIRMED through an
INVESTIGATION and this Court's reviewing of the Motion to Dismiss filed;
however, NOT served on Creditor Newsome.
WHEREFORE, Creditor Vogel Newsome moves this Court for SANCTIONS of and against
Counsel Robert Rex McRaney, Jr./McRaney & McRaney in the amount of S50,000.(X) as well as this
Court's filing of the appropriate Criminal Acts/lnvesrigarions for prosecution (i.e. SUSPENSION,
DISBARMENT, etc.) for the Criminal/Civil wTongs reported herein.
P L E A S E T A K E N O T I C E : That Creditor Vogel Newsome through the above Morions, hereby
demand to be advised of ANY/ALL CONFLICT-OF-INTERESTS in this Court's handhng of the instant
Bankruptcy matter
WHEREFORE, PREMISES CONSIDERED Newsome prays that his Court GRANT the relief set
forth in this instant "Creditor's Motion for Relief From Order/Judgment: Motion for Rule 11 Sanctions of
and Against Robert Rex McRaney Jr, McRaney & McRaney: and Request To Be Advised Of ConfJtci-Of
Interests" and the supporting Motions individually raised m this instant Bankruptcy pleading. Wliile
Newsome believes diat this mstant filing provides the facts and evidence to support the rehef sought
herein and saves of additional costs, she reserves the right to submit to this Court her Memorandum Brief
in support of "CORNCTCBC&jVfTD'" i f said Court deems die motion alone is insufficient and an
additional memorandum brief may be beneficial.
Respectfully submitted this 14* day of July, 2014.
i
S - . : >
" I '•-
By: Vogel Newsome
Cincinnati, Ohio 45250
Phone: (601) 885-9536 or (5 13) 680-2922
Page 27 of 28

C E R T I F I C A T E O F SERNTCE
The undersigned hereby cerdfies that a true and correct copy of the forgoing pleading was
MAILED via U.S. Mail first-class to:
Robert Rex McRaney, Jr.
Clinton, Mississippi 39060
COUNSEL FOR. DEBTOR (LADYE M. imTvlSEND)
Dated this 14* day of July, 2014.
Vogel Newsome
Page 28 of 28

Employee Engagement in Criminal/Civil Wrongs and Bankruptcy

Recomendados

Recomendados

Más contenido relacionado

La actualidad más candente

La actualidad más candente (20)

Destacado

Destacado (20)

Similar a Employee Engagement in Criminal/Civil Wrongs and Bankruptcy

Similar a Employee Engagement in Criminal/Civil Wrongs and Bankruptcy (20)

Último

Último (8)

Employee Engagement in Criminal/Civil Wrongs and Bankruptcy