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MOTION TO REOPEN CASE PURSUANT TO 11 USC § 350 and OTHER
STATUTES/LAWS GOVERNING SAID MATTERS; OBJECTION TO 02/25/16 FINAL
DECREE/ORDER CLOSING CASE PURSUANT TO RULE 5009 and/or RULE 3022 OF
THE FEDERAL RULES OF BANKRUPTCY PROCEDURES; The DECLARATION OF
INDEPENDENCE; REQUEST TO BE ADVISED OF CONFLICT-OF-INTERESTS; and
REITERATION FOR MOTION FOR RECUSAL OF JUDGE EDWARD ELLINGTON
MARCH 7, 2016 BANKRUPTCY COURT FILING
j ; 5 SANKRUrTCYC3l;?IT
SCUIHLRH m s T R i c r or K S
IN THE UNITED STATES BANKRUPTCY COURT • ^, . 3 r,., ,^ . .
t. . ' - I , ' . - / r n l i i ' 2 5
SOUTHERN DISTRICT OF MISSISSIPPI
C A N N ^ v [ MILLER
C L E R K
5YJa..i_ D E P U T Y
IN RE:
LADYE M. TOWNS END CHAPTER 7
DEBTOR CASE NO. 11-00167-ee
MOTION TO REOPEN CASE PURSUANT TO 11 USC § 350 and OTHER STATUTES/LAWS
GOVERNING SAID MATTERS; OBJECTION TO 02/25/16 n N A L DECREE/ORDER
CLOSING CASE PURSUANT TO RULE 5009 and/or RULE 3022 OF THE
FEDERAL RULES OF BANKRUPTCY PROCEDURES; The DECLARATION OF
INDEPENDENCE; REQUEST TO BE ADVISED OF CONFLICT-OF-INTERESTS; and
REITERATION FOR MOTION FOR RECUSAL OF JUDGE EDWARD ELLINGTON '
COMES NOW Creditor Vogel Newsome ("Newsome") without waiving her rights, without
submitting to the jurisdiction of this Court, without waiving previous defenses and claims set forth in her
pleadings filed with this Court and files this her "MOTION TO REOPEN CASE PURSUANT TO 11
USC § 350 and OTHER STATUTES/LAWS GOVERNING SAID MATTERS; OBJECTION TO
02/25/16 FINAL DECREE/ORDER CLOSING CASE PURSUANT TO RULE 5009 and/or RULE 3022
OF THE FEDERAL RULES OF BANKRUPTCY PROCEDURES; The DECLARATION OF
INDEPENDENCE; REQUEST TO BE ADVISED OF CONFLICT-OF-INTERESTS; and
REITERATION FOR MOTION FOR RECUSAL OF JUDGE EDWARD ELLINGTON"
("MTRC&OT02-25-16FDOCC") pursuant to 11 USC § 350, Rule 5009 and/or Rule 3022 of the Federal
Rules of Bankruptcy Procedure ("FRBP"), 28 USC § 455; FRCP Rule 12(G) - consolidation of matters -
and other statutes/laws governing said matters. In support thereof, Newsome states the following
' NOTE: Boldface, italics and underline, etc. represents "emphasis" added.
Page 1 of 33
Page 1 of 33
IN THE UNITED STATES BANKRUPTCY COURT
SOUTHERN DISTRICT OF MISSISSIPPI
IN RE:
LADYE M. TOWNSEND CHAPTER 7
DEBTOR CASE NO. 11-00167-ee
MOTION TO REOPEN CASE PURSUANT TO 11 USC § 350 and OTHER STATUTES/LAWS
GOVERNING SAID MATTERS; OBJECTION TO 02/25/16 FINAL DECREE/ORDER
CLOSING CASE PURSUANT TO RULE 5009 and/or RULE 3022 OF THE
FEDERAL RULES OF BANKRUPTCY PROCEDURES; The DECLARATION OF
INDEPENDENCE; REQUEST TO BE ADVISED OF CONFLICT-OF-INTERESTS; and
REITERATION FOR MOTION FOR RECUSAL OF JUDGE EDWARD ELLINGTON 1
COMES NOW Creditor Vogel Newsome (“Newsome”) without waiving her rights, without
submitting to the jurisdiction of this Court, without waiving previous defenses and claims set forth in her
pleadings filed with this Court and files this her “MOTION TO REOPEN CASE PURSUANT TO 11
USC § 350 and OTHER STATUTES/LAWS GOVERNING SAID MATTERS; OBJECTION TO
02/25/16 FINAL DECREE/ORDER CLOSING CASE PURSUANT TO RULE 5009 and/or RULE 3022
OF THE FEDERAL RULES OF BANKRUPTCY PROCEDURES; The DECLARATION OF
INDEPENDENCE; REQUEST TO BE ADVISED OF CONFLICT-OF-INTERESTS; and
REITERATION FOR MOTION FOR RECUSAL OF JUDGE EDWARD ELLINGTON”
(“MTRC&OT02-25-16FDOCC”) pursuant to 11 USC § 350, Rule 5009 and/or Rule 3022 of the Federal
Rules of Bankruptcy Procedure (“FRBP”), 28 USC § 455; FRCP Rule 12(G) – consolidation of matters –
and other statutes/laws governing said matters. In support thereof, Newsome states the following
1
NOTE: Boldface, italics and underline, etc. represents “emphasis” added.
Page 2 of 33
REITERATED UNCONTESTED FACTS ignored by this Court in its February 25, 2016 Final
Decree/Order Closing Case:
I. LACK OF JURISDICTION – The record evidence STRONGLY supports this Court’s and
opposing Counsel’s INABILITY to PROVIDE EVIDENCE as well as CASE LAWS to
rebut the EVIDENCE as well as LEGAL CONLUSIONS provided below and in
PREVIOUS pleadings brought by Creditor Newsome. Therefore, Creditor Newsome is
AGAIN reiterating and incorporating by reference said defense(s) as set forth in her
previously filed pleadings in this instant Bankruptcy action:
PLEASE NOTE: As required by Rule 8 (General Rules of Pleading) of the Federal Rules of
Civil Procedure, for instance as mentioned in previous filing, Creditor Newsome’s October
13, 2015 Pleading (DOCKET NO. 64) specifically sets forth “short and plain statement(s)”
of the grounds for relief/claims; however, the record evidence WILL SUPPORT this
Court’s/Judge Edward Ellington’s INABILITY to REBUT the FACTS, EVIDENCE and
LEGAL CONCLUSIONS that this Court/he “LACKS” Jurisdiction in this matter.
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
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
Page 3 of 33
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 (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 “MTRC&OT02-25-16FDOCC” 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 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.
Page 4 of 33
MOTION TO REOPEN CASE
COMES NOW Creditor Vogel Denise Newsome WITHOUT waiving the above
foregoing Jurisdictional Defense and in PRESERVATION of her rights and moves this Court to
REOPEN this instant Bankruptcy action PURSUANT to 11 USC § 350, Rule 5010 of the Federal
Rules of Bankruptcy Procedure and other statutes/laws governing said matters. In support
thereof, Newsome states in good faith the following:
1. This Court/Judge Edward Ellington with WILLFUL and MALICIOUS acts issued on or
about February 25, 2016, a Final Decree/Order Closing Case with KNOWLEDGE that
estate HAS NOT been FULLY Administered in accordance to the MANDATORY
requirements governing said Bankruptcy matters. Therefore, Creditor Newsome
TIMELY, PROPERLY and ADEQUATELY submits said Motion to REOPEN this
instant Bankruptcy Case in accordance with 11 USC § 350,
Rule 5010 of the Federal Rules of Bankruptcy Procedure and other
statutes/laws governing said matters:
Page 5 of 33
2. This instant Bankruptcy matter was one INITIATED by Debtor Ladye M.
Townsend in efforts of keeping Creditor Newsome from obtaining RELIEF
through the CIVIL Lawsuit that has been filed in the United States District Court
for the Southern District of Mississippi (Jackson Division) – Case No. 3:10-cv-
00704.
3. Rule 5009 clearly states in part, “Cases under Chapters 7. . . the trustee has filed
a final report and final account and has certified the estate has been fully
administered, and IF within 30 days NO OBJECTION has been filed by. . .a
party of interest, there shall be a PRESUMPTION that the estate has been
FULLY administered. . .” So IF this instant Bankruptcy action is NOW a
Chapter 7 LIQUIDATION matter, in that DEBTOR Ladye M. Townsend and
her Counsel McRaney & McRaney in COLLUSION with this Court/Judge
Edward Ellington DO NOT seem to know themselves what TYPE of Bankruptcy
matter this is,
Page 6 of 33
the RECORD evidence in this instant Bankruptcy action WILL SUPPORT and
SUSTAIN that Creditor Newsome has REPEATEDLY filed TIMELY
OBJECTIONS in compliance with Rule 5009 of the FRBP and other applicable
statutes and/or laws governing said matters FOR REDRESS and, therefore,
PROHIBITS this Court from entering a Final Decree/Order Closing Case in
that the estate HAS NOT been FULLY administered. SEE DECLARATION
OF INDEPENDENCE INDICMENTS BELOW in this instant pleading!
4. Rule 3022 of BRBP clearly states in part, “After an estate is FULLY
ADMINISTERED in a Chapter 11 REORGANIZATION case. . .” and Section
350 of the Code REQUIRES the Court CLOSE the case AFTER the estate is
FULLY ADMINISTERED. . .
So IF this instant Bankruptcy action is NOW a Chapter 11
REORGANIZATION Case, in that DEBTOR Ladye M. Townsend and her
Counsel McRaney & McRaney in COLLUSION with this Court/Judge Edward
Ellington DO NOT seem to know themselves what TYPE of Bankruptcy matter
this is, the RECORD evidence in this instant Bankruptcy action WILL
SUPPORT and SUSTAIN that Creditor Newsome has REPEATEDLY filed
TIMELY OBJECTIONS in compliance with the Federal Rules of Bankruptcy
Procedure and other applicable statutes and/or laws governing said matters for
REDRESS and, therefore, PROHIBITS this Court from entering a Final
Decree/Order Closing Case in that the estate HAS NOT been FULLY
administered. SEE DECLARATION OF INDEPENDENCE INDICMENTS
BELOW in this instant pleading!
5. OBJECTION is made in that the TRUSTEE has NOT FULFILLED the
MANDATORY DUTY(S) requirements PURSUANT to Rule 704 of the FRBP
and other Statutes/Laws governing said matters.
Page 7 of 33
6. Creditor Vogel Denise Newsome further MOVES and REITERATES her
DEMAND for RECUSAL of Judge Edward Ellington because of the existing
“CONFLICT-OF-INTEREST” pursuant to 28 USC § 455 and other governing
statutes/laws governing RECUSAL and those reasons set forth based on the
FACTS, EVIDENCE and LEGAL CONCLUSIONS provide in Creditor
Newsome’s prior pleadings filed with this Court that REMAINS
UNCONTESTED!
7. Creditor Vogel Denise Newsome further MOVES and REITERATE her
DEMAND to be advised and that the RECORD OF THIS COURT reflect
DETAILS the existing CONFLICT-OF-INTEREST present in this Court/Judge
Edward Ellington presiding in this Bankruptcy matter.
8. This Court’s/Judge Edward Ellington’s 02/25/16 Final Decree/Order Closing
Case states in part, “The court having found that the estate of the above named
debtor(s) or debtor(s) in possession has been fully administered in accordance
with the procedures required by Rule 5009 or Rule 3022, Fed. R. Bankr. P.; . . .”
with KNOWLEDGE that said statement and 02/25/16 Final Decree/Order
Closing Case is FRIVOLOUS and UNSUBSTANTIATED by facts, evidence
and Legal Conclusions to sustain it. MOREOVER, that on or about 01/14/16,
Creditor Newsome filed a TIMELY pleading entitled, See Docket No. 73
“OBJECTION TO JANUARY 4, 2016, ORDER ON OBJECTION TO
DECEMBER 8, 2015, ORDER ON OBJECTION TO NOVEMBER 4, ORDER
ON MOTION (sic) RELIEF FROM SEPTEMBER 30, 2015, FINAL JUDGMENT
ON CREDITOR’S (VOGEL NEWSOME) MOTION FOR RELIEF FROM
ORDER/JUDGEMENT (sic); MOTION FOR RULE 11 SANCTIONS OF AND
AGAINST ROBERT REX McRANEY JR./McRANEY & McRANEY; and
REQUEST TO BE ADVISED OF CONFLICT-OF-INTERESTS (DKT. #34);
REITERATION FOR RULE 11 SANCTIONS OF AND AGAINST ROBERT REX
McRANEY, JR./McRANEY & McRANEY; REQUEST TO BE ADVISED OF
CONFLICT-OF-INTERESTS; and REITERATION FOR MOTION FOR
RECUSAL OF JUDGE EDWARD ELLINGTON” which has gone
UNCONTESTED by this Court as well as OPPOSING Party (Debtor Ladye M.
Townsend).
9. The January 4, 2016 Order – Docket No. 71 – of this Court SUPPORTS this
Court’s/Judge Edward Ellington’s KNOWLEDGE of the CRIMINAL/CIVIL
wrongs PUBLICLY made KNOWN and the JUDICIAL INJUSTICES timely,
properly and adequately brought to the ATTENTION of the Court; moreover,
KNOWLEDGE of DESPOTISM Racist/Terrorist Empires as Baker Donelson
Bearman Caldwell & Berkowitz that are INVOLVED in the JUDICIAL,
POLITICAL and CONGRESSIONAL CORRUPTION, etc. in the United States
of America. Criminal and Civil Wrongs by such DESPOTISM Racist/Terrorist
Regimes that LED to INDICTMENTS set forth in the July 4, 1776,
DECLARATION OF INDEPENDENCE in which the Colonies SOUGHT their
FREEDOM, INDEPENDENCE and SEPARATION from Great Britain!
Page 8 of 33
YOUTUBE: https://youtu.be/viLIo7KObUU
ONEDRIVE: http://1drv.ms/1UoahQO
FILES ANYWHERE: https://www.filesanywhere.com/fs/v.aspx?v=8b70658759667475ad6c
Further SUPPORTING and SUSTAINING Creditor Newsome’s filing of
this instant pleading as well as subsequent pleadings. In that this LEGAL
PROCEEDING provides ADDITIONAL EVIDENCE that is NEEDED and
WILL be used to SUPPORT the Blacks’/African-Americans’/People-Of-Color
FREEDOM, INDEPENDENCE and SEPARATION from the DESPOTISM
Government of the United States of America that is being CONTROLLED and
RUN by the likes of ZIONIST/WHITE SUPREMACIST Law Firms as Baker
Donelson Bearman Caldwell & Berkowitz.
The following are the INDICTMENTS SET FORTH IN THE July 4,
1776, DECLARATION OF INDEPENDENCE of the United States of
America – i.e. PLEASE NOTE: Pictures/Graphics have been added for
EMPHASIS and EVIDENCE to support EXISTING Criminal/Civil
violations under the DESPOTISM Government of the United States
of America in 2016. . .and RELATION to the handling of this instant
Bankruptcy Case brought by Debtor Ladye M. Townsend:
Page 9 of 33
Such has been the patient sufferance of these Colonies; and such is now the necessity
which constrains them to alter their former Systems of Government. The history of the
present King of Great Britainis a history of repeatedinjuriesandusurpations, all having
in direct object the establishmentof an absolute Tyranny overthese States. To prove this,
let Facts be submitted to a candid world.
He has refusedhis Assentto Laws, the most wholesomeand necessaryfor the publicgood.
He has forbidden his Governors to pass Laws of immediate and pressing importance,
unless suspended in their operation till his Assent should be obtained; and when so
suspended, he has utterly neglected to attend to them.
He has refused to pass other Laws for the accommodation of large districts of people,
unless thosepeople would relinquishthe rightof Representation in theLegislature, a right
inestimable to them and formidable to tyrants only.
He has called togetherlegislative bodies at places unusual, uncomfortable, and distant
from the depository of their Public Records, for the sole purpose of fatiguing them into
compliance with his measures.
Page 10 of 33
He has dissolvedRepresentativeHousesrepeatedly, for opposing with manly firmness of
his invasions on the rights of the people.
He has refused for a long time, after such dissolutions, to cause others to be elected,
whereby theLegislativePowers, incapable of Annihilation, have returnedto the People at
large for their exercise; theState remainingin the meantime exposedto all thedangersof
invasion from without, and convulsions within.
He has endeavouredto preventthe populationof these States;for that purpose obstructing
the Laws for Naturalization of Foreigners; refusing to pass others to encourage their
migrations hither, and raising the conditions of new Appropriations of Lands.
He has obstructed the Administration of Justice by refusing his Assent to Laws for
establishing Judiciary Powers.
Page 11 of 33
He has made Judges dependent onhis Will alone for the tenure of their offices, and the
amount and payment of their salaries.
Page 12 of 33
He has erected a multitudeof New Offices, and sent hither swarmsof Officers toharass
our people and eat out their substance.
He has kept among us, in times of peace, Standing Armies without the Consent of our
legislatures.
He has affected to render the Military independent of and superior to the Civil Power.
Page 13 of 33
He has combined with others to subject us to a jurisdiction foreign to our constitution,
and unacknowledged by our laws; giving his Assent to their Acts of pretended
Legislation:
Page 14 of 33
For quartering large bodies of armed troops among us:
Page 15 of 33
For protecting them, by a mock Trial from punishment for any Murders which they
should commit on the Inhabitants of these States:
For cutting off our Trade with all parts of the world:
Page 16 of 33
For imposing Taxes on us without our Consent:
For depriving us in many cases, of the benefit of Trial by Jury:
For transporting us beyond Seas to be tried for pretended offences:
For abolishing thefreeSystem of English Laws in a neighbouring Province, establishing
thereinan Arbitrarygovernment, andenlargingits Boundaries so as to render it at once
an exampleand fit instrument for introducing thesame absolute rule into these Colonies
For taking away our Charters, abolishing our most valuable Laws and altering
fundamentally the Forms of our Governments:
For suspendingour own Legislatures, and declaring themselves invested with power to
legislate for us in all cases whatsoever.
Page 17 of 33
He has abdicated Government here, by declaring us out of his Protection and waging
War against us.
Page 18 of 33
He has plundered our seas, ravaged our coasts, burnt our towns, and destroyed the lives
of our people.
He is at this time transporting large Armiesof foreign Mercenaries to compleat the works
of death, desolation, andtyranny, already begun withcircumstances of Cruelty & Perfidy
scarcely paralleled in the most barbarous ages, and totally unworthy the Head of a
civilized nation.
He has constrained our fellow Citizens taken Captive on the high Seas to bear Arms
against their Country, to become theexecutioners of their friends and Brethren, or to fall
themselves by their Hands.
He has exciteddomesticinsurrections amongstus, and has endeavoured to bring on the
inhabitants of our frontiers, the merciless Indian Savageswhoseknown rule of warfare, is
an undistinguished destruction of all ages, sexes and conditions.
In everystage of these Oppressions We have Petitioned for Redress in the most humble
terms: Our repeated Petitions have been answered only by repeated injury. A Prince,
whose character is thus marked by every act which may define a Tyrant, is unfit to be
the ruler of a free people.
Page 19 of 33
10. The GOOD NEWS is going to be when the PUBLIC/WORLD realizes that
the DESPOTISM Zionist/White Supremacist Government Regime – as with
ZIONIST Bernie Madoff in the PONZI Scam – have CLEANED them out! So
Creditor Newsome has been VERY BUSY in EXPOSING the POLITICAL and
GOVERNMENT Corruption of the United States of America!
UNDER THE DECLARATION OF INDEPENDENCE, and other
Statutes/Laws governing said matters, Creditor Vogel Denise Newsome
and others have a DESPOTISM Zionist/White Supremacist Government
of the United States of America to OVERTHROW, ABOLISH, etc.
Page 20 of 33
While the ZIONISTS’ and KLANS’ Law Firm of Baker Donelson Bearman Caldwell &
Berkowitz and its CONSPIRATORS/CO-CONSPIRATORS with their OBSESSION of Creditor
Newsome have been STALKING her for OVER 25 YEARS, Creditor Newsome’s TIME has been
BETTER SPENT – COLLECTING EVIDENCE, RESEARCHING THE LAWS, EDUCATING
THE PUBLIC/WORLD, etc. – on PROVIDING the PLAN and VISION for the LEGAL/LAWFUL
TAKE DOWN and OVERTHROW of the DESPOTISM Zionist/White Supremacist Government of
the United States of America!
For those who may want to KNOW HOW Creditor Vogel Denise Newsome KNOWS so
much about the Klan’s Law Firm Baker Donelson Bearman Caldwell & Berkowitz, she simply
directs their attention to Newsome vs. Entergy, where Baker Donelson was STUPID
enough to enter as Counsel for Entergy:
Page 21 of 33
Baker Donelson having their Judges assigned in the Entergy Law Suit and WITHHELD
this information from Vogel Denise Newsome! For instance, using their Judges as Morey L. Sear
and G. Thomas Porteous. Judge Porteous WHO IS KNOWN for taking BRIBES, KICKBACKS,
etc. for purposes of THROWING Lawsuits in favor of Law Firms as Baker Donelson Bearman
Page 22 of 33
Caldwell & Berkowitz and its CLIENTS! Yes, since the FILING of the Newsome vs. Entergy
Lawsuit, Judge Porteous has been IMPEACHED and REMOVED from the Federal Bench!
EXPOSING THROUGH EVIDENCE the INFILTRATION of the ZIONIST/WHITE
SUPREMACIST Despotism Government Regime and HOW they have GONE ABOUT
DESTROYING the Blacks’/African-Americans’ COMMUNITIES for PURPOSES of BUILDING
their WHITE SUPREMACIST EMPIRES! While the likes of Baker Donelson Bearman Caldwell
& Berkowitz may have TAKEN OFF some of their HOODS and put on BUSINESS SUITS and
ROBES during the DAY, Creditor Vogel Denise Newsome is HERE to PUBLICLY EXPOSE
WHERE they ARE HIDING and HOW they GO ABOUT ORGANIZING, IMPLEMENTING and
CARRYING out their RACIST/TERRORIST and GENOCIDE ATTACKS on Blacks/African-
Americans/People-of-Color! Such as:
PROVIDING HOUSE NEGROES –
For Purposes of Gaining TRUST
Page 23 of 33
(i.e. using Politicians, PREACHERS, etc.)
Page 24 of 33
Using the CONTROL of MEDIA SOURCES to provide FALSE and
MISLEADING information regarding GENTRIFICATION – MASKED as
URBAN RENEWAL! Using sources as Newspapers to SPREAD LIES so that
Blacks/African-Americans/People-of-Color will NOT know of their TRUE
RACIST INTENT!
Page 25 of 33
HOWEVER, Creditor Vogel Denise Newsome believes in KEEPING IT REAL! The
NATIVE Indians BELIEVED the White Man and they wound up on RESERVATIONS!
Now the ZIONISTS and WHITE MAN are after the Property/Lands of the Blacks/African-
Americans/People-of-Color: http://www.slideshare.net/VogelDenise/100715-urban-
renewal-from-the-eyes-of-community-activist-vogel-denise-newsome
Page 26 of 33
THEFT of PROPERTY/LANDS – MASKED as EMINENT DOMAIN where the Klans’ Law Firm
Baker Donelson Bearman Caldwell & Berkowitz (WHO is LEGAL COUNSEL to GOVERNMENT
AGENCIES) WORKS on BOTH SIDES [Plaintiff AND Defendant] of the FENCE to OBTAIN their
GOALS and MASK their CRIMINAL/CIVIL wrongs – CONFLICT OF INTEREST - from the
PUBLIC/WORLD!
That the PUBLIC/WORLD may NEVER SEE the WOLF for the DISGUISES! However, Creditor
Vogel Denise Newsome and others are here to PULL-OFF-THE-SHEETS!
YES, the Klan’s Law Firm of
Baker Donelson Bearman Caldwell & Berkowitz
is LEGAL COUNSEL for United States of America President Barack Obama
– i.e. the Federal Government!
Page 27 of 33
YES, the Klan’s Law Firm of Baker Donelson Bearman Caldwell &
Berkowitz is LEGAL COUNSEL to the Mississippi Governors as PHIL
BRYANT – i.e. EXPLAINING why they are engaging in such FOOLISH DISTRACTIONS as
the FLAG Issue, CONFEDERATE HERITAGE MONTH, etc.
Can you believe that when Mississippi Governor Haley Barbour was in office,
Baker Donelson Bearman Caldwell & Berkowitz had one of Barbour’s
Administrative Staff (Jon Lewis – Chairman of the Mississippi Athletic Commission -
who also serves as a Hinds County, Mississippi Constable) bring FALSE Criminal
Charges AGAINST Vogel Denise Newsome in DEFENSE of a Civil Lawsuit filed
RATHER than ANSWER the Civil Lawsuit? The Criminal Charges AGAINST
Newsome were THROWN OUT! Further EVIDENCE for the DECLARATION OF
FREEDOM, INDEPENDENCE and SEPARATION from the DESPOTISM Government
of the United States of America!
Page 28 of 33
Page 29 of 33
So WHILE they ENGAGE in such FOOLISH DISTRACTIONS, it is
the LEGAL/LAWFUL Duty and Right of Creditor Vogel Denise Newsome
and others to PROVIDE LEGAL/LAWFUL ALTERNATIVES to the
Blacks/African-Americans/People-of-Color ON HOW to IMPROVE their
LIVES (protecting their SAFETY and WELL BEING), LIBERTIES and
PURSUIT OF HAPPINESS and have a GOVERNMENT, COURTS,
CONGRESS, etc. that works for them and NOT AGAINST THEM!
Page 30 of 33
The ZIONISTS/WHITE SUPREMACISTS DESPOTISM Government of the
United States of America THOUGHT their problems were solved through the
DEATHS/MURDERS of Civil Rights Leaders as Medgar Evers, Malcolm X, Martin
Luther King Jr. and others IN THEIR QUEST to RETURN BLACKS/AFRICAN-
Americans BACK to SLAVERY; however, they WERE WRONG!
Page 31 of 33
The ZIONISTS/WHITE SUPREMACISTS DESPOTISM Government of the United States
of America gave you the following HOUSE NEGROES for DISTRACTION and DECEPTION;
however, Creditor Vogel Denise Newsome (a Community Activist/Civil Rights Activist) SAW
through the FAÇADE!
WHEREFORE, PREMISES CONSIDERED, Creditor Newsome files this
instant “MTRC&OT02-25-16FDOCC” for the above claims and/or defenses and
this Bankruptcy, in accordance with the Statutes/Laws governing said matters
WARRANTS the REOPENING case!
IMPORTANT TO NOTE: Is the showing of the IGNORANCE of this
Court/Judge Edward Ellington in that APPEALS CANNOT be brought from
ORDERS! Creditor Newsome has TIMELY, PROPERLY and
ADEQUATELY filed the MANDATORY MOTIONS/OBJECTIONS to
preserve her case as in this instant filing; however, the OBSTRUCTION of the
Page 32 of 33
ADMINISTRATION of JUSTICE, JUDICIAL CORRUPTION, etc. is
running RAMPANT under the DESPOTISM Zionist/White Supremacist
Government Regime of the United States of America that SUPPORTS not
only the OVERTHROW, but ABOLISHMENT, and other LEGAL
RECOURSE of and against the DESPOTISM Government of the United
States of America! The DECLARATION OF INDEPENDENCE provides
ADDITIONAL Legal Recourse and REMEDY for Relief under which
Creditor Newsome also seeks JUSTICE!
Creditor Vogel Denise Newsome RESERVES the right to provide a MEMORANDUM Brief in
support of this instant “MTRC&OT02-25-16FDOCC” should this Court deems necessary in the
PRESERVATION of her rights!
The February 25, 2016, Final Decree/Order Closing Case entered by this Court/Judge Edward
Ellington IS clearly BASELESS, FRIVOLOUS, full of ERRORS, cannot be UPHELD, supports
CONFLICT –OF INTERESTS, criminal acts and much more for purposes of AIDING and ABETTING
Judge Edward Ellington’s Legal Counsel Baker Donelson Bearman Caldwell & Berkowitz. Said
February 25, 2016 Final Decree/Order Closing Case IS NOT worth the ink and paper written on!
Respectfully submitted this 7th
day of March, 2016.
___________________________________
Vogel Denise Newsome
Post Office Box 31265
Jackson, MS 39286
Phone: (513) 680-2922 or (601) 282-7119
Page 33 of 33
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the forgoing pleading was
MAILED via U.S. Mail first-class to:
Robert Rex McRaney, Jr.
Post Office Box 1397
Clinton, Mississippi 39060
COUNSEL FOR DEBTOR (LADYE M. TOWNSEND)
Dated this 7th
day of March, 2016.
_____________________________________
Vogel Newsome
ADMINISTRATION of JUSTICE, JUDICIAL CORRUPTION, etc. is
running RAMPANT under the DESPOTISM ZionktAVhite Supremacist
Government Regime of the United States of America that SUPPORTS not
only the OVERTHROW, but ABOLISHMENT, and other LEGAL
RECOURSE of and against the DESPOTISM Government of the United
States of America! The DECLARATION OF INDEPENDENCE provides
ADDITIONAL Legal Recourse and REMEDY for Relief under which
Creditor Newsome also seeks JUSTICE!
Creditor Vogel Denise Newsome RESERVES the right to provide a MEMORANDUM Brief in
support of this instant "MTRC&OT02-25-16FDOCC" should this Court deems necessary in the
PRESERVATION ofherri^ts!
The February 25, 2016, Final Decree/Order Closing Case entered by this Court/Judge Edward
Ellington IS cleariy BASELESS, FRIVOLOUS, full of ERRORS, cannot be UPHELD, supports
CONFLICT -OF INTERESTS, criminal acts and much more for purposes of AIDING and ABETTING
Judge Edward Ellington's Legal Counsel Baker Donelson Bearman Caldwell & Berkowitz. Said
February 25, 2016 Final Decree/Order Closing Case IS NOT worth the ink and paper written on!
Vogel Denise Newsome
Post Office Box 31265
Jackson, MS 39286
Phone: (513)680-2922 or (601) 282-7119
Page 32 of 33
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the forgoing pleading was
MAILED via U.S. Mail first-class to:
Robert Rex McRaney, Jr.
Post Office Box 1397
Clinton, Mississippi 39060
C O U N S E L FOR D E B T O R ( L A D Y E M . TOW-NSEND)
Dated this 7'" day ofM^Pwa^y, 2016.
Vogel Newsome
Page 33 of 33

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030716 OBJECTION TO 022516 FINAL DECREE (Townsend Matter)

  • 1. MOTION TO REOPEN CASE PURSUANT TO 11 USC § 350 and OTHER STATUTES/LAWS GOVERNING SAID MATTERS; OBJECTION TO 02/25/16 FINAL DECREE/ORDER CLOSING CASE PURSUANT TO RULE 5009 and/or RULE 3022 OF THE FEDERAL RULES OF BANKRUPTCY PROCEDURES; The DECLARATION OF INDEPENDENCE; REQUEST TO BE ADVISED OF CONFLICT-OF-INTERESTS; and REITERATION FOR MOTION FOR RECUSAL OF JUDGE EDWARD ELLINGTON MARCH 7, 2016 BANKRUPTCY COURT FILING
  • 2. j ; 5 SANKRUrTCYC3l;?IT SCUIHLRH m s T R i c r or K S IN THE UNITED STATES BANKRUPTCY COURT • ^, . 3 r,., ,^ . . t. . ' - I , ' . - / r n l i i ' 2 5 SOUTHERN DISTRICT OF MISSISSIPPI C A N N ^ v [ MILLER C L E R K 5YJa..i_ D E P U T Y IN RE: LADYE M. TOWNS END CHAPTER 7 DEBTOR CASE NO. 11-00167-ee MOTION TO REOPEN CASE PURSUANT TO 11 USC § 350 and OTHER STATUTES/LAWS GOVERNING SAID MATTERS; OBJECTION TO 02/25/16 n N A L DECREE/ORDER CLOSING CASE PURSUANT TO RULE 5009 and/or RULE 3022 OF THE FEDERAL RULES OF BANKRUPTCY PROCEDURES; The DECLARATION OF INDEPENDENCE; REQUEST TO BE ADVISED OF CONFLICT-OF-INTERESTS; and REITERATION FOR MOTION FOR RECUSAL OF JUDGE EDWARD ELLINGTON ' COMES NOW Creditor Vogel Newsome ("Newsome") without waiving her rights, without submitting to the jurisdiction of this Court, without waiving previous defenses and claims set forth in her pleadings filed with this Court and files this her "MOTION TO REOPEN CASE PURSUANT TO 11 USC § 350 and OTHER STATUTES/LAWS GOVERNING SAID MATTERS; OBJECTION TO 02/25/16 FINAL DECREE/ORDER CLOSING CASE PURSUANT TO RULE 5009 and/or RULE 3022 OF THE FEDERAL RULES OF BANKRUPTCY PROCEDURES; The DECLARATION OF INDEPENDENCE; REQUEST TO BE ADVISED OF CONFLICT-OF-INTERESTS; and REITERATION FOR MOTION FOR RECUSAL OF JUDGE EDWARD ELLINGTON" ("MTRC&OT02-25-16FDOCC") pursuant to 11 USC § 350, Rule 5009 and/or Rule 3022 of the Federal Rules of Bankruptcy Procedure ("FRBP"), 28 USC § 455; FRCP Rule 12(G) - consolidation of matters - and other statutes/laws governing said matters. In support thereof, Newsome states the following ' NOTE: Boldface, italics and underline, etc. represents "emphasis" added. Page 1 of 33
  • 3. Page 1 of 33 IN THE UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF MISSISSIPPI IN RE: LADYE M. TOWNSEND CHAPTER 7 DEBTOR CASE NO. 11-00167-ee MOTION TO REOPEN CASE PURSUANT TO 11 USC § 350 and OTHER STATUTES/LAWS GOVERNING SAID MATTERS; OBJECTION TO 02/25/16 FINAL DECREE/ORDER CLOSING CASE PURSUANT TO RULE 5009 and/or RULE 3022 OF THE FEDERAL RULES OF BANKRUPTCY PROCEDURES; The DECLARATION OF INDEPENDENCE; REQUEST TO BE ADVISED OF CONFLICT-OF-INTERESTS; and REITERATION FOR MOTION FOR RECUSAL OF JUDGE EDWARD ELLINGTON 1 COMES NOW Creditor Vogel Newsome (“Newsome”) without waiving her rights, without submitting to the jurisdiction of this Court, without waiving previous defenses and claims set forth in her pleadings filed with this Court and files this her “MOTION TO REOPEN CASE PURSUANT TO 11 USC § 350 and OTHER STATUTES/LAWS GOVERNING SAID MATTERS; OBJECTION TO 02/25/16 FINAL DECREE/ORDER CLOSING CASE PURSUANT TO RULE 5009 and/or RULE 3022 OF THE FEDERAL RULES OF BANKRUPTCY PROCEDURES; The DECLARATION OF INDEPENDENCE; REQUEST TO BE ADVISED OF CONFLICT-OF-INTERESTS; and REITERATION FOR MOTION FOR RECUSAL OF JUDGE EDWARD ELLINGTON” (“MTRC&OT02-25-16FDOCC”) pursuant to 11 USC § 350, Rule 5009 and/or Rule 3022 of the Federal Rules of Bankruptcy Procedure (“FRBP”), 28 USC § 455; FRCP Rule 12(G) – consolidation of matters – and other statutes/laws governing said matters. In support thereof, Newsome states the following 1 NOTE: Boldface, italics and underline, etc. represents “emphasis” added.
  • 4. Page 2 of 33 REITERATED UNCONTESTED FACTS ignored by this Court in its February 25, 2016 Final Decree/Order Closing Case: I. LACK OF JURISDICTION – The record evidence STRONGLY supports this Court’s and opposing Counsel’s INABILITY to PROVIDE EVIDENCE as well as CASE LAWS to rebut the EVIDENCE as well as LEGAL CONLUSIONS provided below and in PREVIOUS pleadings brought by Creditor Newsome. Therefore, Creditor Newsome is AGAIN reiterating and incorporating by reference said defense(s) as set forth in her previously filed pleadings in this instant Bankruptcy action: PLEASE NOTE: As required by Rule 8 (General Rules of Pleading) of the Federal Rules of Civil Procedure, for instance as mentioned in previous filing, Creditor Newsome’s October 13, 2015 Pleading (DOCKET NO. 64) specifically sets forth “short and plain statement(s)” of the grounds for relief/claims; however, the record evidence WILL SUPPORT this Court’s/Judge Edward Ellington’s INABILITY to REBUT the FACTS, EVIDENCE and LEGAL CONCLUSIONS that this Court/he “LACKS” Jurisdiction in this matter. 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 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
  • 5. Page 3 of 33 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 (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 “MTRC&OT02-25-16FDOCC” 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 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.
  • 6. Page 4 of 33 MOTION TO REOPEN CASE COMES NOW Creditor Vogel Denise Newsome WITHOUT waiving the above foregoing Jurisdictional Defense and in PRESERVATION of her rights and moves this Court to REOPEN this instant Bankruptcy action PURSUANT to 11 USC § 350, Rule 5010 of the Federal Rules of Bankruptcy Procedure and other statutes/laws governing said matters. In support thereof, Newsome states in good faith the following: 1. This Court/Judge Edward Ellington with WILLFUL and MALICIOUS acts issued on or about February 25, 2016, a Final Decree/Order Closing Case with KNOWLEDGE that estate HAS NOT been FULLY Administered in accordance to the MANDATORY requirements governing said Bankruptcy matters. Therefore, Creditor Newsome TIMELY, PROPERLY and ADEQUATELY submits said Motion to REOPEN this instant Bankruptcy Case in accordance with 11 USC § 350, Rule 5010 of the Federal Rules of Bankruptcy Procedure and other statutes/laws governing said matters:
  • 7. Page 5 of 33 2. This instant Bankruptcy matter was one INITIATED by Debtor Ladye M. Townsend in efforts of keeping Creditor Newsome from obtaining RELIEF through the CIVIL Lawsuit that has been filed in the United States District Court for the Southern District of Mississippi (Jackson Division) – Case No. 3:10-cv- 00704. 3. Rule 5009 clearly states in part, “Cases under Chapters 7. . . the trustee has filed a final report and final account and has certified the estate has been fully administered, and IF within 30 days NO OBJECTION has been filed by. . .a party of interest, there shall be a PRESUMPTION that the estate has been FULLY administered. . .” So IF this instant Bankruptcy action is NOW a Chapter 7 LIQUIDATION matter, in that DEBTOR Ladye M. Townsend and her Counsel McRaney & McRaney in COLLUSION with this Court/Judge Edward Ellington DO NOT seem to know themselves what TYPE of Bankruptcy matter this is,
  • 8. Page 6 of 33 the RECORD evidence in this instant Bankruptcy action WILL SUPPORT and SUSTAIN that Creditor Newsome has REPEATEDLY filed TIMELY OBJECTIONS in compliance with Rule 5009 of the FRBP and other applicable statutes and/or laws governing said matters FOR REDRESS and, therefore, PROHIBITS this Court from entering a Final Decree/Order Closing Case in that the estate HAS NOT been FULLY administered. SEE DECLARATION OF INDEPENDENCE INDICMENTS BELOW in this instant pleading! 4. Rule 3022 of BRBP clearly states in part, “After an estate is FULLY ADMINISTERED in a Chapter 11 REORGANIZATION case. . .” and Section 350 of the Code REQUIRES the Court CLOSE the case AFTER the estate is FULLY ADMINISTERED. . . So IF this instant Bankruptcy action is NOW a Chapter 11 REORGANIZATION Case, in that DEBTOR Ladye M. Townsend and her Counsel McRaney & McRaney in COLLUSION with this Court/Judge Edward Ellington DO NOT seem to know themselves what TYPE of Bankruptcy matter this is, the RECORD evidence in this instant Bankruptcy action WILL SUPPORT and SUSTAIN that Creditor Newsome has REPEATEDLY filed TIMELY OBJECTIONS in compliance with the Federal Rules of Bankruptcy Procedure and other applicable statutes and/or laws governing said matters for REDRESS and, therefore, PROHIBITS this Court from entering a Final Decree/Order Closing Case in that the estate HAS NOT been FULLY administered. SEE DECLARATION OF INDEPENDENCE INDICMENTS BELOW in this instant pleading! 5. OBJECTION is made in that the TRUSTEE has NOT FULFILLED the MANDATORY DUTY(S) requirements PURSUANT to Rule 704 of the FRBP and other Statutes/Laws governing said matters.
  • 9. Page 7 of 33 6. Creditor Vogel Denise Newsome further MOVES and REITERATES her DEMAND for RECUSAL of Judge Edward Ellington because of the existing “CONFLICT-OF-INTEREST” pursuant to 28 USC § 455 and other governing statutes/laws governing RECUSAL and those reasons set forth based on the FACTS, EVIDENCE and LEGAL CONCLUSIONS provide in Creditor Newsome’s prior pleadings filed with this Court that REMAINS UNCONTESTED! 7. Creditor Vogel Denise Newsome further MOVES and REITERATE her DEMAND to be advised and that the RECORD OF THIS COURT reflect DETAILS the existing CONFLICT-OF-INTEREST present in this Court/Judge Edward Ellington presiding in this Bankruptcy matter. 8. This Court’s/Judge Edward Ellington’s 02/25/16 Final Decree/Order Closing Case states in part, “The court having found that the estate of the above named debtor(s) or debtor(s) in possession has been fully administered in accordance with the procedures required by Rule 5009 or Rule 3022, Fed. R. Bankr. P.; . . .” with KNOWLEDGE that said statement and 02/25/16 Final Decree/Order Closing Case is FRIVOLOUS and UNSUBSTANTIATED by facts, evidence and Legal Conclusions to sustain it. MOREOVER, that on or about 01/14/16, Creditor Newsome filed a TIMELY pleading entitled, See Docket No. 73 “OBJECTION TO JANUARY 4, 2016, ORDER ON OBJECTION TO DECEMBER 8, 2015, ORDER ON OBJECTION TO NOVEMBER 4, ORDER ON MOTION (sic) RELIEF FROM SEPTEMBER 30, 2015, FINAL JUDGMENT ON CREDITOR’S (VOGEL NEWSOME) MOTION FOR RELIEF FROM ORDER/JUDGEMENT (sic); MOTION FOR RULE 11 SANCTIONS OF AND AGAINST ROBERT REX McRANEY JR./McRANEY & McRANEY; and REQUEST TO BE ADVISED OF CONFLICT-OF-INTERESTS (DKT. #34); REITERATION FOR RULE 11 SANCTIONS OF AND AGAINST ROBERT REX McRANEY, JR./McRANEY & McRANEY; REQUEST TO BE ADVISED OF CONFLICT-OF-INTERESTS; and REITERATION FOR MOTION FOR RECUSAL OF JUDGE EDWARD ELLINGTON” which has gone UNCONTESTED by this Court as well as OPPOSING Party (Debtor Ladye M. Townsend). 9. The January 4, 2016 Order – Docket No. 71 – of this Court SUPPORTS this Court’s/Judge Edward Ellington’s KNOWLEDGE of the CRIMINAL/CIVIL wrongs PUBLICLY made KNOWN and the JUDICIAL INJUSTICES timely, properly and adequately brought to the ATTENTION of the Court; moreover, KNOWLEDGE of DESPOTISM Racist/Terrorist Empires as Baker Donelson Bearman Caldwell & Berkowitz that are INVOLVED in the JUDICIAL, POLITICAL and CONGRESSIONAL CORRUPTION, etc. in the United States of America. Criminal and Civil Wrongs by such DESPOTISM Racist/Terrorist Regimes that LED to INDICTMENTS set forth in the July 4, 1776, DECLARATION OF INDEPENDENCE in which the Colonies SOUGHT their FREEDOM, INDEPENDENCE and SEPARATION from Great Britain!
  • 10. Page 8 of 33 YOUTUBE: https://youtu.be/viLIo7KObUU ONEDRIVE: http://1drv.ms/1UoahQO FILES ANYWHERE: https://www.filesanywhere.com/fs/v.aspx?v=8b70658759667475ad6c Further SUPPORTING and SUSTAINING Creditor Newsome’s filing of this instant pleading as well as subsequent pleadings. In that this LEGAL PROCEEDING provides ADDITIONAL EVIDENCE that is NEEDED and WILL be used to SUPPORT the Blacks’/African-Americans’/People-Of-Color FREEDOM, INDEPENDENCE and SEPARATION from the DESPOTISM Government of the United States of America that is being CONTROLLED and RUN by the likes of ZIONIST/WHITE SUPREMACIST Law Firms as Baker Donelson Bearman Caldwell & Berkowitz. The following are the INDICTMENTS SET FORTH IN THE July 4, 1776, DECLARATION OF INDEPENDENCE of the United States of America – i.e. PLEASE NOTE: Pictures/Graphics have been added for EMPHASIS and EVIDENCE to support EXISTING Criminal/Civil violations under the DESPOTISM Government of the United States of America in 2016. . .and RELATION to the handling of this instant Bankruptcy Case brought by Debtor Ladye M. Townsend:
  • 11. Page 9 of 33 Such has been the patient sufferance of these Colonies; and such is now the necessity which constrains them to alter their former Systems of Government. The history of the present King of Great Britainis a history of repeatedinjuriesandusurpations, all having in direct object the establishmentof an absolute Tyranny overthese States. To prove this, let Facts be submitted to a candid world. He has refusedhis Assentto Laws, the most wholesomeand necessaryfor the publicgood. He has forbidden his Governors to pass Laws of immediate and pressing importance, unless suspended in their operation till his Assent should be obtained; and when so suspended, he has utterly neglected to attend to them. He has refused to pass other Laws for the accommodation of large districts of people, unless thosepeople would relinquishthe rightof Representation in theLegislature, a right inestimable to them and formidable to tyrants only. He has called togetherlegislative bodies at places unusual, uncomfortable, and distant from the depository of their Public Records, for the sole purpose of fatiguing them into compliance with his measures.
  • 12. Page 10 of 33 He has dissolvedRepresentativeHousesrepeatedly, for opposing with manly firmness of his invasions on the rights of the people. He has refused for a long time, after such dissolutions, to cause others to be elected, whereby theLegislativePowers, incapable of Annihilation, have returnedto the People at large for their exercise; theState remainingin the meantime exposedto all thedangersof invasion from without, and convulsions within. He has endeavouredto preventthe populationof these States;for that purpose obstructing the Laws for Naturalization of Foreigners; refusing to pass others to encourage their migrations hither, and raising the conditions of new Appropriations of Lands. He has obstructed the Administration of Justice by refusing his Assent to Laws for establishing Judiciary Powers.
  • 13. Page 11 of 33 He has made Judges dependent onhis Will alone for the tenure of their offices, and the amount and payment of their salaries.
  • 14. Page 12 of 33 He has erected a multitudeof New Offices, and sent hither swarmsof Officers toharass our people and eat out their substance. He has kept among us, in times of peace, Standing Armies without the Consent of our legislatures. He has affected to render the Military independent of and superior to the Civil Power.
  • 15. Page 13 of 33 He has combined with others to subject us to a jurisdiction foreign to our constitution, and unacknowledged by our laws; giving his Assent to their Acts of pretended Legislation:
  • 16. Page 14 of 33 For quartering large bodies of armed troops among us:
  • 17. Page 15 of 33 For protecting them, by a mock Trial from punishment for any Murders which they should commit on the Inhabitants of these States: For cutting off our Trade with all parts of the world:
  • 18. Page 16 of 33 For imposing Taxes on us without our Consent: For depriving us in many cases, of the benefit of Trial by Jury: For transporting us beyond Seas to be tried for pretended offences: For abolishing thefreeSystem of English Laws in a neighbouring Province, establishing thereinan Arbitrarygovernment, andenlargingits Boundaries so as to render it at once an exampleand fit instrument for introducing thesame absolute rule into these Colonies For taking away our Charters, abolishing our most valuable Laws and altering fundamentally the Forms of our Governments: For suspendingour own Legislatures, and declaring themselves invested with power to legislate for us in all cases whatsoever.
  • 19. Page 17 of 33 He has abdicated Government here, by declaring us out of his Protection and waging War against us.
  • 20. Page 18 of 33 He has plundered our seas, ravaged our coasts, burnt our towns, and destroyed the lives of our people. He is at this time transporting large Armiesof foreign Mercenaries to compleat the works of death, desolation, andtyranny, already begun withcircumstances of Cruelty & Perfidy scarcely paralleled in the most barbarous ages, and totally unworthy the Head of a civilized nation. He has constrained our fellow Citizens taken Captive on the high Seas to bear Arms against their Country, to become theexecutioners of their friends and Brethren, or to fall themselves by their Hands. He has exciteddomesticinsurrections amongstus, and has endeavoured to bring on the inhabitants of our frontiers, the merciless Indian Savageswhoseknown rule of warfare, is an undistinguished destruction of all ages, sexes and conditions. In everystage of these Oppressions We have Petitioned for Redress in the most humble terms: Our repeated Petitions have been answered only by repeated injury. A Prince, whose character is thus marked by every act which may define a Tyrant, is unfit to be the ruler of a free people.
  • 21. Page 19 of 33 10. The GOOD NEWS is going to be when the PUBLIC/WORLD realizes that the DESPOTISM Zionist/White Supremacist Government Regime – as with ZIONIST Bernie Madoff in the PONZI Scam – have CLEANED them out! So Creditor Newsome has been VERY BUSY in EXPOSING the POLITICAL and GOVERNMENT Corruption of the United States of America! UNDER THE DECLARATION OF INDEPENDENCE, and other Statutes/Laws governing said matters, Creditor Vogel Denise Newsome and others have a DESPOTISM Zionist/White Supremacist Government of the United States of America to OVERTHROW, ABOLISH, etc.
  • 22. Page 20 of 33 While the ZIONISTS’ and KLANS’ Law Firm of Baker Donelson Bearman Caldwell & Berkowitz and its CONSPIRATORS/CO-CONSPIRATORS with their OBSESSION of Creditor Newsome have been STALKING her for OVER 25 YEARS, Creditor Newsome’s TIME has been BETTER SPENT – COLLECTING EVIDENCE, RESEARCHING THE LAWS, EDUCATING THE PUBLIC/WORLD, etc. – on PROVIDING the PLAN and VISION for the LEGAL/LAWFUL TAKE DOWN and OVERTHROW of the DESPOTISM Zionist/White Supremacist Government of the United States of America! For those who may want to KNOW HOW Creditor Vogel Denise Newsome KNOWS so much about the Klan’s Law Firm Baker Donelson Bearman Caldwell & Berkowitz, she simply directs their attention to Newsome vs. Entergy, where Baker Donelson was STUPID enough to enter as Counsel for Entergy:
  • 23. Page 21 of 33 Baker Donelson having their Judges assigned in the Entergy Law Suit and WITHHELD this information from Vogel Denise Newsome! For instance, using their Judges as Morey L. Sear and G. Thomas Porteous. Judge Porteous WHO IS KNOWN for taking BRIBES, KICKBACKS, etc. for purposes of THROWING Lawsuits in favor of Law Firms as Baker Donelson Bearman
  • 24. Page 22 of 33 Caldwell & Berkowitz and its CLIENTS! Yes, since the FILING of the Newsome vs. Entergy Lawsuit, Judge Porteous has been IMPEACHED and REMOVED from the Federal Bench! EXPOSING THROUGH EVIDENCE the INFILTRATION of the ZIONIST/WHITE SUPREMACIST Despotism Government Regime and HOW they have GONE ABOUT DESTROYING the Blacks’/African-Americans’ COMMUNITIES for PURPOSES of BUILDING their WHITE SUPREMACIST EMPIRES! While the likes of Baker Donelson Bearman Caldwell & Berkowitz may have TAKEN OFF some of their HOODS and put on BUSINESS SUITS and ROBES during the DAY, Creditor Vogel Denise Newsome is HERE to PUBLICLY EXPOSE WHERE they ARE HIDING and HOW they GO ABOUT ORGANIZING, IMPLEMENTING and CARRYING out their RACIST/TERRORIST and GENOCIDE ATTACKS on Blacks/African- Americans/People-of-Color! Such as: PROVIDING HOUSE NEGROES – For Purposes of Gaining TRUST
  • 25. Page 23 of 33 (i.e. using Politicians, PREACHERS, etc.)
  • 26. Page 24 of 33 Using the CONTROL of MEDIA SOURCES to provide FALSE and MISLEADING information regarding GENTRIFICATION – MASKED as URBAN RENEWAL! Using sources as Newspapers to SPREAD LIES so that Blacks/African-Americans/People-of-Color will NOT know of their TRUE RACIST INTENT!
  • 27. Page 25 of 33 HOWEVER, Creditor Vogel Denise Newsome believes in KEEPING IT REAL! The NATIVE Indians BELIEVED the White Man and they wound up on RESERVATIONS! Now the ZIONISTS and WHITE MAN are after the Property/Lands of the Blacks/African- Americans/People-of-Color: http://www.slideshare.net/VogelDenise/100715-urban- renewal-from-the-eyes-of-community-activist-vogel-denise-newsome
  • 28. Page 26 of 33 THEFT of PROPERTY/LANDS – MASKED as EMINENT DOMAIN where the Klans’ Law Firm Baker Donelson Bearman Caldwell & Berkowitz (WHO is LEGAL COUNSEL to GOVERNMENT AGENCIES) WORKS on BOTH SIDES [Plaintiff AND Defendant] of the FENCE to OBTAIN their GOALS and MASK their CRIMINAL/CIVIL wrongs – CONFLICT OF INTEREST - from the PUBLIC/WORLD! That the PUBLIC/WORLD may NEVER SEE the WOLF for the DISGUISES! However, Creditor Vogel Denise Newsome and others are here to PULL-OFF-THE-SHEETS! YES, the Klan’s Law Firm of Baker Donelson Bearman Caldwell & Berkowitz is LEGAL COUNSEL for United States of America President Barack Obama – i.e. the Federal Government!
  • 29. Page 27 of 33 YES, the Klan’s Law Firm of Baker Donelson Bearman Caldwell & Berkowitz is LEGAL COUNSEL to the Mississippi Governors as PHIL BRYANT – i.e. EXPLAINING why they are engaging in such FOOLISH DISTRACTIONS as the FLAG Issue, CONFEDERATE HERITAGE MONTH, etc. Can you believe that when Mississippi Governor Haley Barbour was in office, Baker Donelson Bearman Caldwell & Berkowitz had one of Barbour’s Administrative Staff (Jon Lewis – Chairman of the Mississippi Athletic Commission - who also serves as a Hinds County, Mississippi Constable) bring FALSE Criminal Charges AGAINST Vogel Denise Newsome in DEFENSE of a Civil Lawsuit filed RATHER than ANSWER the Civil Lawsuit? The Criminal Charges AGAINST Newsome were THROWN OUT! Further EVIDENCE for the DECLARATION OF FREEDOM, INDEPENDENCE and SEPARATION from the DESPOTISM Government of the United States of America!
  • 31. Page 29 of 33 So WHILE they ENGAGE in such FOOLISH DISTRACTIONS, it is the LEGAL/LAWFUL Duty and Right of Creditor Vogel Denise Newsome and others to PROVIDE LEGAL/LAWFUL ALTERNATIVES to the Blacks/African-Americans/People-of-Color ON HOW to IMPROVE their LIVES (protecting their SAFETY and WELL BEING), LIBERTIES and PURSUIT OF HAPPINESS and have a GOVERNMENT, COURTS, CONGRESS, etc. that works for them and NOT AGAINST THEM!
  • 32. Page 30 of 33 The ZIONISTS/WHITE SUPREMACISTS DESPOTISM Government of the United States of America THOUGHT their problems were solved through the DEATHS/MURDERS of Civil Rights Leaders as Medgar Evers, Malcolm X, Martin Luther King Jr. and others IN THEIR QUEST to RETURN BLACKS/AFRICAN- Americans BACK to SLAVERY; however, they WERE WRONG!
  • 33. Page 31 of 33 The ZIONISTS/WHITE SUPREMACISTS DESPOTISM Government of the United States of America gave you the following HOUSE NEGROES for DISTRACTION and DECEPTION; however, Creditor Vogel Denise Newsome (a Community Activist/Civil Rights Activist) SAW through the FAÇADE! WHEREFORE, PREMISES CONSIDERED, Creditor Newsome files this instant “MTRC&OT02-25-16FDOCC” for the above claims and/or defenses and this Bankruptcy, in accordance with the Statutes/Laws governing said matters WARRANTS the REOPENING case! IMPORTANT TO NOTE: Is the showing of the IGNORANCE of this Court/Judge Edward Ellington in that APPEALS CANNOT be brought from ORDERS! Creditor Newsome has TIMELY, PROPERLY and ADEQUATELY filed the MANDATORY MOTIONS/OBJECTIONS to preserve her case as in this instant filing; however, the OBSTRUCTION of the
  • 34. Page 32 of 33 ADMINISTRATION of JUSTICE, JUDICIAL CORRUPTION, etc. is running RAMPANT under the DESPOTISM Zionist/White Supremacist Government Regime of the United States of America that SUPPORTS not only the OVERTHROW, but ABOLISHMENT, and other LEGAL RECOURSE of and against the DESPOTISM Government of the United States of America! The DECLARATION OF INDEPENDENCE provides ADDITIONAL Legal Recourse and REMEDY for Relief under which Creditor Newsome also seeks JUSTICE! Creditor Vogel Denise Newsome RESERVES the right to provide a MEMORANDUM Brief in support of this instant “MTRC&OT02-25-16FDOCC” should this Court deems necessary in the PRESERVATION of her rights! The February 25, 2016, Final Decree/Order Closing Case entered by this Court/Judge Edward Ellington IS clearly BASELESS, FRIVOLOUS, full of ERRORS, cannot be UPHELD, supports CONFLICT –OF INTERESTS, criminal acts and much more for purposes of AIDING and ABETTING Judge Edward Ellington’s Legal Counsel Baker Donelson Bearman Caldwell & Berkowitz. Said February 25, 2016 Final Decree/Order Closing Case IS NOT worth the ink and paper written on! Respectfully submitted this 7th day of March, 2016. ___________________________________ Vogel Denise Newsome Post Office Box 31265 Jackson, MS 39286 Phone: (513) 680-2922 or (601) 282-7119
  • 35. Page 33 of 33 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the forgoing pleading was MAILED via U.S. Mail first-class to: Robert Rex McRaney, Jr. Post Office Box 1397 Clinton, Mississippi 39060 COUNSEL FOR DEBTOR (LADYE M. TOWNSEND) Dated this 7th day of March, 2016. _____________________________________ Vogel Newsome
  • 36. ADMINISTRATION of JUSTICE, JUDICIAL CORRUPTION, etc. is running RAMPANT under the DESPOTISM ZionktAVhite Supremacist Government Regime of the United States of America that SUPPORTS not only the OVERTHROW, but ABOLISHMENT, and other LEGAL RECOURSE of and against the DESPOTISM Government of the United States of America! The DECLARATION OF INDEPENDENCE provides ADDITIONAL Legal Recourse and REMEDY for Relief under which Creditor Newsome also seeks JUSTICE! Creditor Vogel Denise Newsome RESERVES the right to provide a MEMORANDUM Brief in support of this instant "MTRC&OT02-25-16FDOCC" should this Court deems necessary in the PRESERVATION ofherri^ts! The February 25, 2016, Final Decree/Order Closing Case entered by this Court/Judge Edward Ellington IS cleariy BASELESS, FRIVOLOUS, full of ERRORS, cannot be UPHELD, supports CONFLICT -OF INTERESTS, criminal acts and much more for purposes of AIDING and ABETTING Judge Edward Ellington's Legal Counsel Baker Donelson Bearman Caldwell & Berkowitz. Said February 25, 2016 Final Decree/Order Closing Case IS NOT worth the ink and paper written on! Vogel Denise Newsome Post Office Box 31265 Jackson, MS 39286 Phone: (513)680-2922 or (601) 282-7119 Page 32 of 33
  • 37. CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the forgoing pleading was MAILED via U.S. Mail first-class to: Robert Rex McRaney, Jr. Post Office Box 1397 Clinton, Mississippi 39060 C O U N S E L FOR D E B T O R ( L A D Y E M . TOW-NSEND) Dated this 7'" day ofM^Pwa^y, 2016. Vogel Newsome Page 33 of 33