043012 EEOC & OCRC Complaint/Charge (Garretson Resolution Group) BRIEF and EXHIBITS can be downloaded at: https://www.filesanywhere.com/fs/v.aspx?v=8a70628a5b6271a86f9f

1. The April 30, 2012 Cover Letter(s) and Brief ONLY of the EEOC/ORC
Complaint/Charge are presently presented in this document.
PLEASE NOTE THE UPDATED LINKS (Because United
States of America President Barack Obama Had Scribd.com Shut Down) FOR
THE January 10, 2010:
“NOTIFICATION FOR TERMINATION - REQUEST FOR
IMPEACHMENT OF PRESIDENT BARACK HUSSEIN OBAMA II –
RESPONSE TO THE ATTACKS ON FLORIDA A&M UNIVERSITY
REGARDING ALLEGED HAZING INCIDENT – REQUEST FOR
INTERNATIONAL MILITARY INTERVENTION MAY BE NECESSARY.”
CAN BE RETRIEVED/VIEWED IN THE “UPDATED” LINK
DOCUMENT AT:
http://www.slideshare.net/VogelDenise/022712-updated-
links-for-obama-eviction-notice-011012final
PLEASE NOTE THE EEOC/OCRC COMPLAINT/CHARGE
and EXHIBITS IS A LARGE DOCUMENT YOU CAN REVIEW and
DOWNLOADED INFORMATION FROM THE FOLLOWING LINK:
https://www.filesanywhere.com/fs/
v.aspx?v=8a70628a5b6271a86f9f

14. Number of Employees: 15+
Discrimination Based On: (1) Race; (2) Age; (3) Retaliation; (4) Other – knowledge of
engagement in protected activity(s); and (5) Systematic
Discrimination - - - See United States Department of
Labor/EEOC’s - Prohibited Employment Policies/Practices at
EXHIBIT “LXXVI” attached hereto and incorporated by
reference as if set forth in full herein.
Date of Hire: January 2011 [Note: Employed as contract employee]
Date of Recent Discrimination: Latest: October 21, 2011 (Employment Terminated)
October 21, 2011, therefore giving Newsome until
approximately April 18, 2012 and/or approximately August 16,
2012 (i.e. in that this charge is covered by state or local anti-
discrimination law), to file a Charge of Discrimination
Date of Recent Retaliation: Approximately February 3, 2011 – i.e. Filing of Malicious
Lawsuit To Keep Information From Being Released To The
PUBLIC2
If Violations Are Found: EEOC/Ohio Civil Rights Commission/Ohio Department on
Human Rights is to enforce the applicable statutes/laws and seek
to eliminate discriminatory practices, Title VII
violations/employment violations/civil rights violations made
known to it.
EEOC/Ohio Civil Rights Commission/Ohio Department on
Human Rights shall prevent any person from engaging in
unlawful discriminatory practices, provided that, before
instituting formal hearing and/or authorized proceedings, it has
attempted, by informal methods of conference, conciliation and
persuasion, to induce compliance with this chapter. If necessary,
2
EEOC COMPLIANCE MANUAL at No. 3(a), Page 10: Standards Governing Application of the Opposition Clause:
a. Manner of Opposition Must Be Reasonable
The manner in which an individual protests perceived employment discrimination must
be reasonable in order for the anti- retaliation provisions to apply. In applying a "reasonableness"
standard, courts and the Commission balance the right of individuals to oppose employment
discrimination and the public's interest in enforcement of the EEO laws
against an employer's need for a stable and productive work environment.
Public criticism of alleged discrimination may be a reasonable form of opposition. Courts
have protected an employee's right to inform an employer's customers about the employer's alleged
discrimination, as well as the right to engage in peaceful picketing to oppose allegedly
discriminatory employment practices. - See, e.g., Sumner v. United States Postal Service, 899 F.2d
203 (2d Cir. 1990) (practices protected by opposition clause include writing letters to customers
criticizing employer's alleged discrimination).
See EXHIBIT “LXXXV” – EEOC COMPLIANCE MANUAL attached hereto and incorporated
by reference as if set forth in full herein.
Page 2 of 196

15. initiate a complaint and refer it to the attorney general with a
recommendation to seek a temporary or permanent injunction or
temporary restraining order. If this action is required to be
taken, the attorney general shall apply, as expeditiously as
possible after receipt of the complaint, to the court of common
pleas of the county in which the unlawful discriminatory practice
allegedly occurred for the appropriate injunction or order, and
the court shall hear and determine the application as
expeditiously as possible. (ORC 4112.05)
The Garretson Firm Engages in matters that are of SOCIAL and ECONOMICAL
Resolution Group, Inc. interest. Founded in 1998, the Garretson Resolution Group
Specializes has a history as a (“GRG”) is a neutral provider of services to parties who are
“Law Firm:” settling personal injury claims. Each year GRG resolve over
100,000 healthcare obligations for thousands of firms and
companies across the country. GRG’s Resolution and
Compliance Program includes: Healthcare Lien Resolution;
Medicare Set-Aside (MSA); Medicare Secondary Payer (MSP)
Consulting & Mandatory Insurer Reporting; and Complex
Settlement Administration. See EXHIBIT “LXXIX” –
Garretson/About Us attached hereto and incorporated by
reference as if set forth in full herein.
COPY MAILED TO: VIA PRIORITY MAIL: SIGNATURE TRACKING NO. 2306 1570 0001 0580 6978
U.S. Department of Labor
ATTN: Secretary Hilda L. Solis
Frances Perkins Building
200 Constitution Ave., NW
Washington, DC 20210
VIA PRIORITY MAIL: SIGNATURE TRACKING NO. 2306 1570 0001 0580 7005
The United States White House
ATTN: U.S. President Barack Obama
1600 Pennsylvania Ave NW
Washington, DC 20500
VIA PRIORITY MAIL: SIGNATURE TRACKING NO. 2306 1570 0001 0580 6992
U.S. Department of Justice
ATTN: Attorney General Eric H. Holder, Jr.
950 Pennsylvania Avenue, NW
Washington, DC 20530-0001
VIA EMAIL
United States Congress Members (Senate and House of Representatives)
Media/News Outlets
Foreign Nations/Leaders/Media (Under Concealment)
PUBLIC-AT-LARGE (Under Concealment)
Page 3 of 196

16. COMES NOW Vogel Denise Newsome (“Newsome”), an African-American female, and
files this her Official United States Equal Employment Opportunity Commission (hereinafter
“EEOC”) Complaint with the United States Secretary of Labor in care of and through the EEOC’s
Cincinnati Area Office of and against The Garretson Firm Resolution Group Inc. (“GRG”)3 and/or its
representatives and Messina Staffing/Messina Management Staffing (“MStaffing”)4 and/or its
representatives under Title VII of the Civil Rights Act of 1964 [42 U.S.C.A. § 2000e et seq.], 29
C.F.R. § 1601.7, and any/all applicable statutes/laws under which the jurisdiction of the EEOC is
applicable.
This instant Charge is also being filed with the Ohio Civil Rights Commission with the
Cincinnati Regional Director in care of and through its Cincinnati Regional Office of and against
The Garretson Firm Resolution Group Inc. (“GRG”) and/or its representatives under 4112 and
any/all applicable statutes/laws under which the jurisdiction of the Ohio Civil Rights Commission is
applicable. Newsome’s job performance was subjected to heightened scrutiny IMMEDIATELY
AFTER she sought legal action of and against the President of the United States of America (Barack
Hussein Obama II) and GRG’s knowledge of her engagement in protected activities. The temporal
proximity between Newsome’s submittal of legal action against United States of America President
Barack Hussein Obama II and of charges and the heightened scrutiny is enough to establish the
causal connection for purposes of proving a prima facie case of discriminatory and retaliatory
practices. This instant Charge will provide circumstantial evidence which will include the proximity
between the protected activities and changes in GRG’s relationship with Newsome and the terms of
her employment. An investigation will yield how GRG began to closely monitor Newsome and
create conditions (i.e. destroying Claimants’ documentation and attempts to FRAME Newsome for
3
The Garretson Firm Resolution Group Inc. in this Complaint will refer to it, its employees (not including
Newsome in that she is identified) and/or representatives.
4
Messina Staffing/Messina Management Staffing in this Complaint will refer to it, its employees (not including
Newsome in that she is identified) and/or representatives.
Page 4 of 196

17. such criminal activities as well as employing younger whites for the purposes of discrimination,
harassment, creation of a hostile environment, and retaliation to interfere with performance of job
duties, and measures taken to force Newsome to quit and/or out of the workplace) which led to her
unlawful/illegal discharge and/or termination. Newsome believes said interference in which an
investigation may yield a causal connection between her filing of legal action against United States
of America President Barack Hussein Obama II, as well as Newsome’s engagement in prior EEOC
Charges and Legal Lawsuits and/or engagement in protected activities – supporting prima facie
criteria.
In support of this Complaint Newsome states the following:
JURISDICTION
Where the employee worked in both Ohio and Kentucky, the trial court ERRED
in dismissing the state and federal discrimination claims on the basis of lack of
subject matter jurisdiction. Wilkerson v. Howell Contrs., Inc., 163 Ohio App. 3d
38, 836 N.E.2d 29, 2005 Ohio 4418 (2005).
EQUAL EMPLOYMENT OPPORTUNITY COMMISSION:
The jurisdiction of the United States Equal Employment Opportunity Commission (“EEOC”)
is invoked under the Title VII of the Civil Rights Act of 1964 [42 U.S.C.A. § 2000e et seq.], 29
C.F.R. § 1601.7 and the applicable statutes/laws granting said agency jurisdiction. Newsome,
through this instant Charge, is requesting the administration and enforcement of Title VII. The
enforcement of Title VII rights begins with the filing of a charge of unlawful employment
discrimination; moreover, to determine whether Title VII will need to be enforced. Therefore,
Newsome through this instant documentation is filing a Charge of unlawful employment
discrimination. The filing of this instant Charge of Discrimination is being submitted to the EEOC to
provide it with an opportunity to investigate and attempt a resolution of the controversy. Moreover,
is also provided to determine whether or not Newsome is a victim of individual and/or systematic
Page 5 of 196

18. discrimination pursuant to 29 C.F.R. § 1601.6. See EXHIBIT “I” – attached hereto and
incorporated by reference as if set forth in full herein.
Title 29: Labor
PART 1601—PROCEDURAL REGULATIONS
Subpart B—Procedure for the Prevention of Unlawful Employment
Practices
§ 1601.6 Submission of information.
(a) The Commission shall receive information concerning alleged
violations of Title VII . . . from any person. Where the information
discloses that a person is entitled to file a charge with the
Commission, the appropriate office shall render assistance in the
filing of a charge. Any person or organization may request
the issuance of a Commissioner charge for an inquiry
into individual or systematic5 discrimination. Such request,
with any pertinent information, should be submitted to the nearest
District, Field, Area, or Local office.
This instant Charge of Discrimination has been timely filed pursuant to the guidelines and/or
procedures of the EEOC. To preserve Newsome’s rights, the most recent discriminatory act rendered
Newsome by her employer(s), Garretson Resolution Group/The Garretson Firm Resolution Group
Inc. (hereinafter, “GRG”) and/or Messina Staffing/Messina Management Systems (hereinafter,
“MStaffing”) occurred on or about October 21, 2011, therefore giving Newsome
until approximately April 18, 2012 and/or approximately August 16,
2012 (i.e. in that this charge is covered by state or local anti-
discrimination law), to file a Charge of Discrimination – See
http://www.eeoc.gov/cincinnati/timeliness.html which provide the following information:
A charge must be filed with EEOC within 180 days from the date of
the alleged violation, in order to protect the charging party’s rights.
5
EMPHASIS ADDED.
Page 6 of 196

19. This 180-day filing deadline may be extended to 300 days if the
charge also is covered by a state or local anti-discrimination
law…
Cincinnati Area Office Information
An individual has 300 days from the date of alleged harm to file a
charge with this office against an employer with 15 or more
employees for discrimination based on race, color, national origin,
sex, religion, and/or disability in the State of Ohio. . .
This is an action for damages based on unlawful employment discrimination practices
committed by Garretson Resolution Group/The Garretson Firm Resolution Group Inc. and/or
Messina Staffing/Messina Management Systems and jurisdiction of the United States Equal
Employment Opportunity Commission is invoked pursuant to the provisions of 28 USC §
1343(a)(4); 28 USC § 2000e-5(f). This instant Complaint/Charge is a legal action in equity
authorized and instituted pursuant to the Civil Rights Act of 1991, 42 USC § 2000e, et seq. and 42
USC § 1981. It seeks declaratory relief pursuant to 28 USC § 2201, § 2202.
OHIO CIVIL RIGHTS COMMISSION:
The jurisdiction of the Ohio Civil Rights Commission (“OCRC”) is invoked under the
provisions of Section 4112 of the Ohio Revised Code and the applicable statutes/laws granting said
agency jurisdiction regarding unlawful discriminatory practices. Newsome through this instant
Charge is requesting the administration and enforcement of the applicable laws under Section 4112.
The filing of this instant Charge is to initiate a preliminary investigation to determine whether it is
probable that an unlawful discriminatory practice has been and/or is being engaged in. The filing of
this instant Charge is being submitted to the OCRC to determine if unlawful discriminatory practices
occurred. Then if so, Newsome is requesting the OCRC “to initiate a complaint and refer it to
the Attorney General with a recommendation to seek a temporary or permanent
injunction or a temporary restraining order. If this action is taken, the Attorney General
shall apply, as expeditiously as possible after receipt of the complaint, to the court of
Page 7 of 196

20. common pleas of the county in which the unlawful discriminatory practice allegedly
occurred for the appropriate injunction or order, and the court shall hear and determine
the application as expeditiously as possible” pursuant to Section 4112.05(3)(a)(iii).
Pursuant to Ohio Revised Code (“ORC”) Section 4112.02(A)(I):
It shall be an unlawful discriminatory practice:
(A) For an employer, because of the race, color, religion, sex,
military status, national origin, disability, age, or ancestry of
any person, to discharge without just cause, to refuse to hire,
or otherwise to discriminate against that person with respect
to hire, tenure, terms, conditions, or privileges of
employment, or any matter directly or indirectly related to
employment.
(I) For any person to discriminate in any manner against any
other person because that person has opposed any unlawful
discriminatory practice defined in this section or because that
person has made a charge, testified, assisted, or participated in
any manner in any investigation, proceeding, or hearing. . .
The pendent jurisdiction of the Ohio Civil Rights Commission is invoked to address
violations by Garretson Resolution Group/The Garretson Firm Resolution Group Inc. and/or
Messina Staffing/Messina Management Systems of the Ohio Commission on Human Rights Act,
Ohio Revised Codes and/or applicable statutes governing said matters, which Act’s/Statutes’
purpose is to safeguard all individuals within the state from discrimination because of race,
creed, color, religion, sex, age, disability, or national origin in connection to employment. To
protect their interest in personal dignity and freedom from humiliation.
Page 8 of 196

21. Ohio Civil Rights Commission (“OCRC”) Sources Used:
OCRC Complaint No. 9569 (Hatem matter) - See EXHIBIT “II” attached hereto and
incorporated by reference.
19. In order to create a hostile work environment, the conduct
must be “sufficiently severe or pervasive to alter the conditions of
the victim’s employment and create an abusive working
environment.” Harris v. Forklift Systems, Inc., 510 U.S. 17, 21
(1993), quoting Meritor, supra at 67. The conduct must be
unwelcome. Meritor, supra at 68. The victim must perceive the work
environment to be hostile or abusive, and the work environment must
be one that a reasonable person would find hostile or abusive. Harris
at 21-22. If the victim does not subjectively perceive the environment
to be abusive, the conduct has not actually altered the conditions of
the victim’s employment, and there is no Title VII violation. Id.
Garretson Resolution Group/The Garretson Firm Resolution Group (hereinafter "GRG"
encompasses its employees, representatives, etc.) created a HOSTILE work environment in which
employees were allowed to engage in RACIST/CRIMINAL acts leveled against Vogel Denise Newsome
("Newsome) and its conduct being SEVERE and/or PERVASIVE to alter the conditions of Newsome's
employment and create an ABUSIVE and CRIMINAL working environment. The hostile, abusive and
criminal conduct of GRG was UNWELCOMED! Newsome believing/perceiving GRG's work
environment to be HOSTILE, ABUSIVE, RACIST, DISCRIMINATORY, CRIMINAL, etc. Newsome
going as far as to report such unlawful/illegal employment practices both verbally and/or in writing as
evidenced in EXHIBIT "III" October 12, 2011 (i.e. incorrectly dated November 12, 20116) “Meeting
With Sandy Sullivan/HR” attached hereto and incorporated by reference as if set forth in full herein.
20. In examining the work environment from both subjective
and objective viewpoints, the fact-finder must examine “all the
circumstances”, including the employee’s psychological harm and
other relevant factors, such as:
. . .the frequency of the discriminatory conduct; its severity; whether
it is physically threatening or humiliating, or a mere offensive
utterance; and whether it unreasonably interferes with an employee’s
work performance. Id., at 23.
Rabidue v. Osceola Refining Div., 42 FEP Cases 631 (6th Cir.
1986) (plaintiffs must show that a hostile work environment resulted
6
In this instant Complaint/Charge the correct date of October 12, 2011 will be used/noted throughout.
Page 9 of 196

22. not from a single or isolated offensive incident, comment, or conduct,
but from incidents, comments, or conduct that occurred with some
frequency). “A hostile work environment is usually ‘characterized by
multiple and varied combinations and frequencies of offensive
exposures.’” Rose v. Figgie International, 56 FEP Cases 41, 44 (8th
Cir. 1990).
During Newsome's employment with GRG, GRG began bringing in a MAJORITY of
YOUNGER employees - i.e. some of which came in hitting the ground running with their
RACIST/DISCRIMINATORY Bulldog/Pit-Bull/Thuggish mentality with their sights set on Newsome
because of her race. The FREQUENCY of the discriminatory conduct beginning almost
IMMEDIATELY by excluding Newsome from "Training" being offered to majority white employees
and younger than Newsome. Exclusion of Newsome from "Training" sessions although REPEATEDLY
instructed to include her by Senior Project Manager Tina Mullen. The EXCLUSION of Newsome from
"Training" sessions resulted in her being REPEATEDLY subjected to attacks by "white" employees in
such EXCLUSIONS from "Training" INTERFERED with Newsome's ability to perform her job duties
and her not being made aware of any changes in processes needed for Newsome to perform job duties.
Furthermore, resulting in Newsome being subjected to “HOSTILE” emails from co-worker(s) as a direct
and proximate result of such EXCLUSIOIN and DELIBERATE failure to advise Newsome of “Changes”
in processes and/or procedures. See for instance EXHIBIT "IV" – September 29, 2011 email from
Brandy Jansen, attached hereto and incorporated by reference as if set forth in full herein.
SUPERVISOR HARASSMENT:
23. An employer is vicariously liable for a hostile work
environment created by a supervisor with immediate or higher
authority over the employee. Faragher, supra at 2275 (1998). If not
tangible employment action is taken against the employee, then the
employer may raise an affirmative defense to liability or damages.7
Ellerth, supra at 2270; Faragher, at 2293.
INDIVIDUAL LIABILTY: Supervisors and managers may be held
INDIVIDUALLY liable for unlawful discriminatory acts: Wallace v.
Henderson, 138 F. Supp. 2d 980 (S.D. 2000)
7
In Ellerth, the Supreme Court described a tangible employment action as:
. . . a significant change in employment status, such as hiring, firing, failing to promote,
reassignment with significantly different responsibilities, or a decision causing a significant change
in benefits. Id. at 2268.
Page 10 of 196

23. Liability under RC § 4112.02 is NOT limited to employers:
Vandiver v. Morgan Adhesive Co., 126 Ohio App. 3d 634, 710 N.E.2d
1219 (1998).
Newsome believes the record evidence will support her GOOD-FAITH efforts to address concerns of
such bias with GRG’s Supervisors. Furthermore, that it appears that one of GRG’s Project Manager
(Heather Custer) – i.e. which appeared to have been later DEMOTED to “Project Coordinator” –
may have CONSPIRED and played a major role in the CRIMINAL acts and DISCRIMINATORY
practices leveled against Newsome for purposes of forcing her out of the workplace and/or seeing
that GRG TERMINATED her employment in RETALIATION to Newsome’s being promoted from
“Data Entry/Claims Reviewer” to “PROJECT COORDINATOR.”
RETALIATION:
32. In order to establish a prima facie case of retaliation
under R.C. 4112.02(I), the Commission must prove the following
elements:
a. Complainant engaged in protected activity;
b. Respondent knew of Complainant’s participation in the
protected activity;
c. Respondent engaged in retaliatory conduct; and
d. a causal link exists between the protected activity and the
adverse action.
Hollins v. Atlantic Co., Inc., 80 FEP Cases 835 (6th Cir.
1999), aff’d in part and rev’d in part, 76 FEP Cases 533
(N.D. Ohio 1997)(quotation marks omitted).
Newsome believes that an investigation will yield that a “Prima Facie” case of
RETALIATION can be established:
(1) Newsome engaged in protected activity(s);
(2) GRG knew of Newsome’s participation in the protected activity(s) – See
EXHIBIT “V” – Website information previously at
www.vogeldenisenewsome.com attached hereto and incorporated by reference
as if set forth in full herein;
(3) GRG engaged in RETALIATORY conduct – i.e. unlawfully/illegally
terminating Newsome’s employment WITHOUT just cause and then going as
Page 11 of 196

24. far as recent as February 3, 2012, to file a FRIVOLOUS/MALICIOUS Lawsuit
against Newsome alleging what appeared to be “Copyright” Infringement to
keep Newsome from sharing information which is of “PUBLIC” Interest on her
website! – See EXHIBIT “VI” - Docket Sheet in The Garretson Firm
Resolution Group Inc. vs. Vogel Denise Newsome, Hamilton County (Ohio)
Court of Common Pleas, Civil Action No. A1200831 attached hereto and
incorporated by reference as if set forth in full herein. IMPORTANT TO
NOTE: Since GRG’s filing of Lawsuit AGAINST Newsome
the Court has moved to “SEAL” information so that
PUBLIC/WORLD will not have access to information.
Information which, as a matter of law, is now a matter of
PUBLIC RECORD!
When considering a RETALIATION claim, adverse employment
action required a materially adverse change in the terms and conditions
of employment, and, in considering whether an employment action was
materially adverse, a court could consider whether employment was
terminated, whether the employee was demoted, received a decrease in
wage or salary, a less distinguished title, a material loss of benefits,
significantly diminished material responsibilities, or other indices that
might be unique to a particular situation. Brock v. Eaton Corp., 2006
Ohio App. LEXIS 5571, 2006 Ohio 5580 (2006).
Employee’s claim that he was improperly discharged in
retaliation for his complaints of discrimination failed under RC §
4112.02(I), as the employee only complained about discriminatory
conduct by his coworkers, and he neither opposed any unlawful
discriminatory practice by the employer, nor did he make a charge,
testify, assist, or participate in an investigation, hearing or proceeding
under RC ch. 4112: Osaze v. City of Strongsville, 2006 Ohio App.
LEXIS 983, 2006 Ohio 1089 (2006).
While an employee showed that she engaged in protected
activity by retaining counsel and complaining of discrimination by her
employer, and the employer was aware of this protected activity before
it fired the employee, the employee did not show a negative shift in the
employer’s attitude toward the employee, after learning of the protected
activity, so the employer did not demonstrate a case of retaliation. Hall
v. Banc One Mgmt. Corp., 2006 Ohio App. LEXIS 808, 2006 Ohio 913
(2006).
Plaintiff produced sufficient evidence to withstand summary
judgment on his retaliation claim. Plaintiff produced evidence to
show that he engaged in protected activity by opposing defendant’s
alleged discrimination and by filing a charge with the EEOC; the
exercise of his civil rights was known by defendants; defendants took
an adverse employment action against plaintiff; and a reasonable fact-
finder could draw an inference of a causal connection between the
protected activity and the adverse employment action. Imwalle v.
Reliance Med. Prods., 2005 U.S. Dist. LEXIS 27882 (2005).
In order to establish a prima facie case of retaliation under RC
§ 4112.02(I), an employee must prove the following elements (a) the
employee engaged in protected activity; (b) the employer knew of the
employee’s participation in the protected activity; (c) the employer
engaged in retaliatory conduct; and (d) a causal link exists between the
protected activity and the adverse action. Powers v. Pinkerton, Inc.,
2001 Ohio App. LEXIS 138 (8th Dist. 2001).
Page 12 of 196

25. Female employee established the “causal link” between her
discharge and the filing of her complaint for harassment and
satisfied her burden of making prima facie showing of retaliation
based solely on the fact that she was discharged less than one month
after filing her claim: Dorricott v. Fairhill Ctr. for Aging, 2 F.Supp.
2d 982 (1998).
Newsome engages in business transactions outside the State of Ohio.
Therefore, when GRG brought the Lawsuit AGAINST Newsome for exercising
Rights secured under the FIRST Amendment of the United States Constitution
and other laws governing said matters, it ERRED. Furthermore, GRG’s
February 3, 2012 Lawsuit AGAINST Newsome not only INFRINGED upon
Constitutional Rights, Civil Rights, etc. but is subject to matters governing
STRATEGIC LAWSUITS AGAINST PUBLIC PARTICIPATION
(“SLAPP”).
The February 3, 2012, Lawsuit GRG filed AGAINST Newsome is considered a
SLAPP Lawsuit. GRG’s SLAPP Complaint may allege “copyright”
infringement to CAMOUFLAGE and/or MASK/SHIELD its crimes from the
PUBIC/WORLD to keep it from learning of the ROLE United States President
Barack Obama and his Administration played in the UNLAWFUL/ILLEGAL
Employment practices of Garretson Resolution Group as well as the RECENT
attacks on Vogel Denise Newsome’s INTERNET SERVICES and the bringing of
MALICIOUS Prosecution action against Newsome to SILENCE her and
therefore, requiring that “MOTION TO VACATE ORDER GRANTING
MOTION FOR A TEMPORARY RESTRAINING ORDER and/or in the
ALTERNATIVE, MOTION TO DISMISS” (“MTVOGMFTRO”) be filed:
HOW DO YOU KNOW IF YOU HAVE BEEN
SLAPPed?
SLAPPs all arise out of expressive activity which is directed to
public concerns and protected by the First Amendment. Often,
SLAPPs are “camouflaged” as ordinary civil lawsuits; among the
most often used legal theories are the following:
i) Defamation. Broadly defined, this is an alleged
intentional false communication, which is either published
in a written form (libel) or publicly spoken (slander), that
injures one’s reputation.
(Based upon the facts, evidence and legal
conclusions stated in the “MTVOGMFTRO,”
Vogel Denise Newsome has been
IRREPARABLY injured/harmed and
PREJUDICED by GRG’s MALICIOUS
Complaint – i.e. which most likely may be
CAMOUFLAGED under “Defamation” claims
– which may be a claim made; however, not
known since Newsome is NOT waiving
protected rights and NOT submitting to the
jurisdiction of the Hamilton County (Ohio) Court
Page 13 of 196

26. of Common Pleas who LACK jurisdiction over
business conducted in other States such as
California where Newsome’s website was and/or
States where the ANTI-SLAPP Laws are
applicable. Therefore, Newsome is protected
by the Anti-SLAPP Law(s) governing said
matters.)
ii) Malicious Prosecution or Abuse of Process. A
“malicious prosecution” is a criminal or civil lawsuit
which is begun with knowledge that the case lacks merit,
and which is brought for a reason (such as, to harass or
annoy) other than to seek a judicial determination of the
claim. The use of the legal process to intimidate or to
punish the person against whom the suit is brought is
generally referred to as “abuse of process.”
(Based upon the facts, evidence and legal
conclusions stated in the “MTVOGMFTRO,”
Vogel Denise Newsome has been
IRREPARABLY injured/harmed and
PREJUDICED by GRG’s MALICIOUS
PROSECUTION Complaint which has been
brought with KNOWLEDGE that the
Lawsuit/Complaint LACKS MERIT, and has
merely been brought in furtherance of GRG’s
CRIMINAL STALKING, INTERNET
STALKING, BULLYING, THREATS,
HARASSMENT, INTIMIDATION practices,
etc. toward Newsome – i.e. which most likely is
CAMOUFLAGED through its bringing of a
Lawsuit/Complaint against Newsome.
Therefore, Newsome is protected by the Anti-
SLAPP Law(s) governing said matters.)
iii) Invasion of Privacy. This refers to the unlawful use or
exploitation of one’s personality, the publicizing of one’s
private affairs with which the public has no legitimate
concern, or the wrongful intrusion into one’s private
activities.
(Based upon the facts, evidence and legal
conclusions stated in the “MTVOGMFTRO,”
Vogel Denise Newsome has been
IRREPARABLY injured/harmed and
PREJUDICED by GRG’s MALICIOUS
Complaint – i.e. which may be
CAMOUFLAGED under “Invasion of
Privacy” claims – which may be a claim made;
however, not known since Newsome is NOT
waiving protected rights and NOT submitting to
the jurisdiction of the Hamilton County (Ohio)
Court of Common Pleas who LACK jurisdiction
over business conducted in other States such as
California where Newsome’s website was and/or
States where the ANTI-SLAPP Laws are
Page 14 of 196

27. applicable. Therefore, Newsome is protected
by the Anti-SLAPP Law(s) governing said
matters.)
iv) Conspiracy. A conspiracy is an alleged agreement
between two or more persons to commit an illegal,
unlawful, or wrongful act.
(Based upon the facts, evidence and legal
conclusions stated in the “MTVOGMFTRO,”
Vogel Denise Newsome has been
IRREPARABLY injured/harmed and
PREJUDICED by GRG’s MALICIOUS
Complaint in which it is a party to ONGOING
CONSPIRACIES leveled against her to
deprive her PROTECTED Rights secured
under the FIRST Amendment and other laws
governing said matters. Newsome is NOT
waiving protected rights and NOT submitting
to the jurisdiction of the Hamilton County
(Ohio) Court of Common Pleas who LACK
jurisdiction over business conducted in other
States such as California where Newsome’s
website was and/or States where the ANTI-
SLAPP Laws are applicable. Therefore,
Newsome is protected by the Anti-SLAPP
Law(s) governing said matters.)
v) Interference With Contract or Economic Advantage.
This is based on the alleged commission of an act with the
intent to interfere with or cause a breach of a contract
between two people, or hinder a business relationship
which exists between those persons.
(Based upon the facts, evidence and legal
conclusions stated in the “MTVOGMFTRO,”
Vogel Denise Newsome has been
IRREPARABLY injured/harmed and
PREJUDICED by GRG’s MALICIOUS
Complaint brought for the commission of an act
with the intent to INTERFERE with or cause
BREACH OF CONTRACTS with
OneWebHosting.com, Scribd.com, and other
business relationships in which Newsome had
formed and can be EVIDENCED in this instant
pleading and the INTERFERENCE and
BREACH OF CONTRACTS that have resulted
as the direct and proximate result of GRG
contacting business(es) that provide services to
Newsome which allow her to use their FORUMS
to share educational/ informative materials with
the PUBLIC. Newsome is NOT waiving
protected rights and NOT submitting to the
jurisdiction of the Hamilton County (Ohio) Court
of Common Pleas who LACK jurisdiction over
business conducted in other States such as
Page 15 of 196

28. California where Newsome’s website was and/or
States where the ANTI-SLAPP Laws are
applicable. Therefore, Newsome is protected
by the Anti-SLAPP Law(s) governing said
matters.)
vi) Intentional or Negligent Infliction of Emotional
Distress. This is based on an alleged commission of some
outrageous act with the intent and knowledge that the act
will result in severe mental or emotional anguish of
another.
(Based upon the facts, evidence and legal
conclusions stated in the “MTVOGMFTRO,”
Vogel Denise Newsome has been
IRREPARABLY injured/harmed and
PREJUDICED by GRG’s MALICIOUS
Complaint – i.e. which may be
CAMOUFLAGED under “Intentional or
Negligent Infliction or Emotional Distress”
claims – which may be a claim made; however,
not known since Newsome is NOT waiving
protected rights and NOT submitting to the
jurisdiction of the Hamilton County (Ohio) Court
of Common Pleas who LACK jurisdiction over
business conducted in other States such as
California where Newsome’s website was and/or
States where the ANTI-SLAPP Laws are
applicable. Therefore, Newsome is protected
by the Anti-SLAPP Law(s) governing said
matters.)
vii) Injunction. The lawsuit seeks a temporary restraining
order or an injunction against First Amendment activity.
(Based upon the facts, evidence and legal
conclusions stated in the “MTVOGMFTRO,”
Vogel Denise Newsome has been
IRREPARABLY injured/harmed and
PREJUDICED by GRG’s MALICIOUS
Complaint – i.e which most likely may be
CAMOUFLAGED under a malicious
“Complaint” and “Motion for a Temporary
Restraining Order and Application for
Preliminary Injunction Order” which may be
claim(s) made; however, not known since
Newsome is NOT waiving protected rights and
NOT submitting to the jurisdiction of the
Hamilton County (Ohio) Court of Common Pleas
who LACK jurisdiction over business conducted
in other States such as California where
Newsome’s website was and/or States where the
ANTI-SLAPP Laws are applicable. Therefore,
Newsome is protected by the Anti-SLAPP
Law(s) governing said matters.)
Page 16 of 196

29. See EXHIBIT “LXXX” – CALIFORNIA ANTI-SLAPP:
If You’ve Been Sued, How Do You Know If You’ve Been
SLAPPed? Attached hereto and incorporated by reference as if set
forth in full herein.
See EXHIBIT “LXXXI” – ANTI-SLAPP Law In
California attached hereto and incorporated by reference as if set
forth in full herein.
(4) A CAUSAL Link exists between the protected activity and the adverse action.
Furthermore, an investigation will YIELD the ONGOING
“STALKING/INTERNET STALKING” and “BULLYING/CYBER
BULLYING” by GRG and its CONSPIRATORS/CO-CONSPIRATORS (i.e.
such as United States of America President Barack Obama, etc.) attempting to
deprive Newsome of protected rights; moreover, OBSTRUCTING Newsome’s
right to inform the “PUBLIC” of GRG’s unlawful/illegal employment
practices:
Conspirator becomes the agent of the other conspirator (s), and any act done by
one of the combination is regarded under the law as the act of both or all. In
other words, what one does, if there is this combination, becomes the act of both
or all of them, no matter which individual may have done it. This is true as to
each member of the conspiracy, even those whose involvement was limited to
a minor role in the unlawful transaction, and it makes no difference whether or
not such individual shared in the profits of the actions. (Am. Jur. Pleading and
Practice Forms, Conspiracy § 9). TACIT AGREEMENT - Occurs when two or
more persons pursue by their acts the same object by the same means. One
person performing one part and the other another part, so that upon completion
they have obtained the object pursued. Regardless whether each person knew
of the details or what part each was to perform, the end results being they
obtained the object pursued. Agreement is implied or inferred from actions or
statements.
See EXHIBIT “VII”- February 2, 2012 “ANSWER TO COMPLAINT
SUBMITTED TO: OneWebHosting.com BY GARRETSON RESOLUTION
GROUP NO RESPONSE TO THE ANSWER HAS BEEN RECEIVED”
attached hereto and incorporated by reference as if set forth in full herein.
36. The test for determining whether an employee was
constructively discharged is whether the employer’s actions made
working conditions so intolerable that a reasonable person under the
circumstances would have felt compelled to resign. Mauzy v. Kelly
Services, Inc., (1996), 75 Ohio St.3d 578, 1996 Ohio 265, 664 N.E. 2d
1272.
GRG allowed and/or encouraged the unlawful/illegal practices leveled against Newsome by
White employees which made working conditions so INTOLERABLE and UNACCEPTABLE that
Newsome reported her concerns to Supervisors and/or Human Resources. To no avail. Making
working conditions INTOLERABLE and UNACCEPTABLE that a reasonable person under the
Page 17 of 196

30. circumstances would have felt compelled to resign and/or quit. Newsome; however, believed that it
was her duty and obligation to report the unlawful/illegal discriminatory practices and did so. See
EXHIBIT “III”- October 12, 2011 “Meeting With Sandy Sullivan/HR” attached hereto and
incorporated by reference as if set forth in full herein.
37. Whether the discriminatory conduct unreasonably
interfered with Complainant’s work performance is one factor to be
considered. The Commission, however, is not required to show the
Complainant’s “tangible productivity . . . declined as a result of
harassment.” Harris, 63 FEP Cases at 229 (Justice Ginsburg’s
concurrence) quoting Davis v. Monsanto Chemical Co., 47 FEP Cases
1825, 1828 (6th Cir. 1988). Instead the Commission must demonstrate
that a reasonable person subjected to the discriminatory conduct would
find that the harassment so altered working conditions as to “ma[k]e it
more difficult to do the job.” Id.
Newsome believes that an investigation and record evidence will support GRG’s
discriminatory conduct leveled against Newsome UNREASONABLY interfered with her work
performance and subjected to REPEAT attacks by YOUNGER White co-workers which were
condoned by Supervisors and Human Resources. The HARASSMENT, HOSTILE and
DISCRIMINATORY conduct altered the working conditions as well as the working relations between
Newsome and GRG for purposes of making working conditions MORE difficult and unbearable for
her to perform job duties!
38. To support a retaliation claim, the Commission must show
that the change in Complainant’s employment conditions was more
disruptive than a mere inconvenience or an alteration of job
responsibilities. Bowers v. Hamilton City Sch. Dist. Bd. Of Educ., 12th
Dist. No. CA2001-07-160, 2002 Ohio 1343, citing Kocis, 97 F.3d at
886.
GRG’s interference with Newsome’s employment conditions was so DISRUPTIVE – i.e.
unlawful/illegal/criminal – than a mere inconvenience or an alteration of job responsibilities, that
said interference was so CRIMINAL in nature as to FRAME Newsome for the criminal conduct –
i.e. TAMPERING with Claimants’ documents, OBSTRUCTING mail/deliveries, etc. – that such
practices may be SHOCKING to a reasonable person that employees would go so far as to engage in
such CRIMINAL behavior based on RACIAL/DISCRIMINATORY motives.
Page 18 of 196

31. FACTS OF THIS COMPLAINT
Newsome believe it is important to note that the Title VII/Civil Rights/Employment
violations, etc. addressed in this instant Charge may be as a direct and proximate result of the
EEOC’s failure in the past to perform ministerial duties mandated by
statutes/laws. Moreover, as a direct and proximate result of said failure that she has repeatedly
been subjected to such unlawful employment discrimination/practices, systematic
discriminatory practices and criminal acts by The Garretson Firm Resolution
Group Inc. (“GRG”). An investigation will yield that the very policies and practices that the
EEOC acknowledges as discriminatory – i.e. contacting employers and notifying of employee’s past
participation and/or filing of EEOC Charge is the very practice that has been repeatedly allowed to
be used and transferred from one employer to another regarding Newsome. Moreover, the posting of
such protected activity on the INTERNET was deliberately done for purposes of depriving Newsome
equal employment opportunities, equal protection of the laws, due process of laws, life, liberties and
the pursuit of happiness, etc. All because Newsome exposed what is known for a long time to be
systematic discrimination leveled against African-Americans and/or people of color who challenge
employers for discriminatory practices and the government’s handling of such claims. An
investigation into this instant Charge will support systematic discrimination and violation under
Title VII of the Civil Rights Act and other governing statutes/laws have been implemented to prevent
and/or preclude Newsome from obtaining gainful employment – i.e. equal employment opportunities.
Page 19 of 196

32. I. VIOLATION OF STATUTE:
“PERSON” pursuant to the Ohio Civil Rights Commission (OHCRC)
see Ohio Revised Code (“ORC”) 41 ORC § 4112.01, “includes one or more
individuals, partnerships, associations, corporations, legal representatives,
trustees, trustees in bankruptcy, receivers and other organized groups of persons.
“Persons” also includes, but is not limited to, any owner, lessor, assignor,
builder, manager, broker, salesperson, appraiser, agent, employee, lending
institution, and the state and all political subdivisions, authorities, agencies,
boards, and commissions of the state.
“EMPLOYER” pursuant to Ohio Civil Rights Commission (OHCRC)
see Ohio Revised Code (“ORC”) 41 ORC § 4112.01, “includes the state, any
political subdivision of the state, any person employing for or more persons
within the state, and any person acting directly or indirectly in the interest of an
employer.
“EMPLOYMENT AGENCY” includes any person regularly undertaking,
with or without compensation, to procure opportunities to work or to procure,
recruit, refer, or place employees. 41 ORC § 4112.01.
Section 701(c) of Title VII defines the term "employment agency" as
"any person regularly undertaking with or without compensation to procure
employees for an employer or to procure for employees opportunities to work
for an employer and includes an agent of such a person." For further guidance,
see Policy Guidance: What constitutes an employment agency under Title VII,
how should charges against employment agencies be investigated, and what
remedies can be obtained for employment agency violations of the Act?,
Compliance Manual (BNA) N:3935 (9/29/91).
“EMPLOYEE” means an individual employed by any employer, 41
ORC § 4112.01.
“INDEPENDENT CONTRACTOR:” As remedial laws, civil rights statutes
should be liberally construed. Under the economic realities test, persons
denominated as independent contractors may be considered to be employees in
order to meet the four employee minimum: Nehls v. Quad K. Advertising, 106
Ohio App. 3d 489, 666 N.E.2d 579 (1995).
Employee’s co-worker and supervisor could be held liable for
harassment in their INDIVIDUAL capacities: Griswold v. Fresenius USA, 964
F.Supp. 1166 (1997). Ohio Revised Code § 4112.99 permits individual liability
for acts that violate Ohio’s employment discrimination law, despite the fact that
the construction means that a broader class of individuals may be liable under
state law than under federal law: Garraway v. Diversified Material Handling,
975 F.Supp. 1026 (1997).
INDIVIDUAL employees may be held liable for
violations of the Ohio antidiscrimination law:
DeLoach v. American Red Cross, 967 F.Supp. 265
(N.D. 1997)
Page 20 of 196

33. “UNLAWFUL DISCRIMINATORY PRACTICES:” It shall be unlawful
discriminatory practice:
(A) For an employer, because of the race, color, religion, sex, national
origin, disability, age, or ancestry of any person, to discharge
WITHOUT just cause, to refuse to hire, or otherwise to
discriminate against that person with respect to hire, tenure, terms,
conditions, or privileges of employment, or any matter directly or
indirectly related to employment.
1. The Garretson Firm Resolution Group Inc. is an “Employer.” The Garretson Firm
Resolution Group Inc. (“GRG”), Newsome’s former employer, is a private sector employer who
employs approximately 15 or more employees for at least 20 work weeks in the current or preceding
calendar year and is engaged in an activity affecting commerce. GRG is a corporation,
incorporated by virtue of the laws of the State of Ohio, and licensed to do business in the County
of Hamilton, State of Ohio. GRG maintains and administers records relevant to unlawful
employment practices with said County and State of Ohio. GRG is an employer within meaning
of the Civil Rights Act of 1991, Title VII of the Civil Rights Act of 1964, 42 USC § 2000e(b), in
that GRG is engaged in an industry affecting commerce and employs at least fifteen (15)
persons. GRG is an employer within meaning of the Ohio Civil Rights Commission. GRG may
be served in this cause by serving its Human Resources Representative (and/or Sandy Sullivan)
with this instant Complaint/Charge.
2. Messina Staffing is an “Employment Agency.” Messina Staffing (“MStaffing”), also
Newsome’s former employer, is a private sector employer who employs approximately 15 or more
employees for at least 20 work weeks in the current or preceding calendar year and is engaged in an
activity affecting commerce. MStaffing is a corporation, incorporated by virtue of the laws of the
State of Ohio, and licensed to do business in the County of Hamilton, State of Ohio. MStaffing
maintains and administers records relevant to unlawful employment practices with said County
and State of Ohio. MStaffing is an employer within meaning of the Civil Rights Act of 1991,
Title VII of the Civil Rights Act of 1964, 42 USC § 2000e(b), in that MStaffing is engaged in an
industry affecting commerce and employs at least fifteen (15) persons. MStaffing is an employer
within meaning of the Ohio Civil Rights Commission. MStaffing may be served in this cause by
serving its President (and/or Vance Messina) with this instant Complaint/Charge.
3. Sandy Sullivan (Human Resources Manager/Representative) and Matthew Garretson
(Founder and Chief Executive Officer) at GRG are people who act, directly, in the interest of their
employer (GRG) to the employees of said employer.
4. Vince Messina and/or Justin Roehm at MStaffing are people who act, directly, in the
interest of their employer (MStaffing) to the employees of said employer.
5. Newsome worked for covered employer – Messina Staffing/Messina Management
Systems. Newsome being assigned to work at Garretson Resolution Group/The Garretson Firm
Resolution Group in January 2011. Under State/Federal laws governing said matters, Newsome
qualifying as an employee for BOTH MStaffing and GRG.
6. Newsome worked for covered employer – The Garretson Firm Resolution Group Inc.
Newsome’s hire date being effective approximately January 2011. Newsome was employed as Data
Entry/Claims Reviewer. See EXHIBIT “VIII” – “GRG Employee Directory” attached hereto and
Page 21 of 196

34. incorporated by reference as if set forth in full herein. At the time of Newsome’s termination on or
about October 21, 2011, GRG had promoted Newsome to PROJECT COORDINATOR (See
EXHIBIT “IX” – “GRG’s Claims Administration Organization Chart” attached hereto and
incorporated by reference as if set forth in full herein.). GRG still had a need for the job duties
performed by Newsome as Project Coordinator.
7. During Newsome’s employment at GRG she was subjected to systematic
discriminatory practices based on GRG’s and MStaffing’s knowledge of her participation and
engagement in protected activities. See United States Department of Labor/EEOC’s - Prohibited
Employment Policies/Practices at EXHIBIT “LXXVI” attached hereto and incorporated by
reference as if set forth in full herein.
8. During Newsome’s employment at GRG and/or MStaffing, she was subjected to
discriminatory treatment based on her race, age and engagement in protected activity(s). Newsome
is an African-American. Newsome is a female over the age of 45. Newsome participates in
protected activities. Therefore, a member of the protected group. See United States Department of
Labor/EEOC’s - Prohibited Employment Policies/Practices at EXHIBIT “LXXVI” attached hereto
and incorporated by reference as if set forth in full herein.
9. During Newsome’s employment at GRG and/or MStaffing, she was subjected to
unlawful discriminatory practices based on her race, age and engagement in protected activity(s).
Newsome is an African-American. Newsome is a female over the age of 45. Newsome participates
in protected activities. Therefore, a member of the protected group. See United States Department of
Labor/EEOC’s - Prohibited Employment Policies/Practices at EXHIBIT “LXXVI” attached hereto
and incorporated by reference as if set forth in full herein.
10. During Newsome’s employment at GRG and/or MStaffing, she was subjected to
retaliatory treatment for reporting unlawful/illegal/criminal employment practices and/or for
participating/engaging in protected activities.
11. GRG and/or MStaffing changed Newsome’s terms and conditions of employment,
and terminated her employment, in retaliation for having engaged in activity protected by R.C. 4112.
See EXHIBIT “LXXVII” - United States Department of Labor/EEOC -
Facts About Retaliation attached hereto and incorporated by reference as if set forth in full herein.
. . . There are three main terms that are used to describe retaliation. Retaliation occurs when
an employer, employment agency, or labor organization takes an adverse action against a
covered individual because he or she engaged in a protected activity.
ADVERSE ACTION
An adverse action is an action taken to try to keep someone from opposing a
discriminatory practice, or from participating in an employment discrimination
proceeding. . .
 employment actions such as termination, refusal to hire, and denial
of promotion,
 other actions affecting employment such as threats, unjustified
negative evaluations, unjustified negative references, or increased
surveillance, and
Page 22 of 196

35.  any other action such as an assault or unfounded civil or criminal
charges that are likely to deter reasonable people from pursuing
their rights. . .
Even if the prior protected activity alleged wrongdoing by a different employer,
retaliatory adverse actions are unlawful. For example, it is unlawful for a worker's
current employer to retaliate against him for pursuing an EEO charge against a
former employer. . .
COVERED INDIVIDUALS
Covered individuals are people who have opposed unlawful practices,
participated in proceedings, or requested accommodations related to
employment discrimination based on race, color, sex, religion, national
origin, age, or disability. Individuals who have a close association with
someone who has engaged in such protected activity also are covered
individuals. For example, it is illegal to terminate an employee because his
spouse participated in employment discrimination litigation. . .
PROTECTED ACTIVITY
PROTECTED ACTIVITY INCLUDES:
Opposition to a practice believed to be unlawful discrimination
Opposition is informing an employer that you believe that he/she is
engaging in prohibited discrimination. Opposition is protected from
retaliation as long as it is based on a reasonable, good-faith belief
that the complained of practice violates anti-discrimination law; and
the manner of the opposition is reasonable.
Examples of protected opposition include:
 Complaining to anyone about alleged discrimination
against oneself or others; . . .
 Picketing in opposition to discrimination; or
 Refusing to obey an order reasonably believed to be
discriminatory.
Participation in an employment discrimination proceeding.
Participation means taking part in an employment discrimination
proceeding. Participation is protected activity even if the proceeding
involved claims that ultimately were found to be invalid.
Examples of participation include:
 Filing a charge of employment discrimination;
 Cooperating with an internal investigation of alleged discriminatory
practices; or
 Serving as a witness in an EEO investigation or litigation.
12. Newsome believes she was discriminated in employment on the basis of race, age,
retaliation, and her participation in protected activity(s). Said discrimination is in violation of Title
VII of the Civil Rights Act of 1964, 29 CFR 1601 (.7, .6), fair employment practices, and/or the
applicable statutes/laws governing said matters.
Page 23 of 196

36. II. PURPOSE OF TITLE VII:
13. Newsome believes an investigation into this instant Charge will support the facts,
evidence and legal conclusions set forth herein as well as that obtained through an investigation.
Federal case law generally applies to alleged violations of R.C. 4112. Columbus Civ. Serv. Comm. v.
McGlone (1998), 82 Ohio St.3d 569. Therefore, reliable, probative, and substantive evidence means
evidence sufficient to support a finding of unlawful retaliation under Title VII of the Civil Rights Act
of 1964. - OCRC Complaint No. 9496 (Glaser v. HLS Bonding matter)
14. This instant Charge has been filed seeking the EEOC’s/OCRC’s intervention/that
COMMISSIONER Charge ISSUE; moreover: (a) for the prohibition of employment
discrimination;
Czupih v. Card Pak Inc., 916 F.Supp. 687 (N.D.Ohio.E.Div.,1996) -
Purpose of Title VII is to prohibit employer discrimination. Civil
Rights Act of 1964, § 701 et seq., as amended, 42 U.S.C.A. § 2000e et
seq.
(b) deter and protect Newsome from prejudicial and systematic discriminatory treatment rendered
her while employed at GRG and/or MStaffing; (c) achieve employment equality by preventing
discrimination and to make Newsome whole due to the unlawful employment practices/unlawful
discriminatory practices – i.e. it would NOT be in Newsome’s best interest, safe, beneficial, nor
healthy to return her to the position she would have been entitled absent the unlawful discrimination;
and (d) achieve equality and remove the long-standing racial barriers that in the past have been
known to favor whites over African-Americans and/or people of color.
Johnson v. University Surgical Group Associates of Cincinnati, 871
F.Supp. 979 (S.D.Ohio. W.Div., 1994) - Purpose of Title VII is to
protect workers from certain kinds of prejudicial treatment on the job
and not to federalize common-law torts. Civil Rights Act of 1964, §
701 et seq., 42 U.S.C.A. § 2000e et seq.
Adler v. John Carroll University, 549 F.Supp. 652 (N.D.Ohio.E.Div.,
1982) - Twin statutory purposes of Title VII of Civil Rights Act of
1964 are to achieve employment equality by preventing discrimination
and to make persons whole for injuries suffered due to unlawful
employment discrimination; scope of relief is intended to restore victim
of unlawful employment practices to position he would have been in
were it not for unlawful discrimination. Civil Rights Act of 1964, § 701
et seq. as amended 42 U.S.C.A. § 2000e et seq.
Asad v. Continental Airlines, Inc., 328 F.Supp.2d 772
(N.D.Ohio.E.Div., 2004) -The purpose of Title VII, . . . is to achieve
equality of employment opportunities and remove barriers that have
operated in the past to favor an identifiable group of employees over
other employees. Civil Rights Act of 1964, § 701 et seq., 42 U.S.C.A. §
2000e et seq.
15. Ohio’s Anti-Discrimination law prohibits such conduct as that under Title VII and is
constructed identically as Title VII; wherein Title VII is designed to address, expose and rid the
world of such evil acts as discrimination because of a person’s race, age, etc. Therefore, this instant
Charge targets the discriminatory practices of GRG and/or MStaffing and will demonstrate hostility
Page 24 of 196

37. and/or abuse towards Newsome was itself discriminatory and how GRG and/or MStaffing attempted
to cover-up such discriminatory/criminal employment violations – i.e. by waiting until Newsome left
the offices of GRG for purposes of obtaining access to her property so that it can cover-up its
criminal and unlawful/illegal discriminatory practices. Then having MStaffing Justin Roehm’s
contact Newsome and advise her of TERMINATION. – See EXHIBIT “X” – Transcribed
“October 21, 2011 Voicemail Message From Messina Staffing’s Justin Roehm:”
Hey Denise, Um this is Justin Roehm with Um Messina Staffing. Um I know we
talked earlier today. Um yeah, Um I just wanted to let you know that Um Garretson
and. . .you know. . .they called me and they decided that Um. . . they decided that
today is going to be your last day and that Um they do not want to extend your
contract. So Um don't Um go in Monday morning. Um I will get your stuff and Um
you can come by sometime Monday afternoon and pick it up from our office. Um I'll
look over. . . send me your resume. . .I'll look over your resume and if there's
anything else that Um comes up that we can get you in for Um We'll do what we can.
I'll send you an email and everything. Um you know, if you want. . .Yeah, I mean,
we'll just talk Monday. Um I'll probably be out of the office this weekend. Um
Thanks. Bye.
attached hereto and incorporated by reference as if set forth in full herein.
Shoemaker-Stephen v. Montgomery County Bd. of Com'rs, 262
F.Supp.2d 866 (S.D.Ohio. W.Div., 2003) - Ohio anti-discrimination
law prohibits same conduct as Title VII, and is generally construed in
identical fashion to Title VII. Civil Rights Act of 1964, § 703(a)(1), as
amended, 42 U.S.C.A. § 2000e-2(a)(1); Ohio R.C. § 4112.02(A).
Eperesi v. Envirotest Systems Corp., 999 F.Supp. 1026
(N.D.Ohio.E.Div., 1998) - The state statute prohibiting discrimination
based on race is interpreted under the same standards applied to Title
VII. Civil Rights Act of 1964, § 701 et seq., 42 U.S.C.A. § 2000e et
seq.; Ohio R.C. § 4112.02(A).
Neff v. Civil Air Patrol, 916 F.Supp. 710 (S.D.Ohio.E.Div., 1996) -
Title VII is designed to rid the world of work of the evil of
discrimination because of individual's race, color, religion, sex, or
national origin. Civil Rights Act of 1964, § 701 et seq., 42 U.S.C.A. §
2000e et seq.
Walk v. Rubbermaid Inc., 913 F.Supp. 1023 (N.D.Ohio.E.Div., 1994) -
Purpose of Title VII is to create equality in workplace by targeting
discrimination based on race, color, religion, sex, or national origin,
and thus employee must demonstrate that employer's hostility or abuse
was itself discriminatory. Civil Rights Act of 1964, § 703(a)(1), as
amended, 42 U.S.C.A. § 2000e-2(a)(1).
16. Through this instant Charge, Newsome seeks the EEOC’s/OCRC’s
intervention/that COMMISSIONER Charge ISSUE and request that it report violations found to
the proper authorities and file the applicable lawsuit(s) of and against The Garretson Firm Resolution
Group Inc. and/or Messina Staffing/Messina Management Staffing seeking the applicable agency
and/or courts to impose the proper statutes/laws prohibiting such acts and governing injunctive relief
and/or applicable relief to correct the alleged unlawful employment practices addressed herein
because of Newsome’s race/age, engagement in protected activities, etc. and provide a remedy for
Page 25 of 196

38. said violators and continuing efforts of the systematic discriminatory practices made known herein
and past discrimination.
Watson v. Limbach Co., 333 F.Supp. 754 (S.D.Ohio.E.Div., 1971) -
Civil Rights Act of 1964 gives courts jurisdiction to correct alleged
unlawful employment practices because of race and color, and to
provide a remedy for present and continuing efforts of past
discrimination. Civil Rights Act of 1964, § 701 et seq., 42 U.S.C.A. §
2000e et seq.
See United States Department of Labor/EEOC’s - Prohibited Employment Policies/Practices at
EXHIBIT “LXXVI” attached hereto and incorporated by reference as if set forth in full herein.
III. PATTERN-OF-DISCRIMINATION:
17. The direct evidence contained in this instant Charge will support a conclusion that
challenged employment actions of The Garretson Firm Resolution Group Inc. and/or Messina
Staffing/Messina Management Staffing was motivated at least in part by prejudice and systematic
discrimination against Newsome who is a member of the protected group. Moreover, that said
prejudice and discrimination is based on GRG’s and/or MStaffing’s personal knowledge or
observation, that if true (when it is), reveals a fact without inference or presumption.
Kline v. Tennessee Valley Authority, 128 F.3d 337 (C.A.6., 1997) -
Direct evidence and circumstantial evidence paths for proving
employment discrimination are mutually exclusive, and employee need
only prove one or the other, not both; if employee can produce direct
evidence of discrimination McDonnell Douglas burden shifting
paradigm is of no consequence, and if employee attempts to prove its
case using that paradigm, employee is not required to introduce direct
evidence of discrimination.
Johnson v. Kroger Co., 319 F.3d 858 (C.A.6.Ohio, 2003) - Direct
evidence of discrimination does not require a factfinder in a Title VII
action to draw any inferences in order to conclude that the challenged
employment action was motivated at least in part by prejudice against
members of the protected group. Civil Rights Act of 1964, § 701 et
seq., 42 U.S.C.A. § 2000e et seq.
See EXHIBIT “XI” – “October 26, 2011 – Email From Messina Staffing/Justin Roehm
Requesting Newsome Destroy Documents Provided In Support of Email”
You need to delete all of this stuff you attached to this
email. It has some confidential info on Garretson that
they don’t want non-employees having access to. It
really needs to be deleted. I don’t want to see any legal
ramifications come from this. Also, we can throw away some of your
replaceable (plastic silverware, etc.) but that sweater of yours is fairly
nice. I would really appreciate it if you could take just a small amount of
time to pick it up.
Page 26 of 196

39. attached hereto and incorporated by reference as if set forth in full herein. As a matter of the
Statutes/Laws governing said matters, Newsome being an employee of BOTH Messina
Staffing/Messina Management Systems (“MStaffing”) and Garretson Resolution Group/The
Garretson Firm Resolution Group Inc. (“GRG”). The request by MStaffing’s Justin Roehm is
UNLAWFUL/ILLEGAL/CRIMINAL in that it seeks to “OBSTRUCT” the administration of justice,
“OBSTRUCT” Federal/State Investigation(s); and COVER-UP Criminal/Civil violations, etc.
Conducting a Thorough Investigation8
Because discrimination often is subtle, and there rarely is a “smoking gun,”
[Fn. 45 - See Aman v. Cort Furniture Rental Corp., 85 F.3d 1074, 1081-82 (3rd
Cir. 1996)(“It has become easier to coat various forms of discrimination with
the appearance of propriety, or to ascribe some other less odious intention to
what is in reality discriminatory behavior. In other words, while discriminatory
conduct persists, violators have learned not to leave the proverbial ‘smoking
gun’ behind.”); cf. McDonnell Douglas Corp. v. Green, 411 U.S. 792, 801
(1973). . .] determining whether race played a role in the decisionmaking
requires examination of all of the surrounding facts and circumstances. The
presence or absence of any one piece of evidence often will not be
determinative. Sources of information can include witness statements,
including consideration of their credibility; documents; direct observation; and
statistical evidence such as EEO-1 data, among others
18. GRG considered impermissible factors when it made the adverse employment
decision to terminate Newsome’s employment. While GRG advised Newsome that her employment
would be extended through December 2011, GRG knew and/or should have known that it was
providing Newsome with false information and that it had KNOWLEDGE and INTENT to
unlawfully/illegal BREACH employment contract with Newsome. In an effort to cover-up its
employment violations, GRG waited until Newsome left its offices to have her notified of termination
in that it wanted an opportunity to go through her PERSONAL possessions and remove any
EVIDENCE it KNEW and/or should have known would be INCRIMINATING against GRG.
(EMPHASIS ADDED) Such acts which were done with malicious intent to cover-up and obstruct
the administration of justice should Newsome file charges with the proper authorities. In May, 2011,
GRG’s advised Newsome of contract being extended through December 2011 [See EXHIBIT “XII”
– “May 11, 2011 Email Regarding Contract Extension Through December 2011” attached hereto
and incorporated by reference as if set forth in full herein. GRG again confirming again with a
Representative of Messina Staffing/Messina Management Staffing (Justin Roehm) that contract was
being extended through December 2011 on or about October 21, 2011, will also prove to be
PREMEDITATED and acts done with WILLFUL, MALICIOUS, CRIMINAL and WANTON intent.
(EMPHASIS ADDED). See EXHIBIT “XIII” – “October 21, 2011 to Messina Staffing/Justin
Roehm and Garretson Resolution Group/Sandy Sullivan” attached hereto and incorporated by
reference as if set forth in full herein.
Wexler v. White's Fine Furniture, Inc., 317 F.3d 564 (C.A.6.Ohio,
2003) - Under mixed-motive analysis for reviewing employment
discrimination claim, the plaintiff must produce direct evidence that the
employer considered impermissible factors when it made the adverse
employment decision at issue; once the plaintiff has shown that the
unfavorable employment decision was made at least in part on a
discriminatory basis, the burden shifts to the employer to prove by a
preponderance of the evidence that it would have taken the same
8
Taken from EEOC’s Compliance Manual Section 15: Race and Color Discrimination
Page 27 of 196

40. adverse action even if impermissible factors had not entered into its
decision.
See EXHIBIT “X” – “October 21, 2011 Voicemail Message From Messina Staffing’s Justin
Roehm” attached hereto and incorporated by reference as if set forth in full herein.
19. The laws are clear that GRG and/or MStaffing cannot discriminate against Newsome
because she has engaged in protected activities and/or their knowledge of her intent to engage in
protected activities – therefore, terminating employment to interfere with protected rights.
GRG/MStaffing discriminated against Newsome based on its knowledge of her engagement in
protected activities. Moreover, GRG and/or MStaffing terminated Newsome’s employment for what
appears to be Causal Connection/Nexus with participation in protected activities, discriminatory
practices based on race and a pattern-of-discriminatory practices/systematic discriminatory practices
based on:
The United States Constitution as well as laws passed by the
United States Congress will further support the need for the
passing of House Report No. 92-238. Congress demonstrated
its awareness that claimants might not be able to take
advantage of the federal remedy without appointment of
counsel. As explained in House Report No. 92-238:
By including this provision in the bill, the
committee emphasizes that the nature of . .
.actions more often than not pits parties of
unequal strength and resources against each
other. The complainant, who is usually a
member of the disadvantaged class, is
opposed by an employer who . . . has at his
disposal a vast of resources and legal
talent.
H.R. Rep. No. 238, 92nd Cong., 2d Sess., reprinted in 1972
U.S.C.C.A.N. 2137, 2148.
a) Knowledge of Newsome’s filing of past EEOC Charges and/or civil
lawsuits brought by Newsome against other employers. Said knowledge
motivated GRG to abruptly and unlawfully/illegally ABRUPTLY
terminate Newsome’s employment and to go through her PERSONAL
possessions for purposes of removing INCRIMINATING evidence
(EMPHASIS ADDED).
b) Investigation(s) will establish a Causal Connection between Messina
Staffing/Messina Management Systems Jim Messina (i.e. the 2012
Campaign Manager for United States of America President Barack
Hussein Obama II). See EXHIBIT “XIV” – “September 14, 2011
United States of America President Barack Obama’s Attack Website
Article” information attached hereto and incorporated by reference as if
set forth in full herein.
c) GRG’s KNOWLEDGE of Newsome’s engagement in protected
activities is further evidenced in the FRIVOLOUS/MALICIOUS lawsuit
brought against Vogel Denise Newsome on or about February 3, 2012
in the Hamilton County Court (Ohio) of Common Pleas; Civil Action
Page 28 of 196

41. No. A1200831. See EXHIBIT “VI” – Docket Sheet The Garretson
Firm Resolution Group Inc. vs. Vogel Denise Newsome, Hamilton
County (Ohio) Court of Common Pleas, Civil Action No. A1200831
attached hereto and incorporated by reference as if set forth in full
herein.
GRG filing lawsuit AGAINST Newsome approximately ONE
month AFTER Newsome’s January 10, 2012 filing entitled,
“NOTIFICATION FOR TERMINATION - REQUEST FOR
IMPEACHMENT OF PRESIDENT BARACK HUSSEIN OBAMA
II – RESPONSE TO THE ATTACKS ON FLORIDA A&M
UNIVERSITY REGARDING ALLEGED HAZING INCIDENT –
REQUEST FOR INTERNATIONAL MILITARY INTERVENTION
MAY BE NECESSARY.” See EXHIBIT “XV” – attached hereto and
incorporated by reference as if set forth in full herein. Record evidence
will support that on or about January 27, 2012 and February 1, 2012,
Newsome released Email regarding, “UPDATE - - NOTIFICATION
FOR TERMINATION - REQUEST FOR IMPEACHMENT OF
PRESIDENT BARACK HUSSEIN OBAMA II – RESPONSE TO THE
ATTACKS ON FLORIDA A&M UNIVERSITY REGARDING
ALLEGED HAZING INCIDENT – REQUEST FOR
INTERNATIONAL MILITARY INTERVENTION MAY BE
NECESSARY” See EXHIBIT “XVI” - attached hereto and
incorporated by reference as if set forth in full herein.
GRG filing lawsuit AGAINST Newsome coming approximately
ONE week PRIOR to the February 10, 2012, DEADLINE in which
Newsome requested United States of America President Barack Obama
that his employment was being TERMINATED – i.e. President Barack
Obama was FIRED. See EXHIBIT “XVII” – PINK SLIP served on
United States of America President Barack Obama attached hereto and
incorporated by reference as if set forth in full herein. “United States
Postal Service PROOF OF MAILING Receipts” – EXHIBIT “XVIII”
– GREEN CARD and USPS Receipts attached hereto and incorporated
by reference as if set forth in full herein.
IMPORTANT TO NOTE: AFTER
Newsome’s advising the PUBLIC-AT-LARGE via
email of CRIMINAL Practices (i.e. Mail Tampering,
etc.) by United States Of America President Barack
Obama, it appears that the Certified Mail GREEN
Card had been destroyed; however, upon Newsome’s
going PUBLIC, President Barack Obama had the
Certified Mail Green Card TAPED back together
and returned to Newsome. Had Newsome not gone
PUBLIC in EXPOSING the White House’s/President
Page 29 of 196

42. Barack Obama’s CRIMINAL conduct, she would not
have received the GREEN Card back.
See United States Department of Labor/EEOC’s - Prohibited Employment Policies/Practices at
EXHIBIT “LXXVI” attached hereto and incorporated by reference as if set forth in full herein.
d) Investigation(s) will yield and reveal GRG’s KNOWLEDGE of
Newsome’s legal actions sought against United States of America
President Barack Hussein Obama II and the Obama Administration’s
attempt to use it as a “FRONTING” Firm to file a Lawsuit AGAINST
Newsome in efforts of obstructing Newsome’s DUTY to inform the
PUBLIC on matters of PUBLIC Policy and/or matters of PUBLIC
Furthermore, Newsome's unlawful/illegal termination affected a DUTY
that inures to the BENEFIT of the PUBLIC-AT-LARGE and was done
in RETALIATION for Newsome performing an IMPORTANT and
SOCIALLY desirable act, exercising a statutory right, and refusing to
engage and/or be a part of GRG's criminal/discriminatory practices.
e) GRG’s KNOWLEDGE of Newsome’s and the PUBLIC’s interest in the
TRUTH behind the September 11, 2001 World Trade Center Attacks
(“911 Attacks”) and the posting of such concerns on Newsome’s website
at www.vogeldenisenewsome.com. See EXHIBIT “V” attached hereto
and incorporated by reference. Newsome going PUBLIC with her
website about MAY 2011.
f) MATTER OF PUBLIC POLICY - INSIDER JOB: United States of
America’s Government Attempts in COVER-UP of Role in the 911
Attacks and Payouts To Victims - - Investigation(s) will yield and reveal
GRG being retained to handle the PAYOUTS to victims – i.e. such as
those as the 911 Responder Victims:
Q. and A.: The 9/11 Adjuster
In recent weeks, rescue and cleanup workers who sued the city
over health damages they attribute to environmental hazards at
the former World Trade Center site have been receiving letters
explaining how much compensation they would receive under
a recent settlement of their claims.
The Garretson Firm Resolution Group, with offices in
Cincinnati and Charlotte, N.C., is administering the claims,
which involve more than 10,000 plaintiffs. (Ninety-five
percent of the plaintiffs must approve the settlement by Sept. 8
for it to take effect.) We talked with Matt Garretson, the
company’s president and chief executive, about the ins and
outs of 9/11 claims administration and calculating the
individual settlement amounts. Following are our questions
and his responses, edited for clarity and brevity. . .
Q. Who pays your firm in this case?
A. We’re being paid by the W.T.C. Captive Insurance
Company (the city’s insurer). They agreed to pay up to $3.5
million of our expenses.
Page 30 of 196

43. See EXHIBIT “XIX” – “Q. and A.: The 9/11 Adjuster” attached
hereto and incorporated by reference as if set forth in full herein.
. . .The WTC Captive was created with a $1 billion grant
from the Federal Emergency Management Agency to
insure the City of New York and its debris removal
contractors because in the aftermath of 9/11 the City of New
York was unable to procure an adequate amount of liability
insurance coverage in the commercial insurance market for the
World Trade Center site rescue, recovery and debris removal
work.
The settlement will cost the taxpayer-funded WTC Captive
$625 million in cash at the required 95% plaintiff
participation, with an additional $87.5 million paid if certain
conditions are met. Plaintiffs' attorneys are capping their fees
at 25% of the settlement amount, resulting in savings to
plaintiffs of over $50 million. Those savings, together with the
additional funding of up to $50 to $55 million by the WTC
Captive, the waiver of the workers' compensation liens and
credits, and the assumption by the WTC Captive of additional
costs of allocating the settlement proceeds among the
plaintiffs, increase the value of this amended settlement to
plaintiffs by approximately $125 million as compared to the
settlement first announced in March, making the total value of
the settlement $712.5 million. . . .
The WTC Captive was funded with just under $1 billion in
federal funds provided through a grant from the Federal
Emergency Management Agency (FEMA)—part of the $20
billion of such funds requested by the Administration and
authorized by Congress to help New York City and its
people recover and rebuild after 9/11. . .
See EXHIBIT “XX” – “Press Release - WTC Plaintiffs to Receive
Approximately $125 Million in Addition” attached hereto and
incorporated by reference as if set forth in full herein.
. . .As you may know, each claim must be reviewed and
approved by Matt Garretson, who is the Court-appointed
"Allocation Neutral" and his team. Not surprisingly, Mr.
Garretson's office has been inundated with hundreds of
thousands of documents that must be reviewed as part of this
process. You may already be aware that payment authority is
being issued by the Garretson office in “waves” of several
thousand plaintiffs at a time. . . .
See EXHIBIT “XXI” – “Initial Payment Update” attached hereto and
incorporated by reference as if set forth in full herein.
Bernard “Bernie” Madoff [“Ponzi Scam”] matter. It appears that
Garretson Resolution Group/The Garretson Firm Resolution Group Inc.
may have also been retained to handle PAYOUTS in this matter. See
EXHIBIT “XXII” – “Bernard Madoff Ponzi Scheme” attached hereto
and incorporated by reference as if set forth in full herein.
Page 31 of 196

44. g) GRG’s/MStaffing’s relationship and the Causal Connection/Nexus
between these Respondents and United States of America President
Barack Obama is ESTABLISHED in the “February 18, 2012
Chronological Chart of Events” at EXHIBIT “XXIII” attached hereto
and incorporated by reference as if set forth in full herein; wherein the
COMMON Denominator appears to be President Barack Obama’s Legal
Counsel/Advisor Baker Donelson Bearman Caldwell & Berkowitz and
can be “LINKED” to such ATTACKS on Newsome - Pertinent
FACTS/EVIDENCE To Understand:
i. Baker Donelson is OPPOSING Counsel in the Lawsuit
Newsome vs. Entergy – See EXHIBIT “XXIV” –
Docket Sheet attached hereto and incorporated by
reference as if set forth in full herein.
CONFLICT-OF-INTEREST existed in this Lawsuit
which neither Baker Donelson NOR the Court advised
Newsome that the Judges/Justices assigned matters were
those PURCHASED/OWNED by Baker Donelson and
appear on Baker Donelson’s Listing of Judges – i.e. for
instance Judges Morey Sear and G. Thomas Porteous
assigned this lawsuit appear on Baker Donelson’s “List
of Judges.” See EXHIBIT “XXV” attached hereto and
incorporated by reference as if set forth in full herein.
As recent as December 2010, Judge G. Thomas Porteous
was IMPEACHED and removed from the Federal
Bench for taking BRIBES/KICKBACKS, etc. to
“THROW LAWSUITS.” See EXHIBIT “XXVI”
attached
ii. Baker Donelson CONTROLS/RUNS the Courts –
placing its employees, such as James C. Duff in position
of DIRECTOR of the Administrative Office of the
United States Courts. See EXHIBIT “XXVII” – James
C. Duff Info attached hereto and incorporated by
reference as if set forth in full herein.
Baker Donelson seeing to it that it appears on JUDICIAL
Nomination Panels responsible for nominating
Judges/Justices to be appointed to the Judicial Bench.
See EXHIBIT “XXVIII” attached hereto and
incorporated by reference as if set forth in full herein.
iii. Baker Donelson is Legal Counsel/Advisor to J.P. Morgan
Chase Bank – i.e. whose Client is Ponzi Scheme/Scam
Guru Bernard “Bernie” Madoff.
iv. Baker Donelson is Legal Counsel/Advisor to United
States of America President Barack Obama – See
EXHIBIT “XXIX” – “LANCE B. LEGGITT” attached
hereto and incorporated by reference as if set forth in full
herein.
Page 32 of 196