This is a CLASSIC EXAMPLE of an Employee’s ENGAGEMENT in CRIMINAL/CIVIL wrongs

with Baker Donelson Bearman Caldwell & Berkowitz (Legal Counsel for President Barack Obama, Congress, Supreme Court, etc.) such as RACE DISCRIMINATION, LYING DURING

FEDERAL INVESTIGATIONS, etc. Then when they are SUED in their INDIVIDUAL CAPACITIES as Ladye Margaret Townsend, they want to go and file BANKRUPTCY in

attempts to get out of PAYING for their CRIMINAL/CIVIL VIOLATIONS!

Now if Vogel Denise Newsome is NOT ALLOWING the FIRST ALLEGED Black-American

President Barack Obama’s CRIMINAL/CIVIL wrongs not to be EXPOSED, WHY would Ladye Margaret Townsend and her attorney Robert Rex McRaney Jr. think that Newsome

would SPARE them the EXPOSURE they RIGHTFULLY DESERVE!

I N T H E U N I T E D S T A T E S B A T ^ ^ ^ C ^ T C Y C O U R T

S O U T H E R N D I S T R I C T O F ' M I S S I S S I P P I

i U U L |t4 AH 9 : 5 C

IN R E : j - ^ , , , , ,

L A D Y E M . T O W N S E N D < ~ C H A P T E R 7 DEBTOR B Y D E P U W C A S E N O . 11-00167-ee

C R E D I T O R ' S ( V O G E L N E W S O M E ) M O T I O N F O R R E L I E F F R O M O R D E R / J U D G E M E N T ; M O T I O N F O R R U L E 11 S A N C T I O N S O F A N D A G A I N S T R O B E R T R E X M C R A N E Y

J R . / M C R A N E Y & M C R A N E Y ; AND R E Q U E S T T O B E A D V I S E D O F C O N F L I C T - O F I N T E R E S T S ^

COMES N O W Creditor Vogel Newsome ("Newsome") without waiving her rights, without

submitting to the jurisdiction o f this Court, without waiving the defenses and claims set forth in her:

(a) "Creditor's Opposition/Response to Notice of Chapter 7 Bankruptcy Case, Meeting of Creditors, & Deadlines and Motion to be Dismissed, from Action " - Docket 10 - and

(b) "Creditor Vogel Newsome's Opposition/Response to 5/11/11 Discharge of Debtor; Request for Findings of Fact and Conclusions of Law; and Vacating of Discharge of Debtor" -Docket 20 -

and files this her "Creditor's (Vogel Newsome) Motion for Relief From. Order/Judgment; Motion for Rule

11 Sanctions of and Against Robert Rex McRaney Jr./McRaney & McRaney; and Request To Be Advised

Of Conflict-Of Interests" ("CMFRFO/J") pursuant to Rule 60 o f the Federal Rules o f Civ i l Procedure

("FRCP"), FRCP Rule 11; FRCP Rule 12(G) - consohdation o f matters - and odier statutes/laws

governing said matters. In support thereof, Newsome states the following:

L L A C K O F J U R I S D I C T I O N :

There is authority that dismissal o f a bankruptcy case does not mandate dismissal o f all pending adversary proceedings. However, i f an entity joined as a party in an adversary proceeding raised the defense that the court lacks jurisdiction over the subject matter and that defense is sustained, the court

' NOTE: Boldface, italics and underline, etc. represents "emphasis" added.

Page I of 2 ^

Page 1 of 28

IN THE UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF MISSISSIPPI

IN RE:

LADYE M. TOWNSEND CHAPTER 7 DEBTOR CASE NO. 11-00167-ee

CREDITOR’S (VOGEL NEWSOME) MOTION FOR RELIEF FROM ORDER/JUDGEMENT;

MOTION FOR RULE 11 SANCTIONS OF AND AGAINST ROBERT REX MCRANEY

JR./MCRANEY & MCRANEY; AND REQUEST TO BE ADVISED OF CONFLICT-OF

INTERESTS1

COMES NOW Creditor Vogel Newsome (“Newsome”) without waiving her rights, without

submitting to the jurisdiction of this Court, without waiving the defenses and claims set forth in her:

(a) “Creditor’s Opposition/Response to Notice of Chapter 7

Bankruptcy Case, Meeting of Creditors, & Deadlines and

Motion to be Dismissed from Action” – Docket 10 – and

(b) “Creditor Vogel Newsome’s Opposition/Response to 5/11/11

Discharge of Debtor; Request for Findings of Fact and

Conclusions of Law; and Vacating of Discharge of Debtor” –

Docket 20 -

and files this her “Creditor’s (Vogel Newsome) Motion for Relief From Order/Judgment; Motion for Rule

11 Sanctions of and Against Robert Rex McRaney Jr./McRaney & McRaney; and Request To Be Advised

Of Conflict-Of Interests” (“CMFRFO/J”) pursuant to Rule 60 of the Federal Rules of Civil Procedure

(“FRCP”), FRCP Rule 11; FRCP Rule 12(G) – consolidation of matters – and other statutes/laws

governing said matters. In support thereof, Newsome states the following:

I. LACK OF JURISDICTION:

There is authority that dismissal of a bankruptcy case does not

mandate dismissal of all pending adversary proceedings.

However, if an entity joined as a party in an adversary

proceeding raised the defense that the court lacks jurisdiction

over the subject matter and that defense is sustained, the court

1 NOTE: Boldface, italics and underline, etc. represents “emphasis” added.

Page 2 of 28

must dismiss such entity from the adversary proceeding.

Fed.R.Bankr.P. 7019(1).

Mississippi Case: Rice v. McMullen, 43 So.2d 195 (Miss. 1949)

- A court must have jurisdiction of the subject matter and of the

person of the parties, to give validity to its final judgments,

orders and decrees, and legislature cannot under the Constitution

dispense with notice, actual or constructive.

Illinois Cent. R. Co. v. Mississippi Public Service Commission,

135 F.Supp. 304 (S.D.Miss.Jackson.Div.,1955) - “Judicial

power” is the legal right, ability and authority to hear and decide

a justifiable issue or controversy, and such power is ordinarily

vested in a court of justice.

U.S. Supreme Court Case: U.S. v. O'Grady, 89 U.S. 641(1874)

- “Jurisdiction” is the power to hear and determine a cause.

In re N.L.R.B., 58 S.Ct. 1001 (1938) - “Jurisdiction” means, in

one sense, the power to hear and determine the controversy

presented, but a court has “jurisdiction,” in another sense, to

determine whether such power is conferred upon it in the

circumstances disclosed, and if it finds such power is not

granted, it lacks “jurisdiction” of the subject matter and must

refrain from an adjudication of rights in connection therewith.

Other Court Cases: In re Jahelka, 2010 WL 5558990 (Bankr.,

2010) - Subject matter jurisdiction is threshold question in every

case.

In re AE Liquidation, Inc., 435 B.R. 894 (2010) - A motion to

dismiss for lack of subject matter jurisdiction challenges the

power of the federal court to hear a claim or case. Fed.Rules

Civ.Proc.Rule 12(b)(1), 28 U.S.C.A.

Issue of court's subject matter jurisdiction can be raised

in any manner, including on motion of one of the parties or by

the court sua sponte. Fed.Rules Civ.Proc.Rule 12(b)(1), 28

U.S.C.A.

1. Newsome DOES NOT waive her defense to the jurisdictional issue which arises

in this matter. Therefore, Newsome does not submit to the jurisdiction of this

Court. While the laws are clear that Newsome cannot waive jurisdictional rights,

she believes it is necessary to provide information regarding decisions of court(s)

on said issue(s):

In re Kirkland, 600 F.3d 310 (4th

Cir. 2010) - Subject matter

jurisdiction cannot be forfeited or waived, and can be raised by

party, or by court sua sponte, at any time prior to final judgment.

2. This instant “CMFRFO/J” is submitted in good faith and has not been submitted

for purposes of delay, harassment, hindering proceedings, embarrassment,

obstructing the administration of justice, vexatious litigation, increasing the cost

Page 3 of 28

of litigation, etc. and is filed to protect and preserve the rights of Newsome

secured/guaranteed under the United States Constitution and other laws of

the United States.

3. For the purposes of expedition, saving of time and minimize costs associated

with litigation, Newsome consolidate her motions/pleadings herein pursuant to

FRCP Rule 12(G) which states:

FRCP Rule 12(g) Joining Motions.

Right to Join. A motion under this rule may be joined

with any other motion allowed by this rule.

4. Townsend’s Title 11 – Chapter 7 Bankruptcy – proceeding is merely acts in

FURTHERANCE of PATTERN-OF-ABUSE (i.e. for instance, under

CRIMINAL LAWS may be known as “Engaging in a PATTERN of CORRUPT

ACTIVITY”, etc.) to engage in criminal/civil wrongs and efforts to engage/solicit

this Court to cover up such legal injustices. Now it appears from this Court’s

June 27, 2014 Order relying upon a PROPOSED Order provided by Counsel for

Debtor Townsend (Robert Rex McRaney, Jr.) that a Motion to Dismiss –which

has NOT been served on Newsome – was filed with this Court. Service of

process providing Newsome with a copy of the Debtor Townsend’s Motion to

Dismiss has NOT been completed.

In re Spencer, 137 B.R. 506 (1992) - All courts possess inherent

power to protect their jurisdiction and process from abuse. In re

Higginbotham, 111 B.R. 955 (1990).

5. Newsome’s December 3, 2010, filing of the lawsuit – United States District

Court; Southern District of Mississippi (Jackson Division); Civil Action 3:10-cv-

704 - protected her rights and secured District Court with jurisdiction and any

such actions as that brought by Townsend on or about January 18, 2011.

Newsome’s December 3, 2010, lawsuit filed in this action secured District Court

with jurisdiction to hear any such bankruptcy Townsend may attempt to assert in

that Chapter 7 Bankruptcy filing arises out of the relief Newsome seeks through

this instant lawsuit. Therefore, it appears that Townsend has “HIT-A-BRICK-

WALL” in her efforts to try and run and hide from the liability Newsome seeks of

and against her for the legal wrongs addressed in Complaint. As a matter of

law, Newsome is to be dismissed from Townsend’s Bankruptcy action or matter

involving Newsome transferred the United States District Court for purposes of

keeping legal matters combined.

Matter of Wood, 825 F.2d 90 (5th Cir. Miss. 1987) - If

proceeding involves right created by federal bankruptcy law, or

is one which would only arise in bankruptcy, it is core

proceeding, but if proceeding does not invoke substantive right

created by federal bankruptcy law and is one that could exist

outside of bankruptcy, it is noncore proceeding, though it may be

related to bankruptcy because of its potential effect on debtor's

estate. 28 U.S.C.A. § 157.

In re OCA, Inc., 551 F.3d 359 (5th

Cir. 2008) - Bankruptcy

court's adjudicative authority is constrained if the adversary

proceeding is non-core.

Page 4 of 28

6. As a matter of law, the United States District Court – Southern District of

Mississippi (Jackson Division) on December 3, 2010, FIRST retained

jurisdiction over this matter.

Jurisdiction is the power to decide; it must be conferred,

not assumed. Matter of Chicago, Rock Island and Pacific R.

Co., 794 F.2d 1182 (7th

Cir. 1986). All bankruptcy jurisdiction is

given in the first instance to the United States district courts.

Acolyte Elec. Corp. v. City of New York, 69 B.R. 155 (Bankr.

E.D. N.Y. 1986), ordered aff’d, 1987 1987 WL 47763 (E.D.

N.Y. 1987); In re Double TRL, Inc., 65 B.R. 993 (Bankr. E.D.

N.Y. 1986).

The district courts are granted jurisdiction over

bankruptcy cases, that is cases under the Bankruptcy Code and

over three categories of bankruptcy proceedings: (1) civil

proceedings arising under Title 11; (2) civil proceedings arising

in a case under Title 11; and (3) civil proceedings related to

cases under Title 11. 28 U.S.C. § 1334(b). As used in this

statute, the phrase “arising under Title 11” is meant, not to

distinguish between different matters, but to identify collectively

a broad range of matters subject to the bankruptcy jurisdiction of

federal courts. Matter of Wood, 825 F.2d 90 (5th

Cir. 1987).

On or about December 16, 2010, Newsome served Debtor (Ladye M. Townsend

[“Townsend”]) with the required: (a) “Notice of Lawsuit and Request to Waive

Service of Summons;” and (b) “Waiver of the Service of Summons” which was

accompanied by Notification Accompanying Waiver of Service of Summons.

According to United States Postal Service information, Townsend received these

documents on or about December 27, 2010.

7. PLEASE BE ADVISED: There are FOREIGN/INTERNATIONAL Interest in

the Legal proceedings involving Vogel Newsome because it EXPOSES the

CORRUPTION in the United States of America’s JUDICIAL System and

SUPPORTS the RACIST/DISCRIMINATORY handling of lawsuits and

SPECIAL FAVORS given to Terrorist/White Supremacist Regimes as the Law

Firm of Baker Donelson Bearman Caldwell & Berkowitz. You see

Foreign/International Nations have LAWYERS/ATTORNEYS as well and they

can see for themselves THE LEGAL ARGUMENTS and EVIDENCE that

Newsome is presenting in Legal matters involving her and HOW the JUDICIAL

SYSTEM is TAINTED and DETERMINED to COVER-UP Criminal/Civil

wrongs made known to it – i.e. for instance look at the interest the one of Judge

Tom S. Lee’s (United States District Court – Southern District of Mississippi

(Jackson))

Page 5 of 28

NOTE: Information taken from Newsome’s SLIDESHARE Social Forum -

www.SlideShare.net/VogelDenise

8. PLEASE BE ADVISED: Under the statutes/laws governing said matters that the

Southern District Court of Mississippi (Jackson) action (Civil Action 3:10-cv-

704) is STILL very VIABLE and ACTIVE regardless of the APPEARANCE said

Court may want the Public/World to think in displaying it as being

CLOSED/DISMISSED – i.e. it is NOT.

In fact, during the MAY 14, 2014 hearing held by this Court before Judge

Edward Ellington, this REPEATEDLY seem to be an issue that was

CLEARIFIED by Newsome that “DUE TO THE CONFLICT OF INTEREST”

present, any/all RULINGS by the District Court in that Lawsuit is NULL/VOID

and Newsome is in the process of having it addressed and seeing that the proper

actions –i.e. PROSECUTIONS, IMPEACHMENTS, etc. are initiated.

During said May 14, 2014 hearing, this Court attempted to convince/persuade

Newsome that the Southern District Court of Mississippi (Jackson) action (Civil

Action 3:10-cv-704) was a CLOSED/DISMISSED/RESOLVED matter.

However, Newsome NOTIFIED the Court of the statutes/laws governing said

matters which PRECLUDES the acts of Judge Louis Guirola in that lawsuit.

Page 6 of 28

FACTS and EVIDENCE of the CONFLICT-OF-INTERESTS that precludes

Judge Guirola from acting and NEITHER is Newsome required to ENGAGE in

the CRIMINAL Acts of said Court/Judge in which the PROPER pleading(s) have

been submitted and will be UPDATED to support the INVESTIGATION(S)

requested. It is PLEASANT to state that said issues are

PROPERLY/ADEQUATELY and TIMELY PRESERVED. Thus, allowing

Newsome to CONTINUE in her QUESTS to EXPOSE what former United

States of America’s President John Fitzgerald Kennedy announced:

“There’s a PLOT in this country to ENSLAVE

every man, woman and child. BEFORE I leave

this HIGH and NOBLE office, I INTEND to

EXPOSE the PLOT!”

Then approximately seven (7) days later, President Kennedy is assassinated to

SILENCE him!

President Kennedy was nice in using the term “PLOT;” however, Newsome is

going to call it what it is “CONSPIRACY(S)!” So let us move on!

Page 7 of 28

9. Newsome believes given the facts, evidence and legal conclusions not only in

this Bankruptcy matter, but that in the United States District Court, that

Townsend’s Title 7 Bankruptcy proceeding naming Newsome under “Creditors

Holding Unsecured Nonpriority Claims” has been submitted: in bad faith, for

purposes of harassment, for delay, for vexatious litigation, for purposes of

increasing the costs of litigation, for embarrassment, for false and frivolous

reasons in attempts to provide her with a defense to Newsome’s Civil lawsuit

filed in the United States District Court – Southern District of Mississippi

(Jackson Division) [“USDC-MS proceeding”]on or about December 3, 2010;

and other willful, malicious and wanton reasons known to Townsend for the

filing of this Chapter 7 Bankruptcy proceeding. Therefore, supporting the

dismissal of Newsome from Townsend’s Chapter 7 Bankruptcy proceeding:

A district court may transfer a bankruptcy case or

proceeding to a district court . . .in the interest of justice or for

the convenience of the parties. 28 § 1412. In contrast with the

general venue transfer statutes, this provision allows transfer to

any district, not only to districts in which venue would have been

proper had the case been brought in that district.

In determining whether to transfer a bankruptcy case, the

court should consider the following factors: (1) the proximity of

creditors to the court; (2) the proximity of the debtor to the court;

(3) the proximity of the witnesses necessary to the administration

of the estate; (4) the location of the assets; (5) economic

administration of the estate; (6) the necessity of ancillary

administration if liquidation should result. See In re

Commonwealth Oil Refining Co., 596 F.2d 1239, 1247 (5th Cir.

1979), cert. denied, 444 U.S. 1045 (1980) (construing former 28

U.S.C. § 1475, substantially similar to present § 1412O.

Newsome does not believe that based upon the willful, malicious and wanton

acts of Townsend and the filing of this FRIVOLOUS Chapter 7 Bankruptcy

proceeding as a defense to Newsome’s “USDC-MS proceeding,” that a transfer

of this case is warranted or even qualifies for transfer. Therefore, in the

interest of justice and expedition of this case, Newsome timely, properly and

adequately requested to be dismissed as a “Creditor” from Townsend’s Chapter 7

Bankruptcy action in that this Court lacks jurisdiction over Newsome to proceed;

furthermore, that this Court(if it insist on entertaining Townsend’s Bankruptcy

action), in the interest of justice and convenience of parties transfer matter

regarding Newsome to the United States District Court – Southern District of

Mississippi (Jackson Division) for consolidation of cases and convenience to

parties. Townsend’s filing of the Chapter 7 Bankruptcy action clearly supports

that she would not be prejudiced by the transfer of this matter in that it will

remain in SAME venue; however, JURISDICTION of the United States District

Court – i.e. NOT Bankruptcy Court.

Time, Inc. v. Manning, 366 F.2d 690 (5th

Cir. 1966) - Both

jurisdiction and venue are designed to test fairness to defendant

and degree of inconvenience caused him by requiring him to

litigate in a particular court, but jurisdiction is relatively more

concerned with fairness and venue more with inconvenience.

Page 8 of 28

10. It appears that Townsend and her counsel are attempting to get this Court to

usurp jurisdiction over this matter, the laws clearly prohibits such practices.

Brown v. Pyle, 310 F.2d 95 (5th Cir. Miss. 1962) - “Jurisdiction”

is the power to hear and determine a cause-the power to

adjudicate; it is not to be confused with venue.

11. While Newsome does not claim to have knowledge of Chapter 7 Bankruptcy

laws, it is clear that Townsend did not bring this instant Chapter 7 Bankruptcy

proceeding as an “ENTITY,” “BUSINESS” for “ESTATE ADMINISTRATOR.”

Therefore, Newsome believes the laws support her concerns as to the motives for

the Chapter 7 Bankruptcy filing and this Bankruptcy Court’s jurisdiction over

this matter.

12. Newsome further believes that Townsend’s Chapter 7 Bankruptcy proceeding

filed with this Court in her INDIVIDUAL capacity was filed as a DEFENSE to

Newsome’s “USDC-MS proceeding” and therefore, may be precluded by law

given the facts, evidence and laws governing said matters.

In re SemCrude, L.P., 428 B.R. 82 (2010) - As general rule,

subject matter jurisdiction of court is based on state of facts that

existed at time cause of action was filed.

13. Newsome further believes that a “FEDERAL” court judgment on her “USDC-

MS proceeding” may preclude Townsend from bringing Chapter 7 Bankruptcy

proceeding naming Newsome in efforts to avoid the liability owed for damages

Newsome sustained and is addressed in the “USDC-MS proceeding.” Under the

statutes/laws governing issues regarding CONFLICT OF INTERESTS,

Newsome’s Lawsuit in Southern District Court of Mississippi (Jackson) action

(Civil Action 3:10-cv-704) is still LEGALLY/LAWFULLY active despite the

CRIMINAL acts of said court to make it appear that the case is closed (when it is

NOT)!

14. Newsome is NOT a business entity, but a private citizen (individual) of the

United States and is seeking relief of and against Townsend and others in the

“USDC-MS proceeding.”

II. MOTION FOR RELIEF FROM JUNE 27, 2014 CHAPTER 7 BANKRUPTCY ORDER

Vogel Newsome (“Newsome) further moves this Court for “Relief From the June 27, 2014

Order” pursuant to Rule 60 of the Federal Rules of Civil Procedure (“FRCP”) entered in that Counsel for

Debtor – Robert Rex McRaney, Jr./McRaney & McRaney – obtained said ruling as a direct and

proximate result of engaging in “FRAUD UPON THE COURT!” Moreover, that said Order is to be

VACATED in that it was INDUCED and/or PROCURED through FRAUDULENT and CRIMINAL Acts.

Not only that, this Court executed a PROPOSED Order to support a Motion to Dismiss that WAS

NEVER served on Newsome. A PROPOSED Order it appears was produced by Opposing Counsel

Page 9 of 28

Robert Rex McRaney, Jr. via ELECTRONIC Filing; however, the Motion to Dismiss to which said

proposed Order supports was NEVER served on Creditor Newsome. Moreover, to date (July 14, 2014) -

at the time of this filing – Creditor Newsome has NOT been served with the Motion to Dismiss and thus,

having NO KNOWLEDGE prior to the June 27, 2014 PROPOSED Order executed by this Court that a

Motion to Dismiss by Debtor Townsend had been filed. Debtor Townsend’s Counsel Robert Rex

McRaney, Jr./McRaney & McRaney having KNOWLEDGE and UPDATED information regarding

Newsome’s CURRENT/PRESENT mailing address; nevertheless, made a WILLFUL, CONSCIENCE

and MALICIOUS decision to WITHHOLD service of Motion to Dismiss on Creditor Newsome having

KNOWLEDGE it would be CONTESTED if it was served on Newsome.

Page 10 of 28

Rule 60. Relief from a Judgment or Order

(b) GROUNDS FOR RELIEF FROM A FINAL JUDGMENT, ORDER, OR

PROCEEDING. On motion and just terms, the court may relieve a party or its

legal representative from a final judgment, order, or proceeding for the following

reasons:

(1) mistake, inadvertence, surprise, or excusable neglect; . . .

(3) fraud (whether previously called intrinsic or extrinsic),

misrepresentation, or misconduct by an opposing party; . . .

(6) any other reason that justifies relief.

(c) TIMING AND EFFECT OF THE MOTION.

(1) Timing. A motion under Rule 60(b) must be made within a

reasonable time—and for reasons (1), (2), and (3) no more than a

year after the entry of the . . . order or the date of the

proceeding.

(d) OTHER POWERS TO GRANT RELIEF. This rule does not limit a court's

power to:

(1) entertain an independent action to relieve a party from a judgment,

order, or proceeding;

(3) set aside a judgment for fraud on the court. . . .

Fraud, whether intrinsic or extrinsic, misrepresentation, or other

misconduct of an adverse party are express grounds for relief by

motion under amended subdivision (b). There is no sound reason

for their exclusion. The incorporation of fraud and the like

within the scope of the rule also removes confusion as to the

proper procedure. It has been held that relief from a judgment

obtained by extrinsic fraud could be secured by motion within a

“reasonable time,” which might be after the time stated in the

rule had run. Fiske v. Buder (C.C.A.8th, 1942) 125 F.(2d) 841;

see also inferentially Bucy v. Nevada Construction Co.

(C.C.A.9th, 1942) 125 F.(2d) 213.. . .. The amendment settles

this problem by making fraud an express ground for relief by

motion; and under the saving clause, fraud may be urged as a

basis for relief by independent action insofar as established

doctrine permits. See Moore and Rogers, Federal Relief from

Civil Judgments (1946) 55 Yale L.J. 623, 653–659; 3 Moore's

Federal Practice (1938) 3267 et seq. And the rule expressly does

not limit the power of the court, when fraud has been

perpetrated upon it, to give relief under the saving clause. As an

illustration of this situation, see Hazel-Atlas Glass Co. v.

Hartford Empire Co. (1944) 322 U.S. 238.

Page 11 of 28

However the Ninth Circuit Court of Appeals in the case of

Pumphrey v. K.W. Thompson Tool Co., 62 F.3d 1128, 1131 (9th

Cir. 1995) held that a lawyer’s failure to disclose . . . constituted

fraud upon the court.

In further support of said motion,

15. FACT: This Court has before it UNCONTESTED pleadings:

(a) “Creditor’s Opposition/Response to Notice of Chapter 7 Bankruptcy

Case, Meeting of Creditors, & Deadlines and Motion to be

Dismissed from Action” – Docket 10 – and

(b) “Creditor Vogel Newsome’s Opposition/Response to 5/11/11

Discharge of Debtor; Request for Findings of Fact and Conclusions

of Law; and Vacating of Discharge of Debtor” – Docket 20 -

of Vogel Newsome.

16. On or about May 14, 2014, this Court held a hearing:

Page 12 of 28

during said hearing, Judge Edward Ellington advised Newsome of additional

information that the Court needed. Newsome advised the Court/Judge Ellington

of her notation(s) of the Court’s requests and her proceeding to comply with said

request(s). Furthermore, Newsome advised the Court/Judge Ellington of the

JURISDICTION issue wherein it appears Judge Ellington wanted to remain

and/or appear to be oblivious to such CRITICAL/CRUCIAL facts. Moreover, at

said hearing Newsome REITERATED reliance upon said claims and defenses set

forth in her pleadings before the Court.

17. The BODY Language, ACTION as well as CONDUCT of Judge Ellington were

clear that he was DESPERATELY working to AID Counsel for Debtor

Townsend – Robert Rex McRaney, Jr. – in the defense of the SHALLACKING

being rendered by Newsome. Counsel McRaney had NO excuse for FAILURE

to provide a REBUTTAL to Newsome’s pleadings – i.e. at Docket Nos. 10 and 20

of this instant Bankruptcy action. Judge Ellington’s CODED EYEYING of

Opposing Counsel confirmed to Newsome that this Court/Ellington having

KNOWLEDGE that Newsome’s arguments were SOUND and SUBSTANTIATED

by statutes/laws governing said matters and went UNCONTESTED! Thus,

warranting rulings in favor of the relief sought therein.

18. At the end of the May 14, 2014 Bankruptcy Hearing in this instant Bankruptcy

action, this Court, Counsel for Townsend (McRaney) and Newsome UPDATED

Address information for Newsome:

Post Office Box 31265

Jackson, MS 39286

and Newsome advising that the Cincinnati, Ohio mailing address (P.O. Box

14731 – Cincinnati, OH 45250) is also good. McRaney also providing

Newsome with his contact information (2 Business Cards):

Page 13 of 28

19. TO DATE (July 14, 2014), Newsome has NOT been served with the Motion to

Dismiss that this Court’s June 27, 2014 addresses. The EVIDENCE supports that

Newsome provided this Court and Counsel for Debtor (McRaney) with

UPDATED mailing address and RECEIVED this Court’s June 27, 2014

PROPOSED Order created by Counsel for Debtor Robert Rex McRaney, Jr.

20. Creditor Vogel Newsome is PRO SE and is NOT an attorney and DOES NOT

receive NOTICE(s) of filing(s) with this Court ELECTRONICALLY as Counsel

for Debtor Townsend – McRaney. Furthermore, Newsome DOES NOT have

available to her – because of PRO SE/NON-Attorney Status – the ability to

submit filings ELECTRONICALLY through this Court’s Electronic Filing

System.

21. With that being said, the BURDEN OF PROOF is on Counsel for Debtor

Townsend to PROVE by EVIDENCE that he SERVED Newsome with the

Motion to Dismiss pursuant to Rule 5 of the Federal Rules of Civil Procedure and

or other statutes/laws governing said matters:

Rule 5. Serving and Filing Pleadings and Other Papers

(b) Service: How Made.

(1) Serving an Attorney. If a party is represented by an attorney,

service under this rule must be made on the attorney unless the

court orders service on the party.

(2) Service in General. A paper is served under this rule by: . . .

(C) mailing it to the person's last known address—in

which event service is complete upon mailing; . .

(d) Filing.

(1) Required Filings; Certificate of Service. Any paper after the complaint that

is required to be served—together with a certificate of service—must be filed

within a reasonable time after service. . . .

22. With TWO VALID addresses provided to Opposing Counsel Robert Rex

McRaney, Jr. and Creditor Newsome NOT receiving Motion to Dismiss, it

warrants further INVESTIGATION(S) as well as PROOF from Counsel

McRaney that Service has been completed in the handling of the Motion to

Dismiss he based his PROPOSED supporting Order upon.

Page 14 of 28

23. Such FRAUDULENT and CRIMINAL Acts by Debtor Townsend’s Counsel

Robert Rex McRaney, Jr./McRaney & McRaney is PREJUDICIAL and has

caused Creditor Newsome rights SECURED under the Constitution –i.e.

providing her with information so that she can CONTEST (if desired – Newsome

would have contested Motion to Dismiss had she been served). The Constitution

MANDATORILY requires that Creditor Newsome be provided with a copy of

the Debtor Townsend’s Motion to Dismiss to which the PROPOSED Order of

June 27, 2014 was executed upon.

24. Creditor Newsome is CONFIDENT that Counsel for Debtor Townsend

(McRaney) will NOT be able to provide any PROOF/EVIDENCE of mailing(s)

of the Motion to Dismiss ELECTRONICALLY filed, it appears from the

proposed Order signed, because NO such mailing(s) was initiated as

MANDATORILY required by the statute/laws governing said matters.

25. A reasonable mind may conclude that this Court submitted its ruling to Creditor

Newsome at the mailing address (Post Office Box 31265 – Jackson, MS 39286)

provided and Newsome’s RECEIPT is CONFIRMED through this filing;

that most UNLIKE this Court Counsel McRaney did NOT serve Newsome with

the Motion to Dismiss for purposes of ENGAGING in FRAUD UPON THE

COURT and for purposes of obtaining an UNDUE and ILLEGAL advantage in

this instant Bankruptcy action in which he is taking a HEAVY SHELLACKING!

Moreover, the ROLE that it now appears to Creditor Newsome that Counsel

McRaney is FULFILLING in the CHAIN CONSPIRACIES leveled against

Newsome.

It appears it may come down to Creditor Newsome doing further research to

determine WHEN Counsel for Debtor Townsend (McRaney) FILED the Motion

to Dismiss and WHEN (what date) the Lawsuit in the Anna Louise Inn Scandal

was FILED – and HOW SERVICE OF PROCESS (if any) in said scandal was

handled (if at all) – The Anna Louise Inn Lawsuit is an action brought AGAINST

Newsome which is being POSTED in Social Forums for PUBLIC/WORLD

interests:

Page 15 of 28

26. The Anna Louise Inn Lawsuit was filed AGAINST Newsome on or about MAY

28, 2014!

So WHEN did Counsel for Debtor Townsend file the Motion to Dismiss and

how CLOSE (proximity date range - if at all) is said filing with the Lawsuit in

the Anna Louise Inn matter? Such information which is RELEVANT and

PERTINENT in that it NOW appears that the CRIMINAL Acts of Counsel

Robert Rex McRaney, Jr./McRaney & McRaney’ WITHHOLDING of service fo

the Motion to Dismiss may be a DIRECT and PROXIMATE result of his

ROLE(S) in the CHAIN CONSPIRACIES targeting Creditor Newsome - - For

instance:

(a) On or about May 14, 2014, this Court held a Hearing regarding Newsome’s

pleadings (Docket Nos. 10 and 20).

(b) On or about May 28, 2014, a Lawsuit was brought AGAINST Newsome in

the Anna Louise Inn matter.

(c) SO WHEN did Counsel for Debtor Townsend (McRaney)

file the Motion to Dismiss?

Page 16 of 28

27. On or about JUNE 27, 2014, the court in the Anna Louise Inn Matter set for

hearing Newsome’s Motion to Dismiss.

Then ON-THE-SAME-DATE (June 27, 2014), it appears that this Court’s

Judge Ellington EXECUTED the proposed Order provided by Opposing Counsel

Robert Rex McRaney, Jr.

NOW let us look at WHEN this Court EXECUTED the proposed Order

submitted by Counsel for Debtor Townsend (McRaney).

Page 17 of 28

28. This is IMPORTANT/RELEVANT information because the ANNA LOUISE

SCANDAL is DIRECTLY LINKED to the Scandals and CRIMINAL Activities

of United States of America President Barack Obama and his Legal Counsel

Baker Donelson Bearman Caldwell & Berkowitz – i.e. who has an office located

Jackson, Mississippi –

and BAKER DONELSON is LEGAL COUNSEL to the Federal Judges and/or

its Judges/Justices as Judge Edward Ellington as well as it appears may have

played a KEY/MAJOR role in Judge Ellington’s APPOINTMENT to the Bench.

Page 18 of 28

29. In Newsome’s May 22, 2011 pleading entitled, “Creditor Vogel Newsome’s

Opposition/Response to 5/11/11 Discharge of Debtor; Request for Findings of

Fact and Conclusions of Law; and Vacating of Discharge of Debtor” – Docket

20 – she advised this Court that she had “BIGGER FISH TO FRY” which entails

United States of America’s President Barack Obama and his Legal Counsel

Baker Donelson Bearman Caldwell & Berkowitz! See at Docket 20, Pages 4 thru

9.

Page 19 of 28

30. Yes, with CRIMINAL LAWYERS as Baker Donelson Bearman Caldwell &

Berkowitz at the HELM OF THE SHIP in their ATTACKS leveled AGAINST

Newsome, Newsome is getting JOY on EXPOSING what President John F.

Kennedy sought to EXPOSE! It may have cost President Kennedy his life;

however, he was a President UNLIKE President Barack Obama that appears

WOULD NOT compromise with the likes of Baker Donelson Bearman Caldwell

& Berkowitz its TERRORIST/RACIST Regime.

31. Newsome believes there are sufficient, facts, evidence and legal conclusions in

the “USDC-MS proceeding” to support that Townsend’s and her legal counsel’s

(Robert Rex McRaney, Jr.) credibility is lacking. Moreover, that Townsend and

McRaney have a PATTERN-OF-PRACTICE to: (a) provide false and

misleading information; (b) obstruct justice and/or the administration of justice;

and (c) engage in civil/criminal violations for willful, malicious and wanton

intent.

Thigpen v. Kennedy, 238 So.2d 744 (Miss.,1970) - It is duty of

the chancellor to apply “unclean hands” doctrine of its own

motion when it becomes evident that the facts of case are such

they call for application of the doctrine.

32. Newsome believes that based upon the facts, evidence and legal conclusions

provided herein, that Townsend comes before this Court with “UNCLEAN

HANDS” and is AIDED and ABETTED by her attorney (McRaney). The

unlawful/illegal acts of Townsend and McRaney are for purposes of causing

Newsome further injury and harm. Moreover, efforts to preclude Newsome from

recovering from injuries/harm caused by Townsend’s unlawful/illegal actions

addressed in “USDC-MS proceeding.”

Page 20 of 28

Positive Black Talk Inc. v. Cash Money Records, Inc., 394 F.3d

357 (5th

Cir. 2004) - The “unclean hands doctrine” is used to

defeat an undeserving plaintiff's claim for equitable relief against

a defendant that he has injured.

33. Townsend and her counsel (Robert Rex McRaney, Jr. [“McRaney”]) do not come

before this Bankruptcy Court in good faith and clean hands. In fact, this instant

Bankruptcy proceeding has been brought in bad faith and with dirty hands for

purposes of causing needless delay, embarrassment to this Court, increasing the

costs of litigation, harassment of Newsome, intimidation, coercion, obstructing

the administration of justice, committing fraud on this Court and other reasons

known to Townsend and her counsel (McRaney).

In re Stoball's Will, 50 So.2d 635 (Miss.,1951) - He who comes

into an equity court must come with clean hands, and one cannot

use processes of that court when his conduct with respect to

transaction in question has been characterized by wilful inequity,

illegality, and fraud.

34. McRaney is an attorney whose area of SPECIALTY/practice entails,

“BANKRUPTCY” law. Therefore, a reasonable may conclude that McRaney

knew and/or should have known that in the filing of Townsend’s Chapter 7

Bankruptcy action, was done with intent to commit fraud and deceive this Court.

NOW we have Opposing Counsel McRaney’s handling of the Motion to Dismiss

to SUBSTANTIATE such FRUDULENT acts upon this Court as well as the

OBSTRUCTION of the Administration of Justice and other CRIMINAL Acts

known and/or should be known to him as well as this Court. McRaney practicing

before this Court with “DIRTY HANDS!”

Other Court Case: Because Bankruptcy Court is a court of

equity, a person seeking relief in Bankruptcy Court must come

into court in good faith and with clean hands. In re Quality

Trading Co., Inc., Bkrtcy.D.Hawaii 1984, 36 B.R. 265,

reconsideration denied 39 B.R. 42.

Mississippi Cases: Vasser v. Bibleway M.B. Church, 2010 WL

5093741 (Miss. App. 2010) - One seeking relief in equity must

come with clean hands or face refusal by the court to aid in

securing any right or granting any remedy. Community Bank of

Mississippi v. Stuckey, 2010 WL 4983102 (Miss. 2010); Whalen

v. Bistes, 45 So.3d 290 (Miss.App.,2010).

Lane v. Lane, 850 So.2d 122 (Miss.App.,2002) - The court may

apply the unclean hands doctrine sua sponte where it is shown

applicable.

35. Even if Townsend may want to assert she relied upon the counsel of McRaney,

such defense must also fail. Townsend has a history and pattern of engaging in

criminal acts for purposes of obstructing justice. Furthermore, Townsend has an

employment history in law as a Legal Secretary/Assistant. Therefore, a

Page 21 of 28

reasonable mind may conclude the necessary tools to determine whether the

advice given her was lawful or whether she knowingly, deliberately and

intentionally encouraged McRaney to file the Chapter 7 Bankruptcy proceeding

with knowledge that she may have been committing fraud on the United States

Bankruptcy Court – Southern District of Mississippi. Townsend’s PATTERN of

CRIMINAL ACTS are also well documented in “USDC-MS proceeding.”

Creditors could not defeat claim that they filed involuntary

Chapter 7 petition in bad faith by asserting that they relied on

advice of counsel; advice of counsel defense is only available to

those who place good faith reliance on that advice after full

disclosure of material facts, but creditors had intentionally

deceived bankruptcy attorney by building a "Chinese wall"

around him so that he would not know key facts regarding events

surrounding the petition filing. In re Landmark Distributors,

Inc., Bkrtcy.D.N.J. 1995, 189 B.R. 290.

36. Newsome further request through this instant filing that should the United States

Bankruptcy Court find that Debtor’s counsel (Robert Rex McRaney, Jr.) has

engaged in criminal/fraudulent practices that it initiate the applicable

proceedings to have him disciplined – i.e. sanctioned and/or disbarred – if

permissible under the laws governing said matters. Newsome believes that the

appropriate disciplinary actions against McRaney is necessary to DETER and

DISCOURAGE future abuse of the laws as an attorney/officer of the Court.

In re Tbyrd Enterprises LLC, 354 Fed.Appx. 837 (5th

Cir. 2009)

- Bankruptcy court had jurisdiction to impose sanctions under

the Federal Rules of Bankruptcy Procedure against debtor's

owner and debtor's counsel for filing a bad faith petition, since

the imposition of sanctions on litigants in a bankruptcy case was

a matter arising in such a case within meaning of the statute

granting bankruptcy judges authority to hear and determine

matters arising in a bankruptcy case. 28 U.S.C.A. § 157(b)(1);

Fed.Rules Bankr.Proc.Rule 9011, 11 U.S.C.A.

In re Pratt, 524 F.3d 580 (5th

Cir. 2008) - Because Rule 9011 of

the Federal Rules of Bankruptcy Procedure is substantially

identical to Federal Rule of Civil Procedure 11, the Court of

Appeals may refer to Rule 11 jurisprudence when considering

sanctions under Rule 9011. Fed.Rules Bankr.Proc.Rule 9011, 11

U.S.C.A.; Fed.Rules Civ.Proc.Rule 11, 28 U.S.C.A.

In re First City Bancorporation of Texas Inc., 282 F.3d 864 (5th

Cir. 2002) - Sanctions imposed by the bankruptcy court must be

chosen to employ the least possible power to the end proposed;

in other words, the court must use the least restrictive sanction

necessary to deter the inappropriate behavior.

Page 22 of 28

WHEREFORE, Opposing Counsel Robert Rex McRaney, Jr. did KNOWINGLY and

WILLINGLY commit FRAUD UPON THE COURT in the handling of the Motion to Dismiss and

ENGAGED in a PATTERN-OF-CRIMINAL Acts through the use of this Court’s Electronic Filing

System which WARRANTS the proper INVESTIGATIONS and PROSECUTION(S) for criminal/civil

wrongs McRaney engaged in.

III. MOTION FOR SANCTION(S):

Pursuant to Federal Rule of Civil Procedure Rule 12(G) and Rule 11, Creditor Vogel Newsome

(“Newsome”) moves this Court, for the above foregoing reasons and those known to this Court for the

ISSUANCE of Sanctions of and AGAINST Opposing Counsel Robert Rex McRaney, Jr./McRaney &

McRaney in accordance with the Statutes/Laws governing said matters. In support thereof, Newsome

states the following:

Rule 11. Signing Pleadings, Motions, and Other Papers; Representations to

the Court; Sanctions

(a) Signature. Every pleading, written motion, and other paper must be signed by

at least one attorney of record in the attorney's name—or by a party personally if

the party is unrepresented. The paper must state the signer's address, e-mail

address, and telephone number. Unless a rule or statute specifically states

otherwise, a pleading need not be verified or accompanied by an affidavit. The

court must strike an unsigned paper unless the omission is promptly corrected

after being called to the attorney's or party's attention.

(b) Representations to the Court. By presenting to the court a pleading, written

motion, or other paper—whether by signing, filing, submitting, or later

advocating it—an attorney or unrepresented party certifies that to the best of the

person's knowledge, information, and belief, formed after an inquiry reasonable

under the circumstances:

(1) it is not being presented for any improper purpose, such as to harass, cause

unnecessary delay, or needlessly increase the cost of litigation;. . .

Sanctions.

(1) In General. If, after notice and a reasonable opportunity to respond, the

court determines that Rule 11(b) has been violated, the court may impose an

appropriate sanction on any attorney, law firm, or party that violated the rule or is

responsible for the violation. Absent exceptional circumstances, a law firm

Page 23 of 28

must be held jointly responsible for a violation committed by its partner,

associate, or employee.

(2) Motion for Sanctions. A motion for sanctions must be made separately from

any other motion and must describe the specific conduct that allegedly violates

Rule 11(b). The motion must be served under Rule 5, but it must not be filed or

be presented to the court if the challenged paper, claim, defense, contention, or

denial is withdrawn or appropriately corrected within 21 days after service or

within another time the court sets. If warranted, the court may award to the

prevailing party the reasonable expenses, including attorney's fees, incurred for

the motion.

(3) On the Court's Initiative. On its own, the court may order an attorney, law

firm, or party to show cause why conduct specifically described in the order has

not violated Rule 11(b).

(4) Nature of a Sanction. A sanction imposed under this rule must be limited to

what suffices to deter repetition of the conduct or comparable conduct by others

similarly situated. The sanction may include nonmonetary directives; an order to

pay a penalty into court; or, if imposed on motion and warranted for effective

deterrence, an order directing payment to the movant of part or all of the

reasonable attorney's fees and other expenses directly resulting from the

violation.

(5) Limitations on Monetary Sanctions. The court must not impose a monetary

sanction:

(A) against a represented party for violating Rule 11(b)(2); or

(B) on its own, unless it issued the show-cause order under Rule 11(c)(3) before

voluntary dismissal or settlement of the claims made by or against the party that

is, or whose attorneys are, to be sanctioned.

(6) Requirements for an Order. An order imposing a sanction must describe

the sanctioned conduct and explain the basis for the sanction.

A. RULES OF CIVIL PROCEDURE – RULE 11 SANCTIONS:

Skidmore Energy, Inc. v. KPMG, 455 F.3d 564, 569-570 (2006)

– Under the “snapshot” rule, sanctions based on a frivolous

pleading were proper because the lack of legal and evidentiary

support for the pleading at the time it was filed. The . . .court

found the claims lacked both legal and factual support and

imposed more than $500,000 in sanctions against plaintiffs and

their counsel, based on defendants’ reasonable expenses incurred

in litigating against the claims. . . . This test focuses on the

instant when the signature is placed on the document, and the

state of mind of the signer at the time. The test ensures the Rule

11 liability is assessed only for violation existing at the moment

of filing. The . . . court had clearly concluded that the pleadings

were frivolous when filed. The fact that they continued to lack

Page 24 of 28

evidentiary support throughout the proceedings only underscored

the violation.

(n. 4) Both client and attorney have duty to conduct

reasonable inquiry into facts or law before filing lawsuit;

(n. 5) In lawsuit addressing ongoing dispute . . .court did

not abuse its discretion in awarding Rule 11 sanctions against

plaintiffs; rather than sanctioning them for legally frivolous

nature of pleadings, it sanctioned them for . . .factually

groundless allegations in their complaint; and

(n. 7) Fifth Circuit's “snapshot” rule/test ensures that

Rule 11 liability is assessed only for a violation existing at

moment of filing.

37. This Court, upon the use of the U.S. Fifth Circuit Court of Appeals’

“SNAPSHOT Rule” Debtor Ladye M. Townsend’s and her Legal Counsel Robert

Rex McRaney, Jr.’s Motion to Dismiss will find the evidence LACKING to

support dismissal. Moreover, that the CRIMINAL ACTS and PATTERN-OF-

CRMINAL acts of Debtor and her Counsel supports the Bankruptcy action

brought and the listing of Vogel Newsome (an INDIVIDUAL and NOT a

Business Entity) is frivolous and a sham submitted with WILLFUL,

MALICIOUS and WANTON acts to commit fraud upon this Court.

Furthermore, that said pleadings brought by Debtor and her Counsel clearly

lacked legal standing and evidentiary support at the time they were filed.

Therefore, supporting and sustaining the sanction relief Newsome seeks through

this instant filing.

38. Newsome believes that a reasonable mind may conclude that in using the

“SNAPSHOT Rule” as well as COUNSEL Robert Rex McRaney Jr.’s

DELIBERABTE, WILLFUL and MALICIOUS acts in failing to provide

Newsome with a copy of the Motion to Dismiss to which the JUNE 27, 2014

Order is issued were for purposes of fraud, deceit, misrepresentation,

harassment, embarrassment, obstructing justice, delaying proceedings,

increasing the costs of litigation, violating the Rules of the Court and

Federal Rules of Civil Procedures and other reasons known to him.

39. Newsome further believes that the record evidence will support that Debtor

Townsend and her Counsel (McRaney) have established a “PATTERN-OF-

ABUSE” and “PATTERN-OF-ENGAGING-IN-CRIMINAL ACTS” to further

support Rule 11 Sanctions as well as this Court’s reporting of said CRIMINAL

acts to the appropriate agency/entity for prosecution, sanction and disbarment (if

applicable).

40. Rule 11 of the Federal Rules of Civil Procedure are CLEAR of the

MANDATORY requirements for such FRAUDULENT and CRIMINAL acts of

Counsel for Debtor Townsend (Robert Rex McRaney, Jr./McRaney &

McRaney).

41. Newsome believes that the record evidence will support that Rule 11 liability is

deemed appropriate at this time to deter and discourage Counsel for Debtor

Townsend – Robert Rex McRaney, Jr./McRaney & McRaney) from coming

before this Court with fraudulent intent, criminal intent and other willful,

malicious and wanton unethical behavior known to them.

Page 25 of 28

42. Opposing Counsel Robert Rex McRaney, Jr./McRaney & McRaney KNEW that

he/it was ENGAGING in FRAUDULENT practices UPON THIS COURT in the

submittal of the Motion to Dismiss granted through the June 27, 2014 Order

ATTACHED to his/its PROPOSED Order dismissing action. Moreover, that

FAILURE to provide Creditor Newsome with Motion to Dismiss with

KNOWLEDGE that she is PRO SE and is NOT an attorney further SOLIDIFIES

the FRAUDULENT practices INITATED upon this Court and WILLFUL,

MALICIOUS and WANTON acts to ENGAGE this Court in his/its CRIMINAL

ACTS!

Mercury Air Group, Inc. v. Mansour, 237 F.3d 542 (C.A.5.

2001) - Under Rule 11, an attorney must have made a reasonable

inquiry into the facts and law of a case at the time which he or

she affixes his or her signature on any papers to the court.

Fed.Rules Civ.Proc.Rule 11, 28 U.S.C.A.

Walker v. City of Bogalusa, 168 F.3d 237 (C.A.5.1999) - A

signatory violates Rule 11 if he fails to conduct a reasonable

inquiry into the law and facts underlying his motion, or if he

makes a motion to delay, harass or increase the costs of

litigation. Fed.Rules Civ.Proc.Rule 11, 28 U.S.C.A.

Prior to Opposing Counsel Robert Rex McRaney, Jr. AFFIXING his signature to

the PROPOSED Order supporting the Motion to Dismiss, he KNEW that he did

NOT and NEITHER was he intending to provide Creditor Newsome with a copy

of the Motion to Dismiss. In so ENGAGING in such CRIMINAL acts, a

REASONABLE mind may conclude that the CRIMINAL and FRAUDULENT

acts by Counsel Robert Rex McRaney, Jr./McRaney & McRaney was done with

FORETHOUGHT, MALICE and FRAUDULENT intent, etc.

43. The nature and/or area of BANKRUPTCY is within the “LEGAL FIELD and

EXPERTISE” – of Opposing Counsel Robert Rex McRaney, Jr./McRaney &

McRaney. Therefore, supporting KNOWLEDGE that his/its handling of the

Motion to Dismiss this Court executed a PROPOSED Order from Opposing

Counsel on was provided with WILLFUL and MALICIOUS intent to commit

FRAUD UPON THE COURT and to get this Court to ERR on relying upon an

OFFICER OF THE COURT who took an OATH; nevertheless, TOOK A FAR

DEPARTURE from said Oath for purposes of obtaining an

UNDUE/UNLAWFUL/ILLEGAL advantage in this instant Bankruptcy action.

44. During the May 14, 2014 hearing before Judge Ellington, this Court wanted

Creditor Newsome to believe that her Civil Lawsuit in United States District

Court; Southern District of Mississippi (Jackson Division); Civil Action 3:10-cv-

704 was NO LONGER viable; however, Newsome CORRECTED and

INFORMED this Court with Opposing Counsel Robert Rex

McRaney, Jr./McRaney & McRaney present that such

ASSERTION was in ERROR and that the United States District

Court action is ALIVE and WELL despite HOW that Court

wants it to appear to the PUBLIC/WORLD! Thus, allowing

Page 26 of 28

Creditor Newsome to continue to PURSUE other

CRIMINAL/CIVIL prosecution in other matters.

Marlin v. Moody Nat. Bank, N.A., 533 F.3d 374 (5th Cir. 2008) -

“Snapshot rule” ensures that Rule 11 liability is assessed only

for violation existing at moment of filing.

Nevertheless, in this instant matter, Creditor Newsome wants to REITERATE

that the United States District Court; Southern District of Mississippi (Jackson

Division); Civil Action 3:10-cv-704, due to the CONFLICT-OF-

INTERESTS of Judge Louis Guirola, Jr. is ALIVE and WELL

and BEAUTIFULLY Stayed while she pursues OTHER Legal

Resources available to her – i.e. just CONTINUE to WATCH

CAPITOL HILL in Washington, D.C.

45. After the May 14, 2014 Bankruptcy Hearing, Opposing Counsel Robert Rex

McRaney, Jr. advised Creditor Newsome of Debtor Townsend’s financial

situation which led her to have to file for Bankruptcy. McRaney it appears

advising Newsome of such for purposes of obtaining sympathy from her;

however, Newsome advised McRaney, that he would not be getting any

sympathy from her and that Debtor Townsend was fully aware of her actions and

the Civil Lawsuit was a direct and proximate result of her ENGAGEMENT in

Criminal/Civil wrongs – i.e. LYING during Federal Investigation(s) in which

Newsome has documentation supporting same. Moreover, it was obvious that

Creditor Newsome had become VERY UPSET that Opposing Counsel McRaney

was requesting she let Debtor Townsend off the hook because of her financial

situation – i.e. NOT A CHANCE!

Information PERTINENT and RELEVANT for the purposes of SHOWING the

STATE of MIND – i.e. Criminal Intent – of Opposing Counsel McRaney and his

KNOWLEDGE that Creditor Newsome would provide a DEFENSE for any

pleading filed. Therefore, realizing that he FAILED to provide a REBUTTAL

pleading to Creditor’s:

(a) “Creditor’s Opposition/Response to Notice of Chapter 7

Bankruptcy Case, Meeting of Creditors, & Deadlines and

Motion to be Dismissed from Action” – Docket 10 – and

(b) “Creditor Vogel Newsome’s Opposition/Response to 5/11/11

Discharge of Debtor; Request for Findings of Fact and

Conclusions of Law; and Vacating of Discharge of Debtor”

– Docket 20.

It appears from the June 27, 2014 Order of this Court, that Opposing Counsel

Robert Rex McRaney, Jr./McRaney & McRaney did KNOWINGLY and WITH

MALICIOUS intent submit a Motion to Dismiss and a PROPOSED Order that it

UNLAWFULLY/ILLEGALLY withheld from Creditor Newsome for purposes

of obtaining an UNLAWFUL/ILLEGAL advantage in this Bankruptcy action

with KNOWLEDGE that Creditor Newsome would provide a REBUTTAL to the

Motion to Dismiss. In so doing, Creditor Newsome has been

INJURED/HARMED and DEPRIVED for Consritutional and Civi l Rights to CONTEST the Motion to Dismiss because Opposing Coimsel McRaney W I T H H E L D service and may have PERJURED himself and/or LIED, FALSIFIED and/or MISREPRESENTED to this Court that Creditor Newsome had been served - i.e. which can be CONFIRMED through an INVESTIGATION and this Court's reviewing o f the Motion to Dismiss filed; however, NOT served on Creditor Newsome.

WHEREFORE, Creditor Vogel Newsome moves this Court for SANCTIONS o f and against

Counsel Robert Rex McRaney, Jr./McRaney & McRaney in the amount o f S50,000.(X) as well as this

Court's filing o f the appropriate Criminal Acts/lnvesrigarions for prosecution (i.e. SUSPENSION,

DISBARMENT, etc.) for the Criminal/Civil wTongs reported herein.

P L E A S E T A K E N O T I C E : That Creditor Vogel Newsome through the above Morions, hereby

demand to be advised of A N Y / A L L CONFLICT-OF-INTERESTS in this Court's handhng of the instant

Bankruptcy matter

WHEREFORE, PREMISES CONSIDERED Newsome prays that his Court GRANT the relief set

forth in this instant "Creditor's Motion for Relief From Order/Judgment: Motion for Rule 11 Sanctions of

and Against Robert Rex McRaney Jr, McRaney & McRaney: and Request To Be Advised Of ConfJtci-Of

Interests" and the supporting Motions individually raised m this instant Bankruptcy pleading. Wliile

Newsome believes diat this mstant filing provides the facts and evidence to support the rehef sought

herein and saves of additional costs, she reserves the right to submit to this Court her Memorandum Brief

in support of "CORNCTCBC&jVfTD'" i f said Court deems die motion alone is insufficient and an

additional memorandum brief may be beneficial.

Respectfully submitted this 14* day of July, 2014. i

S - . : > \ " I '•-

By: Vogel Newsome Post Office Box 14731 Cincinnati, Ohio 45250 Phone: (601) 885-9536 or (5 13) 680-2922

Page 27 of 28

C E R T I F I C A T E O F S E R N T C E

The undersigned hereby cerdfies that a true and correct copy of the forgoing pleading was

M A I L E D via U.S. Mail first-class to:

Robert Rex McRaney, Jr .

Post Office Box 1397 Clinton, Mississippi 39060 COUNSEL FOR. DEBTOR (LADYE M . imTvlSEND)

Dated this 14* day o f July, 2014.

Vogel Newsome

Page 28 of 28