08-3187 Volume Appendix15.pdf - Medical Supply Chain

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5. Beyond the lack of sufficient resources, I was repeatedly struck by the bias and open hostility exhibited by the Kansas District Court and Tenth Circuit personnel against the claims of my company and how Kansas government attorneys were enlisted to retaliate against my counsel for bringing these actions. I believe this is the bias that Chief Judge Deanell R. Tacha described in her decision dated March 23, 2005. I became concerned and attended the trial phase of my counsel’s representation of James Bolden, an African American small business man who had sought out my counsel when Kansas government attorneys had discouraged or intimidated four of his previous attorneys, the last of which still has not been found. I assisted in the trial preparation for this case believing it would be good practice for Medical Supply’s jury trials. 6. I have now known James Bolden for some time and believe him to be an extraordinarily honest god-fearing man. I also know that his work vehicle was firebombed while it was parked next to his home and the Topeka Police Department refused to even take a police report and that he feared for his life while his case was being litigated in the Kansas District Court. The injuries and threats made against his witnesses who I also know and believe are honest made affidavits of the incidents, including the opposing city attorney, Sherri Price’s threat to criminally prosecute the Topeka business owner Fred Sanders if he testified in federal court on behalf of James Bolden. 7. The City of Topeka and the Topeka office of the US Attorney threatened and intimidated other witnesses I have met because of their testimony in Mr. Landrith’s cases. Affidavits of these incidents were filed in the various Kansas District Court cases and the response of the Kansas judicial branch was to increase its threats against Mr. Landrith, one of which was mailed the afternoon Mr. Landrith had called Mark Hunt a former US 3 08-3187 Medical Supply Chain vs. Neoforma Volume XV 5791
Army officer and an African American to testify in a Topeka Federal courtroom. Mark Hunt was severely retaliated against for that testimony and Melvin Johnson, a retired US Postal worker client of Mr. Landrith was also retaliated against by city officials that night, leaving him homeless. The Topeka office of Eric Melgran the US Attorney caused Melvin Johnson’s key witness, Rosemary Price to be retaliated against for her participation in a deposition held in the Topeka federal courthouse a week later. 8. The Kansas District court repeatedly rebuked Mr. Landrith for documenting the obstruction and deliberate interference of justice that seems to be commonplace in the Kansas legal culture. Magistrate James P. O’Hara issued a very harsh report against Mr. Landrith in the Bolden case that seems to be more about Medical Supply’s case and what has happened to Shughart, Thomson and Kilroy. The Kansas Disciplinary Administrator Stanton Hazlett used the report to justify his investigation and prosecution of Mr. Landrith. 9. I advised Mr. Landrith to file in Kansas District Court to stop the state disciplinary administrator from prosecuting him for representing an African American and his American Indian witness. Affidavits in both cases revealed that Kansas state officials repeatedly obstructed justice and that the opposing counsel Sherri Price had threatened minority business men with criminal prosecution if they testified in Kansas District court against the City of Topeka. I knew that since none of this testimony was ever disputed the District of Kansas would certainly prevent the state from retaliating against Mr. Landrith for his protected speech on behalf of an African American and his American Indian witness. Surprisingly, however the District of Kansas judges recused themselves and the 4 08-3187 Medical Supply Chain vs. Neoforma Volume XV 5792
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IN THE UNITED STATES DISTRICT COURT
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Respectfully submitted, /s/ Jay E.
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After the instant Motion to Compel
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Thus, under Rule 26(a)(1)(A)(i), Pl
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help focus the discovery efforts of
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With respect to the first requireme
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Defendants, are documents that he (
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IT IS SO ORDERED. Dated in Kansas C
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2008 pretrial conference, and an Au
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motive on the part of the movant, r
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Plaintiff’s contention that he ne
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08-3187 Medical Supply Chain vs. Ne
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IN THE UNITED STATES COURT DISTRICT
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FILED United States Court of Appeal
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plaintiff sanctioned for not produc
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Monday, August 18, 2008 9:06 AM Sub
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method of communication, that it ma
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********************PRIVATE AND CON
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Monday, August 18, 2008 9:55 AM Sub
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DJW/bh IN THE UNITED STATES DISTRIC
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MARK A. OLTHOFF KS # 70339 SHUGHART
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Not Reported in F.Supp.2d Page 2 No
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21, 2008. 4 On August 21, 2008, Def
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Here, the parties have submitted se
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Whereas the trial judge has not rev
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(mh) (Entered: 08/20/2008) 7. The d
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that rejected in Glass v. Pfeffer,
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Prior Extrajudicial Source Bias The
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molthoff@stklaw.com ademarea@stklaw
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supplies. Similarly, the defendant
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JUDICIAL COUNCIL THE TENTH CIRCUIT
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the respondent ordered dismissal of
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Appearance Docket of the subject li
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were parties to the action at the t
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21. The petitioner had opposed tran
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State Court and the Western Distric
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dismissed, contradicting controllin
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(1) Respondent’s Effect On Litiga
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enter the market where Missouri doc
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58. Through the petitioner’s lobb
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made by the respondent that would h
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due date for a response to the defe
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Head v. Platte County, Mo., 749 P.2
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this court, we must call attention
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petitioner’s appeal or to other t
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adopted their poorly concealed fals
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without independent review resultin
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The action has the petitioner’s m
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Date: February, 1 st 2008 Office of
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permitted the repeated outcomes her
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JUDICIAL COUNCIL OF THE TENTH CIRCU
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Council. As set out in the miscondu
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Page 169 and 170: MEMORANDUM IN SUPPORT The plaintiff
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Page 185 and 186: enter the market. The Defendants ta
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Page 189 and 190: 598. The USA PATRIOT Act reaffirmed
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Page 213 and 214: Certificate of Service I certify th
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Dated this 24th day of October, 200
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lack of health insurance and the co
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Washington, DC 20004-1206 John K. P
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United States Court of Appeals for
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“Defendant's second allegation is
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3. The defendants were not parties
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tie-in sales and other means of exp
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judicata grounds. The court noted,
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Id pg. 328. d. Identity of claims U
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Heard v. Board of Pub. Util. of Kan
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The hospital supply competitors VHA
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56 states: “By 8/21/04 The NY Tim
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506 (2002); Crawford-El v. Britton,
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The burden to state a claim for int
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502 states: “Defendants through t
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the conspiracy, agreed to commit pr
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enterprise." Mason Tenders District
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“Section 315 of the Patriot Act a
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saml@medicalsupplychain.com Pro se
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!"#$%&"'()&$*'+,$&-(%'()!('()&.'/01
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UNITED STATES COURT OF APPEALS FILE
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in ensuring that the claims he brin
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supplies which included the threat
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Verizon Communications Inc. v. Law
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Certificate of Service I certify I
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! "#!$%&!'()&*+,-(&)#!).!%&*&/0!1&*
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###################################
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08-3187 Volume Appendix15.pdf - Medical Supply Chain

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