08-3187 Volume Appendix15.pdf - Medical Supply Chain

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unsolicited from the questioning of the Disciplinary Administrator and demonstrated a pre appearance coaching or consultation with Stanton Hazlett, especially on the point about Bret Landrith’s competence being less than that of a first year law student. Judge O’Hara could not have known that Landrith had testified the previous day that many states permit law students to represent clients in civil rights actions because of the shortage of counsel willing to undertake this difficult and unlucrative work. See Atch. 9. 27. Judge Vratil, the presiding Judge on Bolden’s case upheld Magistrate O’Hara’s recommendations which cut out many claims based on City of Topeka policies that had a negative impact on members of a protected class. Judge Vratil relied on Magistrate O’Hara’s judgment that the affidavits of misconduct against process servers and Bolden’s witnesses provided no basis for relying on the City’s unqualified appearance as effective service under the alternative use of Kansas serevice of process rules and provided no basis for extending discovery. Judge Vratil also demonstrated an impression that Bret Landrith was mentally incapable of arguing motions before the court in the final case management conference before trial which appeared to be the result of Magistrate O’Hara’s influence. Later Judge Vratil was able to make an independent judgment of Bret Landrith’s competence demonstrated by Bolden prevailing on some motions disputed before trial. 28. When Judge O’Hara returned to Kansas City, events still seemed to be set against Mr. Bolden’s cause. The notice that the record on appeal was complete was erroneously given to the Tenth Circuit, though the mistake was clear from the appearance docket that two transcripts that had been ordered still were not part of the record. The appeals clerk for 9 08-3187 Medical Supply Chain vs. Neoforma Volume XV 5811
Kansas District court would not correct the record, Bolden made a motion to correct the record, which was not addressed by Magistrate O’Hara. See Atch. 10 29. Bolden’s motion for an extension of time was sent to both the Tenth Circuit and the Kansas District Court. However it did not appear on the Tenth Circuit Court of Appeals appearance docket. Bolden’s counsel called the Tenth Circuit and a deputy clerk identified as Kathy stated that it had been received two days before but it was still not docketed. After the call Kathy reentered on the docket that Bolden’s brief was due January 26 th . See Atch. 11 30. On the same day, counsel called the Kansas District Court appeals clerk who stated she was working on the letter correcting the date the record was complete. However, this letter did not appear on the docket the 25 th or even the 26 th . Bolden’s counsel was forced to work without sleep to file an incomplete appellate brief on the 26 th emailing the brief to the court and counsel for the City and turning in the briefs and appendixes to US Postal Delivery service for the Tenth Circuit and the City of Topeka. See Atch. 12 31. Both the Kansas District Court correction of the record on appeal and the Tenth Circuit docketing of the motion for extension occurred after the brief and appendix was received, giving the appearance to an impartial observer that the events were coordinated to manufacture an ethics violation for Bolden’s counsel after the failure of previous attempts. 32. James Bolden is unable to find counsel to represent him in defending against the final steps of the City of Topeka to take his two properties for a public use without compensating him. 10 08-3187 Medical Supply Chain vs. Neoforma Volume XV 5812
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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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SUMMARY OF DEADLINES AND SETTINGS E
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UNITED STATES DISTRICT COURT FOR TH
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MEMORANDUM IN SUPPORT The plaintiff
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law); Cincinnati Insurance Co. v. B
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generating source of the power (to
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Judge Carlos Murguia’s prior deci
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Case 2:05-cv-02299-CM-GLR Document
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Page 185 and 186: enter the market. The Defendants ta
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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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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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###################################
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