CHICAGO-(AEAE)-IN A MOTION TO STRIKE STOLLER INDIRECT CRIMINAL CONTEMPT PETITION http://www.filefront.com/14756757/Lance-G.-Johnson-Charged-with-perjury0001.pdf/ILLINOIS ATTORNEY HAYNES RYAN ADMITS THAT "GORDON & REES LLP CAUSED TO BE FILED CERTAIN AFFIDAVITS CONTESTING PERSONAL SERVICE OF THE COMPLAINT. LEO STOLLER PRODUCED CERTAIN AFFIDAVITS OF THE PROCESS SERVER WHICH CONRADICT THE DEFENDANT (ALFRED GOODMAN) AFFIDAVIT. GORDON AND REES ATTORNEY HAYNES RYAN FILED A MOTION TO STRIKE STOLLER'S PETITION CHARGING HAYES RYAN WITH INDIRECT CRIMINAL CONTEMPT. In Haynes motion to strike Haynes Ryan asserted Stoller citation “is designed solely to harass me as opposing counsel and delay the underlying (defamation) litigation. Accordingly, the Petition should be stricken and Leo Stoller should be sanctioned under Illinois Supreme Court Rule 137”.
STOLLER HAS ASSERTED THAT HAYNES RYAN CHARGES OF INDIRECT CRIMINAL CONTEMPT SHOULD NOT BE STRIKEN BECAUSE HAYNES RYAN KNOWINGLY AND WILLFULLY FAILED TO TAKE REASONABLE CORRECTIVES STEPS NECESSARY TO CORRECT THE PRESENTATION OF GOODMAN’S PERJURED AFFIDAVIT AND FALSE MATERIAL EVIDENCE WHICH RYAN ADMITTS THAT GORDON AND REES CAUSED TO BE FILED.
Stoller argued that Haynes Ryan, who knew that his client Alfred Goodman, with the consent and approval of Respondents, Lance G. Johnson and David Abrams, presented false evidence ( Alfred N. Goodman’s perjured affidavit dated May 18, 2009) failed to take any reasonable corrective steps, including informing the trial court judge Kathy Flanagan1 of the deception. Respondent Hayes Ryan by his failure to take any corrective action actually aided and abided the other Respondents, Alfred G. Goodman, Lance G. Johnson and David Abrams in their Indirect Criminal Contempt and fraud on the court. Attorney Haynes Ryan knew that the burden was on him, the attorney who knew of his Goodman’s dishonesty, to take corrective action, but failed to do so. Romano Brothers Beverage Co. v. D Agostine-Yerow Assoc,. Inc., 1996 U.S. DIST. LEXIS 10730 47 (N.D. Ill. 1996) . Disclosure of Alfred N. Goodman’s perjury was required where respondents Haynes Ryan, Ryan T. Brown, Chance L. Cooper and the Law firm of Gordon & Rees LLP offered material evidence (Goodman’s perjured Affidavit) to the trial court judge Kathy Flanagan and all of the respondents including Mr. Ryan knew or came to know of its falsity, or when disclosure of Goodman’s perjured affidavit was necessary to avoid assisting a criminal or fraudulent act by Goodman, all of the respondents did nothing.Haynes Ryan knew that his duty to disclose Goodman’s perjury to the trial court judge Kathy Flanagan superseded his responsibility to keep client confidences. Haynes Ryan’s failure to “disclose” Alfred Goodman’s perjured affidavit, this material evidence, was necessary to avoid assisting Goodman, Abrams and Johnson in their crime of fraud and Indirect Criminal Contempt on the court.
Which has provoked the said Indirect Criminal Contempt Citation against the respondents, for their unlawful conduct was done “outside” of the purview of the court which has subjected all of the respondents to a valid charge of Indirect Criminal Contempt in the case at bar that was approved by the trial court judge Kathy Flanagan.
Thus far Lance G. Johnson, David Abrams and Alfred Goodman have evaded service of summons, but that day is coming to a rapid end. When they see the process server coming they can run but their not that fast that they can avoid the jurisdiction of the Illinois Cook County Courts much longer. They have a date with the Illinois Cook County Judge on January 19, 2010 http://www.filefront.com/15157881/Dec-15-2009-Order0001.pdf/
LEGAL DISCLAIMER: Haynes Ryan, Ryan T. Brown, Chance L. Cooper and the Law firm of Gordon & Rees LLP Alfred G. Goodman, Lance G. Johnson and David Abrams are considered innocent of all charges until proven guilty beyond any reasonable doubt.
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STOLLER HAS ASSERTED THAT HAYNES RYAN CHARGES OF INDIRECT CRIMINAL CONTEMPT SHOULD NOT BE STRIKEN BECAUSE HAYNES RYAN KNOWINGLY AND WILLFULLY FAILED TO TAKE REASONABLE CORRECTIVES STEPS NECESSARY TO CORRECT THE PRESENTATION OF GOODMAN’S PERJURED AFFIDAVIT AND FALSE MATERIAL EVIDENCE WHICH RYAN ADMITTS THAT GORDON AND REES CAUSED TO BE FILED.
Stoller argued that Haynes Ryan, who knew that his client Alfred Goodman, with the consent and approval of Respondents, Lance G. Johnson and David Abrams, presented false evidence ( Alfred N. Goodman’s perjured affidavit dated May 18, 2009) failed to take any reasonable corrective steps, including informing the trial court judge Kathy Flanagan1 of the deception. Respondent Hayes Ryan by his failure to take any corrective action actually aided and abided the other Respondents, Alfred G. Goodman, Lance G. Johnson and David Abrams in their Indirect Criminal Contempt and fraud on the court. Attorney Haynes Ryan knew that the burden was on him, the attorney who knew of his Goodman’s dishonesty, to take corrective action, but failed to do so. Romano Brothers Beverage Co. v. D Agostine-Yerow Assoc,. Inc., 1996 U.S. DIST. LEXIS 10730 47 (N.D. Ill. 1996) . Disclosure of Alfred N. Goodman’s perjury was required where respondents Haynes Ryan, Ryan T. Brown, Chance L. Cooper and the Law firm of Gordon & Rees LLP offered material evidence (Goodman’s perjured Affidavit) to the trial court judge Kathy Flanagan and all of the respondents including Mr. Ryan knew or came to know of its falsity, or when disclosure of Goodman’s perjured affidavit was necessary to avoid assisting a criminal or fraudulent act by Goodman, all of the respondents did nothing.Haynes Ryan knew that his duty to disclose Goodman’s perjury to the trial court judge Kathy Flanagan superseded his responsibility to keep client confidences. Haynes Ryan’s failure to “disclose” Alfred Goodman’s perjured affidavit, this material evidence, was necessary to avoid assisting Goodman, Abrams and Johnson in their crime of fraud and Indirect Criminal Contempt on the court.
Which has provoked the said Indirect Criminal Contempt Citation against the respondents, for their unlawful conduct was done “outside” of the purview of the court which has subjected all of the respondents to a valid charge of Indirect Criminal Contempt in the case at bar that was approved by the trial court judge Kathy Flanagan.
Thus far Lance G. Johnson, David Abrams and Alfred Goodman have evaded service of summons, but that day is coming to a rapid end. When they see the process server coming they can run but their not that fast that they can avoid the jurisdiction of the Illinois Cook County Courts much longer. They have a date with the Illinois Cook County Judge on January 19, 2010 http://www.filefront.com/15157881/Dec-15-2009-Order0001.pdf/
LEGAL DISCLAIMER: Haynes Ryan, Ryan T. Brown, Chance L. Cooper and the Law firm of Gordon & Rees LLP Alfred G. Goodman, Lance G. Johnson and David Abrams are considered innocent of all charges until proven guilty beyond any reasonable doubt.
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