OPEN LETTER TO THE PRESIDING HON. JUSTICE ROBERT C. COSGROVE OF THE PLYMOUTH COUNTY, MA SUPERIOR COURT DEPARTMENT

OPEN LETTER TO THE PRESIDING HON. JUSTICE ROBERT C. COSGROVE OF THE PLYMOUTH COUNTY, MA SUPERIOR COURT DEPARTMENT: WHITE DEFENDANTS VERSUS BLACK PLAINTIFFS IN FOUR LAWSUITS  AND WHITE JUDGE AND USE OF COLOR TO PRESENT MOTION TO DISMISS


May 9, 2012

AMERICA: COLORED CULTURE OF MOTION TO DISMISS BY PRIVILEGE.

Our question and with reference to several caselaws, lower court through The Supreme Court of the United Sates is whether any judge or court will dismiss the following lawsuits during pre-trial motion hearing. The answer is No because all the defendants (whites) and white presiding Hon. Justice, as usual failed to state claim that would persuade any Judge to grant their Motion to grant their Motion and off this orbit they believe that white color would make them prevail. Further below are Complaints which the defendants desire to use their color to terminate without allowing them to see bright day or trial. Several colored people's cases are prematurely terminated before trial in secret courtroom. The four lawsuits were heard in similar courtroom setting.


SHORTLIS  OF THE LINKS TO PENDING LAWSUITS

http://phillyimc.org/en/event/brockton-ma-superior-court-ofume-v-holyoke-police-department-et-al-question-democratic-policin

http://phillyimc.org/en/event/nigeria-presidential-election-2011-role-us-police-dr-phillip-chukwuma-ofumes-candidacy#comment-70254

http://groups.google.com/group/soc.org.nonprofit/browse_thread/thread/e1b762c0d4745f61?pli=1

http://universal-fashion-art-music.blogspot.com/2011/11/brockton-ma-superior-court-ofume-v-dhcd.html

http://universal-fashion-art-music.blogspot.com/2011/11/massachusetts-complaint-against.html

http://universal-fashion-art-music.blogspot.com/2011/11/massachusetts-commission-on-judicial.html


______________________________________________________________________________
HRRG, IHRRC, LIMPT, INC. & ASSOCIATES
(EDUCATION & WORKFORCE PROJECT -  USA CHAPTER)
c/o Dr. Phillip C. Ofume
P. O. Box 2416
Lynn, MA 01903
Tel.  857-266-2253/781-479-9027
E-mail: limptintinc@gmail.com
globalaids_hivcureinteraction@yahoo.co.uk
 ________________________________________________________________________________

Our Ref. SUP.CT/IHRRGC-LIMPT&A./05-12/ /Compliance/CDN/9689      Date: May 9, 2012

 HAND DELIVERY


The Honourable Justice, Robert C. Cosgrove                                                                                   CXXSuperior Court Administrative Office                                                                                                                    Suffolk County Courthouse, 13th Floor                                                                                                                    Three Pemberton Square                                                                                                                                               Boston, MA 02108
c/o Mr. Robert S. Creedon, Jr.                                                                                                                                      Clerk of the Courts                                                                                                                                                                Plymouth County Superior Court                                                                                                                                     Brockton, MA Office

May It Please Your Honor:

 FURTHER DOCUMENTS OF THE PLAINTIFFS WHICH WERE NOT NECESSARY FOR A PRE-TRIAL MOTION HEARING ON MAY 7, 2012 BUT VIEWED BY THE COURT UNDER  GIVEN PRIVILEGE TO THE DEFENDANTS (100% WHITES) IN DISADVANTAGE TO THE PLAINTIFFS (100% BLACKS)

                    Because Plaintiffs'  Representative and Advocate, Dr. Phillip Chukwuma Ofume did not expect that the defendants will hijack the hearing on May 7, 2012 to their personal interest when they were allowed to convert a pre-trial hearing to final hearing and also empowered to conduct discovery examination also unwarranted and other forms of activities including using unconstitutional privileges to force Plaintiff's representative (Black) to sit on a broken and unserviceable  chair whereas there was better and serviceable unoccupied chair at the hearing round table in the courtroom before the Presiding Honourable Justice Robert C. Cosgrove. Based on lack of Plaintiffs' reference documents on file,  their representative found that during the proceedings on May 7, 2012  several documents filed with the Court by the Plaintiff were not on file.


2.                 On May 7, 2012  the round table could not contain counsels and represenatives and the sitting was squeezed and the Counsel for the Hampden Sheriff who stood directly on Plaintiffs'  file and viewed each proof of service which Plaintiffs' Representative had, may have viewed and confirmed that the Proof of Service on the service upon his Client was left at home by Plaintiffs' representative and used this opportunity as  ground to deny that his client was not served the Summons whereas his client was served the summons by the Sheriff. To avoid this obtruction of justice and to help the Advisement Jury do its work judiciously, Plaintiffs herewith attached this PROOF OF SERVICE and in this letter will be marked EXHIBIT A.



3.            On the other hand, Plaintiffs'  unopposed cases, in the  matter of Ofume v. DTA and DHCD, Plaintiff submitted emergency motion for  Order on their MOTION FOR RECONSIDERATION of the decision denying their Motion requesting for Order in their favor on their unopposed Motion for Summary Judgement and Unopposed Motion sought immdediate order in their favor. Plaintiffs pleaded that these two consolidated Motions be made part of the hearing on May 7, 2012 but these two Motions were not mentioned and what the representative for the Plaintiffs heard was question by the Court to the Counsel for these agencies of the Commonwealth of Massachusetts, DTA and DHCD such as "are you representing the DHCD?" .  The Counsel said "Yes" and the motions (DTA/DHCD) were not formerly mentioned for hearing and contest thereafter.  The  court was brought to abrupt end when the Counsel for the agencies said, " DHCD was not served" and    Plaintiffs are also surprised when the Counsel for the agencies said "DHCD
was not served" but the Court quickly rose without given the Plaintiffs any opportunity to enter opposition because both the counsels and the defendants or their in-house counsel were served all the documents in this case but they did not oppose. In these two motions the services were not limited to services on the agencies' counsel but Plaintiffs expanded services on the offices of DHCD (100 Cambridge Street Suite 300 Boston, MA 02114) and DTA (600 Washington Street, Boston, 4th Floor,m Boston, MA 02111) and all deliveries were by hand because there is long history of service denial by these agencies and their Counsels. Shortlist of Plaintiffs' PROOF OF SERVICES (certified and regular mails) are hereto attached and marked EXHIBITS B, C, and D.


4.     Counsels for the Holyoke Police Department (HPD) contradicted herself severally when she said my client was not served and when the Court and Plaintiff showed her original and photo copies of the PROOF OF SERVICES issued by the Sheriff she revised her earlier oral submission and said, "we were served the complaint but the papers were misplaced between my office and department (police)."  Is this sufficient to grant them more and more privileges and why their Motion should not be dismissed for late filing and significant straws of obstruction of justice and failure to state claim against all Plaintiffs' four lawsuits?  At the beginning of the hearing they raised further obstruction of justice  cloud when they tried to use two different complaints as amended complaints whereas Ofume v. Karen Giard, Department of Children and Families  is cliam for $60million whereas complaint, Ofume v. Holyoke Police et als  is claim for $500million.



5.    Reference to para 4 above, the Representative and Advocate for the Plaintiffs would believe that the Defendants have good friends in the Court. For example the counsel for the HPD filed  NO OPPOSITION AFFIDAVIT when the matter was priorly resolved that Plaintiffs filed opposition to all Motion to Dismiss. On the same case, she filed contradictory AFFIDAVIT indicating that the Plaintiffs filed Opposition. The amazing part of these lies and perjury is that these two affidavits were deliberately dated the same date, April 25, 2012 for bad reason. With their friends in the Court, it is uncertain the part that was forwarded to the Presiding Hon. Justice on May 7, 2012.   In this case the representative for the Plaintiffs have received death threat by the HPD and the Complaint is before the FBI.  
 See EXHIBITS E and F.



 THEREFORE, reason of the foregoing and other submissions before this Court, Plaintiffs request this court to dismiss the entire Motion of the defendants because the motions are trump up in all ramification to obstruct justice.


Yours truly,
HRRG, IHRRC, LIMPT, INC. & ASSOCIATES
(EDUCATION & WORKFORCE PROJECT -  USA CHAPTER)


Phillip C. Ofume, Ph.D.
Representative for the Appellant, the Ofume family