David Gotzh David Gotzh GAL; David Gotzh Attorney at Law; The Road Lawyer; Midwest Appeals LLC David Gotzh rips off clients, incompetent; malpractice; should be disbarred!!!!! Chicago IL

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
LAW DIVISION, SIX DISTRICTS
Mahdee Muhammad
Plaintiff,
v. No. 2019 M6 4314
CHICAGO VOLUNTEER LEGAL SERVICE (CVLS)
DAVID GOTZH
REBEKAH A. RASHIDFAROKHI
Defendant (s)
NOTICE OF Filing
TO: CHICAGO VOLUNTEER LEGAL SERVICE (CVLS)
DAVID GOTHZ
REBEKAH A. RASHIDFAROKHI
By their Lawyer; Jordan M. Heinz
300 North LaSalle
Chicago, Il 60654
On or Before 08/20/19, the attached Plaintiff Response to Defendant’s Motion to Dismiss will be E File
with the Clerk of the Circuit Court of Cook County
FILED
8/20/2019 10:19 PM
DOROTHY BROWN
CIRCUIT CLERK
COOK COUNTY, IL
20196004314
Return Date: No return date scheduled
Hearing Date: No hearing scheduled
Courtroom Number: No hearing scheduled
Location: No hearing scheduled
FILED DATE: 8/20/2019 10:19 PM 20196004314
______________________________
Mahdee Muhammad
Mahdee Muhammad
123 Indianwood Blvd #340
Park Forest, IL 60466
708-819-0619
Atty. No. Pro-Se 9500
FILED DATE: 8/20/2019 10:19 PM 20196004314
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
LAW DIVISIONS, SIX DISTRICTS
MAHDEE H. MUHAMMAD,
PLAINTIFF.
Vs. Case No. 2019 M6 4314
CHICAGO VOLUNTEER LEGAL SERVICE (CVLS)
DAVID GOTZH
REBEKAH A. RASHIDFAROKHI
———————————————————————-
The Plaintiff, Mahdee H. Muhammad, Pro-Se, Response to Defendant’s Motion to Dismiss
herein, respectfully request this court to denied defendants motion:
INTRODUCTION
This is an action for equitable relief and for redress for the violation of rights guaranteed to the
plaintiff Mahdee Muhammad by state and federal laws, including (a) damages for deprivations
by defendants acting under color of State law of plaintiff’s rights, privileges and immunities
guaranteed by the Fourth and Fourteenth Amendments to the United States Constitution pursuant
to 42 USC 1983 and 1988; (b) damages for deprivations by defendants of plaintiff’s rights.
This is a case that the plaintiff has taking to the Illinoi Attorney General Office, ARDC and
others. To be told each time that it was civil case one that needs to be taking to state court, as
such the plaintiff file a civil rights lawsuit based solo on the fact that the defendant actions were
done solo based on race as such, they can be sued for violating the plaintiff civil rights.
THE PARTIES
Plaintiff Mahdee H. Muhammad is a male, Black, African American citizen of the United States,
domiciliary of the State of Illinois and a resident of the County of Cook. As such he is protected
under the Constitution
Defendant David Gotzh is not only a lawyer licensed to practice in the State of Illinois. He is
also a RACIEST! Defendant David Gotzh is being sued personally, and in his individual
FILED DATE: 8/20/2019 10:19 PM 20196004314
capacity, at the times relevant to this complaint he just happens to be employed by Chicago
Volunteer Legal Service, under the Defendant Rebekah A. Rashidfarokhi who is also a lawyer
licensed to practice in the State of Illinois. Who is being sued personally and in her individual
capacity, at the times relevant to this complaint as the Defendant David Gotzh, it was her duty to
stop or investigate the complaint filed by the Plaintiff Mahdee Muhammad.
However, she turned a blind eye and gave Defendant David Gotzh the ok to cause harm and
violate Plaintiff Mahdee Muhammad Constitution Rights.
Chicago Volunteer Legal Service (CVLS) as an organization was also aware of Plaintiff Mahdee
Muhammad compliant on Defendant David Gotzh, and they also did nothing to stop or
investigate his actions.
Case Law
Per case law, a case should not be dismissed on the pleadings, if the pleader desires to amend
unless it is apparent that no cause of action can be stated. Dinn Oil Co. v. Hanover Insurance
Co., 87 Ill.App.2d 206, 211-12; Fanning v. Lemay, 78 Ill.App.2d 166,
Carmack v. Great Am. Indemnity Co., 400 Ill. 93, 96; Danville Producers Dairy v. Preferred
Risk Mut. Insurance Co., 33 Ill.App.2d 359, 362; S.W. Coe & Co. v. Douglass, 334 Ill.App.
195, 196-97),
The court have ruled that if the issues within a complaint is with wording, the plaintiff should
have been granted leave to amend as this would allow for an opportunity to cure the specified
objection by amendment. Central Ill. Elec. & Gas Co. v. Scully, 17 Ill.2d 348, 353.)
If the Trial court believes it is apparent that the plaintiff's pleadings could be amended so as to
cure objections, and that the defendant's motions to dismiss are inadequate for their purpose.
Weidner v. Midcon Corp., 328 Ill. App. 3d 1056, 767 N.E.2d 815, 2002 Ill.
In determining whether a cause of action should be dismissed for the failure to state a cause of
action, all well-pleaded factual allegations must be taken as true and all reasonable inferences
drawn in favor of the pleader.
The plaintiff should have been allowed to have discovered to see if in fact did the defendant (s)
know about the raciest views of Defendant David Gotzh. What was done to cover up anything
that was found or was any inquire done at all.
The appeals courts have ruled on this issue as is use a test to be applied in determining whether
the trial court's discretion was adequately exercised is whether the allowance of the amendment
would further the ends of justice. Ray Dancer, Inc., 230 Ill. App. 3d at 48, 594 N.E.2d at 1349.
As the appeals court feels that leave to amend should generally be granted unless it is apparent
that even after the amendment no cause of action can be stated. City of Elgin v. County of Cook,
169 Ill. 2d 53, 71, 660 N.E.2d 875, 884, 214 Ill. Dec. 168 (1995).
FILED DATE: 8/20/2019 10:19 PM 20196004314
Although pleadings are to be liberally construed, a complaint must, nevertheless, contain facts
necessary to state a cause of action. The complaint if clear; plaintiff Mahdee Muhammad civil
right were violated by Defendant David Gotzh. Hanson v. Hyatt Corp., 196 Ill. App. 3d 618,
620- 21, 554 N.E.2d 394, 395, 143 Ill. Dec. 459 (1990); B.T. Explorations, Inc. v. Stanley, 187
Ill. App. 3d 23, 26, 542 N.E.2d 1292, 1294, 134 Ill. Dec. 785 (1989).
A plaintiff cannot rely simply on mere conclusions of law or fact unsupported by specific factual
allegations, regardless of whether they generally inform the defendant of the nature of the claim
against him or her. From the start plaintiff Mahdee Muhammad has documented that Defendant
David Gotzh was a raciest and he was actions were based solo on race. Grund v. Donegan, 298
Ill. App. 3d 1034, 1039, 700 N.E.2d 157, 161, 233 Ill. Dec. 56 (1998); Hirsch, 299 Ill. App.
3d at 1081, 702 N.E.2d at 270.
To sufficiently state a cause of action, a complaint must set forth a legally recognized claim and
plead facts in support of each element that brings the claim within the cause of action alleged.
The plaintiff did such. Anderson v. Vanden Dorpel, 172 Ill. 2d 399, 408, 667 N.E.2d 1296,
1300, 217 Ill. Dec. 720 (1996); Betts v. Crawshaw, 248 Ill. App. 3d 735, 737, 618 N.E.2d
1262, 1265, 188 Ill. Dec. 692 (1993).
Chapter 735. Civil Procedure § 5/2-616. Amendments § 2-616. Amendments. (a) At any time
before final judgment amendments may be allowed on just and reasonable terms, introducing any
party who ought to have been joined as plaintiff or defendant, dismissing any party, changing the
cause of action or defense or adding new causes of action or defenses, and in any matter, either
of form or substance, in any process, pleading, bill of particulars or proceedings, which may
enable the plaintiff to sustain the claim for which it was intended to be brought or the defendant
to make a defense or assert a cross-claim.
(b) The cause of action, cross claim or defense set up in any amended pleading shall not be
barred by lapse of time under any statute or contract prescribing or limiting the time within
which an action may be brought or right asserted, if the time prescribed or limited had not
expired when the original pleading was filed, and if it shall appear from the original and
amended pleadings that the cause of action asserted, or the defense or cross claim interposed in
the amended pleading grew out of the same transaction or occurrence set up in the original
pleading, even though the original pleading was defective in that it failed to allege the
performance of some act or the existence of some fact or some other matter which is a necessary
condition precedent to the right of recovery or defense asserted, if the condition precedent has in
fact been performed, and for the purpose of preserving the cause of action, cross claim or defense
set up in the amended pleading, and for that purpose only, an amendment to any pleading shall
be held to relate back to the date of the filing of the original pleading so amended.
The Defendant’s argue that per Nichols v. Fahrenkamp, 2019 IL; that the Illinois Supreme Court
ruled that a guardian ad litem are absolutely immune from liability for damage when they are
acting in child best interest: “In 2004, Nichols, age 11, received $600,000 in a settlement for
injuries she suffered in a motor vehicle accident. The court-appointed her mother as her guardian
FILED DATE: 8/20/2019 10:19 PM 20196004314
to administer her estate and appointed attorney Fahrenkamp as guardian ad litem. In 2012
Nichols sued her mother, claiming that she used $79,507 of settlement funds for her own benefit.
The trial court ruled in Nichols’s favor but limited recovery to $16,365, a 2007 Jeep Compass,
and $10,000 in attorney fees. Nichols sued Fahrenkamp for legal malpractice in approving
expenditures that were not in Nichols’s interests. She claimed that Fahrenkamp never met with
her or consulted with her regarding her mother’s expenditures. The circuit court granted
Fahrenkamp summary judgment based on qualified immunity. The appellate court reversed,
reasoning that guardian’s ad litem have a duty to protect their wards’ assets and interests and that
immunizing guardians ad litem from tort suits would be inconsistent with this duty. The Illinois
Supreme Court reinstated summary judgment in Fahrenkamp’s favor, applying the “functional
test” and looking past the title attached to the position to look to the position holder’s role. In the
past, the guardian ad litem served in almost a trustee-like capacity, seeking to specifically
advocate the pecuniary interests of the ward, but a present-day guardian ad litem functions as a
representative of the court-appointed to assist in protecting the ward's best interests.”
Fact the Plaintiff is not suing the Defendants as gal’s; however as private citenzzees; now the
defendants cannot rewrite the plaintiff complaint to make it fit their motion. However, let look at
what the defendants did; they recommend that a 12-year-old African American male be
discharge from the care of the only family he knew for the past 12 years of his life (since he was
3 months). The defendants recommend that the guardians do not have any type of commutation
with them as they did not want the minor to tell them what issue he was having. They had an
issue with the fact that this child called the guardian mom and dad; once more they had him since
he was 3 months and grew up in the house with their other children.
Fact the gal said that this child who had just got accepted into 7th grade stem; was playing
baseball since he was 4; has never got a grade lower than a “A”; living in a 2 family educated
household; was better off living in a apt where 4 days out of the week he would be left from 5
P.M. to 7 A.M; to go live with a woman and get on public aid, to go too one of the worst school
in the CPS was in the “Best Interest” of that child.
No, this case is not about the fact that the judge in that probate case never had legal jurisdiction
over the parties, this case is not about the fact, that without legal jurisdiction there could not be a
clime to immunity. No! This case is about the fact that one of the defendants talk about how they
did not want “Niggas” coming to his town to shop. There is no immunity for being a Raciest!
Argument
Point of fact, this case is not about a GAL. This case is not about what the Defendant (s) did or
did not do in the probate case of Z.W. This is not about how the Defendant (s) lied; fake and
forge legal documents, talks wittiness into telling lies and not coming to court after being
subpoena speaks to what he did in that case.
No, this case is about a Raciest, and not just any type of racist; one that had the power to control
life and death; one that used that power to harm. ARDC said that it was Defendant David Gotzh
word against Plaintiff Muhammad and unless another lawyer came forward, it was nothing they
FILED DATE: 8/20/2019 10:19 PM 20196004314
could do. Well, in this case, Plaintiff Muhammad will have those lawyers in court to tell what
Defendant David Gotzh did; and each action done by Defendant David Gotzh was personal.
This case is about “n***a Time”
What is n***a Time or as it is called “CP” time? This is something that is used to describe laze;
late color people. it is something that some Racist think that all black people are always late and
has become a joke to describe them.
So on about February 8, 2018, I had a conversation with Defendant Davie Gotzh, and it was
during our first call he said to that the only way Joyce would get Zion back; is if “she won the
lottery”. I have an email about this conversation that can support that this was said; I wrote
about him in my first ARCD complaint about him. So, for Defendant Davie Gotzh to say that
what he said to me is in my head; well it was in my head before he tried to judicial lynch me.
Now, Defendant Davie Gotzh and I were talking about the motion I had filed to dismiss the case
as we were never giving service to anything and it was during this conversation he talks to me
about his background and it was in that talk that he wanted to meet Zion. Now during this talk,
Defendant Davie Gotzh talks about not coming on “CP”; he was an old school German and when
he says 3 P.M. that is 3 pm; not 3:10 or “CP” time.
Now, I am over 50 and a White man just told me over the phone not to come on “n***a Time”
and I was to say nothing? Well, that is not how I am built. The conversation ended with
Defendant Davie Gotzh saying to me that he and I will just meet “man to man”. Once more this
is all in my reports from day one; this is all the emails to CVLS. So, I had to have the
forethought that I was going to be at this point to make this up.
So, I have to ask the question what changes in 3 months; Joyce did not hit the lotto; she did have
a one on one with Defendant Davie Gotzh alone and it was during that meeting that he came out
with one job in life; to make me pay. He wanted to cause me harm; he wanted me to pay. Was it
personal due to what Joyce had told him; or done for him; or was it due to the fact that he was
upset that as I black man I dare to stand up to him?
I want to know why this happened; I want to know what was CVLS reason for supporting
Defendant Davie Gotzh; what did he tell them to make them overlook all that he was doing. Is
this the first time CVLS had fake paperwork in a case; is this the norm for them. How many
other black men have been destroyed by CVLS. Last how many other racists do they have
working under them. All these questions I want to get an answer to, as it is the only way I can
move on; I need to know WHY? And A jury can help me get these answers
Was Defendant Davie Gotzh hate for me based solo on the fact that I am black? Or was it a
hatred for a man that was a Muslim; he jokes about Plaintiff Muhammad religious, he made it
clear that he would and was going to do anything that he wanted to, as he is a lawyer and he is
White, and he will be believed over me.
FILED DATE: 8/20/2019 10:19 PM 20196004314
All these action’s and claims are issues that should go before a Jury as the defendants want to
make this case disappear because they knew that they had a raciest working for them and did
nothing to stop him.
During the first conversation that Plaintiff Mahdee Muhammad had with Defendant David
Gotzh; it was two things that Defendant Gotzh made clear, he was an Old-School German, and
he was a Racist. However, the defendants want to say that somehow a raciest has judicial
immunity; or that Plaintiff Mahdee Muhammad will not be able to prove that not only did he
personal suffer harm, however, but this harm was also solo based on race.
We are living in a time where parents are giving up their child so that they can go to school for
free; after Defendant David Gotzh made racist remarks to the Plaintiff, and his actions were
reported; the Defendant (s) did all that was in their power to hurt him. Defendant David Gotzh
made it clear that he was not going to let the Plaintiff adopt this little black boy as the life of
going to school, playing baseball and having life experience of love was not the best life for him.
It was better for him to be on the street, killing, selling drugs; after all, as Defendant David
Gotzh said all black boys are wanting to be gang members.
As for judicial immunity; the state laws allow for Judges to have immunity from being sued for
any legal actions that they do when it falls under the authorly as a judge. However, any actions
done by a judge when they do not have legal jurisdiction are not protected by immunity When a
judge knows that she/him lacks jurisdiction or acts in the face of clearly valid statutes expressly
depriving she/him of jurisdiction, judicial immunity is lost. Rankin v. Howard, (1980)
633 F.2d 844, cert den. Zeller v. Rankin, 101 S.Ct. 2020, 451 U.S. 939, 68 L.Ed 2d 326. In
Rankin v. Howard, 633 F.2d 844 (1980) the Ninth Circuit Court of Appeals reversed an Arizona
District Court dismissal based upon absolute judicial immunity, finding that both necessary
immunity prongs were absent; later, in Ashelman v. Pope, 793 F.2d 1072 (1986), the Ninth
Circuit, en banc , criticized the "judicial nature" analysis it had published in Rankin as
unnecessarily restrictive. But Rankin's ultimate result was not changed, because Judge Howard
had been independently divested of absolute judicial immunity by his complete lack of
jurisdiction. Some Defendants urge that any act "of a judicial nature" entitles the Judge to
absolute judicial immunity. But in a jurisdictional vacuum, (that is, absence of all jurisdiction)
the second prong necessary to absolute judicial immunity is missing. Stump v. Sparkman, id.,
435 U.S. 349. "Where there is no jurisdiction, there can be no discretion, for discretion is
incident to jurisdiction." Piper v. Pearson, 2 Gray 120, cited in Bradley v. Fisher, 13 Wall. 335,
20 L.Ed. 646 (1872) A judge must be acting within his jurisdiction as to subject matter and
person, to be entitled to immunity from civil action for her/his acts. Davis v. Burris, 51 Ariz.
220, 75 P.2d 689 (1938) Generally, judges are immune from suit for judicial acts within or in
excess of their jurisdiction even if those acts have been done maliciously or corruptly; the only
exception being for acts done in the clear absence of all jurisdiction. Gregory v. Thompson, 500
F2d 59 (C.A. Ariz. 1974) There is a general rule that a ministerial officer who acts wrongfully,
although in good faith, is nevertheless liable in a civil action and cannot claim the immunity of
the sovereign. Cooper v. O'Conner, 99 F.2d 133 When a judicial officer acts entirely without
FILED DATE: 8/20/2019 10:19 PM 20196004314
jurisdiction or without compliance with jurisdiction requisites he may be held civilly liable for
abuse of process even though her/his act involved a decision made in good faith, that her/he had
jurisdiction. State use of Little v. U.S. Fidelity & Guaranty Co., 217 Miss. 576, 64 So. 2d 697
Judge Susan Kennedy-Sullivan never had legal judication as such she never was protected under
jurisdiction immunity; as such, Defendant David Gotzh did not have any immunity for his
actions. With all that being said; the Plaintiff Mahdee Muhammad is suing Defendant David
Gotzh for his action’s as a lawyer not as a GAL.
The reason why the defendants even added the conversation about this judge was only done for
one reason and that was to bias this court. The actions of the judge in the probate court have no
bearing on this case; as the judge was only doing what defendant David Gotzh advise her to do
as he was her eyes and ears in her court. The problem she had was that she had a raciest leading
her; and everything he did was solo based on his White Nationalist beliefs.
Plaintiff Mahdee Muhammad is suing Defendant Rebekah A. Rashidfarokhi as she was
Defendant David Gotzh supervisory and did nothing to stop his actions or behavior; she is not
being sued for being a GAL, and CVLS is not either. Each argument made in the defendant’s
motion is an argument that should be made in a trial, not in motion based on no facts. Raciest do
not have the right to clime immunity, and the truth is that the Federal Court said this case should
be heard on the state level and that is why it was filed in the Law Division in 6th district.
The Defendants filed their motion under 735 ILCS 5/2-615 and the laws are clear:
(735 ILCS 5/2-615) (from Ch. 110, par. 2-615)
Sec. 2-615. Motions with respect to pleadings. (a) All objections to pleadings shall be raised
by motion. The motion shall point out specifically the defects complained of, and shall ask for
appropriate relief, such as: that a pleading or portion thereof be stricken because substantially
insufficient in law, or that the action be dismissed, or that a pleading be made more definite and
certain in a specified particular, or that designated immaterial matter be stricken out, or that
necessary parties be added, or that designated misjoined parties be dismissed, and so forth.
(b) If a pleading or a division thereof is objected to by a motion to dismiss or for judgment or
to strike out the pleading, because it is substantially insufficient in law, the motion must specify
wherein the pleading or division thereof is insufficient.
(c) Upon motions based upon defects in pleadings, substantial defects in prior pleadings may
be considered.
(d) After rulings on motions, the court may enter appropriate orders either to permit or require
pleading over or amending or to terminate the litigation in whole or in part.
(e) Any party may seasonably move for judgment on the pleadings.
However, the defendants have used their motion to augur their case; as such if they feel that the
plaintiff cannot prove his case; they should argue these facts before a Jury. As the plaintiff is
FILED DATE: 8/20/2019 10:19 PM 20196004314
ready to prove that the defendants acted willfully, maliciously, and/or with reckless disregard of
the consequences of their actions. Accordingly, the plaintiff is entitled to an award of damages.
The plaintiff complaint gives a background into how the plaintiff was injured and whom he feels
cause his injury and under 735 ILCS 5/2-603) (from Ch. 110, par. 2-603)
Sec. 2-603. Form of pleadings. (a) All pleadings shall contain a plain and concise statement of
the pleader's cause of action, as at fault that is all that is required under 735 ILCS 5/2-601) (from
Ch. 110, par. 2-601)
(735 ILCS 5/2-604) (from Ch. 110, par. 2-604)
Sec. 2-604. Prayer for relief. Every count in every complaint and counterclaim shall contain
specific prayers for the relief to which the pleader deems himself or herself entitled except that in
actions for injury to the person, no ad damnum may be pleaded except to the minimum extent
necessary to comply with the circuit rules of assignment where the claim is filed.
(735 ILCS 5/2-612) (from Ch. 110, par. 2-612)
Sec. 2-612. Insufficient pleadings. (a) If any pleading is insufficient in substance or forms, the
court may order a fuller or more particular statement. If the pleadings do not sufficiently define
the issues, the court may order other pleadings prepared.
(b) No pleading is bad in substance which contains such information as reasonably informs the
opposite party of the nature of the claim or defense which he or she is called upon to meet.
The Plaintiff, in his complaint, made it clear and precise as to what happens and if the defendant
wants to argue the facts; that should be done in a response or during the mandatory arbitration.
Not in a motion saying what the plaintiff listed in the background is not fractural.
(735 ILCS 5/2-616) (from Ch. 110, par. 2-616)
Sec. 2-616. Amendments.
(a) At any time before final judgment amendments may be allowed on just and
reasonable terms, introducing any party who ought to have been joined as plaintiff or
defendant, dismissing any party, changing the cause of action or defense or adding
new causes of action or defenses, and in any matter, either of form or substance, in
any process, pleading, bill of particulars or proceedings, which may enable the
plaintiff to sustain the claim for which it was intended to be brought or the defendant
to make a defense or assert a cross-claim.
Each point made in the defendant motion, not one of them addresses the central allegation in the
plaintiff complaint. That being Defendant David Gotzh is a White National Racist; who have
referred to all Black Males as “gang banger thugs”; and how he wanted to keep them out of his
all “White Town.” Defendant David Gotzh as a lawyer he uses the power giving to him by
CVLS and Rebekah A. Rashidfarokhi to cause harm to plaintiff Mahdee Muhammad an African
American, and this was solo based on RACE!
FILED DATE: 8/20/2019 10:19 PM 20196004314
The defendants want this court to think that this case is about a probate case, and how as the
GAL for a minor they did what was in the best for that minor. This case is far from that it is
about a Racist Lawyer. A raciest lawyer who said that it was better for a 12-year-old African
American male to be removed from the only home that he had known since he was three months.
Just because the plaintiff was a black man that file an ARDC report on him.
The defendant’s in this case felt that it was best for this 12-year-old to go live in a war zone
down on 89th street in the City of Chicago where there are 5 or more shooting a week. However,
they say that it is a up and coming neighborhood. These defendants said it was in the best interest
for a 12-year-old to go live with a woman who was not only still prostitution, however, had just
been evicted from last 7 plaice where she was staying within a year. This is just a little
background into that probate case that the defendants talk about.
Let me be clear this case is about lawyers; it is about a lawyer that condone perjury and perjury
themselves in a court. Lawyer that forges legal paperwork. The Defendant in their motion
address the First District Appellate Court decision of the probate case; once more I do not know
why; however, that decision was based on the fact that Defendant David Gotzh was able to make
the court feels that the case was about notice; as that case was never about notice. It was about
the fact that service was never done, and Defendant (s) knew this. However, the courts allowed
them the defendant (s) tell the story as that is how our systems is set up. Lawyers can lie in court
and nothing has been done. That is why the plaintiff is asking for a jury trial
This is what the defendants want to do in this case; they filed a book hoping this court would just
take their word as Lawyers. In that probate case, the court never got service on anyone, and this
is a fact that is before the Illinois Supreme Court, and the plaintiff will take it up to the U.S
Supreme court if need be.
The Defendants want to cloud this case with their motion. The Defendants want to play same
tricks that they played with the other courts. It wants this court to feel that the actions in the
probate court was in the best interest to that minor; and that a court can judicate a case without
having legal service and legal jurisdiction. When in fact those assumption is for a jury to
considers not, not grounds to bring or received a motion to dismiss.
It is 8/20/19 and I could wait and submit my response on the last day at the last second; however,
I choose this date as this is Zion 13th born day. My wife, children; nor I could call him and wish
him a happy Born Day; that is because Joyce Washington his birth mother phone is off; she is
once more living with someone. Zion has no clothes and he is living with the person that came to
court and lied under oath. She did this as she told me, Davide knew she was going to lie, and he
was ok with it.
To be honest the Judge in the probate case told me to my face that she did not care whom told
lies or not as she does not like me; nor does she trust me and this was all based on the fact that a
Racist had poisoned her mind. He told her stories about me because he could not put me in my
place.
FILED DATE: 8/20/2019 10:19 PM 20196004314
50 years ago, Davide could have just taken me out to the center and had my lynch, today he does
he lynching in a courtroom. I hired a private investigator during the probate case (David Gotzh
knew about this and he told Joyce Washington) and I did not only pay him to let me know about
Joyce; I wanted to know everything about David Gotzh; as he used “color people” time with me
as it was nothing and I wanted to know what type of man he was.
I found out that he was a racist, I found out that his father was a retired state police cop and got
away with ruining over a 12-year-old Hispanic girl and killed her. I reach out to Rebekah A.
Rashidfarokhi time after time to request that he remove him from that case, and she did nothing.
She knew that Joyce was telling lies and she had a choice to make; she was going to be against
racism, or she was going to be with it, and she chose to be with a raciest.
The probate case that the defendant’s talk about in their motion is in the hands of the Illinois
Supreme Court (125045 and 125042); and if they do not take the case, I am going to take it to the
U.S. Supreme court. I am going to fight in the courts to save that little black boy that CVLS toss
away his life like a dirty rag.
There is no case law that gives Raciest Immunity from being sued
I am coming before this case for one reason and only one; My rights were violated based solo on
race and there is no court in the land that has said A racist is immune for being a racist. I am
suing these parties for that reason and only that reason; as such:
The Plaintiff has a JURY TRIAL DEMANDED on Record;
WHEREFORE, plaintiff respectfully requests that this Court to Denied the Defendant’s Motion
and transfer this case for Trail.
Mahdee Muhammad
123 Indinwood Blvd # 340
Park Forest, IL 60466
708-819-0619
Statement of Verification
I have read the above response, and it is correct to the best of my knowledge.
Your signature
.
Pro-Se, Mahdee Muhammad
FILED DATE: 8/20/2019 10:19 PM 20196004314