(TEN)Patricia Lyons and the Friend of the Court

STATE OF MICHIGAN
IN THE 44th JUDICAL CIRCUIT COURT OF (LIVINGSTON COUNTY)
AND FRIEND OF THE COURT
210 S. HIGHLANDER WAY, HOWELL, MICHIGAN, 48843
JUDGE’S COPY
FRIEND OF THE COURT
210 S. HIGHLANDER WAY HON. JUDGE CAROL HACKETT GARAGIOLA
HOWELL, MICHIGAN 48843 Case no. 96-23807-DM
734-250-2734

PATRICIA A. LYONS
1916 NORVELL ROAD
GRASS LAKE, MICHIGAN
Plaintiff
V.

GEORGE EDWARD LYONS
P.O. BOX 226
PINCKNEY, MICHIGAN 48169
734-675-1679 Defendant
___________________________________/

PROOF OF SERVICE

Defendant George Edward Lyons on day of Tuesday, August 07, 2007has used the U. S. Postal service at Pinckney Post office and mail and served a copy of Defendant Objection for referee report and recommendation of Referee Robert J. Hotchkiss. For defendant’s proposed Motion of Parenting time and criminal actions caused by the Plaintiff Patricia Ann Lyons and PROOF OF SERVICE in the action upon: Plaintiff Patricia A. Lyons. Delivery address 1916 Norvell Road, Grass Lake, Michigan

I DECLARE THAT THE ABOVE STATEMENTS ARE TRUE TO THE BEST OF MY INFORMATION, KNOWLEDGE, AND BELIEF.



_________________________________,
GEORGE EDWARD LYONS
P.O. BOX 226
PINCKNEY, MICHIGAN 48169
734-675-1679
Tuesday, August 07, 2007



STATE OF MICHIGAN
IN THE 44th JUDICAL CIRCUIT COURT OF (LIVINGSTON COUNTY)
AND FRIEND OF THE COURT
210 S. HIGHLANDER WAY, HOWELL, MICHIGAN, 48843

FRIEND OF THE COURT
210 S. HIGHLANDER WAY HON. JUDGE CAROL HACKETT GARAGIOLA
HOWELL, MICHIGAN 48843 Case no.96-23807-DM
734-250-2734

PATRICIA A. LYONS
1916 NORVELL ROAD
GRASS LAKE, MICHIGAN
PlaintiffV.

GEORGE EDWARD LYONS
P.O. BOX 226
PINCKNEY, MICHIGAN 48169
734-675-1679 Defendant
___________________________________/



DEFENDANTOBJECTIONSFORREFEREEREPORT ANDRECOMMENDATIONOFREFEREE ROBERT J. HOTCHKISS


NOW COMES THE DEFENDANT George Edward Lyons.

Defendant now argues that the referee report and recommendation of the referee erred in entering the report of referee recommendation. The Defendant feels that the referee is protecting the Plaintiff and other people from criminal actions that the Defendant wants to expose. The defendant is now requesting a de novo hearing pursuant to MCL 552.507 (5).

"To expedite the resolution of a child visitation and Plaintiff criminal actions dispute by prompt and final adjudication, all orders and judgments of the circuit court shall be affirmed on appeal unless the trial judge made findings of fact against the great weight of evidence or committed a palpable abuse of discretion or a clear legal error on a major issue." MCL 722.28.

The trial court’s if the findings are against the great weight of the evidence and if the evidence clearly preponderates in the opposite direction. Mogel v Scriver, 241 Mich App 192, 196; 614 NW2d 696 (2000). The abuse of the Plaintiff is found only in extreme cases in which the result is so palpably and grossly violative of fact and logic that it evidences a perversity of will, a defiance of judgment, or the exercise of passion or bias. Fletcher v Fletcher, 447 Mich 871, 879,880; 526 NW2d 889 (1994). MCL 552.507 (5) provides, in relevant part: (5)

The court shall hold a de novo hearing on any matter that has been the subject of a referee hearing, upon the written request of either party or upon motion of the court. The Defendant is now requesting to hearing on all matters that has been the subject of the referee hearing. Both visitation and criminal actions of the Plaintiff.

The Defendant had met the time and objections was made within 21 days after the recommendation of the referee is made available to that party under subsection.
. .
Thus, if either party objects to the referee’s report or recommendation, the trial court must hold a de novo hearing. Harvey v Harvey, ___ Mich App ___ ; ___ NW2d ___ (Docket No 244950, issued June 24, 2003), citing MCR 3.215(E)(3)(b); Cochrane v Brown, 234 Mich App 129, 133-134; 592 NW2d 123 (1999).2This hearing must be a hearing de novo, not merely a de novo review. Cochrane, supra at 132, citing Mann v Mann, 190 Mich App 526, 529; 476 NW2d 439 1

Some of the allegations against plaintiff were that she was sporadically, she failed to maintain the marital house from a fraudulent foreclosure that the Plaintiff participated in. with Karl and Marian Kopp of which is a criminal act.

o Plaintiff committed a fraudulent domestic charge against Defendant by making a false police report. Supported by Kathy Fett who was investing $ 137,000.00 to pay off Karl and Marian Kopp also who committed a Fraudulent forfeiture against the Defendant.

o Plaintiff filed fraudulent statement in the Divorce papers of the summons and complaint to remove Defendant from marital home wrongly supported by Plaintiff divorce attorney Brian Lavan, also employer of referee Gerald Edit.

o Employees of the Livingston County Court system and others had received bribery. The Legal definition of Bribery is:
Bribery n. the crime of giving or taking money or some other valuable item in order to influence a public official (any governmental employee) in the performance of his/her duties. Bribery includes paying to get government contracts (cutting the roads commissioner in for a secret percentage of the profit), giving a bottle of liquor to a building inspector to ignore a violation or grant a permit, or selling stock to a Congressman at a cut-rate price. Example: Governor (later Vice President) Spiro T. Agnew received five cents from the concessionaire for each pack of cigarettes sold in the Maryland capitol building.

The definition has been expanded to include bribes given to corporate officials to obtain contracts or other advantages which are against company policy.

o Bribery was taken by Livingston County Court employee’s by doing bribery, they committed judicial misconduct, tortuous interference, and civil conspiracy, and more.

o Employees of the Livingston County Court system and other have committed tortuous interference. Legal definition of tortuous interference.

Tortuous interference is the unlawful interference into one’s contractual or business affairs. For example, someone who uses the web to defame an individual’s business and contacts their customers (or prospective customers) may be violating this law. A special case of tortuous interference called “Tortuous Interference with Prospective Advantage” is available in some states to punish those who seek to damage one’s ability to find and retain new customers.

o Employees of the Livingston County Court system and other have committed civil conspiracy. Legal definition of Civil Conspiracy.

CIVIL CONSPIRACY - 'The elements of an action for civil conspiracy are the formation and operation of the conspiracy and damage resulting to plaintiff from an act or acts done in furtherance of the common design. . . . In such an action the major significance of the conspiracy lies in the fact that it renders each participant in the wrongful act responsible as a joint tortfeasor for all damages ensuing from the wrong, irrespective of whether or not he was a direct actor and regardless of the degree of his activity.'' (Doctors' Co. v. Superior Court (1989) 49 Cal.3d 44, citing Mox Incorporated v. Woods (1927) 202 Cal. 675, 677-78.)' (Id. at 511.)

'Conspiracy is not a cause of action, but a legal doctrine that imposes liability on persons who, although not actually committing a tort themselves, share with the immediate tortfeasors a common plan or design in its perpetration. By participation in a civil conspiracy, a coconspirator effectively adopts as his or her own the torts of other coconspirators within the ambit of the conspiracy. In this way, a coconspirator incurs tort liability co-equal with the immediate tortfeasors. Standing alone, a conspiracy does no harm and engenders no tort liability. It must be activated by the commission of an actual tort. ''A civil conspiracy, however atrocious, does not per se give rise to a cause of action unless a civil wrong has been committed resulting in damage.'' 'A bare agreement among two or more persons to harm a third person cannot injure the latter unless and until acts are actually performed pursuant to the agreement. Therefore, it is the acts done and not the conspiracy to do them which should be regarded as the essence of the civil action.' [para.s] By its nature, tort liability arising from conspiracy presupposes that the coconspirator is legally capable of committing the tort, i.e., that he or she owes a duty to plaintiff recognized by law and is potentially subject to liability for breach of that duty.' (Allied Equipment Corp. v. Litton Saudi Arabia Ltd., supra, 7 Cal.4th at 510-11.)

Finally, Defendant alleges that plaintiff and referee Gerald Edit and Dr. Richard Zipper along with Monica Coupland, court appointed attorney for the Defendant and Plaintiff children. These people acted in fabricated false psychological problems against the Defendant to stop the Defendant in having a fair and un-bias trial.
2

MCR 3.215(E) (3) (b), sets forth the requirements for a Defendant to obtain a judicial hearing on any matter that has been the subject of a referee hearing. (1991).

This is supported by the Defendant complaint filed with the Friend of the court. This means that the trial court is required to conduct a hearing as if no friend of the court hearing had been conducted previously, and the court must arrive at an independent conclusion. Marshall v Beal, 158 Mich App 582, 591; 405 NW2d 101 (1986).3

At the hearing before the referee, after both parties made their testimonies and objections, the recommendation stated the following:

The point I am making here, this is a very important matter to the Friend of the Court. These matters are not taken lightly when this is done. The reasons why this matter was brought before the Court is that the referee, after hearing the evidence, made certain recommendations.

After reading what was submitted to this Court referee report, and based on that recommendation and the fact that if this Court may agree that there are too many allegations by the Defendant involved in the visitation of the child and criminal acts of the Plaintiff. It causes complications, leads to unnecessary litigation, under the circumstances, and in light of the referee report minimal analysis, The Defendant will find that the trial court failed to conduct a proper de novo hearing.

The statutorily authorized report and recommendation of the referee are not admissible as evidence at a visitation or the referee failed at his job. Or Custoy hearing unless both parties agree to admit the evidence. Duperon v Duperon, 175 Mich App 77, 79; 437 NW2d 318 (1989). However, the report may be used as an aid to understanding the issues to be resolved that shows the contuious biasness of the Friend of the court and the criminal action against the Defendant. Id.; Harvey, supra.

The, Defendant is objecting to the referee’s report and recommendation and now request a de novo hearing before the State of Michigan administration office for a De nova hearing. And, if the hearing, the trial court expressly stated that it based its decision on the referee’s recommendation. At most, the trial court must conduct a de novo review, and not a de novo hearing. MCL 552.507. (5) Expressly provides for a de novo hearing, and, under MCL 552.507. (5), Defendant is entitled to “a hearing as if no friend of the court hearing had been conducted previously and [the circuit court must] arrive at an independent 3 note that per MCL 552.507. (5)

WRITTEN REQUEST

The Defendant is now placing in writing a request in require in writing by this document. Defendant did at Three (3) different times filed an actual written request for a de novo hearing. And this request be granted, It is clear from the transcripts that Defendant continuously requested an evidentiary hearing throughout the proceedings; Defendant have been able to verify by the record that, before the referee’s recommendation, Defendant filed a written motion which was filed properly for a de novo hearing and Emergency Disqualification of Chief Judge Susan Reck. Chief Judge Susan Reck failed to follow the Michigan Court Rules 2.003. Stating that MCR.2.003 (b).

ALTERNATIVE, IF THIS MOTION IS DENIED, Defendant respectfully demands;

(b) In a single-judge court, or if the challenged judge is the chief judge, on the request of a party, the challenged judge shall refer the motion to the state court administrator for assignment to another judge, who shall decide the motion de novo.

On three (3) different Emergency Motions for Disqualification for Biasness of Judge Susan Reck the Judge fail or refused to this case to the state of Michigan administrator for assignment to another judge, who shall decide the motion for a de novo hearing. The request is to re-open this motion and follow the Michigan Court rules 2.003


The record is clear that the friend of the court referee held a hearing and made his recommendation, the Defendant will want to go before the trial court stating his objections to the referee’s recommendation. Defendant acknowledged in his brief that Defendant will seek review of the referee’s findings, but rather than argue the merits of a hearing pursuant to MCL 552.507 (5), defendant argues that he will be entitled to an evidentiary hearing pursuant to MCR 3.210(C)(7). Defendant raised this issue regarding MCL 552.507 (5) in Defendant brief, the Plaintiff will have time to respond to that argument. Because there has been arguments made that the requirements for requesting a de novo hearing are met, I raise the issue on my own constitution rights as the Defendant.

conclusion.” Marshall, supra at 591. Accordingly, Defendant finds that the trial court’s failure to follow the Michigan Court rules 2.003 on Three (3) different emergency motions for Disqualification of Judge Susan Reck for a hearing de novo in this case was clear error requiring vacation of the court’s order.

The defendant primarily argues that the trial court properly would conduct an evidentiary hearing because under MCR 3.210(C) (7), an evidentiary hearing is required because there was a “contested factual issue to resolve in order to make an informed decision by the Plaintiff.” MCR 3.210(C) (7), provides: (7)

In deciding whether an evidentiary hearing is necessary with regard to a post judgment motion to change visitation and criminal charges against the Plaintiff which cause injustice against the Defendant, the court must determine, by requiring an offer of proof or otherwise, whether there are contested factual issues that must be resolved in order for the court to make an informed decision on the motion. The trial court, however, determine that an evidentiary hearing is necessary under MCR 3.210(C) (7). Rather, the trial court conducted a hearing, but may not improperly rely on the referee’s recommendation in arriving at its decision. Further, the trial court should not state or imply that it relied on MCR 3.210(C) (7) to dispose of the matter.

Therefore, because there may be no indication that the trial court relied on MCR 3.210(C) (7) in arriving at its decision, defendant’s arguments are in place. Defendant will not vacate the order of the trial court and remand this case for a hearing de novo of which Defendant demands that this case be sent to the State of Michigan administration office for a De Novo hearing. In light of Defendant disposition of this issue, Defendant need not address plaintiff’s remaining issues on concerning whether the trial court failed to make findings of fact relative to the best interests of the child. On remand, after a de novo hearing, the trial court must state its independent conclusions, including its findings with regard to the best interests of the child and the criminal acts of the Plaintiff. Defendant do note, Defendant also asserts that the trial court and the referee should be disqualified from the case because they have previously reached prejudicial conclusions through referee Gerald Edit without having heard testimony from the Defendant and refusing to act. Defendant position and leave it to this Court to discover and rationalize a basis for his claim. Wilson v Taylor, 457 Mich 232, 243; 577 NW2d 100 (1998).

Here, Defendants “presented a proper relief [request for relief] with citation and authority.” Id. Accordingly, this issue has been properly presented, and referee has not addressed it. Vacated and remanded for further proceedings consistent with this opinion. The Friend of the court can not retain jurisdiction. And must send this case to the State of Michigan Administration for a De nova hearing, Transferring this case to another Court outside the County of Livingston.

Again Chief Judge Susan Reck on three (3) emergency motion of disqualification for biasness from the Defendant and per the Michigan Court Rule Chief Judge Susan Reck failed to follow the Michigan Court rules 2.003 and refused to send this case to the State of Michigan Administration office for a De nova hearing.

To recap Defendants criminal allegations against Plaintiff and others

Plaintiff Patricia A. Lyons caused the following illegal and criminal actions against Defendant George Edward Lyons.

Plaintiff Patricia A. Lyons actions falls under tortuous interference, civil conspiracy, embezzlement, Plaintiff making false police reports, And Plaintiff Patricia A. Lyons making fraudulent statements that Plaintiff Patricia A. Lyons was the owner of 5640 Shoshoni Pass, Pinckney, Michigan to embezzle monies. Property owned by Defendant George Lyons and his company.

PLAINTIFF CAUSED LOSE OF DEFENDANT’S OFFICES
AND COMPLETE LOSE OF INCOME FOR DEFENDANT NOW AND IN THE FUTURE.A.

First in 1989 Plaintiff Patricia A. Lyons without notice to the Defendant George Edward Lyons went to the one of the offices of Lyons & Associates, Inc. at 2800 South State Street, Ann Arbor, Michigan contacted the office manager and 8 other agents of Lyons & Associates, Inc. that the office is closing.

This was a major downfall of Lyons & Associates, Inc. Company. 6 agents will testify that Plaintiff Patricia A. Lyons this undermining of Lyons & Associates, Inc. causing the company to close the Ann Arbor office and lost of 8 agents. These illegal actions are the beginning of a series of misconduct of Plaintiff Patricia Ann Lyons part against the Defendant George Lyons and his companies.

B. Plaintiff Patricia A. Lyons filed a fraudulent Domestic Abuse police report. This was done by the plaintiff to illegally remove Defendant from the marital home 1194 Camelot, Pinckney, Michigan. This caused the Defendant to be wrongfully charged with a false police report which caused Defendant George Lyons to serve 2 years probation. Evidence for this wrong doing was uncovered in 2005.


PLAINTIFF AND OTHERS HIDE EVIDENCE FROM DEFENDANT.

C. Plaintiff Patricia A. Lyons obstructed the Defendant George Lyons by destroying evidence of the Defendant. This evidence was placed into a dumpster in 2004 and recovered in 2004.


PLAINTIFF EMBEZZLES MONIES FROM DEFENDANT AND CAUSING A LOST OF $ 160,000.00 FOR DEFENDANT.

D. Plaintiff Patricia A. Lyons embezzled monies from Defendant George Edward Lyons Company’s property located at 5640 Shoshoni Pass, Pinckney, Michigan. Plaintiff Patricia A. Lyons stated under oath she was the owner of 5640 Shoshoni Pass, Pinckney, Michigan, to acquire illegal funds from the Defendant and his company.

E. Plaintiff Patricia A. Lyons filed a fraudulent statement to the Friend of the Court referee Gerald Edit.

PLAINTIFF AND FRIEND USES DAUGHTER TO MAKE FRAUDULENT STATEMENT TO FRIEND OF THE COURT AGAINST DEFENDANT.

Plaintiff Patricia A. Lyons wrote a fraudulent letter that the Defendant George Edward Lyons personally stated to there daughters (Jeannine and Justina Lyons that “Defendant George Lyons stated that there was someone out to Kill the Daughters and cut there fingers off with a carpenter knife”. The evidence is proven on audio tapes.

This statement was wrongfully made by Plaintiff Patricia Ann Lyons and her friend Dale Fisher to Defendant and Plaintiff daughters Jeannine Lyons and Justina Lyons.

This wrongful statement made by the plaintiff who caused the Defendant to do supervised visitations with his daughters, and attend wrongfully mental review before Dr. Richard Zipper.

The illegal actions of the Plaintiff Patricia A. Lyons and her wrongful indoctrination or programming of there children Jeannine Lyons and Justina Lyons.

Causing Defendant in not having proper parenting time with his children. For the full year of 2006. And since 1998.

PLAINTIFF FRAUDULENT STATEMENTS CAUSED LOST OF PARENTING TIME OF THE DEFENDANT WITH HIS CHILDREN, AND LOST OF INCOME FOR THE DEFENDANT NOW AND INTO THE FUTURE.

Defendant has only two visitations of his daughters. Which consisted of Defendant first visit 1 hour and his second visit was 2 ½ hours which took place two weeks after Christmas.

The above illegal and criminal actions over the years of the Plaintiff Patricia A. Lyons caused lost of money for the Defendant George Edward Lyons for legal representation.

These illegal actions of the Plaintiff over the years caused the Defendant George Edward Lyons to face fraudulent N.S.F. charges, which caused the Defendant George Edward Lyons to wrongfully be charged and serve 5 years probation.

And caused the Defendant George Lyons the lost of his real estate broker license and his residential builder’s license of 25 + years. Because of the illegal and criminal actions of the Plaintiff Patricia A. Lyons. During the 25+ years of the above Defendant George Lyons or his companies had no violations or lawsuits filed against him or his companies.

These wrongful actions over the years which caused Defendant George Lyons in having no money to pay for an attorney, housing, and child support.

This then caused the Defendant George Lyons to search for a minim wage jobs.

Now the Plaintiff George Lyons having to expose his wrongful felony charges on all workers application, Defendant George Lyons could not acquire a job.

In placing the Defendant in an indigent possession. And being homeless and having to live in a car for 4 years and placing Defendant in arrears of child support.

The following loses Defendant George Lyons caused by the illegal and criminal actions of Plaintiff Patricia Ann Lyons.

1 Defendant lost his rights as a father to his daughters Jeannine
Ann Lyons and Justina Marie Parker Lyons. Because Plaintiff
Patricia Ann Lyons wrongful interference actions.

And Plaintiff Patricia A. Lyons wrongful indoctrination and programming of the Defendant and Plaintiff children against the Defendant George Edward Lyons.

And Plaintiff illegal interference which stops the Defendant from giving proper payments for child support.

2) Defendant George Lyons loses of Martial home 1194 Camelot, Pinckney, Michigan 48169. Because Defendant Patricia Ann Lyons wrongful interference and criminal actions of making a false police report.

3) Defendant George Lyons loses of lot 2 Betty Lyons Lane, Pinckney, Michigan. Because Plaintiff Patricia Ann Lyons wrongful criminal actions.

Important Issue with Plaintiff Patricia A. Lyons and her attorney causing a criminal action against Defendant George Lyons.

4) Plaintiff Patricia A. Lyons wrongful actions of taking Defendants Company warranty deed which was submitted to Plaintiff attorney on lot 2 Betty Lyons Lane, which was granted from Kenneth and Shirley Morgan and granted to Lyons and Associates, Inc. and Karl and Marian Kopp.

5) And stated to grantor Kenneth and Shirley Morgan that Plaintiff of Defendant lost said warranty deed, which was criminally action on Plaintiff Patricia Ann Lyons part.

6) This action of the Plaintiff Patricia Ann Lyons illegally removed Karl and Marian Kopp interest on Lot 2 Betty Lyons Lane, Pinckney, Michigan. This was a criminal action on Plaintiff Patricia Ann Lyons part to acquire wrongful and illegal clear title on lot 2 Betty Lyons Lane, Pinckney, Michigan.

7) The criminal actions of Plaintiff Patricia Ann Lyons caused Defendant George Lyons the lost of $160,000.00 of builders profit.

8) Plaintiff’s Patricia Ann Lyons wrongful interference and embezzlement of funds from 5640 Shoshoni Pass, Pinckney, Michigan. Because of Plaintiff Patricia Ann Lyons criminal actions and fraudulent statement to the Livingston County Court system under where Plaintiff Patricia Ann Lyons was under oath.

Issues on Plaintiff Patricia A. Lyons interference.

9) In other criminal interference of Plaintiff Patricia Ann Lyons caused Defendant George Lyons loses of $ 387,000.00 owed to Defendant George Lyons from past clients cause by Plaintiff Patricia Ann Lyons.


10) The criminal interference of Plaintiff Patricia A. Lyons caused Defendant George Edward Lyons to wrongfully be charged and serves 2 years probation caused by Plaintiff Patricia A. Lyons making fraudulent police report for Domestic Abuse charges.

This was caused by Plaintiff Patricia Ann Lyons and her friend’s criminal actions and in making false statements in filing a fraudulent police report to the Pinckney Police. This evidence was re-discovered in 2005.

11) The illegal interference of the Plaintiff Patricia Ann Lyons the Defendant George Lyons had to serve 5 years probation for fraudulent N.S.F. charges because of Plaintiff Patricia A. Lyons interference.

12) And Plaintiff Patricia Ann Lyons wrongful actions against George Edward Lyons. Causing the Defendant George Lyons to indigent and hopelessness of acquiring employment.

13) In 2006 Plaintiff Patricia Ann Lyons a lawsuit was started by the Defendant George Edward Lyons against Plaintiff Patricia Ann Lyons this lawsuit was dismissed without prejudice by Honorable Judge Reader. The Plaintiff stated that she never received the Summons and Complaint.


Chief of State police Sharon Donnelly retired will testify in
Court that Mrs. Donnelly personally hands delivers the summons and complaint to Plaintiff Patricia Ann Lyons, but Plaintiff Patricia Ann Lyons refused to sign the receivership of the Summons and complaint. This case will be re-opened in the near future.

14) This case or allegation made by the Defendant George Edward Lyons falls under tortuous interference, civil conspiracy, embezzlement, perjury, filing false police reports etc, done by the Plaintiff Patricia Ann Lyons and others.

RELIEF

The Defendant George Edward Lyons hopes and prays Review all Three (3) Emergency motions for Disqualification of Chief Judge Susan Reck and remove this case from the Livingston County court system and send this Case no. 96-23807-DM to the State of Michigan administration office for a De nova hearing.

Defendant wish that this Court would have proceed in the below actions, but it did not happen

That this Honorable court grant a review in Defendants truthful allegations against the Plaintiff Patricia A. Lyons and others and finds Plaintiff Patricia Ann Lyons for her wrongful interferences and criminal actions of the Plaintiff and others against the Defendant George Edward Lyons.

And grant Defendant George Edward Lyons proper Parental Time for daughter Justina Marie Parker Lyons who turned 16 on February 16th 2007, and daughter Jeannie Ann Lyons who is not under this honorable court jurisdiction who turned 21 on April 5th 2007.

This injustice and criminal acts by the Plaintiff Patricia Ann Lyons and others against the Defendant George Edward Lyons has been on going on since 1989.

Respectfully submitted




_________________________________
Defendant George Edward Lyons
And father of Jeannine
And Justina Lyons
P.O. Box 226
Pinckney, Michigan 48169
734-954-4040
Tuesday, August 07, 2007

(Seven) Law suit George Lyons v. Lalonde and Storzbach

STATE OF Michigan
IN THE 44th JUDICAL CIRCUIT COURT OF (LIVINGSTON COUNTY)
210 S. HIGHLANDER WAY, HOWELL, MICHIGAN, 48843


GEORGE EDWARD LYONS A SINGLE MAN HONORABLE JUDGE
1711 PARKER ROAD Case no.
DEXTER, MICHIGAN 48130
734-426-5456

PLAINTIFF
-V-

CURT AND MARY ANN LALONDE H/W
3100 CRYSTAL SPRING LANE (AKA BETTY LYONS LANE)
Pinckney, Michigan 48169

DEFENDANTS

There is two other pending or unresolved criminal actions of Defendants making a false complaint to the State of Michigan Consumer & Industry services, reported against the Plaintiff for breach of contract, and Defendants filing a fraudulent judgment $72,900.00+ against the Plaintiff, arising out of this transaction or occurrence alleged in the complaint.

COMPLAINT

Plaintiff, George Edward Lyons, and for this Complaint, state:

COMMON ALLEGATIONS

1. Plaintiff, George Edward Lyons is a resident of Lima Township,
Washtenaw County, Michigan.

2. Defendants, Curt and Mary Ann Lalonde, are residents of Hamburg Township, in Livingston County, Michigan.

3. The actions of the Defendant, which give rise to this complaint, took place in Hamburg Township, Livingston County, Michigan.

4. Venue is proper in the 44th Judicial Court of Livingston County.


COUNT I-

FILING A FALSE COMPLAINT TO THE STATE OF MICHIGAN CONSUMER & INDUSTRY SERVICES TO SUPPORT STORZBACH FRAUDLENT LAW CASE, AND TO ACQUIRE ILLEGAL GAINS, IN THE LIVINGSTON COUNTY COURT SYSTEM.

5. Defendants Curt and Mary Ann Lalonde, made a fraudulent complaint against Plaintiff George Lyons, and Lyons Builders, Inc. Defendants suppressed evidence against Plaintiff. George Lyons was innocent on all fraudulent complaints made by the Defendants against the Plaintiff.

6. That the Defendants, had SUPPRESSSION OF EVIDENCE: the refusal to produce evidence or to allow evidence to be produced for use in litigation. Suppression of evidence refers most commonly to the sanction in a criminal case for an unreasonable search or seizure that violates a defendant’s constitutional rights. In 1914, the U.S. Supreme Court held that illegally seized evidence must be excluded from use in criminal trials.232 U.S. 383, In 1961, the Courts expanded the exclusionary rule to include state criminal trials, 367 U.S. 643. Defendants Curt and Mary Ann Lalonde, hid this evidence. Suppression of evidence also refers either to a party’s refusal to produce evidence or to interference by a party with the production of evidence when another party seeks the evidence pursuant to the law. In evidence may constitute an admission the evidence is unfavorable to the party refusing to product it. McCormick, Evidence 273 (2d ed. 1972

COUNT II-

filing a false Judgment on 3100 Crystal Spring lane aka Betty Lyons Lane, Pinckney, Mi. for $ 72,900.00+

8. Defendants acquired frauduant claims from the State of Michigan Consumer & Industry services to support there false levy on 3100 Crystal Spring Lane, aka (Betty Lyons Lane)Pinckney, Mi. See documents, and audiotapes.

COUNT III-COLLISION, OBSTRUCTION OF JUSTICE, MALIOUS PR0SECUTION

7. The Defendant may be possibly be charged with covering up evidence, collision, obstruction of justice, and malious prosecution by the Defendants attorney, and the Hamburg Police.

8. On the false filing, a false complaint to State of Michigan Consumer & Industry services. Defendants was audio taped, on may occasions, proving that his statements to Consumer & Industry Services were false and misleading, and that he criminally acquire funds from Lyons Builders, Inc. illegally, against 3100 Crystal Spring Lane, aka (Betty Lyons Lane)Pinckney, Mi.

9. Defendants, had made fraudulent statements to other clients and subcontractors, This was audio taped admitting that he had full knowledge that Defendants did, in fact, file a false and received a illegal Judgment on the Plaintiffs project at 3100 Crystal Spring Lane, aka (Betty Lyons Lane)Pinckney, Mi. giving illegal fraudulent support in the Livingston County Circuit Court.

10. The Plaintiff believes these actions of the Defendants made received a false judgment to illegally gains in 3100 Crystal Spring Lane, aka (Betty Lyons Lane)Pinckney, Mi. from the Plaintiffs.

11. Defendants had full knowledge and expressed it in an audio taped conversations with subcontractors, and George Lyons that Defendants Curt and Mary Ann Lalonde, conspiring against Plaintiff George Lyons and Lyons Builders, Inc. to illegally acquiring illegal control of Plaintiffs equity in 3100 Crystal Spring Lane, aka (Betty Lyons Lane)Pinckney, Mi. See audio tape

12. Plaintiffs has evidence of a criminal nature against Defendants Lalonde’s is available and, under the proper circumstances, will be presented to this honorable court.

13. That after Plaintiff was illegal being removed from 3100 Crystal Spring Lane, aka (Betty Lyons Lane) Pinckney, Mi. by Defendants. Fraudulent statements to Material handlers, and Subcontractors, past clients to protect the Defendants, illegal gains, Documents, audiotapes will be provided.

COUNT IV- filing and receiving a false Judgment 3100 Crystal Spring Lane, aka (Betty Lyons Lane)Pinckney, Mi. for $ 72,900.00+

14. Evidence has been obtained proving that Defendants committed a fraudulent and illegal filing of a $ 51,000,00+ levy on the Plaintiffs property at 5640 Shoshoni Pass, Pinckney, Michigan 48169. And permitting subcontractors to acquire illegal funds from 5640 Shoshoni Pass, Pinckney, Mi. 48169 equity to Plaintiff. This fraudulent clouding of 5640 Shoshoni Pass, Pinckney, Mi forcing to a pay-off subcontractors that was to be paid by Defendants.

DEFENDANTS MOTIVE

15. This Plaintiffs, belief is that Plaintiffs past clients conspired with Defendants Ronald and Virginia Storzbach were illegally removing Plaintiff from 5640 Shoshoni Pass, Pinckney, Mi. and 7709 Partridge Hill, Brighton, Mi. 48116. Defendants false allegations and illegal judgments against the Plaintiff’s, that if the Defendants Ronald and Virginia Storzbach, successfully remove Plaintiffs from and 7709 Partridge Hill, Brighton, Mi. 48116 by fraudulent statements by the Defendants.

16. And Defendants made fraudulent statements to other clients in Partridge Point, and other project outside of Partridge Point, Brighton, Mi. of which caused Plaintiffs in losing clients contracts.

17. That these fraudulent judgments and fraudulent statements would be used against Plaintiff George Lyons equity in 5640 Shoshoni Pass, Pinckney, Mi. and 7709 Partridge Hill, Brighton, Mi. 48116

18. In addition, the Defendants would lose illegal gains in 5460 Shoshoni, Pinckney, Mi. and 7709 Partridge Hill, Brighton, Mi. 48116.

19. In addition, lose of other clients that wanted to build with the Plaintiffs, by Defendants frauduent statements.

20. Defendants Ronald and Virginia Storzbach illegal actions caused major losses in Plaintiff life and career, lose of Plaintiff’s Real Estate Brokers license 25years and Builders license of 18 years with no complaints or violations, until the frauduent actions of the Defendants.

21. Lose of Plaintiff Martial home at 1194 Camelot, Pinckney, Mi. 48169. And forcing Plaintiff to live in a car for 4 years, along with living in an abandon building for 1 year. And Stopping the Plaintiff George Lyons in having proper legal representation to fight the false judgments that were illegal placed against the Plaintiff George Lyons, Defendant were using Plaintiff’s funds, that Defendants illegally acquired to support his legal representative.

22. Because of the Defendants actions, this cause severe reputation destruction and huge losses of funds to Defendant George Lyons and his companies.

23. This was an illegal actions of the Defendants Storzbach’s to acquire illegal equity from 5640 Shoshoni Pass, Pinckney, Mi. and 7709 Partridge Hill, Brighton, Mi. 48116 through fraud.

24. Which stopped George Lyons and Lyons Builders, Inc. from using the 5640 Shoshoni Pass, Pinckney, Mi.and 7709 Partridge Hill, Brighton, Mi. 48116 equity, and put a ripple effect to other past clients.

25. That Plaintiff had approx. $ 160,000.00 + of equity in 5640 Shoshoni Pass, Pinckney, Michigan 48169, and equity in property at 7709 Partridge Hill, Brighton, Mi. 48116 to be determined, to pay for proper legal assistance. Which would of pay for Legal representation against Defendants Ronald and Virginia Storzbach. See Defendants building contract and estimated cost that was signed and approved by Defendants and there legal representative.

26. The Plaintiff has in his possession evidence proving that the Defendants were not using the Defendants but the Plaintiffs money, which caused breaching of contract by the Defendants part.


VIOLATION OF THE MICHIGAN CONSUMER PROTECTION ACT

27. Defendants making fraudulent and criminal statements to State of
Michigan Consumer & Industry services, to acquire false statements to Livingston County Court system, and to acquire illegal funds from Plaintiffs.


FRAUDUALENT AND MISLEADING STATEMENTS MADE BY DEFENDANTS

28. The Defendants stated overwhelming fraudulent statements many times. Placing the Plaintiff’s George Lyons and Lyons Builders, Inc. in a fraudulent light in the eyes of the State of Michigan Consumer & Industry and the Livingston County Court system. SEE AUDIOTAPES.

29. The Defendants used emotions, and false statements and acquiring illegal funds to falsely control Defendants George Lyons, and Lyons Builders, Inc.

30. Plaintiffs states that after looking back by the actions of Defendant Storzbach’s. Defendant Storzbach has made overwhelming false allegations to control Plaintiff George Lyons, Lyons Builders, Inc.

31. And to fraudulently embezzle false equity from the Plaintiffs George Lyons property 5640 Shoshoni Pass, Pinckney, Mi. and 7709 Partridge Hill, Brighton, Mi. 48116.

32. Defendants fraudulently forcing Plaintiff’s in selling Lot 16 Partridge Point, Brighton, Michigan to Defendants.

33. The Plaintiffs recorded many conversations with Defendants, and their fraudulent actions. SEE AUDIOTAPES

PLAINTIFF’S LOSE OF INCOME $8,000,000.00 ON BUILDING LICENSE ALONE.

34. The Plaintiff George Lyons has lost major income over the years because the actions and interference of the Defendants against the Plaintiff and his companies. (See graph).

35. Defendants Karl and Marian Kopp should be held responsible for the Plaintiff losses and pay Plaintiff George Lyons back on all losses.
Damages

36. Plaintiff incorporate by reference paragraphs 1 through 35.

37. Defendant’s fraudulent representations were made intentionally and maliciously and have caused Plaintiff’s to suffer loss of income, humiliation, and outrage, lose of a 20-year marriage, deformation of character, and mental stress, and indignation.

38. Plaintiff should be entitled to damages as results of Defendants
Outrageous and criminal behavior.

39. As a result, of Defendant’s false misrepresentations, Plaintiff has suffered substantial economic losses.

Wherefore, Plaintiff George Edward Lyons request this honorable court enter judgment in his favor against the Defendant’s (Karl and Marian Kopp) in the amount of $14,000,000.00+ of loss income in building only Real Estate income to be determined later. For mental stress. And return to the Plaintiff 1194 Camelot, Pinckney, Mi. 48169 with clear title. Plus costs and attorney fees so wrongfully incurred as a results of the Defendant’s illegal actions. Plaintiff George Edward Lyons requests this honorable court award him damages from the Defendants (Curt Lalonde and Mary Ann Lalonde H/W). That was wrongfully incurred as results of Defendant’s egregious behavior.

Friday, April 09, 2004




By_______________________________
Plaintiff: George Edward Lyons
1711 Parker Road
Dexter, Michigan 48130
734-426-5456



STATE OF Michigan
IN THE 44th JUDICAL CIRCUIT COURT OF (LIVINGSTON COUNTY)
210 S. HIGHLANDER WAY, HOWELL, MICHIGAN, 48843


GEORGE EDWARD LYONS A SINGLE MAN HONORABLE JUDGE
1711 PARKER ROAD Case no.
DEXTER, MICHIGAN 48130
734-426-5456

PLAINTIFF-V-

RONALD STORZBACH AND VIRGINIA STORZBACH H/W
7709 PARTRIDGE HILL,
Brighton, Michigan 48116

DEFENDANTS

There is two other pending or unresolved criminal actions of Defendants making a false complaint to the State of Michigan Consumer & Industry services, reported against the Plaintiff for breach of contract, and Defendants filing a fraudulent Levy $51,000.00+ against the Plaintiff, arising out of this transaction or occurrence alleged in the complaint.

COMPLAINT


Plaintiff, George Edward Lyons, and for this Complaint, state:

COMMON ALLEGATIONS

1. Plaintiff, George Edward Lyons is a resident of Lima Township,
Washtenaw County, Michigan.

2. Defendants, Ronald and Virginia Storzbach, are residents of Hamburg Township, in Livingston County, Michigan.

3. The actions of the Defendant, which give rise to this complaint, took place in Hamburg Township, Livingston County, Michigan.

4. Venue is proper in the 44th Judicial Court of Livingston County.

COUNT I-FILING A FALSE COMPLAINT TO THE STATE OF MICHIGAN CONSUMER & INDUSTRY SERVICES TO SUPPORT STORZBACH FRAUDLENT LAW CASE, AND TO ACQUIRE ILLEGAL GAINS, IN THE LIVINGSTON COUNTY COURT SYSTEM.


5. Defendants Ronald and Virginia Storzbach, made a fraudulent complaint through the State of Michigan Consumer & Industry services, against Plaintiff George Lyons, and Lyons Builders, Inc. Defendants suppressed evidence against Plaintiff. George Lyons was innocent on all fraudulent complaints made by the Defendants against the Plaintiff.

6. The false complaint of the Defendants cause the State of Michigan Consumer & Industry Service to revoke George Lyons and Lyons Builders, Inc. builders license, and Real Estate Brokers license. And falsely fine Plaintiff George Lyons and Lyons Builders Inc $10,000.00.

7. The lose of Plaintiffs builders license cause loss of income of $14,000,000.00 for the illegal harassment of the Defendants Ronald and Virginia Storzbach.

8. That the Defendant through conversations with other past clients, the Defendants would contact them and make fraudulent statements against Plaintiffs George Lyons and Lyons Builders, Inc. to acquire their illegal gains. And extending these harassments into years of illegal actions of the Defendants against the Plaintiffs.

9. That the Defendants, had SUPPRESSSION OF EVIDENCE: the refusal to produce evidence or to allow evidence to be produced for use in litigation. Suppression of evidence refers most commonly to the sanction in a criminal case for an unreasonable search or seizure that violates a defendant’s constitutional rights. In 1914, the U.S. Supreme Court held that illegally seized evidence must be excluded from use in criminal trials.232 U.S. 383, In 1961, the Courts expanded the exclusionary rule to include state criminal trials, 367 U.S. 643. Defendants Ronald and Virginia Storzbachs conceal this evidence. Suppression of evidence also refers either to a party’s refusal to produce evidence or to interference by a party with the production of evidence when another party seeks the evidence pursuant to the law. In evidence may constitute an admission the evidence is unfavorable to the party refusing to product it. McCormick, Evidence 273 (2d ed. 1972

COUNT II- Defendants filed a false Levy on 5640 Shoshoni Pass, Pinckney, Mi. for $ 51,000.00+

8. Defendants acquired frauduant claims from the State of Michigan
Consumer & Industry services to support there false levy on 5640 Shoshoni Pass, Pinckney, Mi. By illegally clouded title of 5640 Shoshoni Pass, Pinckney, Mi.See documents, and audiotapes.


COUNT III-COLLISION, OBSTRUCTION OF JUSTICE, MALIOUS PR0SECUTION

10. The Defendant may be possibly be charged with covering up evidence, collision, obstruction of justice, and malious prosecution by the Defendants attorney, and the Hamburg Police.

11. On the false filing of the false complaint to State of Michigan Consumer & Industry services. Defendants was audio taped, on many occasions, proving that his statements to Consumer & Industry Services were false and misleading, and that he criminally acquire funds from Lyons Builders, Inc. illegally, against 5640 Shoshoni Pass, Pinckney, Mi. 48169 and 7709 Partridge Hill, Brighton, Mi. 48116.

12. Defendants, had made fraudulent statements to other clients and subcontractors and Material Handlers, This was audio taped admitting that he had full knowledge that Defendants did, in fact, file a false and illegal levy on the Plaintiffs property at 5640 Shoshoni Pass, Pinckney, Mi. giving illegal fraudulent support in using Lyons Builders, Inc. and George Lyons funds/equity, in the Livingston County Circuit Court.

13. The Plaintiff believes these actions of the Defendants made a false levy to illegally gains funds/equity in 5640 Shoshoni Pass, Pinckney, and Mi.48169 and 7709 Partridge Hill, Brighton, Mi. 48116 fraudulently from the Plaintiffs.

14. Defendants had full knowledge and expressed it in an audio taped conversations with subcontractors, and George Lyons that Defendants Ronald Storzbach, conspiring against Plaintiff George Lyons and Lyons Builders, Inc. to illegally acquiring illegal control of Plaintiffs funds/equity in 5640 Shoshoni Pass, Pinckney, Michigan and 7709 Partridge Hill, Brighton, Mi. 48116 See audio tape

15. Plaintiffs has evidence of a criminal nature against Defendants Storzbach’s is available and, under the proper circumstances, will be presented to this honorable court.

16. That after Plaintiff was illegal being removed from 7709 Partridge Hill, Brighton, Mi. 48116 by Defendants.

17. Defendants made fraudulent statements to Material handlers, and Subcontractors, past clients to protect the Defendants, illegal gains. Documents,and audiotapes will be provided.


COUNT IV- filing a false levy on 5640 Shoshoni Pass, Pinckney, Mi. for $ 51,000.00+

18. Evidence has been obtained proving that Defendants committed a fraudulent and illegal filing of a $ 51,000,00+ levy on the Plaintiffs property at 5640 Shoshoni Pass, Pinckney, Michigan 48169.
19. Defendants told subcontractors from Storzbach’s project to file false liens against 5460 Shoshoni Pass, Pinckney, Mi. Defendants illegal collect funds from 5640 Shoshoni Pass, Pinckney, Mi. 48169 equity that was owed to the Plaintiff.

20. Defendants fraudulent clouding of title on 5640 Shoshoni Pass, Pinckney, Mi forcing to a pay-off subcontractors that was the responsibility of the Defendants. Plaintiffs was forced to pay Storzbachs subcontractors.


DEFENDANTS MOTIVE

21. Plaintiffs past clients, conspired with Defendants Ronald and Virginia Storzbach were illegally acquire funds on 5640 Shoshoni Pass, Pinckney, Mi. and and illegally acquiring funds and illegally removing Plaintiff from 7709 Partridge Hill, Brighton, Mi. 48116.

22. Defendants false allegations and illegal judgments that Defendant received against the Plaintiff’s.

23. That if the Defendants Ronald and Virginia Storzbach, illegally remove Plaintiffs from and 7709 Partridge Hill, Brighton, Mi. 48116 by fraudulent statements by the Defendants, Ronald and Virginia Storzbach acquired overwhelming illegal funds, through criminal actions and fraud.

24. And Defendants made fraudulent statements to other clients in Partridge Point, and other project outside of Partridge Point, Brighton, Mi. of which caused Plaintiffs in losing other clients building contracts, and lot sales.

25. Defendants would use these fraudulent judgments and fraudulent statements against Plaintiff George Lyons equity in 5640 Shoshoni Pass, Pinckney, Mi. and 7709 Partridge Hill, Brighton, Mi. 48116


26. In addition, lose of other clients, because of the Defendants illegal actions. These other clients wanted to build with the Plaintiffs, and were lost because of Defendants fraudulent statements.

27. Defendants Ronald and Virginia Storzbach illegal actions caused major losses in Plaintiff life and career.

28. Lose of Plaintiff’s Real Estate Brokers license 25 years and Builders license of 18 years that had with no complaints or violations in that period of time, until the frauduent actions of the Defendants.

29. Defendants caused false charged of $10,000.00 fine against the Plaintiffs issued the State of Michigan Consumer & Industry services, because of the illegal action of the Defendants.

30. The Defendants forcing the Plaintiff property 5640 Shoshoni Pass, Pinckney, Mi. 48169 be placed into the circuit court hands for illegal disputation, because of the illegal complaints of Defendants.

31. Ronald and Virginia Storzbach and Richard and Ann Friberg that were under building contracts. FRIBERG WAS on 5640 Shoshoni Pass, Pinckney, Mi.

32. Friberg’s joined the Defendants in making a fraudulent complaint to State of Michigan, Consumer & Industry services.

33. The Fribergs fraudulent complaint against the Plaintiffs was closed by Consumer and Industry services, and the findings of the State of Michigan Consumer & Industry services against Plaintiff George Lyons and Lyons Builders, Inc. is that the Plaintiffs did no violation against the Fribergs.

34. The Fribergs illegal join suit in the Livingston County Circuit court, with the Defendants Ronald and Virginia Storzbach.The defendants Ronald and Virginia Storzbach using fraululent statements and received illegal funds along with Richard and Ann Friberg’s from the Plaintiffs George Lyons and Lyons Builders, Inc.

35. Plaintiff Martial home at 1194 Camelot, Pinckney, Mi. 48169 was lost because of the illegal actions of the Defendants Ronald and Virginia Storzbach and Richard and Ann Friberg.

36. Defendants illegal actions caused the Plaintiff to face false N.S.F. charges, when the Defendants received illegal funds from the 5640 Shoshoni Pass, Pinckney, Michigan closing. Causing the Plaintiff to face 5 years of Probation.

37. And forcing Plaintiff to live in a car for 2 ½ years, along with living in an abandon building for 1 year.

38. Defendants Stopped the Plaintiff George Lyons and Lyons Builders, Inc. in having proper legal representation to fight the false allegations and false judgments that were illegal placed against the Plaintiff George Lyons.

39. Defendants were using Plaintiff’s funds from 5640 Shoshoni Pass, Pinckney, Mi. and 7709 Partridge Hill, Brighton, Mi. 48116 that Defendants illegally acquired to support his legal representative.

40. Because of the Defendants actions, this cause severe reputation destruction and huge losses of funds to Defendant George Lyons and his companies.

41. This was an illegal actions of the Defendants Storzbach’s to acquire illegal equity from 5640 Shoshoni Pass, Pinckney, Mi. and 7709 Partridge Hill, Brighton, Mi. 48116 through fraud.

42. Which stopped George Lyons and Lyons Builders, Inc. from using the 5640 Shoshoni Pass, Pinckney, Mi.and 7709 Partridge Hill, Brighton, Mi. 48116 equity, and put a ripple effect to other clients of Lyons Builders, Inc.

43. That Plaintiff had approx. $ 160,000.00 + of equity in 5640 Shoshoni Pass, Pinckney, Michigan 48169, and equity in property at 7709 Partridge Hill, Brighton, Mi. 48116 to be determined, to pay for proper legal assistance.

44. Which would of pay for Legal representation against Defendants Ronald and Virginia Storzbach. See Defendants building contract and budget cost that was signed and approved by Defendants and there legal representative.

45. The Plaintiff has in his possession evidence proving that the Defendants were not using the Defendants money, but the Plaintiffs money, which caused breaching of contract on the Defendants part.

VIOLATION OF THE MICHIGAN CONSUMER PROTECTION ACT

46. Defendants making fraudulent and criminal statements to State of
Michigan Consumer & Industry services, to acquire false statements to Livingston County Court system, and to acquire illegal funds from Plaintiffs.

FRAUDUALENT AND MISLEADING STATEMENTS MADE BY DEFENDANTS

47. The Defendants stated overwhelming fraudulent statements. Placing the Plaintiff’s George Lyons and Lyons Builders, Inc. in a fraudulent light in the eyes of the State of Michigan Consumer & Industry and the Livingston County Court system. SEE AUDIOTAPES and Documents.

48. The Defendants used emotions, and false statements and acquiring illegal funds to falsely control Defendants George Lyons, and Lyons Builders, Inc.

49. Plaintiffs states that after looking back by the actions of Defendant Storzbach’s.

50. Defendant Storzbach has made overwhelming false and criminal allegations to control Plaintiff George Lyons, Lyons Builders, Inc.

51. And to fraudulently embezzle false equity from the Plaintiffs George Lyons property 5640 Shoshoni Pass, Pinckney, Mi. and 7709 Partridge Hill, Brighton, Mi. 48116.

52. Defendants fraudulently forcing Plaintiff’s in selling Lot 16 Partridge Point, Brighton, Michigan to Defendants.

53. The Plaintiffs recorded many conversations with Defendants, and their fraudulent actions. SEE AUDIOTAPES

PLAINTIFF’S LOSE OF INCOME $8,000,000.00 ON BUILDING ALONE.

54. The Plaintiff George Lyons has lost major income over the years because the actions and interference of the Defendants against the Plaintiff and his companies. (See graph).

55. Defendants Ronald and Virginia Storzbach should be held responsible for the Plaintiff losses and pay Plaintiff George Lyons back on all losses.
Damages

56. Plaintiff incorporate by reference paragraphs 1 through 55 .

57. Defendant’s fraudulent representations were made intentionally and maliciously and have caused Plaintiff’s to suffer loss of income, humiliation, and outrage, lose of a 20-year marriage, deformation of character, and mental stress, and indignation.

58. Plaintiff should be entitled to damages as results of Defendants
outrageous and criminal behavior.

59. As a result, of Defendant’s false misrepresentations, Plaintiff has suffered substantial economic losses.

Wherefore, Plaintiff George Edward Lyons request this honorable court enter judgment in his favor against the Defendant’s (Karl and Marian Kopp) in the amount of $14,000,000.00+ of loss income in building only Real Estate income to be determined later. For mental stress.

And pay market price to return the Plaintiff 1194 Camelot, Pinckney, Mi. 48169 with clear title.

Plus costs and attorney fees so wrongfully incurred as a results of the Defendant’s illegal actions.

Plaintiffs George Edward Lyons requests this honorable court award him damages from the Defendants (Ronald and Virginia Storzbach). That was wrongfully incurred as results of Defendant’s egregious behavior.

Friday, April 09, 2004


By_______________________________
Plaintiff: George Edward Lyons
1711 Parker Road
Dexter, Michigan 48130
734-426-5456

(Six)Law suits case no. and False complaints made to State of Michigan Consumer & Industry Services made by past clients

Case numbers of criminal action caused by Developer and past clients, State of Michigan, Livingston County Court system, and Consumer & Industry services, and Patricia Ann Lyons and Karl and Marian Kopp and more.

1. 92-012061-CK Steeber v. Lyons Builders. Steeber fails a fraudulent law suit to wrongly acquire $ 35,000.00 from Lyons Builders, Inc. Steeber wrongly breach building contract.

Footnote: Brian Lavan was my attorney, and through Conflict of Interest represented my ex-wife Patricia A. Lyons and Friend of the court Gerald Edit who worked for Brian Lavan and Associates represented George Lyons in court.

2. 94-013351-Ch-D Jerry Jarvis and Jarvis Developers v. Lyons Builders. Jerry Jarvis files a fraudulent law suit to illegally acquire back 8 lots owned by Lyons and Associates, Inc. from Partridge Point, Brighton, Michigan. See audio tapes of Jerry Jarvis and Ronald Storzbach try to convince a employee of Cadillac Brick. In asking that employee to make a fraudulent complaint to State of Michigan Consumer & Industry Services to wrongfully remove George Lyons builders license

3. 96-015464-CK Marcich and Fenton Poured walls v. Lyons Builders. Marcich embezzle money from George Lyons and Lyons Builders, Inc.

4. 96-015415-CH Lalonde and Lee Wholesale v. Lyons Builders. Lalonde embezzle money from George Lyons and Lyons Builders, Inc.

5. State of Michigan v. George Lyons and Lyons Builders, Inc. Lalonde and Marcich making false N.S.F. charges against George Lyons and Lyons Builders, Inc. Along with Jarvis, Storzbach and Friberg and Lalonde and Marcich and ex-wife Patricia Lyons and Karl and Marian Kopp cause the lost of George Lyons Builders License and Real estate brokers License.

a. 96-009522-FH Great Lakes Bancorp for money loan to Lalonde that George Lyons being reimburse money back.

b. 96-009524-FH Weatherly plumbing for work on Lalonde 3100 Betty Lyons Lane, Pinckney, Michigan.

c. 96-009526-FH Erb Lumber for Marcich building material use on 3145 Betty Lyons Lane, Pinckney, Michigan.

6. 96-23807-DM Lyons v. Lyons George Lyons and Patricia Lyons Divorce. May 1997 George Lyons is falsely removed from martial home by false statement from Patricia Lyons attorney Brian Lavan.

Footnote: Brian Lavan was my attorney in the case Steeber v. George Lyons and Lyons and Associates, Inc. , and through Conflict of Interest represented my ex-wife Patricia A. Lyons and Friend of the court Gerald Edit who worked for Brian Lavan and Associates represented George Lyons in court.


7. 98-0467 Ex-wife making false domestic abuse charge against George Lyons. February 28th 1998. 8:45 am.

8. 98-027935-PP Ex-wife placing a false Personal protection orders against George Lyons. George Lyons files motion to remove P.P.O. that was false and misleading. The Personal protection order was terminated. See audio tapes

9. False Complaints made by past clients to State of Michigan Consumer & Industry services against George Lyons by Past Clients to acquire illegal funds. George Lyons and Lyons Builders, Inc. preformed over $ 387,000.00 worth of work that was never paid back to George Lyons and Lyons Builders, Inc. All complaints were false and misleading see audio tapes and evidence given to State of Michigan Consumer & Industry services prior to any judgments against George Lyons or his company.

DOCKET NO. 95-0693 COMPLAINT NO. 21-94-0001-00
DOCKET NO. 98-0107 COMPLAINT NO. 21-96-0232-00
DOCKET NO. 98-0108 COMPLAINT NO. 21-96-0232-01
DOCKET NO. 1999-3683 COMPLAINT NO. 89-97-3961-00
DOCKET NO. 1999-3682 COMPLAINT NO. 89-97-3164-00
DOCKET NO. 1999-3674 COMPLAINT NO. 89-97-3962-00
DOCKET NO. 1999-3679 COMPLAINT NO. 89-97-3163-00
DOCKET NO. 1999-3684 COMPLAINT NO. 65-98-0345-00

10. 99-1823-SM Karl and Marian Kopp filing a false forfeiture on martial home 1194 Camelot, Pinckney to wrongly embezzle 1194 Camelot, Pinckney, Michigan.

11. 00-030162 PH Mary Ann Lalonde false Personal protection order against George Lyons.

12. 04-83-MZ George Lyons v. State of Michigan Consumer & Industry service. In Lansing Michigan. See Law suit between Lyons v. State of Michigan Consumer & Industry service.

13. 04-020671-CK George Lyons v. Storzbach, Friberg, Feeback, Lalonde, Marcich, Kopp, Patricia Lyons.

04-020684-CK
1996023807 DM Friend of the Court Divorce.

14. 04-020652-CF-B George Lyons v. Karl Kopp and Marian Kopp for filing a false forfeiture and false police report for entering into 1194 Camelot, Pinckney, Mi. aka marital home of George Lyons.

15. 05-21819-CZ George Lyons v. Patricia Lyons and her criminal actions

16. 06-021758-CZ George Lyons v. Storzbach, Friberg, Feeback, Lalonde, Emergency Motion of Disqualification of Judge Stanley Laterille.

17. 06-021858 George Lyons v. Storzbach, Friberg, Feeback, Lalonde, Marcich, Kopp, Patricia Lyons

18. 06-021977-CZ George Lyons v. James Bailey, for purchasing stolen property at 1194 Camelot, Pinckney, Mi. of George Lyons that Karl and Marian Kopp made a fraudulent forefiture and the sold to James Bailey.

(Five) Wrongful actions of State of Michigan Consumer & Industry Services against George Lyons

STATE OF MICHIGAN
IN THE 30th JUDICAL CIRCUIT COURT OF (Ingham County)
313 W. KALAMAZOO,LANSING MICHIGAN, 48933
517-483-6500

GEORGE EDWARD LYONS HONORABLE JUDGE BEVERLEY NETTLES-NICKERSON
1711 PARKER ROAD Case no. 04-83-MZ
DEXTER, MICHIGAN 48130
734-878-0825

PLAINTIFF
-V-
STATE OF MICHIGAN
DEPARTMENT CONSUMER & INDUSTRY SERVICES
BUREAU OF COMMERCIAL SERVICES
LICENSING DIVISION
Real Estate-Broker and Salesperson License
And
Residential Builders License
P.O.Box 30245
Lansing, Michigan 48909
517-241-9254

DEFENDANTS

There are other pending or unresolved actions of Plaintiff is making against the Defendants, and Defendants filing arising out of this transaction or occurrence alleged in the complaint.

COMPLAINT

Plaintiff, George Edward Lyons, and for this Complaint, state:

COMMON ALLEGATIONS

1. Plaintiff, George Edward Lyons is a resident of Lima Township,
Washtenaw County, Michigan.

2. Defendants, State of Michigan, Consumer & Industry Services are working, in Ingham County, Michigan.

3. The actions of the Defendants, which give rise to this complaint, took place in Ingham County, of Michigan.

4. Venue is proper in the Circuit Court of Ingham County.

COUNT I-Malicious Prosecution

5. Defendants State of Michigan Consumer & Industry Service against Plaintiff George Lyons, Lyons Builders, Inc. and Lyons Inc. located at 1194 Camelot, Pinckney, Mi. 48169. Defendants suppressed or withhold evidence from the following cases.

Pertaining to the following, cases Builders Licensing permanent ID no. 2102095976 Lyons Builders, Inc. or any other Builders license related to Plaintiff George Edward Lyons.

DOCKET NO. 95-0693 COMPLAINT NO. 21-94-0001-00

The Storzbach complaint. And George Lyons evidence is overwhelming and is too large to copy, it the size of New York telephone book. This evidence of innocents was filed prior to and formal complaint of final order. And will be presented upon request. This is Storzbach’s fabercated fraudulent complaint to State of Michigan Consumer & Industry services Enforcement division.

DOCKET NO. 98-0107 COMPLAINT NO. 21-96-0232-00
DOCKET NO. 98-0108 COMPLAINT NO. 21-96-0232-01
DOCKET NO. 1999-3683 COMPLAINT NO. 89-97-3961-00
DOCKET NO. 1999-3682 COMPLAINT NO. 89-97-3164-00
DOCKET NO. 1999-3674 COMPLAINT NO. 89-97-3962-00
DOCKET NO. 1999-3679 COMPLAINT NO. 89-97-3163-00


The Plaintiff has over 20+ bank boxes of evidence that was presented to State of Michigan Consumer & Industry Service. Proving Plaintiff George Lyons innocence. Along with audiotape conversations and transcripts.


6. Pertaining to the following case Real Estate Brokers & Salesperson licensing permanent ID no. 650120239 George Edward Lyons and Lyons, Inc. license or any other license related to George Edward Lyons.DOCKET NO. 1999-3684 COMPLAINT NO. 65-98-0345-00

See Honorable Administration Judge Goldstein Hearing Report. And
Through the freedom of information the false copy of George Lyons, application for Brokers License. Proving that the Board of Real Estate Brokers and Salespersons illegally by the Defendants wrongly removed George Lyons Brokers License.

That the Defendant Consumer & Industry services doctor the Plaintiff Application, from Yes to No. Plaintiff has overwhelming evidence this is true. And the Defendant preformed falsification of documents, against the Plaintiff.

With the huge losses to Plaintiff. The actions of the Defendants, State of Michigan Consumer & Industry services supported the Past Clients to Framed George Lyons for false N.S.F. checks.

Defendant COUNT II-SUPPRESSION OF EVIDENCE AND JOINT LIABILITY

7. That the Defendants, had DOCTOR, AND SUPPRESSSION OF EVIDENCE: the refusal to produce evidence or to allow evidence to be produced for use in litigation. Suppression of evidence refers most commonly to the sanction in a civil or criminal cases for an unreasonable search or seizure that violates a defendant’s constitutional rights. In 1914, the U.S. Supreme Court held that illegally seized evidence must be excluded from use in criminal trials.232 U.S. 383, In 1961, the Courts expanded the exclusionary rule to include state criminal trials, 367 U.S. 643.

8. This evidence was presented to the Defendants before any hearings, or before any final orders were issued against Plaintiff George Lyons, Lyons Builders, Inc or Lyons Inc.

9. Suppression of evidence refers either to a party’s refusal to produce evidence or withhold evidence to interference by a party with the production of evidence when another party seeks the evidence pursuant to the law. In evidence may constitute an admission the evidence is unfavorable to the party refusing to product it. McCormick, Evidence 273 (2d ed. 1972


COUNTIII-COLLISION,OBSTRUCTION OF JUSTICE, MALICIOUS PROSECUTION, JOINT LIABILITY, AND MALPRACTICE.


The Defendants may be possibly being charged with receiving evidence and having full knowledge that the Plaintiff was being railroaded. By the defendants, may possibility charged for the following in collision, obstruction of justice, and malicious prosecution, malpractice and the Defendant preformed falsification of documents, against the Plaintiff.

10. In addition, are in joint liability by the Defendants employees.

DEFENDANTS HAD NO JURISDICTION PER ALL BUILDING CONTRACTS

11. On the false filing a false complaint, all past clients had in there contract arbitration clauses in there building contract and Defendants did not or did review evidence, but withheld evidence. That the Defendant had no jurisdiction until the clients went through arbitration.

12. The Plaintiff believes these actions of the Defendants made actions that supported a ripple effect of false police reports, and supported the past clients to receive illegal gains against the plaintiff.

13. In addition, the past clients of the Plaintiff that made false complaints to the Defendants. That the Defendants had full knowledge of the Plaintiffs innocents before any formal complaints, or final orders were presented.

14. Defendants were in collusion against Plaintiff George Edward Lyons and his companies to illegally acquiring, illegal judgments through Consumer & Industry services, and the Livingston County Court system, of Michigan.

15. Plaintiff’s over the years has proven to Defendants that the past clients made fraudulent complaints against the Plaintiffs.

16. That the past clients were criminally embezzling money from the Plaintiff’s.

The Defendant’s are responsible to protect the public; the Plaintiff’s is the public. Nevertheless, the Defendant’s were protecting their illegal gains on fraudulent fines that they made against the Plaintiff’s of over $ 27,000.00 +. Moreover, the illegal gains of the past clients of $806,000.00 +. And not preformed falsification of documents, against the Plaintiff.

17. Plaintiffs has evidence of a criminal nature against Defendants under the proper circumstances, will be presented to this honorable court.

18. That the Defendant over the many years has respectively submitted overwhelming evidence, to many of the employees proving the Plaintiffs innocence. And a deaf ear has been placed against the Plaintiffs by the Defendant so they could protect their illegal gains.

COUNT IV-FRAUDULENT SUPPORT OF PERJURY FOR THE LIVINGSTON COUNTY COURT SYSTEM

19. Evidence has been obtained proving that Defendants committed fraudulent actions against the Plaintiffs, to support past clients illegal actions.

20. The defendant placed the Plaintiffs in a possession of homeless possession, and non-working possession, by illegally removing both builders and real estate brokers license from having the Plaintiff’s money to have a legal representative to fight the criminal actions of the Defendant’s and the past clients. The Plaintiff was to receive his broker’s license, May 2003 back because of illegal doctoring (falsification) of the Plaintiff’s licensing application, which was never to be revoke because of the Defendant’s illegal actions.

DEFENDANTS MOTIVE

21. This writer’s belief is that Defendants conspired with Livingston County Prosecutors, and the Livingston County court system because of false allegations and illegal judgments.

22. Fraudulent formal complaints and final orders, against the Plaintiff’s, that the Defendants illegal actions caused major losses in Plaintiffs life and career.

23. Because of the Defendants falsification of the Plaintiff application, this action forced Plaintiff to live in a car for 4 years, along with living in an abandon building for 1 year. Moreover, placing the Plaintiff’s life in harms way.

24. Causing dissolving of 20-year marriage stress to the point of a divorce. In addition, lose of his children.

25. In addition, stopping the Plaintiff George Lyons from having proper legal representation to fight the false judgments that were illegal placed against the Plaintiff George Lyons and his companies with no money.

26. That supported Livingston County Prosecutors of Livingston County and lawyer’s illegal actions, and Livingston County court system.

27. Protecting Livingston County Court system, and the first complainant, Ronald and Virginia Storzbach, Ronald Storzbach is a police officer for Hamburg Township police department, along with other past clients.

28. Because of the Defendants falsification actions, cause severe reputation destruction and huge losses of funds to Plaintiffs George Lyons and his companies.

29. Actions of the Defendants, Malicious Prosecution, Malpractice, collusion, falsification of documents, has joint liability in this matter, and because of the Defendant ripple effect, illegal actions, caused Plaintiffs to face Malicious arrest, and Malicious Prosecution, And placed Plaintiff in Harm-way, and set-up past clients to embezzle funds from the Plaintiffs and his companies.


VIOLATION OF THE DEFENDANTS MICHIGAN CONSUMER PROTECTION ACT AND FALSE SUPPORT OF THE BUILDER LIEN ACT.

The Plaintiffs is governed by the rules and regulations of the Michigan Consumer Protection act. The Defendants did not follow the consumer protection act or standards, in placing illegal formal complaints and final orders against the Plaintiff. Moreover, illegally doctoring the Plaintiff Brokers application, which illegal cause the lose of the Plaintiff’s Brokers License. But Defendants preformed falsification of documents, against the Plaintiff to illegally control the plaintiff.
30.

MISLEADING STATEMENTS OF DEFENDANTS

31. See audiotapes on Defendants employees.

32. After looking back by the actions of Defendants employees. Defendant employees made false allegations to control Plaintiff’s George Edward Lyons and his companies. And to protect past clients.

In addition, to fraudulently cause a ripple effect of embezzlements against the Plaintiffs George Lyons, Lyons Builders, Inc. and Lyons Inc. By the Defendants appro. $27,000.00 + in false fines fraudulently filed by the Defendants. And the past clients illegal gains of $806,000.00+. By the Defendant performing falsification of documents, against the Plaintiff.

33. The marital home of Plaintiff’s property in question lost, 1194 Camelot, Pinckney, Michigan 48130 PLAINTIFF LOSE OF INCOME $14,000,000.00+ since 1994

34. The Plaintiff George Lyons has lost major income over the years because the illegal actions and of the Defendants against the Plaintiff and his companies. (See graph).

35. Defendants State of Michigan Consumer & Industry services should be held responsible for the Plaintiff losses and pay Plaintiff George Lyons back on all losses.

Damages Against George Lyons

36. Plaintiff incorporate by reference paragraphs 1 through 35.

37. Defendant’s fraudulent representations were made intentionally and maliciously with joint liability, and have caused Plaintiff’s to suffer loss of income, humiliation, outrage, lose of a 20 year marriage, deformation of character, lose of Plaintiff Marital Home, at 1194 Camelot, Pinckney, Michigan 48169, loss of income through homes that the Plaintiff’s constructed, and mental stress, and indignation. Because of the falsification of the Plaintiff’s application, and other illegal actions.

38. Plaintiff should be entitled to damages plus trebel damages as results of Defendants outrageous illegal behavior.

39. As a result, of Defendant’s false misrepresentations, Plaintiff has suffered substantial economic losses.

Wherefore, Plaintiff’s George Edward Lyons and his companies, request this honorable court enter judgments in his favor against the Defendants State of Michigan Consumer & Industry Services for their illegal actions in the losses of Plaintiff’s builders income amount of $14,000,000.00+ plus trebel damages, and replace 5460 Shoshoni Pass, Pinckney, Mi. and 1194 Camelot, Pinckney, Michigan to at today’s market value against the Defendants. Plaintiff’s losses this does include Real Estate income except for the possible clients, and will be enter later.

Return of the Plaintiff’s home at 1194 Camelot, Pinckney, Mi. 48169 with clear title.

Because of ripple effect of the Defendants. Losses of income from all the past clients fraudulently received of the Plaintiff’s builder’s income.

PLAINTIFF DEMANDS THE Return immediate Plaintiffs Builders License, and Real Estate brokers license. Expunge all fines, levied against the Plaintiff’s licenses any and all, Past and Present.

In addition, completely repair the Plaintiff’s credit to Plaintiff’s satisfaction.

In addition, costs and attorney fees so wrongfully incurred as a results of the Defendant’s illegal actions.

25 to 30 agents were ready to work for and did not work for the Plaintiff, George Lyons; these people should be reimbursed for the money they lost, because of the illegal actions of the Defendants.

Plaintiff’s George Edward Lyons request this honorable court award him damages and trebel damages, from the Defendants State of Michigan Consumer & Industry Services for mental stress.

That was wrongfully incurred as results of Defendant’s egregious behavior.
That this evidence is also being transferred to the Supreme Court investigation team for possible judicial misconduct. Included the Attorney Grievance committee, and judicial tenure committee.



Sunday, June 20, 2004




By_______________________________
Plaintiff: George Edward Lyons
1711 Parker Road
Dexter, Michigan 48130
734-878-0825
prideoflyons@provide.net

(Eight)Patricia Ann Lyons Law Suit

STATE OF Michigan
IN THE 44th JUDICAL CIRCUIT COURT OF (LIVINGSTON COUNTY)
210 S. HIGHLANDER WAY, HOWELL, MICHIGAN, 48843


GEORGE EDWARD LYONS HONORABLE JUDGE
1194 Camelot Case no.
Pinckney, MICHIGAN 48169
734-250-2734

PLAINTIFF
-V-
PATRICIA ANN LYONS
4849 Norvell
Grass Lake, Michigan
517-522-3705

DEFENDANTS


There are three other pending or unresolved criminal actions of Defendants making a false police report against the Plaintiff for Domestic abuse, and Defendants filing fraudulent allegations to the Friend of the court to stop plaintiff from see his children. For collusion, filing a fraudulent embezzlement of funds from a closing on 5654 Shoshoni Pass, Pinckney, Michigan, and embezzlement of lot 2 Betty Lyons Lane, Pinckney, Michigan. Arising out of this transaction or occurrence alleged in the complaint.

COMPLAINT


Plaintiff, George Edward Lyons, and for this Complaint, state:

COMMON ALLEGATIONS

1. Plaintiff, George Edward Lyons is a resident of Lima Township,
Washtenaw County, Michigan.

2. Defendants, Patricia Ann Lyons and Dale Fisher are residents of
Jackson County, Michigan.


3. The actions of the Defendant, which give rise to these complaints, took place in Putnam Township, and Hamburg Township, Livingston County, Michigan.

4. Venue is proper in the 44th District Court of Livingston County.


COUNT I-FILING A FALSE POLICE REPORT


5. Defendant Patricia Ann Lyons filed a fraudulent police report against Plaintiff George Lyons at the marital home 1194 Camelot, Pinckney, Mi. 48169, Defendant Patricia Ann Lyons suppressed evidence, for giving evidence that Plaintiff George Lyons was innocent on a false police report made by the Defendant Patricia Ann Lyons made against the Plaintiff, where the Defendant Patricia Ann Lyons made a false police report for Domestic Abuse at marital home 1194 Camelot, Pinckney, Mi.

6. New evidence was retrieved after judgment. Proving beyond a reasonable doubt, that Defendant Patricia A. Lyons made a fraudulent criminal false police report against the Plaintiff George Edward Lyons.

7. The false Police report by the Defendant Patricia A. Lyons placed Plaintiff George Lyons in an unfavorable light, and large losses of income.

8. Plaintiff George Edward Lyons had to serve 2 years to and report to a probation office wrongly served by the Plaintiff George Edward Lyons because of the criminal actions of the Defendant Patricia A. Lyons, this criminal action of the Defendant was to control the

Plaintiff George Edward Lyons. After this action is overturned, the Defendant should face criminal charges for her illegal actions.

COUNT II-SUPPRESSION OF EVIDENCE

9. That the Defendants, had SUPPRESSSION OF EVIDENCE: the refusal to produce evidence or to allow evidence to be produced for use in litigation. Suppression of evidence refers most commonly to the sanction in a criminal case for an unreasonable that violates a Plaintiff’s at time was George Edward Lyons, constitutional rights. In 1914, the U.S. Supreme Court held that illegally seized evidence must be excluded from use in criminal trials.232 U.S. 383, In 1961, the Courts expanded the exclusionary rule to include state criminal trials, 367 U.S. 643. This evidence was withheld by Defendant Patricia Ann Lyons and Dale Fisher.

10. Suppression or withholding of evidence also refers either to a party’s refusal to produce evidence or to interference by a party with the production of evidence when another party seeks the evidence pursuant to the law. In evidence may constitute an admission the evidence is unfavorable to the party refusing to product it. McCormick, Evidence 273 (2d ed. 1972


COUNT III-COLLISION, OBSTRUCTION OF JUSTICE, MALIOUS PROSECUTION

11. The Defendants Patricia Ann Lyons and Dale Fisher may be possibly be charged with destroying of evidence, withholding evidence, collision,

Obstruction of justice and malicious prosecution by the Defendants

12. On the false filing of the false police report, by the Defendant Patricia Ann Lyons was audio taped by Plaintiff at marital home 1194 Camelot, Pinckney, Mi.

13. Defendant Patricia Ann Lyons was audio taped admitting Plaintiff was removed from marital home 1194 Camelot, Pinckney, Mi. By the Defendant Patricia Ann Lyons attorney, advise.

14. Which was illegal done by the Defendant Patricia Ann Lyons, which caused the Plaintiff George Lyons server losses, over $8,000,000.00, just in Lyons Builders, Inc. income, which was Plaintiff Company?

15. Loss of The Plaintiff marital home at 1194 Camelot, Pinckney, Mi. Loss of income of past clients, that were embezzling monies from the Plaintiff George Lyons and Lyons Builders, Inc. and Lyons, Inc.

16. The Plaintiff believes these actions of the Defendants Patricia Ann Lyons in making a False Police Report to illegally gain 1194 Camelot, Pinckney, Mi. and covering-up embezzled monies from 5654 Shoshoni Pass, Pinckney, Mi. and to illegally/embezzle lot 2 Betty Lyons Lane, Pinckney, Mi. from the Plaintiff George Lyons.

17. The actions of the Defendants were to completely stop the Plaintiff from having any monies to pay legal representation to correct the illegal and criminal actions of the Defendants, and to protect the illegal gains of the Defendants.

18. Plaintiff recorded Marian Kopp acknowledging and expressed it in an audio taped conversations with George Lyons that Karl Kopp, her husband, and Patricia A. Lyons Plaintiff ex-wife were conspiring against George Lyons to illegally acquiring, Plaintiffs home at 1194 Camelot, Pinckney, Michigan and conspiring to acquiring Plaintiffs equity in 1194 Camelot, Pinckney, Mi. See audio tape

19. Plaintiff has evidence of a criminal nature against Defendants Patricia Ann Lyons and Dale Fisher is available and, under the proper circumstances, will be presented to this honorable court.

20. That after Plaintiff was illegal being removed from 1194 Camelot, Pinckney, Mi. 48169 by Plaintiff Patricia A. Lyons. And illegally arrested by the false police report The Defendants and the Kopp’s illegally hidden and removed evidence, to protect the Defendants, illegal gains, pictures will be provided.


COUNT IV-FRAUDULENT FORFEITURE

21. Evidence has been obtained proving that Defendant Patricia Ann Lyons and Karl and Marian Kopp committed a fraudulent forfeiture on the Plaintiff marital home at 1194 Camelot, Pinckney, Michigan 48169.

22. Overwhelming evidence was given to the following people that represented the Friend of the court proving that Plaintiff George Lyons was innocent of Defendants Patricia Ann Lyons and Dale Fisher, false allegation and these people kept Plaintiff children from him.

a. Honorable Judge Susan Reck
b. Gerald Edit friend of the court referee
c. Dr. Richard Zipper:
d. Bonnie Miller, attorney for Defendant Patricia A. Lyons
e. Monica Coupland: court appointed attorney to represent the daughters of Defendant Patricia Ann Lyons and Plaintiff George Lyons.
f. Dale Fisher:

DEFENDANTS MOTIVE

23. This writers belief is that Plaintiffs Patricia A. Lyons conspired with Defendants Karl F. Kopp and Marian Kopp, were illegally removing Plaintiff from 1194 Camelot, Pinckney, Mi. because of false allegations and illegal judgments against the Plaintiff’s George Lyons and Lyons Builders, Inc, that if the Defendant Patricia Ann Lyons and Karl F. Kopp and Marian Kopp, did not remove Plaintiff from marital home 1194 Camelot, Pinckney, Mi. 48169 That these past judgments would be used against Plaintiffs George Lyons equity in 1194 Camelot, Pinckney, Mi.

Defendant Patricia Ann Lyons and Karl F. Kopp and Marian Kopp would lose there investments and equity in the marital home at 1194 Camelot, Pinckney, Mi.

Defendant Patricia Ann Lyons and Karl F. Kopp and Marian J. Kopp illegal actions caused major losses in Plaintiff life and career, forcing Plaintiff to live in a car for 4 years, along with living in an abandon building for 1 year. $8,000,000.00 of loses income for Lyons Builders, Inc.
Stopping the Plaintiff George Lyons in having proper legal representation to fight the false judgments that were illegal placed against the Plaintiff George Lyons and Lyons Builders, Inc. and Lyons Inc.

24. Because of the Defendant Patricia Ann Lyons actions, this cause severe reputation destruction and huge losses of funds to Plaintiff George Lyons and his companies.

25. This was an action of the Defendants and the Kopp’s to acquire 1194 Camelot, Pinckney, Mi. and illegal funds from 5654 Shoshoni Pass, Pinckney, Mi., and Lot 2 Betty Lyons Lane, Pinckney, Mi. through criminal actions causing fraud.

26. These illegal actions of the Defendants stopped George Lyons from using the 1194 Camelot, Pinckney, Mi. That Plaintiff had approx.$ 800,000.00 + of equity in 1194 Camelot, Pinckney, Michigan 48169 to pay for proper legal assistance.

27. The equity would of pay-off Karl F. Kopp and Marian J. Kopp Land contract holders. See appraisal dated 1995 for marital home at 1194 Camelot, Pinckney, Mi. 48169.

FAILURE TO ESCROW WARRANTY DEED

28. Karl and Marian Kopp wrongfully recorded a Warranty Deed that was to be placed into an escrow. If this warranty deed was placed into an escrow account the Plaintiff George Lyons acquire an equity loan, could have used said Warranty deed and pay-off Defendants Land Contract holders. See escrow agreement of Warranty deed.

28. The Plaintiff has in his possession evidence proving that the Defendant Patricia Ann Lyons had full knowledge that Karl and Marian Kopp were paid in full for all monthly payments on said Land Contract and the Defendant Patricia Ann Lyons and Karl and Marian Kopp made at the time of the false forfeiture on Plaintiffs marital property at 1194 Camelot, Pinckney, Mi. 48169.


VIOLATION OF THE MICHIGAN CONSUMER PROTECTION ACT

29. Marian Kopp as a licensed real estate agent used her company Real Estate One, Ann Arbor office, to suppress the Plaintiffs George Lyons in recovering Plaintiffs George Lyons property marital home at 1194 Camelot, Pinckney, and Mi. 48169. And Marian Kopp as listing agent for Real Estate One, Ann Arbor Office suppressed the sale of 1194 Camelot, Pinckney, Mi. and other properties.

PAYING OFF LAND CONTRACT PAYMENTS

30. That the Kopp’s was using a $ 24,000.00 deposit from lot 3 Betty Lyons to Lot on Norcrest, Brighton, Michigan. Lyons Builders, Inc. that Plaintiffs building company to construct a home on Defendant property on there lot on Norcrest, Brighton, Mi. The income of Lyons Builders, Inc. was to be used to pay off land contract between Plaintiffs and the Kopp’s. See contract, plans, and building permits.

31. That Plaintiff George Lyons has audiotape conversation between Marian Kopp a licensed real estate agent, was receiving referrals from Plaintiff George Lyons Real Estate broker, over 100+ referrals, this to was to pay off Land contract between Plaintiff George Lyons real estate broker, and Plaintiff was also working for Country Wide mortgage company in foreclosures, and agreement between Plaintiff George Lyons and Marian Kopp, this to was agreed to pay-off land Contract between Plaintiff George Lyons and the Kopp’s. See audiotapes.


MISLEADING STATEMENTS OF DEFENDANTS

32. Marian Kopp stated overwhelming many times to the Plaintiff George Lyons, that Marian Kopp husband Karl Kopp was having an affair with Defendant Patricia A. Lyons. In placing Plaintiffs ex-wife, (also Defendant Patricia A. Lyons) in an adulterous light in the Plaintiff George Lyons eyes. SEE AUDIOTAPES

33. Marian Kopp after repeating and repeating to the Plaintiff George Lyons, That Defendant Karl Kopp and Patricia A. Lyons were having an affair. SEE AUDIOTAPES

34. Defendant Marian Kopp produced to the Plaintiff George Lyons a Divorce complaint between the Karl Kopp and Marian Kopp.

35. 36. Defendants Marian Kopp persists. Until after Defendants George Lyons divorce.

37. The Defendant, and that Karl Kopp were close friends.

38. Moreover, Plaintiff George Lyons stopped Marian statements of Karl Kopp and Patti Kopp love affair but tried to keep their relationship as friends because Karl and Marian Kopp had control of 1194 Camelot, Pinckney, Mi. 48169. At that, Plaintiff had no evidence to regain back 1194 Camelot, Pinckney, Mi. Evidence that Defendants and the Kopps hidden from the Plaintiff, and kept away from the Plaintiff George Lyons.

39. The Defendants and the Kopp’s used emotions, and false statements to control Plaintiff George Lyons.

40. After looking back by the actions of Defendants and the Kopps and Defendants, and the Kopps made false allegations to control Plaintiff George Lyons.

41. And to fraudulently embezzle Plaintiffs George Lyons property 1194 Camelot, Pinckney, Mi. and Lot 2 Betty Lyons Lane, Pinckney, Mi. and acquiring illegal funds from 5654 Shoshoni Pass, Pinckney, Mi. The Plaintiff recorded many conversations with Defendants and the Kopps, and her fraudulent actions. SEE AUDIOTAPES

$24,000.00 WAS MADE ON PAYMENT ON LAND CONTRACT

42. The Kopps stated that they receive no payments on said Land Contract between Defendants and Plaintiff on said false forfeiture case against the Plaintiff made by the Kopp’s. Plaintiff can prove beyond a reasonable doubt this was criminally embezzlement.

43. The Plaintiff request a emergency Warranty deeds and clear title to 1194 Camelot, Pinckney, Michigan 48169, to 5654 Shoshoni Pass, Pinckney, Michigan, and Lot 2 Betty Lyons Lane, Pinckney, Mi. and all income that Plaintiff lost $8,000,000.00 and to be given back to the Plaintiff.

DEFENDANTS LEFT 1194 CAMELOT IN MAJOR DIS-REPAIR

44. The property in question 1194 Camelot, Pinckney, Michigan 48130 has been gone into major disrepair, the Plaintiff George Lyons also request that the Defendants brings 1194 Camelot, Pinckney, Michigan, 48169 up to Plaintiff satisfactory repair to Plaintiff George Lyons satisfaction, this cost to be Defendants and the Kopp’s responsibility.


POSSIBLE INSURANCE FRAUD

45. The Plaintiff George Lyons notices that the Plaintiff George Lyons property 1194 Camelot, Pinckney, Michigan had a major problem with the heating and plumbing; this was to be cover by the Kopp’s Insurance.

46. The Plaintiff George Lyons believes after investigation used that insurance money, in other uses than 1194 Camelot, Pinckney, Mi. 48169.

47. This action of the Karl and Marian Kopp is possible insurance fraud on that Karl Kopp and Marian Kopp part.

PLAINTIFF LOSE OF INCOME $8,000,000.00

48. The Plaintiff George Lyons has lost major income over the years because the actions and interference of the Defendants against the Plaintiff and his companies. (See graph).

49. Defendants and Karl and Marian Kopp should be held responsible for the Plaintiff losses and pay Plaintiff George Lyons back on all losses.
Damages

50. Plaintiff incorporate by reference paragraphs 1 through 49.

51. Defendant’s fraudulent representations were made intentionally and maliciously and have caused Plaintiff to suffer loss of income, humiliation, and outrage, lose of a 20 year marriage, deformation of character, and mental stress, and indignation.

52. Plaintiff should be entitled to damages as results of Defendants outrageous behavior.

53. As a result, of Defendant’s false misrepresentations, Plaintiff has suffered substantial economic losses.

Conclusion

Wherefore, Plaintiff George Edward Lyons request this honorable court enter judgment in Plaintiff favor complete parental guardianship against the Defendant’s Patricia Ann Lyons and Dale Fisher.

My Daughters Jeannine Ann Lyons and Justina Marie Parker Lyons have been living with their mother(Patricia Ann Lyons) and Dale Fisher (boy friend ) in the same house. This is not the right place where two impressible girls. And Justina Marie Parker Lyons who is age 14 years old. I insist my daughters be removed form this home. And be brought up with a better moral structure living environment.

Plaintiff George Edward Lyons request this honorable court enter judgment in Plaintiff favor against the Defendant’s Patricia Ann Lyons and Dale Fisher for Plaintiff loss of income because of the Defendants illegal actions and false statements $8,000.000.00.

Return to the Plaintiff 1194 Camelot, Pinckney, Mi. 48169 at today’s market price. Return to Plaintiff Lot 2 Betty Lyons Lane, Pinckney, Mi. With clear titles. Return to Plaintiff 5456 Shoshoni Pass, Pinckney, Michigan 48169 at today’s appraised price Plus interest.

That charge’s be also brought against the Plaintiff’s for Tortious interference, civil conspiracy, restriction of trade, making a false police report, and fraud all falls under Statue of Limitations, of 6 years which started June of 2000.

And lost of income from Defendant Patricia A. Lyons illegally and embezzlement of funds from 5456 Shoshoni Pass, Pinckney, Mi 48169.
Plus costs and attorney fees so wrongfully incurred as a results of the Defendant’s illegal actions.

Plaintiff George Edward Lyons request this honorable court award him damages from the Defendants Patricia A. Lyons and Dale Fisher and Karl Francis Kopp and Marian Joan Kopp) for mental stress and loss of income of $8,000,000.00 to the Plaintiff George Edward Lyons.

And full repairs of 1194 Camelot, Pinckney, Mi. to Plaintiff satisfaction.
That was wrongfully incurred as results of Defendant’s Patricia Ann Lyons and Dale Fisher, egregious behavior.

Monday, July 18, 2005





By_______________________________
Plaintiff: George Edward Lyons
1194 Camelot,
Pinckney, Michigan 48169
734-250-2734

(Nine) Friend of the Court and Patricia Lyons

STATE OF MICHIGAN
IN THE 44th JUDICAL CIRCUIT COURT OF (LIVINGSTON COUNTY)
AND FRIEND OF THE COURT
210 S. HIGHLANDER WAY, HOWELL, MICHIGAN, 48843

FRIEND OF THE COURT
210 S. HIGHLANDER WAY HON. JUDGE CAROL HACKETT GARAGIOLA
HOWELL, MICHIGAN 48843 Case no. 96-23807-DM
734-250-2734

PATRICIA A. LYONS
1916 NORVELL ROAD
GRASS LAKE, MICHIGAN
Plaintiff
V.

GEORGE EDWARD LYONS
P.O. BOX 226
PINCKNEY, MICHIGAN 48169
734-675-1679 Defendant
___________________________________/

PROOF OF SERVICE

Defendant George Edward Lyons on day of MONDAY, August 27, 2007has used the U. S. Postal service at Pinckney Post office and mail and served a copy of Defendant EMERGENCY MOTION FOR DISQUALIFICATION OF JUDGE CAROL HACKETT GARAGIOLA FOR BIASNESS. And PROOF OF SERVICE in the action upon: Plaintiff Patricia A. Lyons. Delivery address 1916 Norvell Road, Grass Lake, Michigan

I DECLARE THAT THE ABOVE STATEMENTS ARE TRUE TO THE BEST OF MY INFORMATION, KNOWLEDGE, AND BELIEF.



_________________________________,
GEORGE EDWARD LYONS
P.O. BOX 226
PINCKNEY, MICHIGAN 48169
734-675-1679
MONDAY, August 27, 2007




STATE OF MICHIGAN
IN THE 44th JUDICAL CIRCUIT COURT OF (LIVINGSTON COUNTY)
AND FRIEND OF THE COURT
210 S. HIGHLANDER WAY, HOWELL, MICHIGAN, 48843

FRIEND OF THE COURT
210 S. HIGHLANDER WAY HON. JUDGE CAROL HACKETT GARAGIOLA
HOWELL, MICHIGAN 48843 Case no.96-23807-DM
734-250-2734

PATRICIA A. LYONS
1916 NORVELL ROAD
GRASS LAKE, MICHIGAN
Plaintiff
V.

GEORGE EDWARD LYONS
P.O. BOX 226
PINCKNEY, MICHIGAN 48169
734-675-1679 Defendant
___________________________________/

EMERGENCY MOTION FOR DISQUALIFICATION FOR BIASNESS
HONORABLE JUDGE CAROL HACKETT GARAGIOLA


Plaintiff George E. Lyons makes this motion and says:

1. Within the past (14) days, Plaintiff has become aware of facts giving Rise to disqualification and therefore this motion has been brought in a proper, timely manner under MCR 2.003 et seq.

2. This Honorable Court and other legal representatives cannot impartially hear any matter involving this case because:

3. That her. JUDGE CAROL HACKETT GARAGIOLA is being called on a witness in this case.

a. This Court and other legal representatives is biased or prejudiced for or against either or both of the parties to this action, and biased in favor of past/present Plaintiff’s. Plaintiff’s attorney, which is disqualifying under MCR 2.003(B) (2);

b. This Honorable Court and other legal representatives are disqualified by law for numerous other reasons under the provisions of MCR 2.003(B) (7).

1. That this Honorable Court and other legal representatives and all other Livingston County judicial or Circuit officers and court personnel should be disqualified from acting upon, hearing, deciding or otherwise participating in any further disposition of this case in any manner, except to disqualify as requested; as required by MCR 2.003(B) (2) and to disqualify as requested; as required by MCR 2.003 (B) (2) and or MCR 2.003 (B) (7), the grounds for which are stated herein are stated herein and in the attached affidavit.

2. That per Plaintiff Witness List the following is included. In previous emergency motion of Disqualification of Judge Susan Reck. Case no.96-23807-DM

5. Charles Widmaier (P-38376) Material Witness Live
Attorney for the Defendants confirm audio
822 E. Grand River Avenue
Brighton, Michigan
(810-229-9340)

6. Employee’s of Harris & Literski Material Witness Live
317 E. Grand River confirm audio
Brighton, Michigan 48116

9. All Judge’s of Livingston County Material Witness Live
Court system District / Circuit confirm audios
And all employee’s

. Honorable Judge Burress Material witness Live

58. Honorable Judge Haggerty Material witness Live

59. Honorable Judge Laterille Material witness Live

60. Honorable Judge Reader Material witness Live

61. Honorable Judge Delvero Material witness Live

62. Honorable Judge Reck Material witness Live

63. Honorable Judge Pickeranin Material witness Live

All employees of Livingston County Material witness Live

64. Magistrate Brown Material witness Live

And if the above would follow under conflict of Interest, and are not used as witnesses in this case and others cases that are being filed in the future. And attorney’s and court referee Gerald Edit, Attorney Coupland and Dr. Richard Zipper, would fall under support of perjury.

The July 10, 1995 amendments of MCR 2.003, and Rules 3A, 3D, 6C, and 7B of the Michigan Code of Judicial Conduct, and new MCR 9.227 and Rule 7D of the Michigan Code of Judicial Conduct, are based on the proposed revision of the Michigan Code of Judicial Conduct submitted by the State Bar Representative Assembly. See 442 Mitch 1216 (1993). They are effective September 1, 1995.

(3) Ruling. The challenged judge shall decide the motion. If the challenged judge denies the motion,

(a) In a court having two or more judges, on the request of a party, the challenged judge shall refer the motion to the chief judge, who shall decide the motion de novo;

(b) In a single-judge court, or if the challenged judge is the chief judge, on the request of a party, the challenged judge shall refer the motion to the state court administrator for assignment to another judge, who shall decide the motion de novo.

WHEREFORE, Plaintiff respectfully request:

A. That this motion be granted; and,
B. That this matter be thereafter transferred to the State Court Administrator’s office for reassignment to wherefore another circuit as required by MCR 2.003 et seq.

ALTERNATIVE, IF THIS MOTION IS DENIED, Plaintiff respectfully demands;

A. That this motion be referred and transferred the 44th Circuit Court Chief Judge for a de nova hearing and /or other or further proceedings MCR. 2003 et seq.,

B. That this Honorable Court to set aside any and all judgments and refrain from taking any further actions on this case during the pendency of said disqualification proceedings, as required under MCR 2.003 et seq., and
C. That this Court refrain from taking any further action on this case during the tendency of said disqualification proceedings, except those ministerial action necessary to comply with applicable statutes, court rules and case law.

Procedure:

Proper procedure for handling a motion to disqualify is well established and was recently summarized in Czuprynski v Bay 1 2 follows:

“The procedure for disqualification of a trial judge . . . which was formerly provided by statute is now provided by court rule. MCR 2.003 generally, that procedure is exclusive and must be followed. “10/31.
: MCR 2.003 provides that a party or attorney seeking disqualification must file a written motion supported by an affidavit of facts and including all know grounds for disqualification. The Judge complained of then holds a hearing and decides the motion. If the motion is denied, then the party or attorney may refer the motion to the chief judge who must decide the motion de novo on the record 32/33

Respectfully submitted this Monday, August 27, 2007




By: __________________________________
George E. Lyons, Defendant
P.O.Box 226
Pinckney, Michigan 48169
734-657-1679


STATE OF MICHIGAN
IN THE 44th JUDICAL CIRCUIT COURT OF (LIVINGSTON COUNTY)
AND FRIEND OF THE COURT
210 S. HIGHLANDER WAY, HOWELL, MICHIGAN, 48843

FRIEND OF THE COURT
210 S. HIGHLANDER WAY HON. JUDGE CAROL HACKETT GARAGIOLA
HOWELL, MICHIGAN 48843 Case no. 96-23807-DM
734-250-2734

PATRICIA A. LYONS
1916 NORVELL ROAD
GRASS LAKE, MICHIGAN
Plaintiff
V.

GEORGE EDWARD LYONS
P.O. BOX 226
PINCKNEY, MICHIGAN 48169
734-675-1679 Defendant
___________________________________/



AFFIDAVIT SUPPORTING EMERGENCY MOTION FOR DISQUALIFICATION OF HONORALBE JUDGE CAROL HACKETT GARAGIOLA


Defendant George E. Lyons, being first duly sworn, deposes and says that the following facts are true to the best of his personal knowledge; or are based on information and belief, and as to those he believes them to be true; and if sworn as a witness in this matter he would competently testify and produce other evidence to conclusively prove as follows:

1. HONORABLE JUDGE CAROL HACKETT GARAGIOLA, and other legal representatives, and on information and belief, has numerous personal contacts and acquaintances among all of Livingston County judges, court clerks, other court employees and personnel.

2. HONORABLE JUDGE CAROL HACKETT GARAGIOLA, and other legal representatives, these allegations beginning many years ago, became directly, indirectly, regularly and routinely involved and enmeshed with all Livingston County and Washtenaw judges and other court personnel in numerous legal, political, fraternal and social organizations. Structures and activities; all of which on information and belief, has provided and continues to provide numerous opportunities for judicial and extra-judicial ex-parte contacts with Livingston County and Washtenaw judicial officers and other court personnel.

3. DEFENDANT believes that the HONORABLE JUDGE CAROL HACKETT GARAGIOLA and other legal representatives, acting herein, has and will actively use his/ and their long-time positions, influence, access to judges and access to court records: to make ex-parte contacts with members of the Livingston County bench and /or their employees in attempts to create bias in defendant’s favor; to surreptitiously remove materials from court records to which Plaintiff is a party; and to otherwise deprive Plaintiff of his rights to due process in this case in any manner possible.
4. On information and belief, HONORABLE JUDGE CAROL HACKETT GARAGIOLA and Other legal representatives, for past clients has already used his status and connections to misinform and intimidate potential attorneys for defendants in this case and thereby effectively deprived DEFENDANT of legal representation herein.

4. DEFENDANT believes that, from it inception, Plaintiff’s and other past clients has been given special considerations in the handling and treatment of the instant case by 44th Livingston county Circuit court and Friend of the court personnel, due to bias in favor of Plaintiff’s and her attorney.

6. HONORABLE JUDGE CAROL HACKETT GARAGIOLA, and other legal representatives, herein is inextricably involved and enmeshed in numerous judicial and extra-judicial matters which include, in general, all Livingston County judicial and circuit officers and other court personnel.

7. All members of the Livingston Judicial and Circuit and Friend of the court County bench would have a natural inclination or tendency, if sitting in judgment, to be biased in favor of Plaintiff’s and/or against DEFENDANT due to the status and judicial connections of Plaintiff’s counsel and her past attorney’s and Friend of the court referee’s .

8. HONORABLE JUDGE CAROL HACKETT GARAGIOLA and other legal representatives, WOULD HAVE too many opportunities, and is of a mind, and has already undertaken, to improperly engage in ex-parte communications with Livingston County Judicial and Circuit court and Friend of the court judges relative to this case; And the has repeatedly representation of Due to the circumstances and relationship existing between the HONORABLE JUDGE CAROL HACKETT GARAGIOLA and other legal representatives, and all judicial and Circuit court officers in Livingston County; DEFENDANT believes he cannot get a fair trial or hearing in this county.

9. DEFENDANT WILL present to this court, and other courts evidence to support the removal of this Case LYONS VS. LYONS to a de nova hearing to the State of Michigan Administration Hearing to be transfer to another circuit court.

10. Defendant George E. Lyons hereby swears under penalty of perjury that all facts stated in the forgoing Affidavit In Support of Emergency Motion for Disqualification of HONORABLE JUDGE CAROL HACKETT GARAGIOLA for Biasness, the Defendant’s are true to the best of his personal knowledge or stated on information and belief, and as to those facts he believes them to be true.



By: _____________________________
George E. Lyons, DEFENDANT
Subscribed and sworn to before me
This 27TH day of AUGUST. 2007

Notary Public: ____________________________.




STATE OF MICHIGAN
IN THE 44th JUDICAL CIRCUIT COURT OF (LIVINGSTON COUNTY)
AND FRIEND OF THE COURT
210 S. HIGHLANDER WAY, HOWELL, MICHIGAN, 48843

FRIEND OF THE COURT
210 S. HIGHLANDER WAY HON. JUDGE CAROL HACKETT GARAGIOLA
HOWELL, MICHIGAN 48843 Case no. 96-23807-DM
734-250-2734

PATRICIA A. LYONS
1916 NORVELL ROAD
GRASS LAKE, MICHIGAN
Plaintiff
V.

GEORGE EDWARD LYONS
P.O. BOX 226
PINCKNEY, MICHIGAN 48169
734-675-1679 Defendant
___________________________________/


BRIEF MEMORANDUM OF LAW IN SUPPORT OF EMERGENCY MOTION FOR DISQUALIFICATION FOR BIASNESS


DISQUALIFICATION LAW AND ARGUMENT

These underlying principles of disqualification law are well settled. What the Michigan Supreme Court said almost 125 years ago in Stockton v Township Board is and Peninsular Railway v Howard, it remains valid and binding today:

“It Is among the First objects of civil government, to deprive persons of the power in adjudge finally for themselves, and conclusively assert their own causes; and so fundamental is this rule of justice, so essential to the order, peace, and even stability of government, that however broad the terms of a grant of judicial power may be, this principle remains operative, and gives rise to a tacit exception from the general words of the grant’s…The principle … asserts itself wherever judicial powers are employed by a body appointed by law…the rule is not confined to cases where the person is both judge and party. The principle… applies to the elements and substance of the controversy, and in general, where the case is of such a nature as to make it necessary, in its course or final issue for the trier to pass upon his own implicated rights or interest, the rule attaches and unseats him. Subtle
…
… The court ought not to be astute to discover refined subtle distinctions to save a case from the operation of the maxim, when the principle it embodies bespeaks the propriety of its application. The immediate rights of the litigants are not the only object of the rule. A sound public policy, which is interested in preserving every tribunal appointed by law from discredit, imperiously demands its observance. “10

Exactly what are the: implicated rights or interests”10 which will disqualify a judge? As was held in Stockton, supra, the can be found in the “elements and substance of the controversy:” what the Supreme Court almost a century later referred to as the “circumstances and relationships” of a case when it decided Glass v State Highway Commission, 23 citing the U.S. Supreme Court in Murchison. 2:

“A fair trial is fair tribunal is a basic requirement of due process. Fairness of course requires an absence of actual bias in the trial of cases. But our system of law has always endeavored to prevent even the probability of unfairness. To this end no man can be a judge in his own case and no man is permitted to try cases where he has an interest in the outcome. That interest cannot be defined with precision. Circumstances and relationship must be considered. This court has said, however, that every procedure which would offer a possible temptation to the average man as a judge…not to hold the balance site, clear and true between the state and the accused, denies the latter due process of law, ’23 Such a stringent rule may sometimes bar trial by judges who have no actual bias and who would do their very best to weigh the scales of justice equally between contending parties. But to perform it high function in the best way justice must satisfy the appearance of justice.” 24

The Glass court said, “Such reasoning applies equally to Michigan’s assurance of due process.” Therefore, virtually any “circumstances or relationship existing between a judge and a party litigant which would offer “ possible temptation to an average” person “ not to hold the balance nice, clear and true” between contending litigants denies due process of law and is interest enough to provide grounds for disqualification. ”23”
We expect our judges to be human beings with normal human faults and shortcomings like the rest of us, not angles in robes. We realize there are some situations where it would be extremely difficult for any judge to remain neutral and impartial, the often-quoted opinion in Wayne County Prosecutor v. Doerfler 24

“Justice Cardozo has stated.

“ Deep below consciousness are other forces, the likes and dislikes, the predilections and the prejudices, the complex of instincts and emotions and habits and convictions which make the man, be he litigant or judge. “27

A judge is not expected to bring with him to the bench a blank mind and personality. As he becomes, by necessity, a composition of the general experiences of his life, refined and honed by his legal training and legal experience so that the desired judicial temperament will hopefully emerge. “28

To require a blank mind is unreasonable, but to demand an impartial and clear appraisal of each new case is not. A judge may well be subconsciously prejudiced in one way towards the evidence or the parties in a case before him. It is his duty not to permit these prejudices to override his responsibilities in providing a fair forum for the determination of controversy. This duty should ideally motivate the judge to request reassignment of the case if he is aware of any prejudices which he holds which would interfere with his impartiality “29

Modern disqualification rules, grounded in public policy, exist as much for the good of the court as for the good of any litigant; and every judge has a duty to avoid even the appearance of bias, prejudice or partiality. Freely granting disqualification when justified and necessary to achieve that end. As was said in Warren Schools v. MERC: 2

“The object of this rule…is more than guaranties that a legal dispute will be resolved objectively by unbiased and impartial persons. It is also a shield against any suspicion on the part of the litigants and the public that any subjectivity, bias and partiality contributed to the outcome of the dispute. The though behind such was best expressed by Justice Frankfurther in Baker v Carr 22:
The Court’s authority – possessed of neither the purse nor the sword – ultimately rests on sustained pubic confidence in its moral sanction. Such feeling must be nourished by the Court’s complete detachment, in fact and in appearance…” 22

The Michigan Supreme Court has adopted a rule stated by the U.S. Supreme Court in Withrow:”4 judges and decision-makers should be disqualified without a showing of actual bias where “experience teaches that probability of actual bias on the part of the judge or decision-maker is too high to be constitutionally tolerable, “4

Throughout the last century. Courts have slowly but surely broadened the measure by which a disqualification “threshold” can be reached, steadily relaxing the standards for it employment. While early decisions tended more toward requiring concrete evidence of bias such as direct financial or personal interest, there was a gradual movement toward requiring only an appearance of bias, now well-established; and, more recently, the trend is allowing a petitioner’s reasonable belief that bias exists to establish the appearance of bias, to wit:
In a 1981 decision, Pitoniak v Borman’s, 5 the court held:
“A basic requirement of the constitutional right is due process is a hearing before a fair, unbiased and impartial decision-maker. 1/2/3/4/5 A party who challenges the impartiality of a judge need not show actual prejudice; it is one in which: experience teaches that the probability of actual bias on the part of the judge or decision-maker is too high to be constitutionally tolerable. “4/5/6

Then in 1982, the Michigan Court of Appeals held, in People v Lowenstein: 14

“… (Some disqualification cases)… deal with how much of an allowance our courts will make for a judge’s inherent human failings. No human being (even a judge) is completely prejudice-free. But our judicial system requires judges. Therefore we make allowances. Under normal circumstances, we will assume (absent evidence to the contrary) that the judge is free enough from bias to make a tolerably non-partisan decision. For example, a judge will occasionally preside over a case involving a defendant who had earlier pleaded guilty to the offense. Because this situation often enough arises and because the appearance of impropriety is not that high, we allow the trial judge to remain in charge of the case absent a showing of actual bias…A C However, we realize that some situations are just too dangerous. Judges normally are not subjected to such special pressures and “under a realistic appraisal of psychological tendencies in human weaknesses, we find that the appearance of justice requires the judge to disqualify himself. The test is not (just) whether or not actual bias or an appearance of bias that the judge was unable to hold the balance between vindicating the interests of the court and the interests of the accused. “17 In fact, even though a judge personally believes himself to be unprejudiced, unbiased and impartial, he should nevertheless certify disqualification where there are circumstances of such a nature to cause doubt as to his partiality, bias or prejudice. “18/6/2 (emphasis added)

And circumstances of such a nature as to cause doubt can arise from the mind of a petitioner, as was held in1986 by the Florida Supreme Court, which arrived at the Michigan result by applying the same analysis from a different perspective, making several important points along the way as emphasized below:

“ … The facts alleged in a motion to disqualify need only show that the party making it has a well-grounded fear that be or she will not receive a fair trial at the hands of the judge. Judicial inquiry should focus on the reasonableness of the affiant’s belief that the judge. Judicial inquiry should focus on the reasonableness of the affiant’s belief that the judge may be biased, and not the judge’s own perception of his or her ability to act fairly. … The sufficiency of the allegations depends upon whether he or she has successfully established the actual existence of prejudice. The letter standard would render the motion for disqualification virtually futile and result in the sort of adversary proceeding between judge and petitioner that create bias or the appearance thereof even where none had existed before. “33 (emphasis added)

And further to that:

“Generally, disqualification of a judge from action in a proceeding in which he is not wholly free, disinterested and independent is intended not merely for the benefit of the parties to the suit, who are entitled to the cold neutrality of an impartial judge, but for the general interests of justice, by preserving the purity and impartiality of the courts, and the respect and confidence of the people for their decisions. Moreover, judicial tribunals must not only be, but appear to be impartial, so that where circumstances are such as to create in the mind of a reasonable man a suspicion of bias, disqualification may be warranted although there is no proof of actual bias. “36 (emphasis Case no.96-23807-DM added)

No matter where the evolution of disqualification theory may lead, the eternal catch 22 of disqualification law will always follow: upon any request for disqualification, if there exists even a reasonable suspicion of the presence of bias, prejudice or partiality any failure to grant the request tends to beg the question, lead to more suspicion and possibly create the evil otherwise truthfully denied and sought is be avoided.

A truly independent non-biased judge considering such a situation should not care about retaining jurisdiction of any particular case; but instead rise above one’s self, respect a petitioner’s well-plead request and promptly proceed to remove all grounds for any suspicion of doubt, by granting disqualification.

Procedure:

Proper procedure for handling a motion to disqualify is well established and was recently summarized in Czuprynski v Bay 1 2 follows:

“The procedure for disqualification of a trial judge . . . which was formerly provided by statute is now provided by court rule. MCR 2.003 generally, that procedure is exclusive and must be followed. “10/31.

: MCR 2.003 provides that a party or attorney seeking disqualification must file a written motion supported by an affidavit of facts and including all know grounds for disqualification. The Judge complained of then holds a holds a hearing and decides the motion. If the motion is denied, then the party or attorney may refer the motion to the chief judge who must decide the motion de novo on the record 32/33


Respectfully submitted this August 27, 2007



By ______________________________________
George Edward Lyons
P.O.Box 226
Pinckney, Michigan 48169
734-657-1679


TABLE OF CITATIONS AND AUTHORITIES

1. US Const, Am XIV; Mich Const 1963,art 1,set 17;
2. In Re Murchison, 349 US 133, 136; 75 S Ct 623( 1955)
3. Gibson v Berryhill, 411 US 564, 579; 93 S Ct 1689 ( 1973)
4. Crampton v Dep’t of State, 395 Mich 347, 351 ( 1975 )
5. Pitoniak v Borman’s, Inc. 104 Mich App 718, 722-723(1981)
6. Withrow v Larkin, 421, US 35, 47; 95 S Ct 1455( 1975)
7. Mathews v Eldridge,424, US 319, 335; 96 S Ct 893 ( 1976 )
8. Goldberg v Kelly, 397 US 254, 263-271; 90 S Ct 1011 ( 1970)
9. Wayne Circuit Judges v Wayne County, 386 Mich 1 ( 1971)
10. Stockwell v Township Board, 22 Mich 341 ( 1871)
11. Peninsular Railway Co. v. Howard, 20 Mich 18 ( 1870 )
12. People v Houston, 179 Mich app 753, 756 ( 1983 )
13. Clemens v Bruce, 122 Mich App 35, 37-38 ( 1982 )
14. People v Lowenstein, 118 Mich App 475, 481-432 ( 1982 )
15. United State v Grinnell, 384 US 563; 86 S C: 1698 ( 1966 )
16. People v Rider, 93 Mich App 383 ( 1979 )
17. Ungar v Sarafite. 376 US 573, 588: 84 S Ct 841 ( 1964 )
18. Merritt v Munster, 575 P2d 623, 624 ( Okla. 1978 )
19. Strong v Pontiac General. 117 Mich App 143, 148 ( 1982 )
20. Wayne County v Recorder’s Court, 81 Mich App 143, 148 ( 1982 )
21. Warren Schools v MERC. 67 Mich App 58 ( 1976 )
22. Baker v Carr. 369 US 186, 267; 82 S Ct 691. 737 – 738 ( 1962 )
23. Tumey v Ohio 273 US 510; 47 S Ct 437 ( 1927 )
24. Offutt v United States, 348 US 11, 14; 75 S Ct 11 ( 1955 )
25. Glass v State Hwy Const. 370 Mich 482 ( 1963 )
26. Wayne County Prosecutor v Doerfler, 14 Mich App 428( 1968 )
27. Cardozo, Nature of the Judicial Process, p. 167.
28. Utilities Com v Pollak, 343 US 451, 466; 72 S Ct 813 ( 1952 )
29. Mirych v State Fair Commission, 376 Mich 384( 1965 )
30. Consumer Power v Iosco Circuit Judge, 210Mich 572 ( 1920 )
31. Hayes-Albion v Kuberski, 108Mich App 642, 657-658 ( 1981 )
32. Gruprynski v Bay Judge, 166 Mich 118, 123-124 (1988)
33. People v Gauntlett, 134 Mich 737, 757-761 ( 1984 )
34. MCR 2.003 et seq.
35. Caleffe v Vitale,65 ALR 4th 67, 71-72 ( 1986 )
36. See 46 Am Jur 2d, Judges ss. 86; see also ss. C ( 1 ) ( a. b ) of Canon 3 of the Code 3 of the Code of Judicial Conduct ( Am Jur 2d Desk book )


EX-WIFE MAKES FALSE DOMESTIC ABUSE CHARGE AGAINST GEORGE LYONS

1. AS DIVORCE PROCEEDING BEGIN, MRS. LYONS WAS DIRECTED BY HER ATTORNEY BRIAN LAVAN TO REMOVE PLAINTIFF FROM THEIR MARITAL HOME LOCATED AT 1194 CAMELOT, PINCKNEY, MI. AND ON FEB. 28TH 1998 FILE A FALSE DOMESTIC ABUSE CHARGE AGAINST PLAINTIFF GEORGE LYONS. (SEE AUDIO TAPE).

HISTORY OF ATTORNEY BRIAN LAVAN AND HIS COVER-UP OF ATTORNEY DALE COOPER.

2. CASE NO: 94-12621 CK HONORABLE STANLEY J. LATERILLE

ATTORNEY DALE COOPER committed perjury by stating that George Lyons committed Fraud, to enter a law suit into the Livingston County Courts. All building contracts were under the American Arbitration Clause:

Attorney Brian Lavan of Brian Lavan & Associates, at the time of his representation of George Edward Lyons. In addition, Lyons & Associates, Mr. Lavan firm was at 132 E. Grand River, Brighton, and Mi 48116.

1. On November 1st 1991, Attorney Brian Lavan and his wife Karen Lavan Leased 210 East Street, Brighton, Mi 48116, to Lyons & Associates, Inc. ( aka Lyons Builders, Inc ) and George Edward Lyons.

2. On approx. April 1, 1993 Attorney Brian Lavan and his employee Gerald Edit represented George Lyons in a Livingston County Circuit court, case Jim and Betty Steeber vs. Lyons & Associates, and George Lyons for the Steebers, committed breach of building contract. The same Steebers that was in the court case of Storzbach, Friberg, Steeber, etc. The same case that Ex-Wife Patricia Lyons was being represented by Brian Lavan, against Lyons Builders, Inc. vs. Storzbach, Friberg, Steeber, etc.

3. Attorney Brian Lavan held up 3 checks of George Lyons of Lyons & Associates, Inc. after George Lyons renovated the lease office at 210 East Street, Brighton, Mi. 48116 in approx. $ 9,000.00 + of new carpeting, painting etc.

4. Attorney Brian Lavan called George Lyons and requested George Lyons to file a false complaint to Consumer & Industry services, against the commercial leasing agent Richard Baker of the Baker Team of Novi, Michigan. “ I know it was not your fault for the eviction, I have a property in foreclosure, and your on a lease with option to by I cannot wait, Richard has a cash buyer, but I already paid Richard Baker for your commission, I do not want to pay him for this next commission. I want you to make a complaint against Baker with the License, so I do not have to pay the commission; I refused to do any illegal action, Brian Lavan then stated: and then I will contact your attorney (Thomas Brady, George Lyons attorney, and talk to him.)

5.CONFLICT OF INTEREST: Attorney Brian Lavan in the State of Michigan in the Circuit Court for the County of Livingston, Represented ex-wife Patricia A. Lyons and Attorney Brian Lavan filed a Complaint for Divorce April 2nd 1996, Case No. 96-23807 before Honorable Judge Burress, Brian Lavan represented Patricia Ann Lyons, in the complaint of Divorce in the complaint for Divorce, making a false statements against George Edward Lyons that See page 3. Paragraph 13 George Lyons asked Patricia A. Lyons, and audio taped.


That conversation was:

“Patti, on page 3 paragraph 13. Injunction: Making a false statement against Defendant (George Lyons) has physically abused Plaintiff in the past and because of the action now taken by Plaintiff (Patricia A. Lyons), in the filing of this divorce action, Plaintiff is justly fearful for her physical well being and is justly fearful that Defendant will assault, beat, molest or wound her unless he is restrained from doing so by order of this Court. Defendant, asked Patricia Ann Lyons why in this in the complaint of divorce, I never hit you, or strike you, in the 19 years we been together “Patricia it been 20 years”, George why is this in here, Patricia A. Lyons stated, I know you didn’t hit me, Brian said it was for better negotiation.”) This is on audio taped conversation.

6. On 12/4/1996 Brian Lavan then represented Patricia Ann Lyons, in case Livingston County Circuit court system before Honorable Stanley Laterille against the following Storzbach, Friberg, Chelsea lumber and JIM AND BETTY STEEBER AND LYONS BUILDERS, INC. AKA (Lyons & Associates, Inc.)

7. The same Jim and Betty Steeber that Brian Lavan represented Lyons & Associates, Inc. for Breach of contract in the above paragraphs, this writer believes that Attorney Brian Lavan committed CONFLICT INTEREST.

8. Brian Lavan also representing Patricia A. Lyons to acquire illegal funds from this case in a possible embezzling of $ 10,000.00 from Lyons Builders, Inc. by Patricia A. Lyons

9. Attorney Brian Lavan had full knowledge on Lyons Builders, Inc. Lose approx. $ 160,000.00 that was due Lyons Builders, Inc. for work done on 5654 Shoshoni Pass, Pinckney, Mi, in the Friberg and Storzbach case.

10. There is a possible collusion between Court receiver Attorney Dale Cooper and Attorney Brian Lavan, in the Livingston County Court Circuit before Honorable Judge Stanley Laterille.

11. Defendant request before Judge Burress a motion to remove Brian Lavan for Conflict of Interest and all evidence was presented, Lease agreement, and the Case of: Steeber v. Lyons & Associates, Inc. that Brian Lavan represented George Lyons and Lyons & Associates, Inc etc. Prior to the Steeber’s case prior to ex-wife Patricia A. Lyons case. Motion was denied.

12. EXAMPLE:

A. Brian Lavan Lease with option to buy a commercial property at 215 S. East Street, Brighton, Michigan to George Edward Lyons and Lyons & Associates, Inc. (aka Lyons Builders, Inc.)

B. Attorney Brian Lavan was hired to represent Lyons & Associates, Inc. (aka Lyons Builders, Inc.) And George Lyons against Jim and Betty Steeber for breach of Contract.

C. Attorney Brian Lavan illegal evicts George Edward Lyons from 215 S. East Street, Brighton, Michigan. To purchase a Foreclosure commercial property on Grand River Ave. Brighton, Michigan.

D. Attorney Brian Lavan then was hired by George Edward Lyons ex-wife Patricia A. Lyons to illegal acquire illegal funds from 5654 Shoshoni Pass, Pinckney, Michigan. Against George Edward Lyons and Lyons Builders, Inc. and JIM AND BETTY STEEBER THE SAME PEOPLE THAT BRIAN LAVAN, Represented in the Law suit in the Breach of Contract JIM AND BETTY STEEBER.

IMPORTANT: Attorney Brian Lavan then represented Patricia A. Lyons in a divorce against George Edward Lyons. SEE NUMBER 5: THIS IS A HUGE CONFLICT OF INTEREST. But two motion to remove Attorney Brian Lavan in representing Patricia A. Lyons for conflict of Interest. The judge denied the motion.

* IMPORTANT: Friend of the Court Referee GERALD EDIT work for Attorney Brian Lavan on the CASE AGAINST (Lyons Builders, Inc.) V JIM AND BETTY STEEBER BREACH OF CONTRACT CASE, Friend of Court Referee Gerald Edit.


13. Defendant George Lyons presented a motion for Emergency Disqualification of Judge Burress for Biasness; the case was to go to the Lansing Administration office, for a De nova hearing. It was not sent to the Lansing administration office it was sent to a Judge in Jackson, Michigan. The motion was denied. This motion if denied was structured showed that Judge Daniel Burress is Bias against George Lyons.

14. * I have more evidence that include Brian Lavan employee Gerald Edit now representing the Friend of the Court of Livingston County court referee.

15. * George Lyons requested Referee Gerald Edit to be removed as Referee, for conflict of Interest, Before Honorable Judge Susan Reck, overwhelming evidence was given to referee, Gerald Edit, proving that there may be possible collusion, and withholding evidence, and having full knowledge of Patricia A. Lyons through audiotapes, and presented documents shown to Referee Gerald Edit’s collusion, and biasness, Referee Gerald Edit is still representing Lyons v Lyons in the Livingston County Friend of the court.

The following charges against attorney Brian Lavan, trying to forcing George Lyons in making a false complaint to State of Michigan Consumer & Industry services continue Conflict of Interest, and collusion. And charges for Tortuous Interference and Civil Conspiracy. AND RESTRICTION OF TRADE, AND OBSTRUCTION OF JUSTICE.


BALANCE HISTORY OF COURT RECEIVER DALE COOPER WHO SHOULD BE DISBARRED

Attorney Dale E. Cooper Committed perjury by stating that George Lyons committed Fraud, to support his obstruction of justice actions, in reports to the Livingston County Court system. This is greatly supported by audio tapes.

1. In approx 1997, my ex-wife Patricia A. Lyons filed a complaint with the Attorney Grievance committee File no. 1781 / 97:

2. ATTORNEY DALE E. COOPER stated that he never made this statement. That Patricia A. Lyons stated in Attorney Grievance Complaint, that Mr. Cooper was going to give Mrs. Patricia A. Lyons a list because of the reduction in the price for needs of repairs in excess of $ 22,000.00, for 5654 Shoshoni Pass, Pinckney, Michigan 48169.
3. This was a fabrication on Attorney Dale E. Cooper part. I have in my possession audiotape of Attorney Dale E. Cooper acknowledging that he would give Patricia A. Lyons that list of repairs in excess of $ 22,000.00

4. This writer also has an appraisal of 5654 Shoshoni Pass prior to any suit that appraised out for $300,000.00

5. I also have letters from Real Estate One in communities to Attorney Dale Cooper acknowledging that they have two other offers over $ 265,000.00 to $ 275,000.00 that Dale Cooper received prior to the offer of $ 220,000.00.

6. Dale Cooper Court Receiver for Judge Stanley Laterille represent Laterille court, but it seems that he also represented Storzbach and Friberg’s to possibly embezzle funds from George Lyons and Lyons Builders, Inc. and Lyons, Inc. Court receiver Dale Cooper forced George Edward Lyons to sign a Warranty deed, without the legal representation of an a attorney.

7. During a hearing in Lyons v. Lyons divorce proceeding, Court receiver appeared with a Warranty Deed who was invited by Patricia A. Lyons attorney Brian Lavan. For Lot 88 Arrowhead Subdivision, aka 5654 Shoshoni Pass, Pinckney, Michigan 48169.

8. Court receiver Dale Cooper stated to Patricia A. Lyons and George Lyons. “I want you two to sign this Warranty deed on Shoshoni Pass. George Lyons stated to Patricia A. Lyons not to sign said Warranty Deed.

9. Court receiver Dale Cooper, ask George Lyons to sign side Warranty deed, George Lyons stated I would want an attorney to review this Warranty deed. “Dale Cooper stated you don’t need an attorney, and if you don’t sign this deed right now; I am going to throw your ass in jail. George Lyons again stated I would want this to be reviewed by my attorney.

10. Dale Cooper stated then your going to jail; we’ll just sit here and wait for Judge Burress. The same Judge that refused to be Disqualify for biasness, and rejected the Motion for Attorney Brian Lavan for Conflict of Interest.

11. George Lyons and Patricia A. Lyons, was threaten to sign said Warranty deed by Court Receiver Dale Cooper, George Lyons stated that I am signing this Warranty deed and stated to the notary republic, and to Dale Cooper who was present. “That I am signing this warranty deed under duress. THIS WAS TAPE-RECORDED.

12. In addition, with the figures at the beginning of these documents that Storzbach only paid Lyons Builders, Inc. $70,400.00 and through the Livingston County Building department, Lyons Builders, Inc. preformed $ 169,000.00 + and Friberg’s through the State of Michigan Consumer & Industry service, in Friberg’s complaint.

13. The Letter from the State of Michigan C & I services state the case is closed and that Lyons Builders, Inc. DID NO VIOLATION. But Storzbach and Friberg’s continue to embezzled funds form Lyons Builders, Inc. and George Lyons

14. . Now because of the illegal actions of court receiver Dale Cooper AND THE DEFENDANT(S)-APPELLEE(S) also caused George Lyons to face fraudulent N.S.F. charges. The above conversation was audiotape by this writer.

Collusion:

HISTORY OF EX-WIFE EMBEZZLING MONEY FROM 5640 SHOSHONI PASS, PINCKNEY, MI

15. Another illegal action of Court Receiver Dale Cooper: was during negotiations Patricia Ann Lyons and Attorney Brian Lavan illegal actions in wrongfully stating that Patricia Ann Lyons was the owner of Lot 88 Arrowhead Subdivision aka 5654 Shoshoni Pass, Pinckney, Michigan 48169. This writer can prove that Patricia A. Lyons removed herself as resident agent 1 month after Lyons, Inc. was started. See Letter from Consumer & Industry services in 1993.

16. REAL ESTATE REPRESENTATION DIRECTOR Ann Milburn, ordering Patricia A. Lyons to either become a Real Estate Broker or remove herself from the Corporate records of Lyons, Inc.

17. That only a Licensed Broker could become a resident agent, Brian Lavan had knowledge to this fact. And Patricia Ann Lyons received illegal funds from Lyons, Inc. A Michigan Corporation for stating that she was legal owner of Lot 88 Arrowhead, 5654 Shoshoni Pass, Pinckney, Mi. 48169

18. Other evidence is a letter from Patricia A. Lyons to Consumer & Industry services REAL ESTATE REPRESENTATION DIRECTOR Ann Milburn , Statement in the letter states I Patricia A. Lyons is removing myself from Lyons, Inc. This was done in a corp. meeting, and witnessed in 1993.

19. So Dale Cooper did not get a clear title to Lot 88 Arrowhead Subdivision. Aka 5654 Shoshoni Pass, Pinckney, Mi. And that George Lyons is the true holder of Lyons, Inc.

20. And now request the property of 5654 Shoshoni Pass; Pinckney, Mi. back and that Dale Cooper should be responsible to return Lot 88 Arrowhead Subdivision, AKA 5654 Shoshoni Pass, Pinckney, Michigan. And time is of the essence. Or possibly charged along with Patricia A. Lyons and Attorney Brian Lavan and Court Receiver Dale Cooper for Tortuous Interference and Civil Conspiracy.

21. Another possible illegal action of Court receiver Dale Cooper: was during negotiations on 5654 Shoshoni Pass, Pinckney and Brian Lavan was stating the Patricia Ann Lyons was the owner of Lot 88 Arrowhead Subdivision. Patricia Ann Lyons stated to Dale Cooper on the offer to purchase of Lot 88 Arrowhead Subdivision aka 5654 Shoshoni Pass, Pinckney, Mi.

22. “Patricia A. Lyons stated to Dale Cooper on the offer to purchase lot 88 Arrowhead Subdivision we had an offer of $ 267,000.00 why am I accepting an offer for $ 220,000.00.

23. Dale Cooper court receiver stated “because their still a lot of things that have to be done to finish the Property. Patricia Ann Lyons, what things. Patricia Ann Lyons requested a list. Dale Cooper promised that he would acquire that List. THEN COURT RECEIVER DALE COOPER: came into the Courtroom as stated before this paragraph and Forced George Lyons and Patricia Ann Lyons to sign the illegal Warranty Deed to the reduce price of the property on Lot 88 Arrowhead Subdivision, aka 5654 Shoshoni Pass, Pinckney, Mi.

24. IMPORTANT: STORZBACH PAID LYONS BUILDERS, INC. $70,400.00 AND LYONS BUILDERS, INC. PERFORMED OVER $169,000.00+ WORTH OF WORK PER LIVINGSTON COUNTY BUILDING DEPARTMENT.

25, AND FRIBERG’S COMPLAINT TO THE STATE OF MICHIGAN CONSUMER & INDUSTRY SERVICES, THERE CASE WAS CLOSED AND FOUNDED THAT LYONS BUILDERS DID NO VIOLATIONS.

26. Patricia Ann Lyons informed George Lyons the rightful owner of Lyons, Inc. A Michigan
Corporation: and informed Him that the offer to purchase Lot 88 Arrowhead Subdivision aka 5654 Shoshoni Pass, Pinckney, Mi. the reduction of the property Shoshoni Pass. Pinckney, Mi to $ 220,000.00.

27. After receiving this information George Lyons went to the office of Court Receiver Dale Cooper and asks him if it true about the reduction of the property at 5654 Shoshoni Pass, Pinckney, Mi. And is he not accepting the other two offers on Shoshoni Pass, Pinckney, Mi. that were $ 265,000.00 and $275,000.00.

28. VERY IMPORTANT: After finding about this problem from the ex-wife Patricia A. Lyons. George Lyons went to Dale Cooper office of court receiver Dale Cooper: George Lyons asked Dale Cooper why you reduced the price of 5654 Shoshoni Pass, Pinckney, Mi 48169 to $220,000.00 Dale Cooper stated “Because there still has to be a lot of work done on Shoshoni Pass,

29. George Lyons then showed Court Receiver Dale Cooper a copy of an Appraisal for $300,000.00 on Lot 88 Arrowhead Subdivision aka 5654 Shoshoni Pass, Pinckney, Mi. Court receiver Dale Cooper had his secretary copy the appraisal.

30. George Lyons asked Court receiver Dale Cooper, “Patti Lyons told me that the reason you’re taking the offer of $220,000.00 because there things have to be done on the property. Dale Cooper stated to George Lyons. George Lyons stated to Dale Cooper “I have a certificate of Occupancy”.

31. Then George Lyons then stated, “There nothing has to be done on Shoshoni Pass, and the Livingston County Building Department does not give out Certificate of Occupancy and thing has to be done.” I have a Certificate of Occupancy Dale. Here it is. There is nothing to be done on the property”.

32. Then George Lyons stated “And that you promise her a list of things to be done on the property”. (5654 Shoshoni Pass, Pinckney, Mi. 48169”.

33. “Dale Cooper court receiver : Yes and I will get you a copy of those things have to be done, I’ll get a copy of the list to Patti, George I would like to have a copy, I make sure you get copy to”. AUDIO TAPE CONVERSATION.

34. Dale Cooper statement back to Attorney Grievance committee letter on 5654 Shoshoni Pass, Pinckney, Michigan. I never heard of a list and I never promised such a list for 5654 Shoshoni Pass, Pinckney, Michigan. This letter was support by Patricia A. Lyons Attorney Brian Lavan.

35. THIS WAS NOT TRUE. SEE AUDIO TAPE CONVERSATION AND DOCUMENTS AND APPRAISIAL THAT WAS GIVEN TO COURT RECEIVER DALE COOPER.
36. Dale Cooper: This was a cover-up and possible illegal action on Court receiver DALE COOPER. Also a cover-up letter from Patricia Ann Lyons attorney BRIAN LAVAN. FOOTNOTE: BRIAN LAVAN representing Lyons & Builders, Inc. against Steebers. Now Patricia Ann Lyons Divorce attorney. CONFLICT OF INTEREST.

37. FOOTNOTE: TO THE BUILDERS READING THIS EMAIL: George Lyons state what are you saying there nothing to be done, we have a CERTIFICATION OF OCCUPANCY ON THE PROPERTY AND Livingston County Building department would not grant a certification of Occupation without everything being done. “Did you say you’ll get a list of thing to be done to Patti (ex-wife)”?

38. Dale Cooper stated yes and I can you get her a copy. DALE COOPER STATED, AND I’LL SEE YOU GET A COPY TO. BUT A LETTER TO ATTORNEY GREIVANCE COMMITTEE DALE COOPER STATED I HAVE NO IDEA OF A LIST.

39. FOOTNOTE: Evidence shows Storzbach only paid Lyons Builders, Inc. $70,400.00 and through the Livingston County Building Department Lyons Builders, Inc. preformed $ 169,000.00 worth of work on Storzbach’s project a $98,000.00 difference.

40. THIS IS VERY IMPORTANT: Court Receiver DALE COOPER then came in to Court and force Patricia Ann Lyons and George Edward Lyons to signing a Warranty deed for lot 88 Arrowhead Subdivision aka 5654 Shoshoni Pass, Pinckney, Michigan 48169 under duress. As stated in the audiotape.

41. NOW THIS IS IMPORTANT: Being upset because Patricia Ann Lyons never received a copy of thing to be done on 5654 Shoshoni Pass, Pinckney, Michigan, Patricia Ann Lyons makes a complaint to the ATTORNEY GRIEVANCE COMMITTEE

42. Court Receiver Dale Cooper reduced the price of Lot 88 Arrowhead Subdivision aka 5654 Shoshoni Pass, Pinckney, Michigan. And then state back to Attorney Grievance committee that he Dale Cooper stated he had no knowledge about a reduction or a List. On 5654 Shoshoni Pass, Pinckney, Mi. This false and misleading on court receiver Dale Cooper part.

43. George Lyons is asking the Attorney Grievance committee to investigate Court Receiver Dale Cooper an investigate the reduction of the price of 5654 Shoshoni Pass, Pinckney, Mi. and that Dale Cooper promised to Patricia Lyons and George Lyons a list that caused the reduction from $ 265,000.00 to $ 220,000.00 That Patricia A. Lyons nor George Lyons never did received said reduction list that was promised from court receiver Dale Cooper.

44. IMPORTANT TO REMEMBER: And through the Consumer & Industry services a complaint filed Ronald and Virginia Storzbach WHICH that Lyons Builders, Inc. preformed $ 169,000.00 and WAS approved by Livingston County Building Department, and Ronald and Virginia Storzbach only paid $70,400.00 and Friberg’s complaint to the State of Michigan Consumer & Industry services complaint was closed and C&I stated the Lyons Builders, Inc. DID NO VIOLATIONS

45. And on Richard and Ann Friberg’s Complaint to Consumer & Industry services closed complaint stated that Lyons Builders, Inc. DID NO VIOLATIONS. Both suits were fraudulent to embezzle money from Lyons Builders, Inc. See permits history both on Storzbach’s and Friberg’s projects.

46. Honorable Judge Stanley Laterille combined both Ronald and Virginia Storzbach and Richard and Ann Friberg’s suits. Which combined other attorney grievance letters of attorney’s Richard Conlin, Brian Lavan.


Respectfully Submitted



_______________________
George Edward Lyons
P.O. Box 226
Pinckney, Michigan
48169