Wednesday, October 15, 2008

PEOPLE OF MICHIGAN IS THERE CORRUPTION IN LIVINGSTON COUNTY, MICHIGAN

State of Michigan
In the Livingston County Circuit Court
204 S. Highlander Way, Howell, Michigan 48843
517-546-9816

George Edward Lyons,
11994 Weiman
Pinckney, Michigan 48169
734-954-4040
Plaintiff,
vs.

James Brady and wife,
1194 Camelot,
Pinckney, Mi.48169
Phone unavailable
Defendants,

DEFENDANT’S ATTORNEY
Attorney for Defendant
Douglas J. Cameron
McCririe & Cameron Attorneys and Counselors
317 W. Main St.Brighton, MI 48116810-229-6167

POSSIBLE OTHER DEFENDANTS
Karl and Marian Kopp H/W
Case no. 04-020652-CF-B LYONS V. KOPP
Case No.: 07-23338-CH
Hon. Judge Latreille





CASE EVALUATION OF PLAINTIFF GEORGE LYONS

AND ANSWERS TO DEFENDANT JAMES BRADY EVALUATION STATEMENTS.


1. INTRODUCTION

The following Plaintiff statements are in response to the fraudulent statements of Attorney Douglas Cameron and his clients Defendant JAMES Brady and Mr. & Mrs. Kopp in the said Document Mr. Cameron presented as a CASE EVALUATION OF DEFENDANT JAMES BRADY. Also named in this response are the Judges of Livingston County as IN NOT following the letter of the Law.

PAGE 1 and Paragraph 1 of the Case Evaluation of Defendant JAMES BRADY states: The Plaintiff GEORGE LYONS has commenced yet another bizarre action.

Plaintiff response statement: Plaintiff presented motions that were made and not followed by the Livingston County court Judge’s and hereby not giving the Plaintiff his due process of Law and these Judge’s did not follow the U.S. Constitution by both the Livingston County judges and Attorneys.

Further, the Plaintiff states it is the bizarre actions by the attorneys including Defendant James Brady and Attorney Douglas Cameron who may be committing fraud upon this court. Along with the Judge’s of Livingston County who may have committed interference with Interstate Commerce by not disqualifying themselves in previous cases that were heard by these same said judges and not granting the Plaintiff his Due Process of Law.

Examples: Plaintiff George Lyons was not given his due process of Law. Should a Livingston County judge not disqualify himself, then the judge is violation of the Due Process Clause of the U.S. Constitution. United States v. Sciuto, 521 F.2d 842, 845 (7th Cir. 1996)


("The right to a tribunal free from bias or prejudice is based, not on section 144, but on the Due Process Clause."). Should a judge issue any order after he has been disqualified by law, and if the parties has been denied of any of his / her property, then the judge’s may have been engaged in the Federal Crime of "interference with interstate commerce".
The judge has acted in the judge's personal capacity and not in the judge's judicial capacity. It has been said that this judge, acting in this manner, has no more lawful authority than someone's next-door neighbor (provided that he is not a judge). However some of these judges may not follow the law.

The Livingston county judge’s did issue an order after he has been disqualified by law, and if the George Lyons has been denied of any of his / her property, the Livingston County judge’s have been engaged in the Federal Crime of "interference with interstate commerce".

The Livingston county judge’s has acted in the judge's personal capacity and not in the judge's judicial capacity. These Livingston County Judges are acting in this manner, and therefore have no more lawful authority than someone's next-door neighbor (provided that he is not a judge). However, these Livingston County Judges did not follow the law.)

Plaintiff response statement: TO PAGE 1 and Paragraph 1 of the Case Evaluation of Defendant JAMES BRADY: The Plaintiff is seeking damages and the return of certain Real property located at 1194 Camelot, Pinckney, Michigan. (AKA SEC 36 T1N R4E CAMELOT SHORES #3 LOT 28 & 29 AND THE SW'LY 33 FT M/L OF LOT 30 SPLIT 3/92 FROM 029.) The AFORE MENTIONED property is currently criminally and wrongfully owned by the Defendant JAMES BRADY.
The Defendant criminally and fraudulently received a false warranty deed through a false forfeiture committed by the Kopp’s from the Plaintiff George Lyons and his ex-wife Patricia Ann Lyons of the 1194 Camelot property from the Defendant’s attorney Douglas Cameron in representation of Karl and Marian Kopp. Attorney Douglas Cameron represented both the Defendant and the Kopp’s and committed fraud upon the court by submitting a false summary disposition to the Livingston County Court to acquire illegal gains from the Plaintiff and his ex-wife.

Prior to this, the ownership of the property 1194 Camelot residence was owned by the Plaintiff and his ex-wife. The Plaintiff’s Complaint demands the court to find Mr. Brady is guilty of receiving and concealing stolen property and embezzlement. Plaintiff’s Complaint also seeks in excess of $1,000,000.00 (1 million dollars) due to the illegal and criminal actions of Mr. & Mrs. Kopp and Defendant James Brady in which property 1194 Camelot, Pinckney, Mi. was wrongfully sold by Mr. & Mrs. Kopp and received by Defendant James Brady.

Plaintiff states that Karl and Marian Kopp criminally filed a fraudulent forfeiture against the Plaintiff and his ex-wife. The Kopp’s committed fraud upon the court, by committing perjury in their false forfeiture on 1194 Camelot, Pinckney, Michigan by stating they never received any monies from the Plaintiff and his ex-wife. These statements and false forfeiture were in fact liable and perjury committed by the Kopp’s on their part in a sworn court of law. The Plaintiff further states the Kopp’s received a $24,000.00 (TWENTY-FOUR THOUSAND DOLLARS) official check on which it is noted on the back of said check FOR THE PAYMENT ON CAMELOT. See EXHIBIT A.

The Kopp’s also received equity from the Plaintiff in lot 2 Betty Lyons Lane, Pinckney, Michigan. of which at the time was in excess of $35,000.00 (Thirty-Five Thousand dollars). The Kopp’s were receiving these monies from the Plaintiff and his company for the sole purpose of making additional payments towards the said property located at 1194 Camelot, Pinckney, Michigan. See also Exhibits A: See audio tapes.

The Kopp’s also breached the building agreement that was approved by the Kopp’s and Plaintiff building company on lot 1 Norcrest, Brighton, Michigan of which the Kopp’s were receiving another $50,000.00 ( FIFTY THOUSAND DOLLARS ) in builder’s costs from the Plaintiff's building company namely, (Lyons Builders Inc. ). In which this payment was to be also to be used to make payments toward 1194 Camelot, Pinckney, Michigan. See Exhibits A See audio tapes.

The Plaintiff states that the Defendant’s attorney Douglas Cameron is again trying to wrongfully discredit the Plaintiff George Lyons by his fraudulent means of giving this court a grand delusion that his clients the Kopp’s and Plaintiff Brady are innocent against the charges that the Plaintiff is filing against the Defendant James Brady and Mr. & Mrs. Kopp in their criminal actions against the Plaintiff.

The Plaintiff further states that Attorney Douglas Cameron trying to file yet again, another fraudulent and fabricated Summary Disposition against the Plaintiff. Attorney Douglas Cameron is committing further/additional fraud upon the court by presenting this fabricated Document of Case Evaluation of Defendant James Brady.

Further to this, the Plaintiff presented overwhelming evidence that was presented in the prior cases by the Plaintiff proving that attorney Douglas Cameron had full knowledge that he and his law firm, were in fact, committing fraud upon the Livingston County court by filing the last fraudulent summary disposition against the Plaintiff George Lyons and his company.

Attorney Douglas Cameron is again presenting yet another fraudulent Summary Disposition and by doing so is committing again another fraud upon the Livingston County court along with and in doing so further committing an additional criminal act against the Plaintiff.

The Plaintiff further states that the additional false Summary Disposition requested by Defendant’s attorney Douglas Cameron for Summary Disposition cannot survive a Summary Disposition because the Plaintiff George Lyons did set forth all legal cognizable causes of action and therefore this case is able to be tried by this court.

The Plaintiff George Lyons in previous cases was denied Due Process of Law which is governed by the United States Constitution. Again Plaintiff George Lyons' Due Process was denied by the Livingston County Judges, attorneys and their present and past clients.

Attorney Douglas Cameron, the Kopp’s and Defendant James Brady which is supported by this document in their wrongful and criminal acts against the Plaintiff George Lyons. The Plaintiff did in fact answer Mr. Brady’s false statements and allegations raised by these three Defenses:

(1) The Plaintiff should not be denied this law suit against the Defendant because of the illegal actions of the Defendant James Brady, Past Defendant’s Karl F. Kopp and Marian J. Kopp and their Attorney Douglas Cameron in his action to commit fraud upon this court. And the judges in their suppressing of the Plaintiff's rights of due process of Law in previous cases which is governed by the United States Constitution.
(2) Plaintiff has in fact stated a claim of which relief can be granted and again is repeated in this document. Finally,
(3) there is in fact a genuine issue as to all material facts and the Plaintiff George Lyons is entitled to a Judgment in his favor as a matter of Law against the Defendant.


II. BACKGROUND


Plaintiff Response statement to PAGE 2 and Paragraph 2 of the Case Evaluation of Defendant JAMES BRADY: Plaintiff correcting the false statements of Attorney Douglas Cameron. Prior to 1997, Plaintiff and Defendant’s predecessors in title, Mr. & Mrs. Kopp, were friends and had a relationship of which Mr. Karl F. Kopp did in fact have an adulterous relationship with the Plaintiff ex-wife Patricia Ann Lyons.

Marian Kopp was the office Manager of Lyons Builders Inc. at 1194 Camelot, Pinckney, Mi. Which primarily involved Mr. & Mrs. Kopp funding the Kopp’s a building project on lot 3 Betty Lyons Lane, Pinckney, Michigan.

Plaintiff George Lyons who until 2000 was at the time a licensed residential builder and real estate broker. Plaintiff response statement: Sometime around 1994 these License’s were wrongfully and criminally removed by the State of Michigan (Plaintiff will explain in court).

Also please review Reference Book that has already been present to this court will support the State of Michigan Consumer & Industry services illegal and criminal actions in wrongfully removing Plaintiff licensed residential builders and real estate broker’s license.

The Plaintiff, Mr. Lyons began experiencing personal difficulties due to the extortion and embezzlement by past clients STORZBACHS, FRIBERGS, FEEBACKS, LALONDES AND MARCICHS who had embezzled from the Plaintiff and his company.

The approximate amount of embezzlement of funds from the Plaintiff George Lyons by the afore mentioned people is in the amount of $770,000. 00 (SEVEN HUNDRED AND SEVENTY THOUSAND DOLLARS).

Review Plaintiff’s accounting and recovered documents that was hidden by Mr. & Mrs. Kopp to protect their embezzlement from Plaintiff George Lyons. The actual figure of this monetary amount can be verified with proof of accounting and bank statements.

The Kopp’s, did in fact, embezzle the Plaintiff's marital residence located at 1194 Camelot, Pinckney, Michigan by making a fraudulent forfeiture against Plaintiff George Lyons marital home. This dwelling and property located at 1194 Camelot, Pinckney, Michigan ( AKA SEC 36 T1N R4E CAMELOT SHORES #3 LOT 28 & 29 AND THE SW'LY 33 FT M/L OF LOT 30 SPLIT 3/92 FROM 029.) ) was appraised for in 1996 for $800,000.00 (EIGHT HUNDRED THOUSAND DOLLARS).

Again, during that false forfeiture created by the Kopp’s, the Plaintiff was denied Due Process of Law as is governed by the United States Constitution. The Livingston County court system, the State of Michigan Consumer & Industry Service (also known as the Department), past clients and the Kopp’s that the Plaintiff was building homes for. These statements are supported by a document that has already been presented to this court. See Exhibit A: referred to as the 'reference book'.

The PLAINTIFF-REFERENCE BOOK proves beyond a reasonable doubt that a report from the State of Michigan Consumer & Industry Service's Administrator, Judge Mourning was given a fabricated report by State employee auditor Nicolas Myers and past clients Ronald and Virginia Storzbach and their witnesses did knowingly commit perjury to acquire illegal funds from the Plaintiff George Lyons. Judge Mourning, did in fact, deny Plaintiff George Lyons his Due Process of Law which is supported by the United States Constitution.

The false Hearing report by Judge Mourning on the Storzbach’s' false complaint to the State of Michigan Consumer & Industry Services was wrongfully used by many other past clients and the Kopp’s to acquire illegally funded monies obtained by criminal means from the Plaintiff George Lyons and his company.

The same false Hearing by Judge Mourning has also poisoned the Plaintiff’s credibility in the Livingston County Court system and their Judges.

This REFERENCE BOOK has been presented in this case as evidence in which it proves that the Livingston County Court System and the State of Michigan Consumer & Industry Services were denied jurisdiction to hear any complaints by the past clients and the Kopp’s. Further to this, the entire building contracts of these past clients and the Kopp’s were governed by the Federal American Arbitration clause in all past clients and Kopp’s contracts.

Both The Livingston County Courts and the State of Michigan Consumer & Industry services did in fact deny the Plaintiff George Lyons his Due Process of Law in previous cases which is governed by the United States Constitution.

Further to this, the Livingston County Judges did in fact issue Orders/Rulings/Judgments after he/she was disqualified by law.

The Plaintiff George Lyons has been denied and continues to be denied of any or all of his property despite proof of his sole ownership, this further lays cause to believe based on documented evidence whether intentional or otherwise that the Livingston County Judges may have been or are currently engaged in the Federal Crime of

"interference with interstate commerce" of any and all cases in the Livingston county court system along with the State of Michigan offices of the State of Michigan Consumer & Industry services aka Department of Labor and Economic Growth administration Judge’s”.

This further identifies, that both the Livingston County Court System and the State of Michigan Consumer & Industry Service did in fact deny Plaintiff George Lyons his Due Process of Law, which was governed by the United States Constitution and is supported by the Federal Arbitration clauses in all the of the Kopp’s and past clients' contracts. In which the Livingston county judges did in fact deny the Plaintiff George Lyons his Due Process of Law.

The Federal Arbitration clause in all contracts proves overwhelmingly that the Livingston County Courts and the State of Michigan Consumer & Industry Service Judicial Department had no jurisdiction against the Plaintiff George Lyons and his companies and all of the cases that were brought forward by past clients and Mr. & Mrs. Kopp in their fraudulent forfeiture against the Plaintiff and/in illegally acquiring 1194 Camelot, Pinckney, Michigan ( AKA SEC 36 T1N R4E CAMELOT SHORES #3 LOT 28 & 29 AND THE SW'LY 33 FT M/L OF LOT 30 SPLIT 3/92 FROM 029 ) the Plaintiff's marital home.

PAGE 2 and Paragraph 2 of the Case Evaluation of Defendant JAMES BRADY: In an attempt to address these difficulties on a financial which affected the Plaintiff's ability to complete building projects, deal with his customers and in an attempt to address these difficulties on financial basis (caused due to the embezzlement of over $770,000.00 (SEVEN HUNDRED AND SEVENTY THOUSAND DOLLARS) in monies from the Plaintiff and his company by past clients and Mr. & Mrs. Kopp taking the advantage of the Plaintiff ).

Past client Karl Kopp then approached Plaintiff Lyons and his present ex-wife Patricia Lyons requesting instead the Plaintiff Lyons going to a financial group to acquire an equity loan.

After this, Karl Kopp and Marian Kopp further requested Plaintiff George Lyons to consider them for the loan to finish CONSTRUCTION ON 5640 Shoshoni Pass, Pinckney, Michigan in Richard and Ann Friberg's project.

Footnote: The Friberg’s false complaint to the State of Michigan Consumer & Industry Service was overturned by Consumer & Industry Service that Plaintiff George Lyons did no violations against Richard and Ann Friberg and the false complaint was closed. Evidence already presented.

As stated on the audio tape, Karl Kopp stated they could use the interest on funds that the Plaintiff was to borrow from a financial group. Mr. Lyons and Patricia Lyons regrettably agreed to the request from the Kopp’s with stipulations.

Karl Kopp also stated on audio tape (That the monthly payments did not have to start until the sale of 5640 Shoshoni Pass, Pinckney, Michigan, since 5640 Shoshoni Pass did not close until December 1997)

This money borrowed from the Kopp’s was used to finish Shoshoni Pass, Pinckney, Michigan whereas the Friberg’s refused to make any more payments on their project, the reason given that they were transferring to Gordonville, Virginia. The Friberg’s did in fact, breach their building contract with Plaintiff George Lyons and his building company.

Again The Plaintiff George Lyons agreed to take the Loan for $90,000.00 (NINETY THOUSAND DOLLARS) from the Kopp’s. Along with that the agreement that the Plaintiff did not have to make any payments until the sale of 5640 Shoshoni Pass, Pinckney, Michigan. See the time dated audio tapes Exhibit A: with the Kopp’s supporting these statements above by the Plaintiff.

As per the closings on the Loan of $90,000.00 (NINETY THOUSAND DOLLARS) two deeds on 1194 Camelot, Pinckney, Michigan were to be placed into an escrow account. One deed to the Kopp’s and the second back to the Plaintiff and his wife Patricia Ann Lyons for 1194 Camelot Pinckney, Michigan.

These warranty Deeds for 1194 Camelot, Pinckney, Mi. were not to be removed from the approved escrow account. See Exhibit A: audio tapes with the Kopp’s.

The Kopp’s' wrongfully and criminally acquired these signed warranty deeds from the escrow account and recorded said warranty deed at the Register of Deeds from Plaintiff Grantor’s George Lyons and his wife to the Grantee’s Kopp’s.

The second warranty deed on 1194 Camelot, Pinckney, Mi. from Grantor’s Karl and Marian Kopp’s that was to be placed into an escrow account.

Which would give back 1194 Camelot, Pinckney, Michigan to the Grantee’s Plaintiff George Lyons and his ex-wife Patricia Lyons. This Warranty deed for 1194 Camelot, Pinckney, Michigan was illegally removed from the escrow account by the Kopp’s (or by Marian Kopp’s and this deed was again taken to the Register of Deed’s and recorded/registered on title by Marian Kopp. See Exhibit A:

THIS ACTION OF MARIAN KOPP’S GAVE BACK THE POSSESSION OF 1194 CAMELOT, PINCKNEY, MICHIGAN, WHICH WAS RECORDED BY MARIAN KOPP FOR INTEREST OF ONE DOLLAR ($1.00). SEE EXHIBIT A:

This Warranty deed for 1194 Camelot, Pinckney, Mi. again was recorded by LAND CONTRACT HOLDER MARIAN KOPP. This action of Mrs. Kopp proves that the Kopp’s had no right to take any possession/ or sell of 1194 Camelot, Pinckney, Michigan to Defendant James Brady.

The real record shows that the sale of 1194 Camelot, Pinckney, Michigan back to Plaintiff George Lyons and his ex-wife Patricia Ann Lyons for the said amount of $1.00 (ONE DOLLAR). Was recorded by Marian Kopp on May 30th 2005

This action of the Kopp’s proves overwhelming in fact that Defendant James Brady did in fact purchase fraudulently and unlawfully and did acquire property from Karl and Marian Kopp who in fact fraudulently stole the property located at 1194 Camelot, Pinckney, Michigan from the Plaintiff and his now ex-wife Patricia Lyons.

The true owners George Lyons Plaintiff and his now ex-wife of 1194 Camelot, Pinckney, Michigan. See Exhibits A:

Plaintiff response statement to: Attorney Douglas Cameron false statement in DEFENDANT JAMES BRADY EVALUATION STATEMENTS:” Despite the infusion of cash, Mr. Lyons business and personal problems persisted and payments on land contract ceased shortly after it had been signed”.

(SEE EXHIBIT A: OF OFFICIAL CHECK FROM PLAINTIFF GEORGE LYONS COMPANY TO THE KOPP’S FOR PAYMENT ON CAMELOT and this official check did in fact paid in full for all past and future payments on Plaintiff's George Lyons marital home at 1194 Camelot, Pinckney, Mi ).

Now the attorney Douglas Cameron's statements in the DEFENDANT JAMES BRADY EVALUATION STATEMENTS are fabricated by the Kopp’s. The act of the Kopp’s and their attorney Douglas Cameron is their way of committing fraud upon the court.

Again please SEE EXHIBIT A: AN OFFICIAL CHECK TO KARL & MARIAN KOPP FOR $24,000.00 (TWENTY-FOUR THOUSAND DOLLARS) DATED JUNE 30TH 1995 which WAS ENDORCED OVER TO KARL AND MARIAN KOPP AND STATED ON THE BACK, 'FOR PAYMENT ON CAMELOT'. This official check dated June 30th 1995, from George Lyons Company was a contract between the Plaintiff George Lyons and his company and Karl & Marian Kopp.

This Official check proves that the Kopp’s did in fact, accept payments for 1194 Camelot, Pinckney, Michigan on The Land Contract payment between Plaintiff and his company and Mr. and Mrs. Karl Kopp’s. This also proves the Kopp’s did in fact file a fraudulent and falsified forfeiture against the Plaintiff’s property located at 1194 Camelot, Pinckney, Michigan.

The following statement is from the Case Evaluation of Defendant James Brady on page 2, paragraph two. “Finally, after receiving no payments on the Land contract for approximately three years, Mr. & Mrs. Kopp commenced a land Contract forfeiture action in the 53rd District Court.”

The above STATEMENT IS FALSE AND MISLEADING IT ALSO PROVES THAT THE KOPP’S STARTED A FABRICATED FALSE FORFEITURE AGAINST THE PLAINTIFF AND HIS EX-WIFE after receiving full payments on all past and future payments as stated in the land contract between the said Parties.

Per Exhibits A: Which proves that the statement of the Kopp’s: page 2, paragraph 2 of the Case Evaluation of Defendant, James Brady: that “Finally, after receiving no payments on the Land contract for approximately three years.

Which was in fact, false and misleading and this statement provided by the Kopp’s proves the Kopp’s did in fact commit perjury in the eyes of the court and liable on a legal document. See closing statement on 1194 Camelot, Pinckney, Michigan DATED MARCH 11TH 1994. Payment was made by Plaintiff to the Kopp’s DATED June 30th 1995. For $24,000.00 (TWENTY FOUR-THOUSAND DOLLARS). See Exhibit: A

FOOTNOTE: Also please review audio tapes known as Exhibit A: in which Karl Kopp states to Plaintiff George Lyons. “George you don’t have to make any payments on Camelot, until you close on Shoshoni Pass.”

THE OFFICIAL CHECK OF $24,000.00 (Twenty-Four Thousand) TO KARL & MARIAN KOPP STATES: PAID TO THE ORDER OF KARL AND MARIAN KOPP FOR PAYMENT ON CAMELOT. THIS WAS CASHED AND DEPOSITED IN THE KOPP’S MICHIGAN NATIONAL BANK ACCOUNT BY THE KOPP’S DATED JUNE 30TH 1995 SEE EXHIBITS.

Attorney Cameron's statement in the Case Evaluation of Defendant James Brady on page 2 paragraph two THIS STATEMENT SHOULD BE REPEATED (“Finally, after receiving no payments on the land contract for approximately three years, Mr. & Mrs. Kopp commenced land contract forfeiture in the 53rd District court.” ) THIS STATEMENT OF THE KOPP’S ATTORNEY CAMERON IS TOTALLY FABRICATED by the Kopp’s and their attorney Douglas Cameron.

Attorney Douglas Cameron did in fact have full knowledge that the Kopp’s did in fact receive payment of $24,000.00 in an official check from Plaintiff George Lyons and his company.

Through previous documents and played audio tapes presented to attorney Cameron he did in fact have full knowledge prior to making this false statement and not coming forth with the truth.

This proves overwhelmingly that attorney Cameron is committing and did commit a fraudulent act upon the court in protecting the illegal and criminal actions of the Kopp’s by omitting known evidence. (See enclose description on fraud upon the court.)

Further the statement in the case evaluation of Defendant James Brady on page 2 paragraph two of attorney Cameron's statement of their case of Evaluation of Defendant, James Brady Background. (“After one adjournment at Mr. Lyons request, (1). He and his wife failed to appear for the second scheduled hearing and a Default Judgment of Forfeiture was entered by Judge Delvero. There was no appeal from the Judgment nor was a redemption made. Despite his failure to comply with the Forfeiture Judgment.

Plaintiff response statement to Mr. Lyons embarked on an ever-increasing pattern of bizarre behavior and on several occasions attempted to take up residence in the Camelot property. (The local police became involved and Mr. Lyons was ordered to stay away from the premises. “)

Per above statement please review documents on the Kopp’s filing a fraudulent police report against the Plaintiff. That the Plaintiff enters the property without permission per audio tape Marian Kopp did in Fact gave Plaintiff George Lyons permission to move back into 1194 Camelot, Pinckney, Mi. and start up land contract payment.
This Statement of Marian Kopp was never rescinded this statement. See false police report of the Kopp’s this again was an illegal action of the Kopp’s in stopping Plaintiff George Lyons in receiving back Plaintiff’s marital home at 1194 Camelot, Pinckney, Mi.

1. To the above false statement of Attorney Cameron. Plaintiff was never given notice to re-appear in Judge Delvero's court for a second scheduled hearing; this could have been an accident by Mr. and Mrs. Kopp’s attorney not sending notification to appear in court or the attorney's secretary somehow missed sending out notification, or the notice could have been lost in the mail.

During that period of time the Plaintiff between 1996-1997 was removed from the Plaintiff's home at 1194 Camelot by a false injunction in his divorce complaint.

The notice could have been sent to 1194 Camelot, Pinckney, Michigan and because of the Plaintiff's ex-wife adulterous affair with Karl Kopp. This notice could have been taken and not shown to Plaintiff by his ex-wife. This is a statement supported by audio tape conversations with the Kopp’s and Plaintiff ex-wife.

Plaintiff response statement to page 3 paragraphs 1 of attorney Cameron's statements of their case of Evaluation of Defendant, James Brady's Background.

In August of 2000, Mr. Lyons began filing Pro-Per Motions in the District Court forfeiture action. The first such Motion was denied by Judge Delvero on September 11, 2000. Approximately two weeks later, Mr. Lyons filed a Motion to set aside the Forfeiture Judgment and again requested immediate possession of the home. A Hearing on this Motion was held on October 16, 2000 at which time Mr. Lyons' Motions were denied and he was sanctioned by Judge Delvero. A proposed order was submitted to which Mr. Lyons filed objections. Mr. & Mrs. Kopp, through their attorney, filed a Motion to settle the Order and a Hearing was held on November 13, 2000. At this Hearing Kopp’s Proposed Order was entered with Judge Delvero further ordering that there could be no filing by Mr. Lyons or Hearings in the forfeiture case until Mr. Lyons paid sanctions in the amount of $1,500.00. These sanctions have been paid. Mr. Lyons, however, continued his harassment of Mr. & Mrs. Kopp by filing a lien against the Camelot property and inundating them with paperwork outlining all of the terrible things that had happened to Mr. Lyons allegedly due to actions of Mr.& Mrs. Kopp. Due to a number of business disputes that Mr. Lyons had with customers and his behavior, Mr. Lyons builder’s and broker’s licenses were revoked by the State of Michigan in 2000. Mr. Lyons had also filed several other Pro-per actions in the County and Ingham County against the State of Michigan and various former customers of his. None of these cases have been successful.

TO READERS PLEASE UNDERSTAND ALL OF PLAINTIFF EVIDENCE WAS HIDDEN BY THE KOPP’S. THE KOPP EVEN TRIED TO DESTROY SAID EVIDENCE FROM PLAINTIFF GEORGE LYONS SEE EXHIBIT #'S INCLUDING AUDIO TAPES. THIS AGAIN WAS A CRIMINAL ACT ON THE KOPP’S PART AGAINST THE PLAINTIFF AND HIS EX-WIFE.

(THESE ABOVE STATEMENTS OF ATTORNEY DOUGLAS CAMERON ARE BEING USED ONLY IN THE DISCREDITING OF THE PLAINTIFF BY THE KOPP’S ATTORNEY DOUGLAS CAMERON BY USING SMOKE AND MIRRORS TO ILLEGALLY AND FALSELY DISCREDIT THE PLAINTIFF.) AND IN TRYING TO SUPPORT JUDGE DELVERO IN HIS WRONGFUL AND ILLEGAL ACTIONS AGAINST THE PLAINTIFF.


THE FOLLOWING PROVES THAT FROM THE BEGINNING OF THE KOPP’S ILLEGAL FORFEITURE IN THE COURT OF JUDGE FRANK R. DELVERO IN ANY AND ALL JUDGMENTS, ORDERS AND/OR RULINGS OF ARE LEGALLY DENIED.

AND NONE OF THE JUDGMENTS, ORDERS AND/OR RULINGS ISSUED BY JUDGE FRANK R. DELVERO HAS BEEN DISQUALIFIED BY LAW PRIOR TO ANY JUDGMENTS, ORDERS AND/OR RULINGS THROUGH MOTIONS MADE BY THE PLAINTIFF.

JUDGE FRANK R. DELVERO DID NOT FOLLOW THE COURT RULES OF DISQUALIFICATION AND ANY RULINGS, JUDGMENTS AND/OR ORDERS OF JUDGE DELVERO WOULD BE VOID AS A MATTER OF LAW, AND ANY AND ALL JUDGMENTS, ORDERS AND/OR RULES JUDGE FRANK R. DELVERO HAD NO LEGAL FORCE. BECAUSE JUDGE FRANK R. DELVERO DENYING THE PLAINTIFF GEORGE LYONS MOTION FOR THE EMERGENCY MOTION OF DISQUALIFICATION OF JUDGE FRANK R. DELVERO FOR BIASNESS.

Plaintiff response statement: Prior to Judgments/orders of 53RD District Judge Delvero. Judge Delvero had a motion presented against him and his court. For the Disqualification of Judge Delvero for Biasness. Judge Delvero denied this motion. Under the federal law.

Judge Frank R. Delvero did not have any discretion not to disqualify himself. By law, Judge Delvero is bound to follow the law. Should Judge Frank R. Delvero did not disqualify himself as required by law, and then the judge has given another example of his "appearance of partiality" which, possibly, further disqualifies the judge. Should another judge not accept the disqualification of the judge, then the second judge has evidenced an "appearance of partiality" and has possibly disqualified himself/herself.

None of the orders issued by Judge Delvero who has been disqualified by law would appear to be valid.

It would appear that they are void as a matter of law, and are of no legal force or effect.
Should a Judge Delvero not disqualify himself, then the judge is violation of the Due Process Clause of the U.S. Constitution. United States v. Sciuto, 521 F.2d 842, 845 (7th Cir. 1996)

("The right to a tribunal free from bias or prejudice is based, not on section 144, but on the Due Process Clause.").

The Fifth Amendment to the United States Constitution reads:
“
No person shall be ... deprived of life, liberty, or property, without due process of law....
”
The Fourteenth Amendment to the United States Constitution reads:
“
No State shall deprive any person of life, liberty, or property, without due process of law ...
”

Should a judge Delvero issue any order after he has been disqualified by law, and the plaintiff has been denied of any of his / her property Then the Judge Delvero has been engaged in the
Federal Crime of "interference with interstate commerce".
The judge has acted in the judge's personal capacity and not in the judge's judicial capacity. It has been said that this judge, acting in this manner, has no more lawful authority than someone's next-door neighbor (provided that he is not a judge). However some judges may not follow the law.

The Livingston county judge Delvero did in fact issue orders after he has been disqualified by law, and the Plaintiff George Lyons and his wife have been denied of any of his / her property, the Livingston County judge Delvero have been engaged in the Federal Crime of "interference with interstate commerce".

The Livingston county Judge Frank R. Delvero has acted in the judge's personal capacity and not in the judge's judicial capacity.

Livingston county Judge Frank R. Delvero, was acting in this manner, and has no more lawful authority than someone's next-door neighbor (provided that he is not a judge). And all Judgments/orders/ rulings of Judge Delvero are and should be dismissed.

Footnote: IMPORTANT ITEM of the Kopp’s filing a false police report against the Plaintiff for entering without permission:
See EXHIBIT B: which proves the Kopp’s did in fact file a false police report against Plaintiff George Lyons which also is an additional criminal act by the Kopp’s See chain of evidence the Kopp’s false police report against the Plaintiff George Lyons:


IMPORTANT ISSUES


On March 31st 2005 at 1:56 pm. (Exhibit 8: Warranty Deed in the transfer in the conveyed of the warrant of 1194 Camelot, Pinckney, Michigan. to the Plaintiff Lyons from the Kopp’s for $1.00).

Marian Kopp, who was named on the Land Contract between Lyons and Kopp’s. (Mrs. Kopp in having the authority to transferred possession of 1194 Camelot, Pinckney, Michigan. back to Plaintiff George Edward Lyons and ex-wife Patricia A. Lyons.

Marian Kopp’s motive to submit the Transfer of Warranty Deed to register the deed’s of 1194 Camelot, Pinckney, Michigan to Plaintiff and ex-wife Patricia Lyons as per audio tapes Exhibit A:. Marian Kopp has stated on audio tape her husband and the Plaintiff's ex-wife tried to criminally acquire 1194 Camelot, Pinckney, Michigan. from the Plaintiff as heard on Exhibit A: audio tapes and that Marian Kopp’s' husband Karl Kopp was having an adulterous affair with the Plaintiff's wife at the time, Patricia A. Lyons. See Exhibit A:

Through-out the case history of the relationship of the Plaintiff’s ex-wife and the criminal protection of Mr. Karl Francis Kopp they sought to embezzle 1194 Camelot, Pinckney, Michigan from Plaintiff. See Exhibit A:

Footnote: The warranty Deed still stands as the sole owners of 1194 Camelot, Pinckney, Michigan are the Plaintiff George Lyons and ex-wife Patricia Ann Lyons.

Any transfer of a Warranty deed of 1194 Camelot, Pinckney, Michigan to Defendant James Brady was completely illegal. Again the Kopp’s had no legal rights to sell to 1194 Camelot, Pinckney, Mi. to Defendant James Brady as they were not in legal possession of the said property.

The Plaintiff demands total and immediate possession of 1194 Camelot, Pinckney, Michigan. And the Defendant James Brady and Karl & Marian Kopp are defrauding this Honorable court.
AT THIS POINT IN TIME THE DEFENDANT DOES NOT HAVE ANY INTEREST IN 1194 CAMELOT, PINCKNEY, MI.

Plaintiff response statement Page 4, paragraph 1 of attorney Cameron's statements of their Case of Evaluation of Defendant, James Brady Background.

In March 2004, Mr. Lyons wrote a letter to Mr. & Mrs. Kopp advising them that he would be re-taking possession of the Camelot residence. This letter was quickly followed by Mr. Lyons filing a law suit in the Livingston County Circuit Court against Mr. & Mrs. Kopp. Mr. Lyons entered a Default against Mr. & Mrs. Kopp without having bothered to notify them of the Law suit or serve them with process.
The Default was set aside by Judge Burress on his Motion. Judge Burress denied two Motions of Mr. Lyons for immediate possession of the Camelot residence and warned him that he faced sanctions in that matter and that he should engage the services of an attorney.

IMPORTANT: Again the previous statement of Attorney Douglas Cameron has only a fractional part and one-sided of truth in his statement:

Mr. & Mrs. Kopp’s received over 5 different certified mailings sent to the address at their marital home located at 4849 Gallagher, Whitmore Lake, Hamburg Township Michigan 48189 of which the Kopp’s refused acceptance of the certified mailings.
Both on the Summon and Complaint and Notice for Appearance in court on the Default Judgment for possession of 1194 Camelot, Pinckney, Michigan. See return certified mailings return notice of delivery from the U.S. POSTAL SERVICES FOR THE KOPPS.

Marian Kopp refused to take or sign for Notice of Summon and Complaint and Notice to appear in court by a witness who was the process server who will testify against the Kopp’s in this court.
ALSO The Kopp’s did not IN FACT notify the Plaintiff when they went before Judge Burress and acquire an illegal removal of Judge Burress Default Judgment against the Kopp’s for possession of 1194 Camelot, Pinckney, Mi. SEE audio tapes.

FOOTNOTE: Judge Burress and Judge Reader had MOTIONS OF Emergency Motion for Disqualification for Biasness FOR BOTH JUDGE’S 4 to 5 times by Plaintiff George Lyons. This was denied by Judge Burress and also denied by Judge Reader.

Plaintiff response statement page 4, paragraphs 1 of attorney Cameron's statements of their case of Evaluation of Defendant, James Brady Background.

On March 19, 2005. The Court, by Judge Reader, entered an Order granting Summary Disposition in favor of Mr. & Mrs. Kopp’s Counter Complaint. This Order also specifically Dismissed Mr. Lyons Complaint with prejudice and vested title to Camelot residence in Mr. & Mrs. Kopp. This Order is attached hereto as Exhibit “A”. Mr. Lyons made several appeals to the Court of Appeals and Michigan Supreme Court. All of which were summarily denied.

Again the previous statement of Attorney Douglas Cameron has only a fractional part and one-sided of truth in its statement: Judge Reader had an Emergency Motion of Disqualification for Biasness.

And Per the Federal Courts have repeatedly held that positive proof of the partiality of a judge is not a requirement, only the appearance of partiality. Liljeberg v. Health Services Acquisition Corp., 486 U.S. 847, 108 S.Ct. 2194 (1988) (what matters is not the reality of bias or prejudice but its appearance); United States v. Balistrieri, 779 F.2d 1191 (7th Cir. 1985) (Section 455(a) "is directed against the appearance of partiality, whether or not the judge is actually biased.") ("Section 455(a) of the Judicial Code, 28 U.S.C. §455(a), is not intended to protect litigants from actual bias in their judge but rather to promote public confidence in the impartiality of the judicial process.").

That Court also stated that Section 455(a) "requires a judge to recuse himself in any proceeding in which her impartiality might reasonably be questioned." Taylor v. O'Grady, 888 F.2d 1189 (7th Cir. 1989). In Pfizer Inc. v. Lord, 456 F.2d 532 (8th Cir. 1972), the Court stated that "It is important that the litigant not only actually receive justice, but that he believes that he has received justice."

The Supreme Court has ruled and has reaffirmed the principle that "justice must satisfy the appearance of justice", Levine v. United States, 362 U.S. 610, 80 S.Ct. 1038 (1960), citing Offutt v. United States, 348 U.S. 11, 14, 75 S.Ct. 11, 13 (1954). A judge receiving a bribe from an interested party over which he is presiding, or protecting attorney’s fraud upon the courts summary dispositions does not give the appearance of justice.

"Recusal under Section 455 is self-executing; a party need not file affidavits in support of recusal and the judge is obligated to recues herself sua sponte under the stated circumstances." Taylor v. O'Grady, 888 F.2d 1189 (7th Cir. 1989).

Further, Judge David Reader and Judge Daniel Burress have a legal duty to disqualify himself even if there is no motion asking for his disqualification. The Seventh Circuit Court of Appeals further stated that "We think that this language [455(a)] imposes a duty on the judge to act sua sponte, even if no motion or affidavit is filed." Balistrieri, at 1202.

Judges do not have the discretion not to disqualify themselves. By law, they are bound to follow the law. Should a Judge David Reader not disqualify himself as required by law, and then the judge Reader has given another example of his "appearance of partiality" which, possibly, further disqualifies the judge. Should another judge not accept the disqualification of the judge, then the second judge has evidenced an "appearance of partiality" and has possibly disqualified himself/herself. None of the orders issued by any judge who has been disqualified by law would appear to be valid.

It would appear that they are void as a matter of law, and are of no legal force or effect.
Should a Judge David Reader not disqualify himself, then the Judge David Reader is violation of the Due Process Clause of the U.S. Constitution. United States v. Sciuto, 521 F.2d 842, 845 (7th Cir. 1996)

("The right to a tribunal free from bias or prejudice is based, not on section 144, but on the Due Process Clause.").

Should a Judge David Reader issue any order after he has been disqualified by law, and if the party has been denied of any of his / her property, then the Judge David Reader may have been engaged in the Federal Crime of "interference with interstate commerce".
Judge Reader has acted in the judge's personal capacity and not in the judge's judicial capacity. It has been said that this judge, acting in this manner, has no more lawful authority than someone's next-door neighbor (provided that he is not a judge). However some judges may not follow the law.

The Livingston county judge David Reader did issue an order after he has been disqualified by law, and if Plaintiff George Lyons and his ex-wife have been denied of any of his / her property, the Livingston County Judge Reader have been engaged in the Federal Crime of "interference with interstate commerce".

The Livingston county judge’s has acted in the judge's personal capacity and not in the judge's judicial capacity. These Livingston county judge’s, are acting in this manner, and has no more lawful authority than someone's next-door neighbor (provided that he is not a judge). However Livingston county Judge David Reader did not follow the law.


Plaintiff response statement: per page 4, paragraphs 2 of attorney Cameron's statements of their Case of Evaluation of Defendant, James Brady Background.

Plaintiff JAMES BRADY subsequently purchased the Camelot residence from Mr. & Mrs. Kopp on December 30, 2005. This was an open market, arms length transaction with a formal closing, tile insurance and delivery of a warranty deed. Despite the fact that Mr. Brady has never met Mr. Lyons or had any other contact with him, Mr. Lyons apparently feels he now has free reign to harass Mr. Brady.

Again the previous statement of Attorney Douglas Cameron has only a fractional part and one-sided of truth in his statement: And in this statements and other statements are Attorney Douglas Cameron unlawful act of committing fraud upon the court.

On March 31st 2005 at 1:56 pm. (Exhibit 8: Warranty Deed in the transfer in the conveyed and warrant of 1194 Camelot, Pinckney, Michigan to the Lyons from the Kopp’s for $1.00).

Marian Kopp ( Who is named on Land Contract between Lyons and Kopp’s and Mrs. Kopp having the full authority) to transfer possession of 1194 Camelot, Pinckney, Michigan back to Plaintiff George Edward Lyons and ex-wife Patricia A. Lyons. Marian Kopp’s motive to submit the transfer of warranty deed to register of deed’s of 1194 Camelot, Pinckney, Michigan to Plaintiff and ex-wife as per audio tapes. Marian Kopp’s' husband had criminally acquired 1194 Camelot, Pinckney, Michigan from Plaintiff and per audio tapes Marian Kopp’s husband Karl Kopp was having an ongoing an adulterous affair with the Plaintiff's wife Patricia A. Lyons. See Exhibit A:

Through-out the case history of the relationship of the Plaintiff’s ex-wife and her criminal protection of Mr. Karl Francis Kopp to embezzle 1194 Camelot, Pinckney, Michigan from Plaintiff. See Exhibit A:

Footnote: The Warranty Deed still stands as the only owner of 1194 Camelot, Pinckney, Michigan is the Plaintiff George Lyons and ex-wife Patricia Ann Lyons.

The transfer of a false Warranty deed of 1194 Camelot, Pinckney, Mi. To Defendant James Brady was completely illegal. The Kopp’s had no legal rights to sell to 1194 Camelot, Pinckney, Mi. The Plaintiff demand total and immediate possession of 1194 Camelot, Pinckney, Michigan. And the Defendants James Brady and Karl & Marian Kopp are defrauding this Honorable court.

Plaintiff response statement: per page, 4 paragraphs 2 of attorney Cameron's statements of their Case of Evaluation of Defendant, James Brady Background. This was an open market, arms length transaction with a formal closing, title insurance and delivery of a Warranty Deed.

Again the previous statement of Attorney Douglas Cameron has only a fractional part and one-sided of truth in his statement: And in this statements and other statements are Attorney Douglas Cameron unlawful act of committing fraud upon the court.

Plaintiff response statement: This was not an open market, nor a arms length transaction with a formal closing. The Title Company Metropolitan Title Company had full knowledge that the Kopp’s made a false forfeiture on the Plaintiff, (2) and had full Knowledge that the Kopp’s received a $24,000.00 (TWENTY-FOUR THOUSAND DOLLAR) official check for payments on 1194 Camelot, Pinckney, Mi. from the Plaintiff.

IMPORTANT Metropolitan Title company WAS PROTECTING THEIR ILLEGAL ACTS ON OTHER ILLEGAL ACTS THEY COMMITTED AGAINST THE PLAINTIFF IN OTHER CASES OF PAST CLIENTS THAT WERE FILING FRAUDULENT LAWSUITS AGAINST THE PLAINTIFF. THIS ILLEGAL ACTION OF METROPOLITAN TITLE COMPANY WAS TO STOP THE PLAINTIFF FROM RECEIVING ANY MONEY TO ACQUIRE ANY LEGAL REPRESENTATION.
The Metropolitan Title Company had full Knowledge that the Kopp’s and Plaintiff George Lyons were in court, and the title company protected the Kopp’s in their illegal actions. See audio tape conversations with Metropolitan Title Company.

Second an open Market: Defendant had full knowledge of the illegal actions of the Kopp’s and still proceeded in wrongfully purchase 1194 Camelot, Pinckney, Michigan.

Footnote: Defendant James Brady prior to purchasing 1194 Camelot, Pinckney, Michigan.
JAMES BRADY'S PRIOR PROPERTY was 5136 Gallagher, Whitmore Lake, Michigan approximately one minute from Karl and Marian Kopp’s' marital property 4849 Gallagher, Whitmore Lake, Michigan.

Prior to wrongfully purchasing 1194 Camelot, Pinckney: JAMES BRADY lived at and owned 5136 GALLAGHER, WHIMORE LAKE, MICHIGAN 48189 on the same street of Karl and Marian Kopp’s marital home, 4849 Gallagher, Whitmore Lake, Michigan 48189 PRIOR TO WRONGFULLY PURCHASING 1194 CAMELOT, PINCKNEY, MICHIGAN. SEE EVIDENCE:

1. Defendant lived approximately one minute from Kopp’s marital property located at 4849 Gallagher, Whitmore Lake, and Michigan per Yahoo map

2. Defendant in the illegal action to illegal remove the Warranty Deed from the Kopp’s possession. The Kopp’s acquire a friend in their neighborhood to purchase 1194 Camelot, Pinckney, Mi. for ½ the price $400,000.00. of 1194 Camelot, Pinckney, Michigan which should have been on the market for $800,000.00

3. This was civil conspiracy on the Brady and Kopp’s part. To illegal acquire funds from Plaintiff George Lyons and his ex-wife Patricia Ann Lyons of who Karl Kopp was having an adulterous affair with Patricia Lyons prior to the Divorce of Plaintiff and his ex-wife Patricia A. Lyons.

4. This is supported by audio tapes, witnesses and the enclosed evidence on property of the Kopp’s and the Defendant James Brady.

5. Plaintiff response statement: 4, paragraph 2 of attorney Cameron's statements of their Case of Evaluation of Defendant, James Brady Background. Mr. Lyons apparently feels he now has free reign to harass Mr. Brady.

Again the previous statement of Attorney Douglas Cameron has only a fractional part and one-sided of truth in its statement and again trying his best to discredit Plaintiff.

Plaintiff George Lyons in his search from truth in the judicial system and Plaintiff working against a corrupted legal attorney’s in the past and now: In the stopping these attorneys from committing fraud upon the court and their filing fabricated Summary Dispositions against the Plaintiff. To acquire illegal gains for their clients, and their law firm.

Plaintiff response statement page 4, paragraphs 3 of attorney Cameron's statements of their Case of Evaluation of Defendant, James Brady Background: It should be noted by this by this Panel that in a unrelated matter, Lyons v. Marcich, 44th Circuit Court File No. 04-021106, Court of Appeals docket numbers 267969 and 269576, the Court of Appeals denied Mr. Lyons’ Motion to waive fees to curb his serious abuses in filing Motions in that matter in that matter and went so far as to call Mr. Lyons “an abuser of the judicial system.”


Again the previous statement of Attorney Douglas Cameron has only a fractional part and one-sided of truth in his statement:

The Marcich joined forces with other past clients starting with the Storzbach’s, Friberg’s, Feeback’s, and most of all Lalonde’s to embezzle over $770,000.00 from Plaintiff George Lyons and his Company.

Between the Marcich’s and the Lalonde’s Plaintiff has overwhelming evidence that these past clients framed Plaintiff George Lyons and his company for N.S.F. Charges. The actions of the above people committed civil conspiracy and tortuous interference.
IMPORTANT TO REMEMBER THE KOPP’S HAD HIDDEN AND TRIED TO DESTROY EVIDENCE OF THE PLAINTIFF WHICH THE PLAINTIFF DID EVENTUALLY RECOVER.


Again these past clients embezzle over $770,000.00 from the Plaintiff and his Company. These illegal actions were started with RONALD AND VIRGINIA STORZBACH filing a false complaint to the State of Michigan Consumer & Industry services. A fabricated Hearing report has been presented to this court and is the court file of Lyons vs. Brady.

1. Plaintiff George Lyons had to face complete destruction of his company and his life because the wrongful actions of the Defendant James Brady and past Defendant’s and Karl and Marian Kopp.

2. That as results of Karl F. Kopp and Marian J. Kopp in there filing a fabricated false forfeiture against Plaintiff George Lyons property 1194 Camelot, Pinckney, Mi.. Along with Karl and Marian Kopp filing a false police report for entering with out permission into 1194 Camelot, Pinckney, Mi.. And along with Karl and Marian Kopp slandering the title of Plaintiff property 1194 Camelot, Pinckney, Mi.

3. That in recording said false forfeiture and acquire illegal title to 1194 Camelot, Pinckney, Michigan that Karl and Marian Kopp violated provisions along with Marian Kopp being a licensed real estate agent have violated provisions MCLA 565.108; and MSA 26.1278 which entitling Plaintiff to damages including reasonable attorney fees.

4. That further, Karl and Marian Kopp and Defendant James Brady and their criminally recording of said alleged title and the wrongfully acquirement of title of Plaintiff property 1194 Camelot, Pinckney, Mi. by Karl and Marian Kopp and the Defendant James Brady through embezzlement.

5. These illegal actions done by Karl and Marian Kopp and Defendant James Brady with such gross indifference and to such reckless disregard to the Plaintiff George Lyons and ex-wife Patricia Ann Lyons and his companies, as to constitute a willful and wanton act entitling Plaintiff to exemplary damages.

6. That the Plaintiff George Lyons has been damage for aside wrongful actions of the Defendant James Brady and Karl Kopp and Marian Kopp.

7. That, as the results of slander of title aforesaid that plaintiff has incurred damages consisting of the following.
a. Impairment of vendibility;
b. Ligation expensive;
c. Loss or impairment of credit;
d. Deformation of Character;
e. Major Loss of income;
f. Mental stress;
g. Exemplary damages;
h. Reasonable attorney fees;

Plaintiff response statement page 5, paragraphs 2 of attorney Cameron's statements of their Case of Evaluation of Defendant, James Brady.

III. PLAINTIFF ARGUMENT AND RELIEF REQUESTED

The Plaintiff demands judgment in such sum of excess of $1,000,000.00 ( One million dollars ) and if Defendant James Brady and Karl and Marian Kopp H/W are found guilty of the following RECEIVING & CONCEALING STOLEN PROPERTY [MCL 750.535] with knowledge that the property was stolen, under Michigan law defines 3 levels of R&C: $20,000 or more: Felony -- up to 10 years and/or $15,000 fine (or 3x property's value), if Defendant’s are found guilty of the following EMBEZZLEMENT [MCL 750.174].

Since 01/01/1999, Michigan defines 4 levels of Embezzlement: under $200: Misdemeanor -- up to 93 days and/or $500, or 3 times amount embezzled, whichever is greater or per as found to be owning plus interest, cost and attorney fees, and Plaintiff now demands the immediate return with clear title without clouds the Plaintiff property 1194 Camelot, Pinckney, Michigan 48169.

It is Obvious that no cause of action exists for the Defendant James Brady against Plaintiff George Lyons and that the Summary Disposition is illegal action of Attorney Douglas Cameron to commit fraud upon the court. It is equally obvious that the Plaintiff should be granted Summary Disposition in favor of the Plaintiff George Lyons against the Defendant James Brady.

If Attorney Douglas Cameron is found guilty of committing fraud upon the court. Mr. Cameron should be charged with sanctions by this panel and the court for committing fraud upon the court.

That the Plaintiff has any and all past cases in the Livingston County court is re-opened all with cases that where Plaintiff George Lyons was wrongfully denied Due Process of Law.

Along with all cases in Livingston County District court, The State of Michigan Consumer & Industry courts, the Ingham County Court, the Michigan Court of Appeals and the Michigan Supreme Court.

This Panel can, however, impede Defendant’s efforts to further abuse the judicial system by unanimously finding that Defendant James Brady and his Attorney Douglas Cameron action is frivolous pursuant to MCR 2.403(K)(4) AND MCL 600.4963(2) and grant the Plaintiff George Lyons the immediate possession of 1194 Camelot, Pinckney, Michigan with a complete clear title.

This panel and court bring criminal charges against the Defendant James Brady and Karl Kopp and Marian Kopp for the enclosed criminal acts and that any and all Judge’s committing and stopping the Plaintiff George Lyons from having Due Process of Law be reviewed and charged and sent to the Judicial Tenure Committee of The State of Michigan further civil and criminal charges will follow. This is the relief which Plaintiff George Edward Lyons, respectfully requests.

Respectfully submitted,




________________________________________
GEORGE EDWARD LYONS - PLAINTIFF
11994 Weiman
PINCKNEY, MICHIGAN 48169
734-954-4040
Friday, October 24, 2008
http://findingjusticeforpeople.blogspot.com/

Friday, September 19, 2008

LOOK AT THIS ONE.. GOING TO THE NEWS MEDIA

State of Michigan ( PLEASE READ AFTER THE FOLLOWING DEFINATIONS )
Please review Emergency Disqualification of Judge's in this blog (Article THREE).
This motion is similar to all the Motions that was presented to all these judge's.
State of Michigan In the Livingston County Circuit Court
204 S. Highlander Way, Howell, Michigan 48843
517-546-9816


George Edward Lyons,
11994 Weiman
Pinckney, Michigan 48169
734-954-4040
Plaintiff,
vs.

James Brady and wife,
1194 Camelot,
Pinckney, Mi.48169
Phone unavailable
Defendants,

DEFENDANT’S ATTORNEY
Attorney for Defendant
Douglas J. Cameron
McCririe & Cameron Attorneys and Counselors
317 W. Main St.Brighton, MI 48116810-229-6167

POSSIBLE OTHER DEFENDANTS
Karl and Marian Kopp H/W
Case no. 04-020652-CF-B LYONS V. KOPP

Case No.: 07-23338-CH
Hon. Judge Latreille

Judge’s who refused to disqualify themselves/
Plaintiff disqualify the enclosed Judges.

Motions for Disqualification of Judge Stanley Laterille or be charge for possible treason
"Fraud on The Court By An Officer Of The Court"And "Disqualification Of Judges, State and Federal"

To review one of George Lyons Emergency Motions for Disqualification’s of these Judge’s please go to http://findingjusticeforpeople.blogspot.com
(Article Three that was drafted by George Edward Lyons)

Definitions: These definitions are to help the reader to have a better outlook in the illegal actions that was preformed against George Edward Lyons in the Livingston County courts systems.

1. Who is an "officer of the court"?

A judge is an officer of the court, as well as are all attorneys. A state judge is a state judicial officer, paid by the State to act impartially and lawfully. A federal judge is a federal judicial officer, paid by the federal government to act impartially and lawfully.
State and federal attorneys fall into the same general category and must meet the same requirements. A judge is not the court. People v. Zajic, 88 Ill.App.3d 477, 410 N.E.2d 626 (1980).

2. What is "fraud on the court"?

Whenever any officer of the court commits fraud during a proceeding in the court, he/she is engaged in "fraud upon the court". In Bulloch v. United States, 763 F.2d 1115, 1121 (10th Cir. 1985), the court stated

"Fraud upon the court is fraud which is directed to the judicial machinery itself and is not fraud between the parties or fraudulent documents, false statements or perjury. ... It is where the court or a member is corrupted or influenced or influence is attempted or where the judge has not performed his judicial function --- thus where the impartial functions of the court have been directly corrupted."

"Fraud upon the court" has been defined by the 7th Circuit Court of Appeals to "embrace that species of fraud which does, or attempts to, defile the court itself, or is a fraud perpetrated by officers of the court so that the judicial machinery cannot perform in the usual manner its impartial task of adjudging cases that are presented for adjudication." Kenner v. C.I.R., 387 F.3d 689 (1968); 7 Moore's Federal Practice, 2d ed., p. 512, ¶ 60.23. The 7th Circuit further stated "a decision produced by fraud upon the court is not in essence a decision at all, and never becomes final."

3. What effect does an act of "fraud upon the court" have upon the court proceeding?
"Fraud upon the court" makes void the orders and judgments of that court. It is also clear and well-settled Michigan law that any attempt to commit "fraud upon the court" vitiates the entire proceeding. The People of the State of Illinois v. Fred E. Sterling, 357 Ill. 354; 192 N.E. 229 (1934)
("The maxim that fraud vitiates every transaction into which it enters applies to judgments as well as to contracts and other transactions."); Allen F. Moore v. Stanley F. Sievers, 336 Ill. 316; 168 N.E. 259 (1929) ("The maxim that fraud vitiates every transaction into which it enters ..."); In re Village of Willowbrook, 37 Ill.App.2d 393 (1962) ("It is axiomatic that fraud vitiates everything."); Dunham v. Dunham, 57 Ill.App. 475 (1894), affirmed 162 Ill. 589 (1896); Skelly Oil Co. v. Universal Oil Products Co., 338 Ill.App. 79, 86 N.E.2d 875, 883-4 (1949); Thomas Stasel v. The American Home Security Corporation, 362 Ill. 350; 199 N.E. 798 (1935).

Under Michigan and Federal law, when any officer of the court has committed "fraud upon the court", the orders and judgment of that court are void, of no legal force or effect.

4. To the reader's What causes the "Disqualification of Judges?"

Federal law requires the automatic disqualification of a Federal judge under certain circumstances.

In 1994, the U.S. Supreme Court held that "Disqualification is required if an objective observer would entertain reasonable questions about the judge's impartiality. If a judge's attitude or state of mind leads a detached observer to conclude that a fair and impartial hearing is unlikely, the judge must be disqualified." [Emphasis added]. Liteky v. U.S., 114 S.Ct. 1147, 1162 (1994).

Courts have repeatedly held that positive proof of the partiality of a judge is not a requirement, only the appearance of partiality. Liljeberg v. Health Services Acquisition Corp., 486 U.S. 847, 108 S.Ct. 2194 (1988) (what matters is not the reality of bias or prejudice but its appearance); United States v. Balistrieri, 779 F.2d 1191 (7th Cir. 1985) (Section 455(a) "is directed against the appearance of partiality, whether or not the judge is actually biased.") ("Section 455(a) of the Judicial Code, 28 U.S.C. §455(a), is not intended to protect litigants from actual bias in their judge but rather to promote public confidence in the impartiality of the judicial process.").

That Court also stated that Section 455(a) "requires a judge to recuse himself in any proceeding in which her impartiality might reasonably be questioned." Taylor v. O'Grady, 888 F.2d 1189 (7th Cir. 1989). In Pfizer Inc. v. Lord, 456 F.2d 532 (8th Cir. 1972), the Court stated that "It is important that the litigant not only actually receive justice, but that he believes that he has received justice."

The Supreme Court has ruled and has reaffirmed the principle that "justice must satisfy the appearance of justice", Levine v. United States, 362 U.S. 610, 80 S.Ct. 1038 (1960), citing Offutt v. United States, 348 U.S. 11, 14, 75 S.Ct. 11, 13 (1954). A judge receiving a bribe from an interested party over which he is presiding, does not give the appearance of justice.

"Recusal under Section 455 is self-executing; a party need not file affidavits in support of recusal and the judge is obligated to recuse herself sua sponte under the stated circumstances." Taylor v. O'Grady, 888 F.2d 1189 (7th Cir. 1989).

Further, the judge has a legal duty to disqualify himself even if there is no motion asking for his disqualification. The Seventh Circuit Court of Appeals further stated that "We think that this language [455(a)] imposes a duty on the judge to act sua sponte, even if no motion or affidavit is filed." Balistrieri, at 1202.

Judges do not have discretion not to disqualify themselves. By law, they are bound to follow the law. Should a judge not disqualify himself as required by law, then the judge has given another example of his "appearance of partiality" which, possibly, further disqualifies the judge.
Should another judge not accept the disqualification of the judge, then the second judge has evidenced an "appearance of partiality" and has possibly disqualified himself/herself. None of the orders issued by any judge who has been disqualified by law would appear to be valid.

It would appear that they are void as a matter of law, and are of no legal force or effect.
Should a judge not disqualify himself, then the judge is violation of the Due Process Clause of the U.S. Constitution. United States v. Sciuto, 521 F.2d 842, 845 (7th Cir. 1996)

("The right to a tribunal free from bias or prejudice is based, not on section 144, but on the Due Process Clause.").

The Fifth Amendment to the United States Constitution reads:
“
No person shall be ... deprived of life, liberty, or property, without due process of law ....
”
The Fourteenth Amendment to the United States Constitution reads:
“
No State shall deprive any person of life, liberty, or property, without due process of law ...”

Should a judge issue any order after he has been disqualified by law, and if the party has been denied of any of his / her property, then the judge may have been engaged in the Federal Crime of "interference with interstate commerce".
The judge has acted in the judge's personal capacity and not in the judge's judicial capacity. It has been said that this judge, acting in this manner, has no more lawful authority than someone's next-door neighbor (provided that he is not a judge).
However some judges may not follow the law.

The Livingston county judge’s did issue orders after he has been disqualified by law, and if the George Lyons has been denied of any of his / her property, the Livingston County judge’s have been engaged in the Federal Crime of "interference with interstate commerce".

The Livingston county judge’s has acted in the judge's personal capacity and not in the judge's judicial capacity.
These Livingston county judge’s, are acting in this manner, and had no more lawful authority than someone's next-door neighbor (provided that he is not a judge). However these Livingston county judges did not follow the law.

George Edward Lyons as a non-represented litigant, and the Livingston county courts did not follow the law as to non-represented litigants, then the judge has expressed an "appearance of partiality" and, under the law, it would seem that he/she has not disqualified him/herself.

However, since not all judges keep up to date in the law, and since not all judges follow the law, it is possible that a judge may not know the ruling of the U.S. Supreme Court and the other courts on this subject. Notice that it states "disqualification is required" and that a judge "must be disqualified" under certain circumstances.

IMPORTANT:

The Supreme Court has also held that if a judge wars against the Constitution, or if he acts without jurisdiction, he has engaged in treason to the Constitution.

If a judge acts after he or she has been automatically disqualified by law, then he is acting without jurisdiction, and that suggest that he is then engaging in criminal acts of treason, and may be engaged in extortion and the interference with interstate commerce.

In the judge’s acting without jurisdiction. All of the building contracts of George Edward Lyons building company carried the American Federal arbitraction clause, All case were governed by this arbitration clause:

All Judge’s in Livingston’s county had no jurisdiction to make any rulings against George Edward Lyons. George Lyons made outrageous amount of Motion’s that were made in all cases by George Edward Lyons that the Livingston County Courts had no jurisdiction. All of the Livingston County Courts Judge’s rulings of George Lyons Motions were denied.

Courts have repeatedly ruled that judges have no immunity for their criminal acts. Since both treason and the interference with interstate commerce are criminal acts, no judge has immunity to engage in such acts.

THE FOLLOWING JUDGE’S WERE DISQUALIFIED FOR BIASNESS BY PLAINTIFF GEORGE LYONS FOR THE JUDGE’S IN THE LIVINGSTON COUNTY JUDGE’S over 34 motions for disqualification on the below judge’s.
That these judge’s denied Plaintiff George Edward Lyons from his Constitutional rights.
These Judge’s did not have jurisdiction in to making any rulings against George Lyons in any of the cases that were filed in Livingston County Court system.

44th Circuit Court Judge David Reader and Daniel Burress Judicial Center Building - 204 S. Highlander Way, Suite 5, Howell, MI 48843
Phone 517.548.1120Fax 517.545.9688

44th Circuit Court Judge Stanley Latreille and Judge Susan Reck Judicial Center Building - 204 S. Highlander Way, Suite 5, Howell, MI 48843
Phone 517.546.3060Fax 517.552.2512

53rd District Court Chief Judge Michael Hegarty Died also Judge Hegarty law partners with Attorney Brian Lavan.Brighton District Court - 224 N. First St., Brighton, MI 48116.
Judge Michael Hegarty was Law partners with Attorney Brian Lavan, who was once George Lyons attorney. George Lyons was also purchasing a commercial property from Attorney Brian Lavan, and Brian Lavan also represented George Lyons and his company against James and Betty Steeber.

Attorney Brian Lavan illegally represented George Lyons ex-wife Patricia Ann Lyons in a divorce. In representing Patricia Ann Lyons. Attorney Brian Lavan then filed suit against George Lyons and James and Betty Steeber.

There is more on Attorney Lavan on tape recorded by George Lyons in Mr. Lavan requesting George Lyons to file a fraudulent complaint with the State of Michigan Consumer & Industry services against a Realtor in the effort in not paying said Realtor a commission Named Richard Baker of the Baker Team.

IMPORTANT:
George Lyons made many motion’s to remove Attorney Brian Lavan for CONFLICT OF INTEREST from his ex-wife lawsuit against George Lyons with Judge Daniel Burress and Judge Stanley Laterille.
BOTH JUDGES DENIED GEORGE LYONS MOTION to removal of Attorney Brian Lavan for Conflict of Interest. And committing fraud upon the Livingston county court.


53rd District Court Judge Delvero Judicial Center Building - 204 S. Highlander Way, Howell, MI 48843

George Lyons had a home at 1194 Camelot, Pinckney, Mi. George Lyons borrowed $90,000.00 from a friends Karl and Marian Kopp to finish a building project at 5640 Shoshoni Pass, Pinckney, Mi.

The Friends Karl and Marian Kopp filed a fraudulent forfeiture against George Lyons and his wife at that time 1194 Camelot, Pinckney, Michigan appraised for $800,000.00. and Lyons only owed the $65,000.00 To the Kopp’s, in the Kopp’s false forfeiture the Kopp’s stated that they never received any money for the monthly payments from the Lyons’s

This Fraudulent forfeiture was false and misleading by the Kopp’s. Against George Lyons who had no evidence to deny this false allegation of the Kopp’s.

Until 2007 the Kopp’s were removing evidence from 1194 Camelot, Pinckney, Michigan. George Lyons recovered a $24,000.00 check which made to the Kopp’s for payment on Camelot. This $24,000.00 check was cash and approved by the Kopp’s in a there signature on the back of the check.

THIS CHECK WAS A CONTRACT BETWEEN THE KOPP’S AND LYONS. WHERE THEY ACCEPTED PAYMENT ON 1194 CAMELOT, PINCKNEY, MI. THE STATEMENT ON THE CHECK STATED FOR PAYMENT ON CAMELOT-MEANS THE KOPP’S DID IN FACT ACCEPTED PAYMENTS ON 1194 CAMELOT, PINCKNEY, MI.

In the Kopp’s filing a fraudulent forfeiture against the Lyons the Kopp’s stated they never received any payments on the contract between George and Patricia Lyons and Karl and Marian Kopp.

These illegal action of the Kopp’s proves the Kopp’s did committ against George Lyons extortion and embezzlement upon the Lyons. The Kopp’s also committed fraud upon the Livingston county courts to illegally acquire 1194 Camelot, Pinckney, Michigan.

This check from George Lyons of $24,000.00 to the Kopp’s cover any all past payments and future payments for 1194 Camelot, Pinckney, Michigan. This check stated on the back for payment for Camelot.
The Kopp’s falsely stated in there false forfeiture “The Lyons made no payments on 1194 Camelot, Pinckney, Michigan. This statement was false and criminal act committed by the Kopp’s against the Lyons.


In the Kopp’s trying to Stop George Lyons in his lawsuit again the Kopp’s requested George Lyons to re-enter 1194 Camelot, Pinckney, Michigan.
The Kopp’s then Framed George Lyons for entering without permission. In filing a false police report, where George Lyons was wrongfully arrested, and taken to the Livingston County Jail, and prosecuted by the Livingston County Prosecutor's then this story really starts.

Prior to this Marian Kopp gave George Lyons permission to enter into 1194 Camelot, Pinckney, Mi. and start payments to the Kopp’s on the original land contract this conversation was taped recorded by George Lyons.

After two weeks living in 1194 Camelot, Pinckney, Mi. Karl Kopp made a fraudulent Police report to Pinckney Police, that George Lyons enters 1194 Camelot, Pinckney, Mi. George Lyons was wrongfully arrested and went before Judge Delvero.

Having no money, because of the extortion of the Kopp’s and other’s. George Lyons was given a Court appointed attorney Mack Spickard of Howell, Mi.
George Lyons played the audio tape giving George Lyons permission to move back into 1194 Camelot, Pinckney, Mi. George Lyons taped recorded court appointed attorney listening to Marian Kopp’s approval to enter into 1194 Camelot, Pinckney, Mi and start making payments.

Now all the court appointed Attorney Mack Spickard of George Lyons had to do was take the audio tape into court and state to Judge Delvero Mr. Lyons was given permission to enter 1194 Camelot, Pinckney, Mi. Attorney Spickard DID NOT DO THIS.

Prosecutors of Livingston County made a motion that George Lyons is examine by the Ypsilanti Forensic center for Competence to stand trial. George Lyons was exam by Dr. Judith Thompson of the Forensic center.

George Lyons played the same audio tape of Marian Kopp giving George Lyons permission to enter into 1194 Camelot, Pinckney, Mi. to Dr. Judith Thompson of the Forensic center and recorded her commitments on the tape. Mrs Thompson stated the Kopp’s did give permission to enter into 1194 Camelot, Pinckney, Michigan George Lyons marital property.

Again George Lyons recorded the Conversation with Dr. Judith Thompson listening to Marian Kopp tape recording giving George Lyons permission to enter into 1194 Camelot, Pinckney, Michigan. Dr. Thompson did agree that George Lyons was given permission to enter into 1194 Camelot, Pinckney, Mi. By Marian Kopp.

And again all Dr. Thompson had to do was tell Judge Delvero Mr. Lyons had permission to enter 1194 Camelot, Pinckney, Mi. DR. THOMPSON DID NOT DO THIS.

Wrongfully Dr. Thompson filed a letter to Judge Delvero that George Lyons was not compendent to stand trial. This was a lie on Dr. Thompson part. Both actions of Court appointed attorney Mack Spickard and Dr. Judith Thompson should be charged with committing Fraud upon the court of Judge Delvero.

This illegal action of these two is a common illegal act performed by attorneys in Livingston County Court system.
This Stopped George Lyons and his ex-wife from acquiring back his marital property 1194 Camelot, Pinckney, Mi. Furthermore the Livingston County Prosecutor’s office did have both a copy of the $24,000.00 check that was given to the Kopp’s for payment on 1194 Camelot, Pinckney, Michigan

Proving that the Kopp’s made a fraudulent forfeiture against George Lyons and his ex-wife Patricia Lyons and also there office also had a copy of the Marian Kopp audio tape approval of George Lyons to enter into 1194 Camelot, Pinckney, Mi.

Footnote: Both Karl Kopp and Marian Kopp both were on the Land Contract on proving that Marian Kopp had full permission and rights to give George Lyons permission to enter into 1194 Camelot, Pinckney, Mi. with or without permission of Karl Kopp, and Karl Kopp had full Knowledge prior to filing his false police report to Pinckney, Mi. that Marian Kopp gave George Lyons permission to enter into 1194 Camelot, Pinckney, Mi.

There was no rescinding by Marian Kopp in giving George Lyons her permission to enter 1194 Camelot, Pinckney, Mi. This is proven through audio tapes of the Kopp’s.

The following people and Governmental department should be charged with committing fraud upon the court. Livingston County Prosecutor’s office, Court appointed attorney Mack Spickard and Ypsilanti Forensic center Dr. Judith Thompson, and Karl and Marian Kopp.

Judge Delvero was removed from his seat on the Livingston County Courts for sexual harassment.



Dated this September 18, 2008



______________________________
George Edward Lyons / Plaintiff
11994 Weiman
Pinckney, Michigan 48169
734-954-4040





Tuesday, January 15, 2008

Defendant's Storzbach's attorney Richard Conlin Lawsuit

State of Michigan
In the Livingston County Circuit Court
204 S. Highlander Way, Howell, Michigan 48843
517-546-9816


George Edward Lyons,
11994 Weiman
Pinckney, Michigan 48169
734-954-4040

Plaintiff,
vs.

Ronald Allen Storzbach and
Virginia E. Storzbach, H/W
912 Sand Wedge Court
Bowling Green, Ky. 42103-2508
Last known address
Phone unavailable
Defendants,

Michael R. Coad
3053 Adams
Rochester Hills, Michigan
Last known address
Phone unavailable
Defendant

Case No.:




Complaint



NOW COMES THE PLAINTIFF GEORGE EDWARD LYONS, and complaint against Defendants Ronald Storzbach and Virginia Storzbach H/W, and Defendant Michael R. Coad stating as follows:

COMMON ALLEGATIONS AND COMPLAINT
ALL PLAINTIFF’S RESPONSES FOR THIS COMPLAINT ARE DONE IN BLUE.

1. That Plaintiff George Edward Lyons is a resident of Township of Putnam Township, Livingston County, Michigan. Defendant Ronald Storzbach and Virginia Storzbach was a resident of Hamburg Township, Livingston County, Michigan. Who is now residing in 912 Sand Wedge Court, Bowling Green, Kentucky.

2. That Plaintiff George Edward Lyons is a resident of Township of Putnam Township, Livingston County, Michigan. Defendant Michael R. Coad was a subcontractor Carpenter for Defendant Storzbach on lot 16 Partridge Pointe, Michigan, Hamburg Township, Livingston County, Michigan. Who in last notification resides 3053 Adams, Rochester Hills, Michigan.
3. Storzbach’s Complaint drafted by Storzbach’s Attorney Richard Conlin. Plaintiff is responding to every false allegations starting with the Following:

4. Storzbach’s and there attorney Richard Conlin received consent judgment by criminal actions. Storzbach made terrorized threats to the health and lives against Plaintiff and his Family. If Plaintiff George Lyons did not sign the consent judgment.

Plaintiff George Lyons Complaint case because Storzbach’s committed terrorized the Plaintiff, and extortion, embezzlement, tortuous Interference. Civil conspiracy against Plaintiff. And forcing Plaintiff to wrongfully signing consent judgment.

The Plaintiff Motion to re-open case because of Defendant’s criminal actions was filed 1 day after consent judgment was signed.

Per letter from Defendant’s attorney Richard Conlin dated October 27th 1995 committed extortion. Forcing Plaintiff to either sell Defendant lot 16, Partridge Point, Brighton, Michigan or he would file a wrongful levy against all 8 lots that Plaintiff owned in Partridge Point, Brighton, and Mi. See attached Short version page 7 and 11. Plaintiff was force to sell lot 16 Partridge Point, Brighton.

To do this Plaintiff sold this property for $ 4,900.00 less then what plaintiff paid for the Lot 16, Partridge Point, Brighton, Mich. If Plaintiff did not sell the property for what Storzbach’s and their attorney Richard Conlin did committed extortion. Plaintiff would lose 4 other clients that were interest in Plaintiff property.

a. Defendant attorney Richard Conlin committed perjury in Judge Stanley Laterille court: Plaintiff George Lyons was represented by attorney Thomas Brady: Defendant’s attorney Conlin stated “that attorney Richard Conlin personally put document (NOTICE TO APPEAR IN COURT). into mail box”

b. This statement was false and misleading on attorney Richard Conlin part to acquire a Default Judgment against Plaintiff George Lyons. Proof of Services shows that Richard Conlin did not deposit notice to appear as stated in court.

c. Attorney Richard Conlin law firm was to send copy of notice to Plaintiff George Lyons and his attorney Thomas Brady to appear before Judge Stanley Laterille.

d. Attorney Richard Conlin stated before Judge Stanley Laterille, that he had no idea that George Lyons was represented by an attorney Thomas Brady, this false statement was to acquire a default judgments for his Clients Ronald and Virginia Storzbach from Plaintiff George Lyons for $ 51,000.00 and fraudulent attorney fees for $ 3,000.00.

e. Per audio tape conversation between Plaintiff George Lyons and Storzbach Attorney Richard Conlin and Plaintiff attorney Thomas Brady. “That Storzbach Attorney Richard Conlin agreed to send all documents to Thomas Brady office in Farmington Hills in Defendant Storzbach’s Lawsuit.


f. Per Audio tape conversation Attorney repeated the address back to Thomas Brady. This was recorded in George Lyons Chrysler New Yorker, on his hands free set. Approx. 30 days prior to Storzbach attorney Richard Conlin filed suit, and Storzbach’s attorney Richard Conlin false notice to appear in court.

THIS IS DONE PER STORZBACH’S FRAUDULENT LAWSUIT-COMPLAINT FILED BY DEFENDANT’S ATTORNEY RICHARD CONLIN DATED: MAY 5TH 1994. Evidence enclosed as Short version of Defendant’s Storzbach’s and Long Version of Defendant’s Storzbach’s Short version will be used as Exhibits.

PLAINTIFF RESPONSE AND COMPLAINT SHALL BE VIEWED AS BLUE
ALL STATEMENTS DONE BY DEFENDANT’S ARE DONE IN BLACK

5. That on or about September 4th 1993, Plaintiffs and Defendants entered into a Building Contract for the construction of a residential home for Plaintiffs for the total price, including land, of $ 205,000.00, to be erected on real property described as Unit 16, Partridge Point, Hamburg Township, and Livingston County, Michigan. Further, that said Contract was subsequently amended on October 28th, 1993. A copy of said Contract, as amended in attached hereto and made a part hereof. (See attached Exhibit “A”)

PLAINTIFF RESPONSE: Further, that said Contract was subsequently amended on October 28th, 1993. A copy of said Contract, as amended in attached hereto and made a part hereof. (See attached Exhibit “A”).

CONTRACT WAS AMENDED UNDER FORCE BY STORZBACH ATTORNEY RICHARD CONLIN. SEE STORZBACH SHORT VERSION. STORZBACHS COMMITTED EXTORTION, AND EMBEZZLEMENT. A LETTER FROM STORZBACHS ATTORNEY TO PLAINTIFF LYONS ATTORNEY THOMAS BRADY DATED: OCTOBER 27TH 1993.

STATING THE FOLLOWING: PAGE ONE: As stated by Storzbach’s attorney Richard Conlin in a letter to Plaintiff attorney Thomas Brady in paragraph b. An equitable lien will be filed with the Livingston County Register of Deeds on all the lots being purchased.

PER BUILDING CONTRACT SIGNED AN APPROVED BY STORZBACH STATES. SEE PARAGRAPH. GEORGE LYONS HAD 8 LOTS IN PARTRIDGE POINT, BRIGHTON, MI. THE ATTORNEY RICHARD CONLIN STATE UNDER OATH

PAGE TWO OF LETTER FROM ATTORNEY RICHARD CONLIN TO PLAINTIFF ATTORNEY THOMAS BRADY: Hopefully these steps will not be necessary, but I can assure you they will be taken unless my client obtains immediate security in the form of A WARRANTY DEED FOR THE $41,000.00 OF THEIR MONEY PRESENTLY POSSESSED BY LYONS BUILDERS. THIS IS CALLED EXTORTION. ATTACHED SHORT VERSION PAGE 4 AND 5 OF 32 PAGES.

DEFINING EXTORTION - The use, or the express or implicit threat of the use, of violence or other criminal means to cause harm to person, reputation, or property as a means to obtain property from someone else with his consent. USC 18

DEFINING EMBEZZLEMENT [MCL 750.174]
· Since 01/01/1999, Michigan defines 4 levels of Embezzlement:
o under $200: Misdemeanor -- up to 93 days and/or $500, or 3 times amount embezzled, whichever is greater
o at least $200 but less than $1,000 (or repeat offender of above): Misdemeanor -- up to 1 year and/or $2,000, or 3 times amount embezzled, whichever is greater
o at least $1,000 but less than $20,000 (or repeat offender of above): Felony -- up to 5 years and/or $10,000, or 3 times amount embezzled, whichever is greater
o $20,000 or more (or repeat offender of above): Felony -- up to 10 years and/or $15,000, or 3 times amount embezzled, whichever is greater · The essence of this crime is a violation of trust --- the agent (e.g., employee) was entrusted with the principal's (e.g., employer) property, acquired the principal's property through that relationship of trust, and dishonestly disposed of/took/hid/converted the property to his own use

On October 30th 1993: Plaintiff George Lyons was forced to sell lot 16 Partridge Point, Brighton, Michigan to Ronald and Virginia Storzbach by Storzbach’s attorney Richard Conlin. On October 30th 1993: Plaintiff transfer warranty deed to Ronald and Virginia Storzbach for $ 41,000.00 which on the same day same closing with Storzbach’s attorney present. Plaintiff George Lyons of Lyons Builders, Inc. Paid $ 45,900.00. A $ 4,900.00 difference/lose to Plaintiff George Lyons. Why would Plaintiff do this is to protect other clients interested in Plaintiff’s lots in Partridge Pointe, Brighton, Michigan.

Per the above Storzbach stated to State of Michigan Consumer & Industry Service that Defendant’s Storzbach’s paid Plaintiff George Lyons of Lyons Builders, Inc. A retainer of $ 41,000.00 and Defendant paid $ 41,000.00 for Lot 16 Partridge Pointe, Brighton, Michigan. This was a fraudulent statement on the Storzbach’s part.
PLAINTIFF RESPONSE: THIS FRAUDULENT STATEMENT IN THE DEFENDANT’S STORZBACH’S FALSE STATEMENTS TO CONSUMER & INDUSTRY SERVICES AND THEN TO THE LIVINGSTON COUNTY COURT SYSTEM COMPLETELY SHOWED THAT DEFENDANTS STORZBACH’S PAID PLAINTIFF $ 82,000.00 PLUS $ 29,400.00. THIS STATEMENT BY DEFENDANT’S STORZBACH SHOWS EMBEZZLEMENT AND EXTORTION...

Storzbach’s used this false statement to acquire a fraudulent report from Consumer & Industry Service. This fraudulent report was used in the Defendant’s Storzbach’s fraudulent lawsuit against Plaintiff George Lyons and his company Lyons Builders, Inc.

On October 30th 1993: Defendant’s Storzbach’s used Plaintiff retainer of $ 41,000.00 to purchase Lot 16 Partridge Point, Brighton, Michigan.

Per accounting and as of October 30th 1993. Plaintiff was in the whole $24,411.51 by using the $ 41,000.00 to start construction. Then Plaintiff had to use his own money in the returning retainer to Storzbach’s see accounting:

BUILDING CONTRACT WAS CONTINGENT UPON STORZBACH’S ACQUIRING FINANCING SEE AUDIO TAPES AND DOCUMENTS WHICH STORZBACH’S DID NOT RECEIVE THERE CONSTRUCTION LOAN UNTIL NOVEMBER 3RD 1993.

THIS IS WHEN THE TRUE BUILDING CONTRACT STARTED. THE STATEMENT ON STORZBACH’S PART WAS DELAYED BECAUSE DEFENDANT’S STORZBACH’S WERE NOT PAYING THEIR OBLIGATIONS ON THE CONTRACT.

Storzbach’s went to Chelsea Lumber in Chelsea, Mi. to acquire a construction loan. Storzbach’s hold-up was Storzbach’s applied for a loan through General Motors Mortgage company after weeks of hold-ups Storzbach’s found out that General Motors Mortgage Company did not do Construction Loans 9/24/93. PAGE 4 OF STORZBACH’S LONG VERSION.

Defendant’s Storzbach’s in going to Chelsea lumber, Chelsea, Michigan for a construction loan. Chelsea Lumber requirements are the following:

This was Defendant’s Storzbach’s construction loan and requirements per building contract, the requirements are to have money to pay for Defendant’s obligations. This was neither Plaintiffs obligation nor Lyons Builders, Inc obligation.

Defendant’s Storzbach’s per the building contract with Lyons Builders, Inc.

ARTICLE X: POSSESSION OF PREMISES/CLOSING

THE CONTRACTOR SHALL HAVE FULL AND EXCLUSION POSSESSION OF SAID PREMISES AND RISK OF LOSS UNTIL HE HAS RECEIVED FULL PAYMENT FOR ALL SUMS DUE HIM UNDER THIS CONTRACT. POSSESSION SHALL BE TRANSFERRED AT THE TIME OF CLOSING UNDER THE BUILDING CONTRACT. PAGE 14 OF BUILDING CONTRACT OR PAGE 20 OF 51 STORZBACH LONG VERSIONS.

FOOTNOTE: THERE WAS EXTORTION OF LOT 16 PARTRIDGE POINT BY THE DEFENDANT’S STORZBACH AND THERE ATTORNEY RICHARD CONLIN, THERE WAS NO FULL PAYMENT TO BE MADE TO CONTRACTOR FOR ALL SUMS DUE HIM UNDER THIS CONTRACT TO THE CONTRACTOR (PLAINTIFF). THERE WAS THEIF BY DEFENDANT’S STORZBACH’S AGAINST PLAINTIFF.

AND THERE WAS NO CLOSING UNDER THE BUILDING CONTRACT. THERE WAS EMBEZZLEMENT ON DEFENDANT’S STORZBACH’S PART AGAINST PLAINTIFF. THERE WAS THEIF ON DEFENDANT’S STORZBACH’S PART IN NOT PAYING FOR UPGRADE’S THAT WERE CRIMINALLY CHARGED AGAINST PLAINTIFF. SEE AUDIO’S

THE FOLLOWING IS AN OBLIGATION BY DEFENDANT’S STORZBACH’S TO ACQUIRE A CONSTRUCTION LOAN THROUGH CHELSEA LUMBER FINANCIAL DEPARTMENT. BUT THIS WAS NOT PLAINTIFF’S OBLIGATION THROUGH CHELSEA LUMBER. THERE WAS A SIGNED AND APPROVED BUILDING CONTRACT BY DEFENDANT’S STORZBACH’S PRIOR TO CHELSEA LUMBER CONSTRUCTION LOAN. THAT DEFENDANT’S STORZBACH’S DID NOT FOLLOW.

Home Construction Financing Detail Sheet

1. You bring a set of blueprints to Chelsea Lumber Company.

2. Chelsea Lumber Company completes a material estimate for you.

3. Bring your completed credit application to Chelsea Lumber Company.

4. You collect bids for labor and/or materials from subcontractors as shown on the reverse side of this sheet. (See Storzbach’s Long version page 50).

5. Chelsea Lumber representative meets with you to transfer your bids to Chelsea Lumber’s worksheet and mutually agree on a dollar needed to complete the project.

6. Chelsea Lumber Company orders certified appraisal.

7. You deliver a copy of existing title policy to Chelsea Lumber Company. If a Title policy is not available, a copy of a deed or land contract will suffice.

8. Chelsea Lumber Company updates the title policy, insuring Chelsea Lumber Company. This process could take two (2) weeks. This fee will be charged to your account.

9. You deliver a copy of a builder’s risk of homeowner’s insurance policy to Chelsea lumber Company. No binders, client must pay a one-year premium in advance. Mortgages clauses must read as follows:

1st Mortgages
Mail Code 3394
Commercial & Real Estate Loan Documentation Dept.
Comerica Bank
P.O. Box 33019
Detroit, Mi 48232-5019

2nd Mortgages
Chelsea Lumber Company & additional insured
1 Old Barn Circle
Chelsea, Mi 48118

10. You take out a workman’s compensation insurance policy and provide a certificate of such policy or application to Chelsea Lumber Company.

11. After the foundation is completed. Chelsea Lumber Company representative meets
With client to sign necessary documents and close on construction mortgage.

12. After the foundation is completed. Chelsea Lumber Company orders a mortgage survey.
This fee will be charged to your account.

13. If there is an existing Land-contract or mortgage pay-off, lending laws require Chelsea Lumber Company to wait at least three (3) Business days from the time of signing the mortgage until we can open the account and payoff the property.


Reverse side of Storzbach’s Home Construction Financing Check List:
BIDDING CHECK LIST (APPROVED BY STORZBACH’S)

1
FOUNDATION EXCAVATION
7,000.00
2
DRIVEWAY
1,000.00
3
BLOCK FOUNDATION*
2,500.00
4
POURED FOOTING &FOUNDATION
17,000.00
5
CHELSEA LUMBER MATERIAL PACKAGE
50,141.09
6
ROUGH FRAMING LABOR
16,200.00
7
FINISH TRIM MATERIAL*
included

8
FINISH TRIM LABOR

9
WINDOWS*
5,600.00
10
EXTERIOR DOORS*
included
-
11
ROOFING-LABOR & MATERIAL*
included
2,000.00
12
CONCRETE FLATWORK
included
-
13
PLUMBING-LABOR AND MATERIALS
3,430.00
14
BATH FIXTURES
included

15
HEATING-LABOR & MATERIALS
5,800.00
16
ELECTRICAL-LABOR & MATERIALS
4,900.00
17
LIGHT FIXTURES* INCLUDED IN ELECTRICAL
included
-
18
INSULATION -LABOR & MATERIALS*
include/labor
1,000.00
19
DRYWALL-LABOR & MATERIALS*
include/labor
3,000.00
20
BRICK-HOUSE AND LABOR
and labor
2,500.00
21
BRICK-FIREPLACE
included
22
KITCHEN CABINETS*
4,500.00
23
COUNTERTOPS*
included

24
BATH VANITY & TOPS*
included

25
SEPTIC FIELD (OR TAP FEE)
3,000.00
26
WELL (OR TAP FEE)
2,500.00
27
PAINT & STAIN-LABOR & MATERIALS*
2,000.00
28
FLOORING-CARPET, VINYLE, TILE
4,800.00
29
APPLIANCES*
900.00
30
GUTTERS*
not included

31
UTILITIES HOOKUP
not included
-
32
RISK INSURANCE
500.00
33
PERMIT & FEES
1,000.00
34
WORKMAN'S COMPENSATION INSURANCE
owner
-
Total money for construction STORZBACH HOME
141,271.09
SEE AUDIO
LOT 16 PARTRIDGE POINTE, BRIGHTON, MICHIGAN
41,000.00
182,271.09
BUILDING CONTRACT PRICE
(205,000.00)
BALANCE OWED LYONS BUILDERS, INC.
(22,728.91) THIS DOES NOT INCLUDED THE CHANGE'S MADE BY DEFENDANT'S STORZBACH'S

COUNT I –BREACH OF CONTRACT

6. That pursuant to the terms of the contract as previously set forth herein, Defendants were obligated as follows:
a. To construct a home for Plaintiff in accordance with the construction plans for a total price, including land, in the amount of $ 205,000.00.

PLAINTIFF RESPONSE: Defendant’s Storzbach’s committed breach of contract, also per audio tapes show an overwhelming of up-grades that Defendant’s Storzbach’s acquired without Plaintiff George Lyons permission. That Defendant’s Storzbach’s embezzled from Plaintiff George Lyons.

b. To complete the home on or before December 1, 1993, which said date was subsequently amended to extend it to ninety days following closing of Plaintiff’s construction loan. Said construction loan closed on or about November 5, 1993. Further to pay a penalty to Plaintiff in the amount of $ 25.00 per day if not completed within said time frame (Contract. Article 1).

PLAINTIFF RESPONSE: Defendant’s Storzbach’s did not follow contract: Page 3 and 4 of Short version. Stated by Storzbach’s attorney Richard Conlin in a letter to Plaintiff attorney Thomas Brady.

PAGE TWO: Hopefully these steps will not be necessary, but I can assure you they will be taken unless my client obtains immediate security in the form of A WARRANTY DEED FOR THE $41,000.00 OF THEIR MONEY PRESENTLY POSSESSED BY LYONS BUILDERS. THIS IS CALLED EXTORTION ON STORZBACH’S AND HIS ATTORNEY RICHARD CONLIN PART.

PAGE 1: Storzbach’s Building contract was Signed and approved September 4th 1993. On October 27, 1993 53 DAYS AFTER SIGNING BUILDING CONTRACT. Storzbach’s attorney criminally forces George Lyons of Lyons Builders, inc. to CHANGE BUILDING CONTACT AND FORCING IN SELLING Lot 16 Partridge Point, Pinckney, Michigan. NOT PER CONTRACT.

DEFENDANT'S ATTORNEY STATED As stated in b. An equitable lien will be filed with the Livingston County Register of Deeds on all the lots being purchased.

c. To be paid pursuant to Article 4 of the contract, only upon completion of certain work, as follows: a) 20% at time of signing the contract to be held and used as a retainer;

PLAINTIFF RESPONSE: WHERE STORZBACH’S IN RECEIVING BACK THE $ 41,000.00 RETAINER FOR LOT 16 PARTRIDGE POINT, BRIGHTON, MICHIGAN.

STORZBACH’S ATTORNEY RICHARD CONLIN IS STILL INSISTING THAT PLAINTIFF RECEIVED THE RETAINER AND STORZBACH PAID $ 41,000.00 FOR LOT 16 PARTRIDGE POINT, BRIGHTON, MICHIGAN. SHOWING THAT FALSE STATEMENT THAT STORZBACH’S PAID $82,000.00.

THIS PARAGRAPH IS FALSE AND MISLEADING TO THE LIVINGSTON COUNTY COURT SYSTEM ON STORZBACH’S AND STORZBACH’S ATTORNEY RICHARD CONLIN PART.

THE ONLY MONEY RECEIVED FROM STORZBACH IS $ 41,000.00 RETAINER THAT WAS USED TO PURCHASE LOT 16 PARTRIDGE POINT, BRIGHTON, MICHIGAN.

PLAINTIFF RESPONSE: THE ONLY MONEY RECEIVED FROM STORZBACH IS $ 41,000.00 RETAINER THAT WAS USED TO PURCHASE LOT 16 PARTRIDGE POINT, BRIGHTON, MICHIGAN.

AND $ 29,500.00 FOR WORK THAT HAS ALREADY BE DONE AND APPROVED BY STORZBACH’S AND CHELSEA LUMBER LOAN FOR CONSTRUCTION.

PER CHELSEA LUMBER CONSTRUCTION LOAN FOR STROZBACH’S PLAINTIFF GAVE CHELSEA LUMBER LOAN DEPARTMENT ALL SWORN STATEMENTS AND WAIVERS OF LIENS, AND PARTIAL AND FULL UN-CONTIONAL AND CONTIIONAL WAVIERS OF WHICH ALL SWORN STATEMENTS AND MATERIAL HANDLERS AND SUBCONTRACTOR WERE CONTACTED AND ASK IF THEY WERE PAID BY LYONS BUILDERS, INC.

COPIES OF THESE DOCUMENTS WERE ALSO GIVEN TO DEFENDANTS STORZBACH’S. SEE AUDIO TAPES OF STORZBACH’S RECEIVING THESE DOCUMENTS.

DEFENDANTS STORZBACHS BREACH BUILDING CONTRACT BY TAKING BACK RETAINER $ 41,000.00 TO PURCHASE LOT 16 PARTRIDGE POINTE, BRIGHTON, MICHIGAN.
.
b) First draw only upon completion of “excavation of basement, rough frame of house and windows, roofing material, septic or sewer hookup, well, etc.”;

PLAINTIFF RESPONSE: THIS WAS FOLLOWED BY THE PLAINTIFF PER STORZBACH’S CONSTRUCTION LOAN WITH CHELSEA LUMBER FINANCIAL DEPARTMENT. SEE STORZBACH’S ACCOUNTING ENCLOSED. ALL SWORN STATEMENTS WERE GIVEN TO STORZBACH’S AND CHELSEA LUMBER FINANCIAL DEPARTMENT FOR REVIEW.

c) rough heating, rough mechanics, rough plumbing, etc.”; d) third draw upon the completion of “drywall, finish lighting, carpentry, cabinets, plumbing, countertops, tile work, paint, stain, garage doors and openers, etc,”; e) fourth, Certificate of Occupancy , finish permits and waivers of any and all work.

PLAINTIFF RESPONSE: THIS WAS FOLLOWED BY THE PLAINTIFF PER STORZBACH’S CONSTRUCTION LOAN WITH CHELSEA LUMBER FINANCIAL DEPARTMENT. SEE STORZBACH’S ACCOUNTING ENCLOSED. ALL SWORN STATEMENT WAS GIVEN TO STORZBACH’S AND CHELSEA LUMBER FINANCIAL DEPARTMENT FOR REVIEW.
d. To “give all necessary notices to, and obtain the necessary permits and sanctions of the proper governmental authorities concerning the work and the safety and protection of personal property, in respect to said work, and general comply with the building codes and other regulation of said authorities”. (See Article 2, Contract)

PLAINTIFF RESPONSE: THIS WAS FOLLOWED BY THE PLAINTIFF PER STORZBACH’S CONSTRUCTION LOAN WITH CHELSEA LUMBER FINANCIAL DEPARTMENT. SEE STORZBACH’S ACCOUNTING ENCLOSED. ALL SWORN STATEMENT WAS GIVEN TO STORZBACH’S AND CHELSEA LUMBER FINANCIAL DEPARTMENT FOR REVIEW.

e. To prior to the receipt of any construction draw, deliver to the owner a sworn statement listing the names and amounts due all subcontractors, mechanics, workman, and suppliers and to furnish waivers of lien from persons furnishing labor or material in connection with the erection of the home. (See Article 8, Contract)

PLAINTIFF RESPONSE: THIS WAS FOLLOWED BY THE PLAINTIFF PER STORZBACH’S CONSTRUCTION LOAN WITH CHELSEA LUMBER FINANCIAL DEPARTMENT. SEE STORZBACH’S ACCOUNTING ENCLOSED. ALL SWORN STATEMENT WAS GIVEN TO STORZBACH’S AND CHELSEA LUMBER FINANCIAL DEPARTMENT FOR REVIEW. REPRESENTATIVE FROM CHELSEA LUMBER ARE MORE THAN WILLING TO TESTIFY BEFORE THIS COURT.


PLAINTIFF RESPONSE: THE ONLY MONEY RECEIVED FROM STORZBACH IS $ 41,000.00 RETAINER THAT WAS USED TO PURCHASE LOT 16 PARTRIDGE POINT, BRIGHTON, MICHIGAN.

AND $ 29,500.00 FOR WORK THAT HAS ALREADY BE DONE AND APPROVED BY STORZBACH’S AND CHELSEA LUMBER LOAN FOR CONSTRUCTION.

PER CHELSEA LUMBER CONSTRUCTION LOAN PLAINTIFF GAVE CHELSEA LUMBER LOAN DEPARTMENT ALL SWORN STATEMENTS AND WAIVERS OF LIENS, OF WHICH ALL SWORN STATEMENTS AND MATERIAL HANDLERS AND SUBCONTRACTOR WERE CONTACTED AND ASK IF THEY WERE PAID BY LYONS BUILDERS, INC.

COPIES OF THESE DOCUMENTS WERE ALSO GIVEN TO DEFENDANTS STORZBACH’S. SEE AUDIO TAPES OF STORZBACH’S RECEIVING THESE DOCUMENTS.

f. To pay transfer tax when title to the property passes pursuant to Article 10 of the contract.
g. To provide an Owner’s policy of title insurance without standard exceptions in the amount of the contract price at contractor’s expense pursuant to Article 10 of the contract.
7. That nevertheless and in spite of said contractual duties, Defendants breached the same in the following respects:

PLAINTIFF RESPONSE: THIS WAS FOLLOWED BY THE PLAINTIFF PER STORZBACH’S CONSTRUCTION LOAN WITH CHELSEA LUMBER FINANCIAL DEPARTMENT. SEE STORZBACH’S ACCOUNTING ENCLOSED. ALL SWORN STATEMENT WAS GIVEN TO STORZBACH’S AND CHELSEA LUMBER FINANCIAL DEPARTMENT FOR REVIEW AND TRUTHFULNESS.

a. In failing to construct the home for Plaintiffs in the amount of $ 205,000.00, including land, as contracted; and /or to make satisfactory progress in the construction of said home so that said home could foreseeably have been built for said sum and in a timely fashion. As a result of Defendant’s anticipatory breach in failing to make adequate progress in said construction.

b. Plaintiffs were forced to remove the Defendants in December 1993 and complete the home on their own at an excess expense of approximately $ 50,000.00.

PLAINTIFF RESPONSE: was wrongfully removed from property not in December 1993. Per permit history Plaintiff performed over $ 175,890.00 worth of work on Storzbach project.

See accounting that Storzbach’s did not reimburse Plaintiff. Upgrades over $ 75,000.00+ done by Storzbach’s that were not in building contract. Audio tapes conversation with Storzbach’s on upgrades that Storzbach’s was repetitively asked to sign.

See accounting. Audio tape conversations with Storzbach’s and Jerry Jarvis developer of Partridge Pointe, Brighton, Michigan asking subcontractor’s to make a fraudulent complaint to the State of Michigan Consumer & Industry services to wrongfully remove Plaintiff builders license to Stop Plaintiff George Lyons in having any money for an attorney.

c. In failing to obtain necessary permits or notify utility companies of upcoming needs for services resulting in excessive expense for Plaintiffs. Further, in violating certain ordinances in the maintenance of the premises in burning construction debris on site.

PLAINTIFF RESPONSE: DATES IN OBTAINS ALL NECESSARY PERMITS:
CHECK NO 1378 2-Sep-93

LIVINGSTON COUNTY HEALTH DEPARTMENT FOR WELL AND SEPTIC PERMITS
CASH 2-Sep-93

HAMBURG LAND USE PERMIT
CHECK NUMBER 1382 3-Sep-93

LIVINGSTON COUNTY BUILDING DEPARTMENT PERMIT 23-Sep-93


PLAINTIFF RESPONSE: CHECK NUMBER: DATE OF CHECK FOR CONSUMER POWER. ALL NECESSARY WERE ACQUIRED PER FOLLOWING DATES ON STORZBACH’S PROJECT.

NOTIFICATION OF UTILITY COMPANIES WERE ACQUIRED 27-JUN-1993 STORZBACH’S WERE NOTIFIED TO CALL UTILITY COMPANY AND GIVE THEM THERE SOCIAL SECURITY NUMBER: PER CONTRACT SPECIFICATIONS ADDED TO CONTRACT. STORZBACH’S WERE OBLIGATED FOR ALL GAS AND ELECTRIC BILLS.


Check number: 1270 27-Jun-93
CONSUMER POWER-STORZBACH’S WAS TOLD TO CONTACT-NEEDED SOCIAL SECURITY NUMBER>

APPLICATION FOR LOT 16 PARTRIDGE ($20.23)


PER STORZBACH’S SPECIFICATION ADDED TO CONTRACT:

PARAGRAPH 1.3 WORK NOT INCLUDED:

C. GAS AND ELECTRIC BILLS…………………………………………………………..NOT INCLUDED


SEE AUDIO TAPE OF CONVERSATION WITH STORZBACH’S THAT PLAINTIFF ORDER INSTALLATION OF GAS AND ELECTIC 27-JUNE-1993 FROM CONSUMER POWER: DEFENDANT’S STORZBACH’S NEEDED TO VERIFY HIS SOCIAL SECURTITY NUMBER TO ORDER THE CONSUMER POWER: (CONSUMER POWER INCLUDES: GAS AND ELECTRICITY.


SUBCONTRACTOR BURNED BUILDING MATERIAL, WITHOUT THE PERMISSION OF PLAINTIFF. WHEN PLAINTIFF FOUND OUT ABOUT THE BURNING OF MATERIALS. PLAINTIFF ACQUIRED BURN PERMIT.

IN ALL SUBCONTRACTOR AGREEMENTS, SUBS ARE TO LEAVE PROJECT IN BROOM CLEAN CONDITION.

d. In applying for and receiving construction draws without supplying the necessary sworn statements and waivers and prior to completion of the work called for in the contract. In spite of the contract language, the first draw (after payment of the $41,000.00 retainer) was applied for and received in the amount of $ 29,400.00 prior to the completion of most of the work under the terms of the contract for the first draw payment. Rough framing, as called for was.


PLAINTIFF RESPONSE: Defendant’s Storzbach breach building contract by not paying retainer of $ 41,000.00. . Per permit history Plaintiff performed over $ 175,890.00 worth of work on Storzbach project. See accounting that Storzbach’s did not reimburse Plaintiff. Upgrades that were not in building contract. Audio tapes conversation with Storzbach’s on upgrades that Storzbach’s was repeteively asked to sign change agreements.

See accounting. Audio tape conversations with Storzbach’s and Jerry Jarvis developer of Partridge Pointe, Brighton, Michigan asking subcontractor’s to make a fraudulent complaint to the State of Michigan Consumer & Industry services to wrongfully remove Plaintiff builder’s license to Stop Plaintiff George Lyons in having any money for an attorney.

Only completed in mid-December and then only after the carpenters had left the project after being given a bad check by Defendants. In spite of the fact that some of the first draw items were not completed, an application for a second draw was made in early December, again without adequate or proper supporting sworn statement or waivers lien.

PLAINTIFF RESPONSE: PLAINTIFF DID NOT GIVE CARPENTERS BAD CHECK PAGES 38 TO 41 OF SHORT VERSION WILL PROVE THIS: ALL SWORN STATEMENTS AND WAIVERS OF LIENS WERE GIVEN TO STORZBACH’S AND CHELSEA LUMBER FINANCIAL DEPARTMENT FOR APPROVAL OF MONEY PAID BY PLAINTIFF AND HIS COMPANY. THIS WAS DEFENDANT’S RULES AND REGULATION OF CHELSEA LUMBER FINANCING COMPANY. Neither PLAINTIFF NOR HIS COMPANY.


CARPENTER MICHALE R. COAD COMMITTED FRAUD, EMBEZLLEMENT, AND OTHER CRIMINALS ACTS. SEE AUDIO TAPES.


AUDIO TAPE CONVERSATION WITH MR. COAD: MR. COAD ENTERS WITHOUT PERMISSION. AT THE OFFICE OF LYONS BUILDERS, INC. PINCKNEY, MI.

AUDIO TAPED CONVERSATION WITH MR. COAD AND PLAINTIFF. BEFORE ENTERING WITHOUT PERMISSION. PLAINTIFF STATED TO MR. COAD. PLAINTIFF STATED I MADE OUT YOUR CHECK AND SIGNED IT AND PUTTING IT INTO MY CHECK REGISTER, I CAN NOT RELEASE THIS CHECK UNTIL I GET A DEPOSIT FROM STORZBACH AND PUT IT INTO MY ACCOUNT AND HAVE THREE DAYS TO CLEAR. WHEN IT CLEARS I WILL CONTACT YOU TO PICK-UP THE CHECK.

MR. COAD WENT BACK TO MY OFFICE AND ENTER WITHOUT PLAINTIFF PERMISSION AND REMOVED THE $5,000.00 CHECK FROM THE PLAINTIFF REGISTER. THIS IS CALL IN LAYMANS TERMS STEALING BY DEFENDANT COAD.

AUDIO TAPE: OF PLAINTIFF CONFRONTING MR. COAD IN WRONGFULLY REMOVING THE CHECK. THIS WAS CRIMINAL ACT AGAINST PLAINTIFF ON MR. COAD PART.

AUDIO CONVERSATION WITH CARPENTER MIKE COAD STATING TO PLAINTIFF GEORGE LYONS THAT HE DID ENTER PLAINTIFF OFFICE WITHOUT PLAINTIFF PERMISSION AND WRONGFULLY REMOVE $5000.00 CHECK FROM PLAINTIFF OFFICE WITHOUT PLAINTIFF PERMISSION. AND WRONGFULLY TRIED TO CASH $5000.00 CHECK. PLAINTIFF STATED THAT HE PUT A STOP PAYMENT ON THE CHECK TO MR. COAD

WORKERS OF ROUGH CARPENTER MICHALE R. COAD WILL TESTIFY THAT THE ROUGH CARPENTRY FOR STORZBACH’S PROJECT WAS ONLY $ 9,800.00 AND THAT MICHAEL R. COAD DID IN FACT EMBEZZLE MONEY FROM PLAINTIFF AND HIS COMPANY.
AUDIO TAPES BETWEEN MR. COAD AND PLAINTIFF WILL ALSO VERIFY MICHAEL R. COAD ALSO DID IN FACT COMMITTED THEIF OF THE CHECK, ENTERING WITHOUT PERMISSION AND EMBEZZLEMENT FROM PLAINTIFF AND HIS COMPANY. BY MR. COAD STATING THAT HIS CONTRACT WITH LYONS BUILDERS, INC. WAS $16,000.00. THIS FALLS UNDER GRAND THEIF. FROM PLAINTIFF AND HIS COMPANY THAT’S MORE THAN $ 2,000.00.


PLAINTIFF RESPONSE: DEFENDANT SUBCONTRACTOR MICHAEL COAD AND HIS PARTNER COMMITTED EMBEZZLEMENT OF $8,000+ FROM PLAINTIFF THROUGH AUDIO TAPE CONSVERSATION WITH DEFENDANT MICHAEL COAD STATING THAT COMPLETE ROUGH CARPENTARY COST WAS $9,800.00 ONLY.
DEFENDANT STORZBACH'S COMMITTED EMBEZZELMENT AND FRAUD BY MAKING FRAUDULENT STATEMENTS TO DEFENDANT’S STORZBACH’S AND CAUSING A LOST OF FUNDS OVER $8,000.00+ AND THIS SNOW BALLED INTO LOSSES TO THE PLAINTIFF GEORGE EDWARD LYONS AND HIS COMPANY OVER $20,000.00+. THIS IS A CIVIL CASE. CRIMINAL CHARGES WILL BE FILED AFTER CIVIL CASE.

DEFINING EMBEZZLEMENT [MCL 750.174]
· Since 01/01/1999, Michigan defines 4 levels of Embezzlement:
o under $200: Misdemeanor -- up to 93 days and/or $500, or 3 times amount embezzled, whichever is greater
o at least $200 but less than $1,000 (or repeat offender of above): Misdemeanor -- up to 1 year and/or $2,000, or 3 times amount embezzled, whichever is greater
o at least $1,000 but less than $20,000 (or repeat offender of above): Felony -- up to 5 years and/or $10,000, or 3 times amount embezzled, whichever is greater
o $20,000 or more (or repeat offender of above): Felony -- up to 10 years and/or $15,000, or 3 times amount embezzled, whichever is greater
· The essence of this crime is a violation of trust --- the agent (e.g., employee) was entrusted with the principal's (e.g., employer) property, acquired the principal's property through that relationship of trust, and dishonestly disposed of/took/hid/converted the property to his own use.

SEE TRANSCRIPT OF AUDIO TAPE OF DEFENDANT RONALD STORZBACH’S BEING NOTIFIED 10 DAYS BEFORE MAKING ANY MORE PAYMENTS TO DEFENDANT MICHAEL R. COAD. NOT TO PAY MICHAEL R. COAD OF DIMENSION IN WOOD ANY MORE MONEY. THAT DIMENSION IN WOOD WAS PAID IN FULL.

AND THE BALANCE OF THE CONTRACT TO BE PAID TO LYONS BUILDERS, INC. SHORT VERSION. THIS TRANSCRIPT ALSO PROVES THAT DEFENDANT’S STORZBACH’S TOOK OVER ALL PAYMENTS TO SUBCONTRACTOR’S AND DID MAKE ALL SUBCONTRACTOR’S PAYMENTS AND MATERIAL HANDLERS.

THAT PLAINTIFF DID NOT HAVE ANY CONTROL OVER AND PAYMENTS OF DEFENDANT’S STORZBACH’S. AND HIS PAYMENTS ON UPGRADES THAT WAS NOT IN THE CONTRACT. THAT WAS OVER $ 75,000.00- ON STORZBACH’S PROJECT. AND DEFENDANT’S STORZBACH’S STATING TO HIS ATTORNEY THAT THE UPGRADES WERE IN THE CONTRACT.

DEFENDANT’S FILE FRAUDULENT LAWSUIT TO ACQUIRE A FRAUDULENT LEVY AGAINST PLAINTIFF PROPERTY 5654 SHOSHONI PASS, PINCKNEY, MI. AND DEFENDANT’S STORZBACH STATED TO SUBCONTRACTOR’S ON THE STORZBACH’S PROJECT THAT HE PAID PLAINTIFF GEORGE LYONS THERE MONEY. AND THAT THEY TO SHOULD FILE MECHANICAL LIENS AGAINST PLAINTIFF PROPERTY 5654 SHOSHONI PASS, PINCKNEY, MICHIGAN. DEFENDANT’S WRONGFULLY AND CRIMINALLY AND CLOUDED TITLE OF 5654 SHOSHONI PASS, PINCKNEY, MICHIGAN.
d. In failing to complete the contract in a timely fashion under the terms of the contract.

PLAINTIFF RESPONSE: DEFENDANT’S STORZBACH FAIL TO FOLLOW CONTRACT. AND IN DOING SO DEFENDANT’S STORZBACH BREACH BUILDING CONTRACT WITH PLAINTIFF AND HIS COMPANY.

DEFENDANT STORZBACH'S DID FORCE PLAINTIFF TO USE PLAINTIFF RETAINER TO PURCHASE LOT 16 PARTRIDGE POINT, BRIGHTON, and MI. AND NEVER REPLACED RETAINER WITH THE PLAINTIFF AND HIS COMPANY. OR GET A CHANGE AGREEMENT WITH THE PLAINTIFF OR HIS COMPANY. PLAINTIFF NEVER DID RECEIVE REMIBURST MET OF RETAINER OF $ 41,000.00 FROM THE DEFENDANT’S STORZBACH’S.

DEFENDANT’S STORZBACH’S TOOK OVER ALL SUBCONTRACTOR’S PAYMENTS AFTER THE FIRST AND ONLY DRAW OF $ 29,500.00. SEE AUDIO TAPE.

e. In failing to provide transfer taxes to the owner at time of passage of title.

PLAINTIFF RESPONSE: TRANSFER OF TAXES WAS TRANSFER. AT THE SAME TIME OF CLOSINGS OF PLAINTIFF PAID $ 45,900.00 AND DEFENDANT PAID $ 41,000.00 AND $ 4,900.00 LOSES TO THE PLAINTIFF. DEFENDANT’S STORZBACH ATTORNEY ORGISTRATED THE CLOSING AT METROPOLIATION TITLE COMPANY. SEE AUDIO TAPE OF CLOSING PROVES EXTORTION ON DEFENANT’S STORZBACH’S AND THEIR ATTORNEY PART.

f. In failing to provide title insurance to the owner at time of passage of title.

PLAINTIFF RESPONSE: DEFENDANT’S STORZBACH ATTORNEY ORGISTRATED THE CLOSING AT METROPOLIATION TITLE COMPANY. SEE AUDIO TAPE OF CLOSING PROVES EXTORTION. AND AGAIN DEFENDANT MADE ACQUIRE A $ 4,900.00 FROM THE PLAINTIFF. TRUE COST OF THE PROPERTY LOT 16 PARTRIDGE POINT, BRIGHTON, MI. WAS $ 59,000.00 TO THE PLAINTIFF. SEE TITLE POLICY TO DEFENDANT STORZBACH FROM PLAINTIFF.

g. In failing to make advance provisions for utilities.

PLAINTIFF RESPONSE: NOTIFICATION OF UTILITY COMPANIES WERE ACQUIRED 27-JUN-1993 STORZBACH’S WERE NOTIFIED TO CALL UTILITY COMPANY AND GIVE THEM THERE SOCIAL SECURITY NUMBER: PER CONTRACT SPECIFICATIONS ADDED TO CONTRACT. STORZBACH’S WERE OBLIGATED FOR ALL GAS AND ELECTRIC BILLS.


CHECK NUMBER 1270 27-Jun-93
CONSUMER POWER-STORZBACH’S WAS TOLD TO CONTACT-NEEDED SOCIAL SECURITY NUMBER>

APPLICATION FOR LOT 16 PARTRIDGE
($20.23)


PER STORZBACH’S SPECIFICATIONS ADDED TO CONTRACT:

PARAGRAPH 1.3 WORK NOT INCLUDED:

C. GAS AND ELECTRIC BILLS……………………………………………………………NOT INCLUDED


SEE AUDIO TAPE OF CONVERSATION WITH STORZBACH’S THAT PLAINTIFF ORDER INSTALLATION OF GAS AND ELECTIC 27-JUNE-1993 FROM CONSUMER POWER: DEFENDANT’S STORZBACH’S NEEDED TO VERIFY HIS SOCIAL SECURTITY NUMBER TO ORDER THE CONSUMER POWER: (CONSUMER POWER INCLUDES: GAS AND ELECTRICITY).

J. In failing to order certain materials in a timely fashion.

PLAINTIFF RESPONSE: DEFENDANTS STORZBACH’S BUILDING CONTRACT NEVER STARTED, DEFENDANT’S STORZBACH’S NEVER STARTED THEY DID NOT FOLLOW THE APPROVED BUILDING CONTRACT, DEFENDANT’S STORZBACH’S FORCE PLAINTIFF TO GIVE-UP $ 41,000.00 RETAINER TO PURCHASE LOT 16 PARTRIDGE POINT, BRIGHTON, MI.

PER THE CONSTRUCTION OF DEFENDANT’S PROJECT, PLAINTIFF PER THE LIVINGSTON COUNTY BUILDING DEPARTMENT PERMIT HISTORY: PLAINTIFF GEORGE EDWARD LYONS AND HIS COMPANY LYONS BUILDERS, INC. PERFORMED OVER $ 175,890.00 SEE LIVINGSTON COUNTY BUILDING DEPARTMENT INSPECTION CODES ENCLOSED DEFENDANTS STORZBACH’S SHORT VERSION: PAGE 31 OF 32 PAGES.

TO PUT THIS IN PERSPECTIVE: Defendant’s Storzbach’s $ 41,000.00 for lot 16 Partridge Pointe, Brighton, Michigan. $ 29,400.00 for first and only draw. A total of $70,400.00.

Plaintiff George Lyons company performed per Livingston County Building Inspection permit history. Lyons Builders, Inc. performed $ 175,890.00 this did not include subcontractor’s work after Lyons Builders, Inc. was criminally removed from Defendant’s Storzbach’s project. So Defendant’s Storzbach’s criminally embezzle free work and Lyons Builders Inc. money.


Direct result of said breaches; Plaintiffs have incurred the following damages:
a. Excess cost in completion of the house in the approximate amount of $ 50,000.00
;

PLAINTIFF RESPONSE: THERE WERE NO EXCESS COST IN COMPLETION OF THE HOUSE AGAINST PLAINTIFF’S THIS IS JUST ANOTHER FABERCATION OF DEFENDANT’S STORZBACH’S AND THEIR ATTORNEY RICHARD CONLIN TO ACQUIRE ILLEGAL UPGRADES AGAINST THE PLAINTIFF THAT DEFENDANT DID NOT WANT TO PAY FOR.

b. Contractual penalties for delay of completion in the approximate amount of $ 1,500.00;

PLAINTIFF RESPONSE: THERE WERE NO CONTRACTUAL PENALTIES OF $ 1,500.00 AGAINST PLAINTIFF’S THIS IS JUST ANOTHER FABERCATION OF DEFENDANT’S STORZBACH’S AND THEIR ATTORNEY RICHARD CONLIN: TO ACQUIRE ILLEGAL FUNDS FROM THE PLAINTIFF AND COMMITT DEFERMATION OF CHARACTER AGAINST PLAINTIFF GEORGE LYONS BY DEFENDANT’S STORZBACH’S.

c. Title insurance in the amount of $ 885.00 and $ 45.10 for transfer tax.

PLAINTIFF RESPONSE: CHECKS PAID BY PLAINTIFF FOR DEFENDANT’S STORZBACH’S

CHECH NUMBER 27 24-Feb-94
METROPOLITAN TITLE COMPANY $ 120.00

COUNTER 24-Feb-94
HAMBURG TOWNSHIP TAXES FOR PARTRIDGE POINT $ 163.02

CHECK NUMBER: 20 28-Feb-94
FIRST OF AMERICA TAXES FOR PARTRIDGE POINT $ 154.60

THE ABOVE TITLE INSURANCE AND TRANSFER TAXES WAS PAID FOR BY PLAINTIFF FOR STORZBACH’S PROJECT. PAID AT THE CLOSING OF LYONS BUILDERS, INC. AND JARVIS DEVELOPMENTS THAT PLAINTIFF PAID $ 45,900.00 AND THE CLOSING ½ HOUR AFTER THE ABOVE CLOSING DEFENDANT STROZBACH’S CRIMINALLY PAID ONLY $ 41,000.00.


BECAUSE OF THE EXTORTION ACTS OF DEFENDANT’S STORZBACH’S AND THEIR ATTORNEY RICHARD CONLIN. PLAINTIFF LOSES WERE A $ 4,900.00 DIFFERENCE AT THE TIME OF CLOSINGS.


BOTH CLOSING WERE ORGETSTRATED BY DEFENDANT’S STORZBACH’S ATTORNEY RICHARD CONLIN. IF THERE WERE ANY MISTAKES IN THE CLOSING THIS WOULD FALL ON DEFENDANT’S STORZBACH’S AND THEIR ATTORNEY RICHARD CONLIN.

Wherefore, the Plaintiffs demand Judgment in the amount of $ 55,000.00 plus interest, cost and attorneys fees.

PLAINTIFF RESPONSE: Wherefore, the Plaintiff George Lyons demand Judgment in the amount of $ 2,000,000.00 plus interest, cost and future attorney fees.

COUNT II-SLANDER OF TITLE
Plaintiffs reiterate and rellege the allegation contained in Paragraphs 1 through 8 of this Complaint.

PLAINTIFF RESPONSE
: Plaintiff George Lyons reiterate and rellege the allegation contained in Paragraphs 1 through 8 of the Complaint.

9. That pursuant to the terms of the aforementioned contract, Plaintiffs became the owners of subject property on or about October 28, 1993, at the approximate time of the closing of the construction loan.

10. That at the time Plaintiffs terminated Defendant as a contractor on the project, Defendants, in retaliations, presented to Plaintiff a Claim of Lien, claiming a construction lien in the amount of $ 52,000.00. Said lien was not recorded at the time of presentation.

PLAINTIFF RESPONSE: Defendant’s had no right to terminate Plaintiff. Defendant’s Storzbach’s terminated Plaintiff to embezzle money from Plaintiff.

11. That, subsequent thereto, as Plaintiffs reached completion of their home on their own, and were in the process of applying for their mortgage financing. Defendants caused to be filed and recorded the previously presented alleged construction lien. The amount of said lien, however, was first changed from $ 52,000.00 to $ 35,000.00 and then recorded in liber 1809, page 001, Livingston County Records. (See attached Exhibit ‘’B’’)

PLAINTIFF RESPONSE: Defendant’s Storzbach reached completion of their home by using Plaintiff subcontractors. Along with stating to them that the Defendant’s Storzbach’s stated to the Subcontractor’s lies by stating that they paid George Lyons their money. See long version and Short version enclosed. Defendant’s committed criminal act in these actions.

12. That, at the time said lien was recorded, Defendants had no legitimate interest in the property in question and did not have the right to file said lien.

PLAINTIFF RESPONSE: PER THE ABOVE DESCRIPTION OF THE ITEMS THAT PLAINTIFF WENT THROUGH BECAUSE OF THE CRIMINAL ACTIONS OF THE DEFENDANT’S STORZBACH’S. PLAINTIFF DID HAVE INTEREST IN THE PROPERTY AND PER BUILDING CONTRACT:

Defendant’s Storzbach’s per the building contract with Lyons Builders, Inc.

ARTICLE X: POSSESSION OF PREMISES/CLOSING

THE CONTRACTOR SHALL HAVE FULL AND EXCLUSION POSSESSION OF SAID PREMISES AND RISK OF LOSS UNTIL HE HAS RECEIVED FULL PAYMENT FOR ALL SUMS DUE HIM UNDER THIS CONTRACT. POSSESSION SHALL BE TRANSFERRED AT THE TIME OF CLOSING UNDER THE BUILDING CONTRACT.

PAGE 14 OF BUILDING CONTRACT OR PAGE 20 OF 51 STORZBACH LONG VERSIONS.

FOOTNOTE: THERE WAS EXTORTION OF LOT 16 PARTRIDGE POINT BY THE DEFENDANT’S STORZBACH AND THERE ATTORNEY RICHARD CONLIN, THERE WAS NO FULL PAYMENT TO BE MADE TO CONTRACTOR FOR ALL SUMS DUE HIM UNDER THIS CONTRACT TO THE CONTRACTOR (PLAINTIFF). THERE WAS THEIF BY DEFENDANT’S STORZBACH’S AGAINST PLAINTIFF.

AND THERE WAS NO CLOSING UNDER THE BUILDING CONTRACT. THERE WAS EMBEZZLEMENT ON DEFENDANT’S STORZBACH’S PART AGAINST PLAINTIFF. THERE WAS THEIF ON DEFENDANT’S STORZBACH’S PART IN NOT PAYING FOR UPGRADE’S THAT WERE CRIMINALLY CHARGED AGAINST PLAINTIFF. SEE AUDIO’S

THE FOLLOWING IS AN OBLIGATION BY DEFENDANT’S STORZBACH’S TO ACQUIRE A CONSTRUCTION LOAN THROUGH CHELSEA LUMBER FINANCIAL DEPARTMENT. BUT THIS WAS NOT PLAINTIFF’S OBLIGATION THROUGH CHELSEA LUMBER. THERE WAS A SIGNED AND APPROVED BUILDING CONTRACT BY DEFENDANT’S STORZBACH’S PRIOR TO CHELSEA LUMBER CONSTRUCTION LOAN. THAT DEFENDANT’S STORZBACH’S DID NOT FOLLOW. WHICH DEFENDANT’S STORZBACH’S USED HIS ATTORNEY AS A BULLY.


14. That, further, the filing of the lien was done with malice in an obvious to prevent Plaintiffs from Obtaining financing to pay off their construction loan.

PLAINTIFF RESPONSE: THE ABOVE STATEMENT IS CALL DEFERMATION OF CHARACTER ON DEFENDANT’S STORZBACH’S PART AGAINST PLAINTIFF.

THE LIEN WAS PLACE AGAINST STORZBACH’S PROPERTY BECAUSE STORZBACH DID NOT DO THE FOLLOWING.


A. DID NOT FOLLOW THE BUILDING CONTRACT WHICH WAS APPROVED BY DEFENDANT’S STORZBACH’S.

B. DID NOT PAY SUBCONTRACTOR’S AND STATED TO THEM THAT THEY SHOULD FILE FRAUDULENT MECHANICAL LIENS AGAINST 5640 SHOSHONI PASS, PINCKNEY, MI.

C. SEE ACCOUNTING ( PER ACCOUNTING LYONS BUILDERS, INC. WERE NOT RESPONSIBLE TO PAY FOR DEFENDANT’S DESIGN WORK THAT DEFENDANT’S STORZBACH STOLE DESIGN FROM (BASIC DESIGN COMPANY.)

D. DID NOT PAY PLAINTIFF RETAINER OF $ 41,000.00 PER CONTRACT.

E. DEFENDANT’S STORZBACH’S DID COMMIT CRIMINAL ACTS AGAINST PLAINTIFF.


14. That, as result of the filing of said false construction lien, Defendants have slandered the title of Plaintiff’s property.

PLAINTIFF RESPONSE: PLAINTIFF DID HAVE FULL RIGHT TO FILE LIEN AGAINST DEFENDANT’S STORZBACH’S PROPERTY.

PER THE ABOVE DESCRIPTION OF THE ABOVE ITEMS THAT PLAINTIFF WENT THROUGH AND BECAUSE OF THE CRIMINAL ACTIONS OF THE DEFENDANT’S STORZBACH’S. PLAINTIFF DID HAVE INTEREST IN THE PROPERTY AND PER BUILDING CONTRACT:

As Defendant’s Storzbach’s and per the building contract with Lyons Builders, Inc.

ARTICLE X: POSSESSION OF PREMISES/CLOSING

THE CONTRACTOR SHALL HAVE FULL AND EXCLUSION POSSESSION OF SAID PREMISES AND RISK OF LOSS UNTIL HE HAS RECEIVED FULL PAYMENT FOR ALL SUMS DUE HIM UNDER THIS CONTRACT. POSSESSION SHALL BE TRANSFERRED AT THE TIME OF CLOSING UNDER THE BUILDING CONTRACT.

PAGE 14: REVIEW OF BUILDING CONTRACT OR PAGE 20 OF 51 STORZBACH LONG VERSIONS.

ACQUIRING A LOAN IS TOTALLY DIFFERENT FROM CLOSING ON STORZBACH’S PROJECT.

DEFENDANT’S STORZBACH’S HAD TWO DIFFERENT CHOOSES:

ARTICLE X: POSSESSION OF PREMISES/CLOSING

THE CONTRACTOR SHALL HAVE FULL AND EXCLUSION POSSESSION OF SAID PREMISES AND RISK OF LOSS UNTIL (A) HE HAS RECEIVED FULL PAYMENT FOR ALL SUMS DUE HIM UNDER THIS CONTRACT.

(B). POSSESSION SHALL BE TRANSFERRED AT THE TIME OF CLOSING UNDER THE BUILDING CONTRACT.

PLAINTIFF NEVER RECEIVED FULL PAYMENT FOR ALL SUMS DUE HIM UNDER THE CONTRACT.

AT THE TIME OF CLOSING UNDER THE BUILDING CONTRACT. BECAUSE DEFENDANT’S STORZBACH FORCE THE USE OF THE RETAINER TO BE USED AS PURCHASING FUNDS FOR LOT 16 PARTRIDGE POINT, BRIGHTON, MI. THE BUILDING CONTRACT WAS BREACH BY THE DEFENDANT’S STORZBACH’S.

FOOTNOTE: THERE WAS EXTORTION OF LOT 16 PARTRIDGE POINT BY THE DEFENDANT’S STORZBACH AND THERE ATTORNEY RICHARD CONLIN, THERE WAS NO FULL PAYMENT TO BE MADE TO CONTRACTOR FOR ALL SUMS DUE HIM UNDER THIS CONTRACT TO THE CONTRACTOR (PLAINTIFF). THERE WAS THEIF BY DEFENDANT’S STORZBACH’S AGAINST PLAINTIFF.

AND THERE WAS NO CLOSING UNDER THE BUILDING CONTRACT. THERE WAS EMBEZZLEMENT ON DEFENDANT’S STORZBACH’S PART AGAINST PLAINTIFF.

THERE WAS THEIF’S ON DEFENDANT’S STORZBACH’S PART IN NOT PAYING FOR UPGRADE’S THAT WERE CRIMINALLY CHARGED AGAINST PLAINTIFF. SEE AUDIO’S THIS CIVIL CASE SHALL FOLLOW WITH A CRIMINAL FILING AGAINST DEFENDANT’S BY THE PLAINTIFF.

THE FOLLOWING IS AN OBLIGATION BY DEFENDANT’S STORZBACH’S TO ACQUIRE A CONSTRUCTION LOAN THROUGH CHELSEA LUMBER FINANCIAL DEPARTMENT. BUT THIS WAS NOT PLAINTIFF’S OBLIGATION THROUGH CHELSEA LUMBER. THERE WAS A SIGNED AND APPROVED BUILDING CONTRACT BY DEFENDANT’S STORZBACH’S PRIOR TO CHELSEA LUMBER CONSTRUCTION LOAN. THAT DEFENDANT’S STORZBACH’S DID NOT FOLLOW. WHICH DEFENDANT’S STORZBACH’S USED HIS ATTORNEY AS A BULLY.

15. That, in recording said false construction lien Defendants have violated provisions of MCLA 565.108; MSA 26.1278 entitled Plaintiffs to damages, including reasonable attorney fees.

PLAINTIFF RESPONSE: PER THE ABOVE DESCRIPTION OF THE DEFENDANT’S STORZBACH’S AND THE ATTORNEY. PLAINTIFF HAD FULL RIGHTS IN FILING A CONSTRUCTION LIEN AGAINST DEFENDANT’S STORZBACH’S

16. That, further, the recording of said alleged construction lien was done by Defendants with such gross indifference to and / or reckless disregard for the Plaintiffs, as to constitute a willful and wanton act entitling Plaintiffs to exemplary damages.

PLAINTIFF RESPONSE: PER THE ABOVE DESCRIPTION OF THE DEFENDANT’S STORZBACH’S AND THE ATTORNEY. PLAINTIFF HAD FULL RIGHTS IN FILING A CONSTRUCTION LIEN AGAINST DEFENDANT’S STORZBACH’S. AND WITH THE ABOVE DISREGARD OF INVESTIGATION OF DEFENDANT’S FILES. PLAINTIFF IS WRONGLY AQUISED BY DEFENDANT’S STORZBACH FOR DEFERMATION OF CHARACTER AGAINTS PLAINTIFF. AND PLAINTIFF CONSIDERS THE ABOVE STATEMENTS IN TOTAL PERJURIOUS.

17. That, as a result of the slandered title as aforesaid Plaintiffs have incurred damages consisting of the following:

PLAINTIFF RESPONSE: That as a result of slandered title as aforesaid Plaintiff George Lyons has incurred damages consisting of the Following:

a. Impairment of vendibility;

PLAINTIFF RESPONSE: PER THESE DOCUMENTS THIS IS FABERCATED AND FALSE STATEMENT ON THE DEFENDANT’S STORZBACH’S PART.

b. Litigation expenses;

PLAINTIFF RESPONSE: PER THESE DOCUMENTS THIS IS FABERCATED AND FALSE STATEMENT ON THE DEFENDANT’S STORZBACH’S PART. PER STORZBACH’S ATTORNEY RICHARD CONLIN AND PERJUIOUS STATEMENT IN COURT TO ACQUIRE A FRAUDULENT DEFAULT JUDGMENT FOR HIS CLIENTS RONALD AND VIRGINIA STORZBACH’S THE DEFENDANT’S. FILE A COMPLAINT WITH THE STATE OF MICHIGAN ATTORNEY GRIEVANCE COMMITTEE TO REMOVE STORZBACH’S ATTORNEY RICHARD COLIN LICENSE TO PRACTICE LAW.

c. Loss or impairment of credit;

PLAINTIFF RESPONSE: BECAUSE OF THE CRIMINAL ACTIONS OF THE DEFENDANT’S STORZBACH’S AND THEIR ATTORNEY RICHARD CONLIN. PLAINTIFF GEORGE LYONS LOSES THE FOLLOWING.

a. Over $ 387,000.00 that the Defendant’s Storzbach’s interference with other clients to acquire illegal funds.

b. Lose of 7 lots in Partridge Pointe, Brighton, Michigan.

c. Lose of 4 clients in Partridge Pointe, Brighton, Michigan because of Defendant’s false statements to these clients. And lose of 3 clients off Whitewood Road, Pinckney, Michigan and Defendant’s Storzbach’s fabricated statements to them.

d. Lose of income from for 5640 Shoshoni Pass, Brighton, Michigan.

e. Lose of Plaintiff home at 1194 Camelot, Pinckney, Michigan cause by Defendant’s Storzbach interference.

f. Complete loss of credit because of Defendant’s Interference.

g. Lose of income on 4 homes off Whitewood Road, Pinckney, Michigan because of Defendant’s Storzbach’s interference.

h. Lose of Builders License and Real Estate License because of false complaints to the State of Michigan Consumer & Industry service.

i. Lose of income from 1994 to present because of the criminal actions of Defendant’s Stozbach’s.

j. Defendant’s Storzbach’s cause Plaintiff to be homeless for 4 years. Evidence against Defendant’s was discovered and located in 2007. For which bring forth this case.

k. Mental stress, Defendant’s caused lost of a 20 year marriage of the Plaintiff and 10 years of lost income, lost income from 8 clients because the defendant’s interference. Plaintiff mental stress caused by Defendant’s Storzbach’s.

l. Abuse of process by the Defendant’s n. the use of legal process by illegal, malicious, or perverted means. Defendant’s include serving (officially giving) a fraudulent complaint to the State of Michigan Consumer & Industry service by Defendant’s Storzbach when it has actually been filed, just to intimidate an enemy, the Defendant’s Storzbach in filing a false declaration to other clients against Plaintiff (defendant’s Storzbach did file a paper or communicated a untruthfully stating a lies that someone has officially given a notice to another person.

Then Defendant’s Storzbach did file a lawsuit which has no basis at law, but is intended to get acquire illegal funds, or force payment through fear of legal entanglement or gain an unfair or illegal advantage against Plaintiff.

Defendant’s thought they were clever by abusing the process this way. A few unscrupulous lawyers do so intentionally and can be subject to discipline and punishment. Defendant’s attorney lawyer did abuse the process; an honest attorney will promptly correct the error and apologize. This was never done by Defendant’s or their attorney Richard Conlin and did in fact commit abuse of process against this Plaintiff.

d. Exemplary damages

PLAINTIFF RESPONSE: exemplary damages n. often called punitive damages, these are damages that Plaintiff George Lyons requests and/or awarded in this lawsuit when the defendant's Storzbach’s were willful and committed acts that were malicious, violent, oppressive, fraudulent, wanton, or grossly reckless.

The above acts of the Defendant’s Storzbach warranting award for Plaintiff for Defendant’s committed exemplary damages against Plaintiff:

Also Plaintiff will show beyond a reasonable doubt that Defendant’s Storzbach’s Defendant’s Michael R. Coad of Dimension in wood and Defendant’s Storzbach’s were malicious, violent, oppressive, fraudulent, wanton, a and grossly reckless, in this civil lawsuit and future criminal actions that they did committed the above against Plaintiff George Edward Lyons.


e. Reasonable attorney fees.

PLAINTIFF RESPONSE: PER THESE DOCUMENTS THIS IS FABERCATED AND FALSE STATEMENT ON THE DEFENDANT’S STORZBACH’S PART. PER STORZBACH’S ATTORNEY RICHARD CONLIN AND PERJUIOUS STATEMENT IN COURT TO ACQUIRE A FRAUDULENT DEFAULT JUDGMENT FOR HIS CLIENTS RONALD AND VIRGINIA STORZBACH’S THE DEFENDANT’S. FILE AN COMPLAINT WITH THE STATE OF MICHIGAN ATTORNEY GRIEVANCE COMMITTEE TO REMOVE STORZBACH’S ATTORNEY RICHARD COLIN LICENSE TO PRACTICE LAW.

PLAINTIFF RESPONSE: The Defendant’s caused Tortuous interference, in the common law of tort, occurs when Defendant’s Storzbach’s and Defendant Coad intentionally damages the plaintiff's contractual or with other business relationships (past clients). This tort is broadly divided into two categories, one specific to contractual relationships (irrespective of whether they involve business), and the other specific to business relationships or activities (irrespective of whether they involve a contract).

Defendant’s Tortuous interference with Plaintiff contract rights occur where the Defendant’s tortfeas did convinces a party to breach the contract against the plaintiff, or where the Defendant’s tortfeasor disrupts the ability of one party to perform his obligations under the contract, thereby preventing the plaintiff from receiving the performances promised.
The Defendant’s Tortious interference with Plaintiff business relationships occurs where the Defendant’s tortfeasor acts to prevent the plaintiff from successfully establishing or maintaining business relationships.

This tort was first described in the case of Keeble v. Hickeringill, (1707) 103 Eng. Rep. 1127,

PLAINTIFF RESPONSE: The Defendant caused 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 which Defendant’s Storzbach’s and Defendant Coad action caused the major significance of the conspiracy lies in the fact that it renders each Defendant’s in the wrongful act responsible as a Defendant’s joint tortfeasor for all damages ensuing from the defendant’s wrong, irrespective of whether or not Defendant’s caused a direct actor or actors 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.)

DEFINING CIVIL CONSPIRACY OR CRIMINAL CONSPIRACY: Conspiracy (civil) a civil conspiracy or collusion is an agreement between two or more parties to deprive a third party of legal rights or deceive a third party to obtain an illegal objective.[1] A conspiracy may also refer to a group of people who make an agreement to form a partnership in which each member becomes the agent or partner of every other member and engage in planning or agreeing to commit some act.

It's not necessary that the conspirators be involved in all stages of planning or be aware of all details. Any voluntary agreement and some overt act by one conspirator in furtherance of the plan are the main elements necessary to prove a conspiracy. A conspiracy may exist whether legal means are used to accomplish illegal results, or illegal means used to accomplish something legal.[2] "Even when no crime is involved, a civil action for conspiracy may be brought by the persons who were damaged."[3]In the law of tort, the legal elements necessary to establish a civil conspiracy are substantially the same as for establishing a criminal conspiracy, i.e. there is an agreement between two or more natural persons to break the law at some time in the future or to achieve a lawful aim by unlawful means.

The criminal law often requires one of the conspirators to take an overt step to accomplish the illegal act to demonstrate the reality of their intention to break the law, whereas in a civil conspiracy, an overt act towards accomplishing the wrongful goal may not be required. Etymologically, the term comes from Latin con- "with, together", and spirare "to breathe".

PLAINTIFF RESPONSE: George Lyons with audio tapes of other clients and Defendant’s Storzbach’s and Defendant Michael Coad Plaintiff will prove beyond a shadow of Doubt that both Defendant’s Storzbach’s and others committed civil conspiracy.

PLAINTIFF RESPONSE: The Defendant’s committed embezzlement against the Plaintiff George Lyons. Defendant’s embezzlement was the fraudulent appropriation by a Defendant’s to his own use of property or money entrusted to that Defendant’s care but owned or was to be owned by Plaintiff.

Wherefore, the Plaintiffs demand Judgment in such sum in excess of $ 10,000.00 as found to owe plus interest, costs and attorney fees.

PLAINTIFF RESPONSE: Wherefore the Plaintiff George Lyons demand Judgment in such sum in excess of $ 2,000,000.00+ as found to owe because of the criminal actions of the Defendant’s.

COUNT III –VIOLATION OF MICHIGAN BUILDERS TRUST FUND ACT

PLAINTIFF RESPONSE: Plaintiff never committed any violation against the Michigan Builders Trust fund act.

The Defendant’s did commit fraudulent fabricated complaints to the Michigan Builders Trust act. To acquire illegal funds.

Plaintiffs reiterate and reallege the allegations contained Paragraphs 1 through 19 of this Complaint.

PLAINTIFF RESPONSE: Plaintiff reiterates and realleges the Allegation contained Paragraphs 1 through 20 of this Complaint.

18. That under the terms of MCLA 570.151 et seq. / MSA 26.3 et seq., a contractor who is paid funds by an owner for the construction of a residence shall be considered a Trustee of as funds for the benefit of the person making the payment, Plaintiff herein.

PLAINTIFF RESPONSE: THE ABOVE STATEMENT IS FALSE AND MISLEADING. THAT THE DEFENDANT’S STORZBACH’S TOOK OVER ALL PAYMENTS TO SUBCONTRACTORS AND MATERIAL HANDLERS, SEE AUDIO TAPES. AND PLAINTIFF FEELS THAT THIS STATEMENT ON DEFENDANT’S PART IS FABERCATED.

DEFENDANT’S SHOULD BE CRIMINAL CHARGED WITH FILING FALSE COMPLAINTS WITH THE MICHIGAN BUILDERS TRUST ACT, TO ACQUIRE ILLEGAL FUNDS FROM THE STATE OF MICHIGAN BUILDERS TRUST FUND ACT. TO ACQUIRE ILLEGAL FUNDS.

19. That further, pursuant to the terms of said act, the appropriation by a contractor of any monies paid to him before the payment by him of all monies due or to be come due laborers, subcontractors, material men or others entitled to payment shall be evidence of intent to defraud.

PLAINTIFF RESPONSE: DEFENDANT’S STORZBACH’S TOOK OVER ALL PAYMENTS TO SUBCONTRACTORS AND MATERIAL HANDLERS, SEE AUDIO TAPES. AND PLAINTIFF FEELS THAT THIS STATEMENT ON DEFENDANT’S PART IS FABERCATED.

DEFENDANT’S STORZBACH'S SHOULD BE CRIMINAL CHARGED WITH FILING A FALSE COMPLAINTS WITH THE MICHIGAN BUILDERS TRUST ACT, AND TO THE STATE OF MICHIGAN CONSUMER & INDUSTRY SERVICES TO ACQUIRE ILLEGAL FUNDS FROM THE STATE OF MICHIGAN BUILDERS TRUST FUND ACT.

DEFENDANT’S STORZBACH’S SHOULD BE CRIMINALLY CHARGE FOR NOT PAYING SUBCONTRACTOR’S AND MATERIAL HANDLERS BY FALSELY STATING TO THEM THAT THEY PAID GEORGE LYONS THEIR MONEY. FORCING SUBCONTRACTOR AND MATERIAL HANDLERS TO FILE FALSE MECHANICAL LEINS AGAINST 5640 SHOSHONI PASS, PINCKNEY, MICHIGAN.

20. That Plaintiff did, in fact, pay to the Defendants sums under the terms of their contract which were subsequently appropriated to Defendants own use not in connection with the construction of said residence. That, in spite of demands by Plaintiffs have been damaged as result of said wrongful conversion of funds.


PLAINTIFF RESPONSE: THIS STATEMENT IS FALSE AND MISLEADING ON THE
DEFENDANT’S PART. THE PLAINTIFF USED ALL FUNDS GIVEN TO PLAINTIFF IN THE CONSTRUCTION OF DEFENDANT’S STORZBACH’S PROJECT. PLUS EXTRA (SEE ENCLOSED DEFENDANT’S STORAZBACH’S ACCOUNTING).

Showing that Lyons Builders, Inc performed over 82.50 % of the Defendant’s project.

See Livingston County Building Department permits history for work that has been done by Plaintiff George Edward Lyons and his company Lyons Builders, Inc.

WHEREFORE, the Plaintiffs demand Judgment in such sum in excess of $ 10,000.00 as found to be owing plus interest, cost and attorney fees. We declare that the statements above are true to the best of our information, knowledge and belief.

PLAINTIFF RESPONSE: The illegal and criminal acts of these Defendant’s still are as prevalent as today 2008 and continue as they were first wrongfully file by Defendant’s in 1994. They still continue to harm the Plaintiff today and in the future.

PLAINTIFF RESPONSE: WHEREFORE the Plaintiff George Lyons demands Judgment in
such sum in excess of $2,000,000.00 + as found to owing plus interest since 1994, plus cost of future attorney fees. Plaintiff declares the statements above are true to the best of his information, knowledge and belief.

Respectfully submitted







____________________________________
George Edward Lyons-Plaintiff
11994 Weiman
Pinckney, Michigan 48169
734-954-4040
Monday, January 07, 2008

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