Section 37. Slavery--prohibition

Section 37. There shall be neither slavery, nor involuntary servitude, within the State, otherwise than for the punishment of crimes, whereof the party shall have been duly convicted.

 For purposes of prosecution under these authorities, the Court held, “the term ‘involuntary servitude’ necessarily means a condition of servitude in which the victim is forced to work for the defendant by the use or threat of physical restraint or physical injury, or by the use or threat of coercion through law or the legal process.”35

request $25000 bond for injunction  if issued.

Where such is the case, an injunction is often deemed mandatory, rather than prohibitory, and a greater showing is required of the moving party. See Jacobson & Co. v. Armstrong Cork Co., 548 F.2d 438, 441 (2d Cir.1977). In these circumstances, we have held that an injunction should issue “only upon a clear showing that the moving party is entitled to the relief requested,” Flintkote Co. v. Blumenthal, 469 F.Supp. 115, 125-26 (N.D.N.Y.), aff’d, 596 F.2d 51 (2d Cir.1979),or where “extreme or very serious damage will result” from a denial of preliminary relief, Clune v. Publishers’ Ass’n, 214 F.Supp. 520, 531 (S.D.N.Y.), aff’d, 314 F.2d 343 (2d Cir.1963). In sum, we have shown “greater reluctance to issue a mandatory injunction than a prohibitory injunction.” Hurley v. Toia, 432 F.Supp. 1170, 1175 (S.D.N.Y.), aff’d mem., 573 F.2d 1291 (2d Cir.1977).
Abdul Wali v. Coughlin, 754 F.2d 1015 (2d Cir. 1985)

 A mandatory injunction “`goes well beyond simply maintaining the status quo pendente lite [and] is particularly disfavored.'” Anderson v. United States, 612 F.2d 1112, 1114 (9th Cir.1979) (quoting Martinez v. Mathews,544 F.2d 1233, 1243 (5th Cir.1976)). When a mandatory preliminary injunction is requested, the district court should deny such relief “`unless the facts and law clearly favor the moving party.'” Id. Our first task is to determine whether Coach Stanley requested a prohibitory injunction or a mandatory injunction.
Stanley v. University of Southern California, 13 F.3d 1313 (9th Cir. 1994)

O Centro Espirita Beneficiente v. Ashcroft, 389 F.3d 973 (10th Cir. 2004)

In any event, it is certainly true that courts have historically applied a more stringent standard to mandatory preliminary 979*979 injunctions for the very reason that those injunctions generally do alter the status quo. See, e.g., In re Microsoft Corp. Antitrust Litig., 333 F.3d 517, 526 (4th Cir.2003); Tom Doherty Assocs. v. Saban Entm’t, Inc., 60 F.3d 27, 34 (2d Cir.1995); Anderson v. United States, 612 F.2d 1112, 1114 (9th Cir.1979). In fact, most courts decide whether a given preliminary injunction is “mandatory” or “prohibitory” by determining whether or not it alters the status quo. See, e.g., Tom Doherty Assocs., 60 F.3d at 34; Acierno v. New Castle County, 40 F.3d 645, 647 (3d Cir.1994); Stanley v. Univ. of S. Cal., 13 F.3d 1313, 1319 (9th Cir.1994); Martinez v. Mathews, 544 F.2d 1233, 1242-43 (5th Cir.1976).

There is good reason, however, to distinguish between mandatory injunctions and injunctions which alter the status quo and to treat both types as disfavored.
Without regard to whether a mandatory preliminary injunction alters the status quo, however, it is still appropriate to disfavor such injunctions “because they affirmatively require the nonmovant to act in a particular way, and as a result they place the issuing court in a position where it may have to provide ongoing supervision to assure the nonmovant is abiding by the injunction.” SCFC ILC, 936 F.2d at 1099.

10 ways they have had unclean hands.
privity with city. bad acts by city.
example, joell palmer case, where we went together to the supreme court .
of the 1000 cases, how many had been to the supreme court to watch indianapolis lose?
stewart v taylor
ran for judge, ran for state representative, ran for county clerk.
did that turn up in your due dilligence?

do you understand that your conduct posed a grave risk to the public, to me,and yourself, in that it could have triggered an acute episode, as it  did back in 2001?

1. joell and bad acts by city
2.    reported cases, judicial notice
3.    home invasion, stalking
4.    defective hearing, pattern of hearing denial
5.    [complicity in denial of counsel, creates appearance of impropriety.]
6.    commandeering of court chambers, appearance of impropriety.
7.    caused 2001 nervous breakdown - proximate cause, not underlying cause.
8.    possible racism and sexism in crew that did the property invasion, contrary to public policy.
9.    possible gang-related past of crew members.
10.   may have lied about smith entry. need text of hearing. but there is no record.

20 questions for h and h.

Interrogatories and or requests for admission of law or fact.

1. You mentioned whatshername has 1000 other clients. List them.

2. Of those, how many were represented by counsel?
List counsel
                    and cases. emails if known.
3   how many of the 1000 cases involved counterclaims?
4         how many raised constitutional issues?
5          what affirmative defenses, if any, have been raised in those cases?
did any prevail?

hourly rates, if known.
6Of those, how many are attorneys?
7. Were any cases involving whatshername appealed and reported?

8.     Of the 1000 were any of them suing the county or its various alter egos?
9    how many had already sued and won against the county?
10      do you have any policies in place about how to avoid an appearance of impropriety?
11 do you vote?
12 do you show id?
13 do you have your id with you? is this it?
14 is it ok if i read off some of this info?
15 do you know your social security number?
16 have you ever been the victim of a crime?
17 have you ever given testimony that later turned out not to be true?
18 do you believe that police or health inspectors sometimes lie on the sttand?
19 have you ever told a lie?
20 what is a white lie?
21 do you prefer bagels or donuts?
22 have you ever made a false statement under oath?
23 have you ever made a true statement under oath?
24 do you always know the difference?

25 who is matt guttwein?
26 did you conspire with matt guttwien to enforce the h and h code?
27 eviction case - mark smith
28    eviction case - belinda williams
29  can you think of any examples of actions taken by h and h  that might indicate unclean hands?
30 have you ever heard the expression dropping a dime? do you work with stool pigeons, rats, confidential informants? might some of these people have unclean hands?

did you conspire, either before, during or after the fact, with [name of attorney] to enter my property and take photographs, knowing you did not have a warrant?
have you been asked to make a written waiver of conflict of interest?
what does the idiom thrown to the wolves mean?
do you speak any russian?
who do you admire?
are you a communist or socialist? do you have a creed?
do you belong to any worldwide conspiracies?
do you donate to any charities? which? how much? what is guilt?
do you take any continuing education? describe.
do you subscribe to any magazines? newspapers?
do you have a passport?
have you used it? how?
do you believe in the devil?
who was francis marion?
social media sites?
dues to any organizations? which? how much?
college transcripts?
have you ever been in trouble?
how do you spell that?
paper matches case?
has the aclu ever claimed that h and h acted unethially?
do you subscribe to the hippocratic oath?
is there any code of ethics your department follows?
did you follow that code 100% in this case?
does a hospital corporation have any duty of care to its former patients?


did you ever think you'd gotten away with something, right up until the day you were asked about it under oath? what was that?
what is graft?
what is the difference between graft and a bribe?
if you had been offered a bribe in this case, you would have refused it, right?
do you think my interaction with you has been stressful? my blood pressure today was ___. that indicates hypertention.
are you aware of the histtory of this dispute?

ever belong to a union?
would you be willing to attend a training session held by the aclu?
what is your understanding of the allegations in the cross-complaint?
is there anything you need made more clear?
how does it make you feel, emotionally?
do you understand anything about how much pain and suffering you have been causing me?
coffee. could kill me. back injury. pain with every step, hard to get out of bed.
do you know of any crimes, which you have not previously reportee to police? no no bad question.
have you ever been the victim of a crime? discuss. have you ever, before this case, been the perpetrator of a crime?
have you ever abused a child? or a pet? or an old person? use the widest use of abused that you can think of.

have you read the declaration of independence? is there anything in there about searches or warrants?
how old were you the firs ttime you read the indiana constitution?
how recently have you read it?
are you tested on it as part of your training?
are there records or copies of such tests - request for documents.

what did they teach you about the 4th amendment?
ok how about the first?
second?
third?
7th?
8th?
9th?
10th?
how about the indiana bill of rights.
section 1.
section 9.
section 11.
section 12. ask her to read those out loud.







do you know anyone who voted for trump?
have you worked in the private sector?
if you decided to stop working for (organized crime), is the private sector job you could do, would like, would pay better, etc?
8    What is the jurisdiction of h and h? is its jurisdiction exclusive, or overlapping with other governmental units?
standard of review  proof?
of the 1000, how many have had or will have adminstrative hearings.
6.     do you understand true and false? equitable and inequitable?
clean v unclean hands? good and evil? right and wrong?
education?
have there been any prior cases where there were allegations of wrongful conduct by H and H?  if yes, list cases, cause numbers, any known citation or url.
have there been any disciplinary complaints against cross-defendant? we assume none.
has she ever, as an adult, been arrested?
where do you reside?
are you known by your neighbors?
do you have a reputation in your community for honesty, or dishonesty, r a bit of both?
who do you know who could testify? 3. how long have they known you? how could we contact them if we need to?
do you have any enemies?
are you as pure as the driven snow?
the supreme court recently said "tyranny and sin". would you recognize tyranny or sin if saw it?
do you see well? with your glasses on, what is your vision?
are you a sinner?
have you committed any crimes?
do you have a conscience?
have you ever been mentally evaluated? for example, can we rule out that you are a psychopath of some sort, or a sociopath?
why have you been trying to kill the defendant?
were you trained?
are you supervised?
are there a written policy book? can we get that into evidence?
what was your training? how long did it last, what was the formaat, who taught, was it standardized r custom?
how long on the us constitution or bill of rights?
how long on the indiana constitution?
excessive fines clause policy?
due process policy?
hearings?
did you engage in due diligence?
did you read the old case files?
did you understand mr stewart is someone who does not do agreed judgments,and sometimes files counterclaims?
how many such cases have you had?

do you stand by your refusal to reinspect, knowing that that's why we are here?

all you had to do was knock, and the door shall be opened unto you.

what was your training and policy toward the mentally ill?

are you, now, aware that your agency provided treatment to (me) for major depression, including counseling, zoloft,and zyprexa?

do you have a policy of "first, do no harm"?

what do you know about depression?
is it a serious, life-threatening illness?

do you happen to know the elements of battery under this state's criminal statutes? are you deemed to know the law?

when you came into my home and took pictures,   did you have an administrative warrant? what paperwork, if any, did you have with you?
was someone with you? if so who?




7.   
8.   
9.   
10.   

1.
2.   
3.   
4.   
5.   
6.   
7.   
8.   
9.   
10.