Petition for Writ of Certiorari — Douglas Lemon, Petitioner v. Illinois

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IN

ORIGINAL

THE

SUPREME COURT OF THE UNITED STATES

JUNE TERM, 2024

Douglas

FILED

JUN 17 im

Lemon

Petitioner,

-VsPeople Of State Of Illinois

Respondent,

PETITION FOR WRIT OF CERTIORARI

TO THE CHIEF JUSTICE OF THE UNITED STATES AND THE ASSOCIATE JUSTICE

OF THE SUPREME COURT OF THE UNITED STATES:

May It Please The Court;

Come's now, Petitioner Douglas Lemon,cpursuant to 28 U.S-C. section

i2S7(.3).trespectfully prays that a ' Writ Of Certiorari ' issue to review the'decision

of the appellate court of illinois- First Judicial District-

Douglas Lemon, ProlSe

In care of;

Douglas Lemon=N-12405

Vfestem Illinois Carr. Center

2500 Rt. 99 South

>ia310B3rHOi0doH3a|ffi[-l|t.sterling Illinois

RECEIVED

I JUL - 1 2024 |

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QBESTjE0SSOflPRESBNTBS&flEOK3 REVIEW

On august 29-2013, case No. 05-CR-28068, Petitioner fii&d a Pro'se Petition

stating several Constitutional Violations. Listed pages ( C1.334,336-444 ) petitioner states ;

(l),He was not given a fair

Fitness Evaluation Nor Hearing, Due Process Right, U.S. Con­

stitution, Amendment, 14th, ILL. Const. ( 1970 ) Art; 1 § 2; detailed in Issue #1,( CE.378-85 ).

(2),The People failed to

Disclose Evidence,

5th, and 14th, amendment of Illinois and fed­

eral constitution, duerprocess clause. ®§t^led>riatis5U!fei#2~,.a(i (3x38S?®l-n)r. 5th. Entail'd in Issue

(3),ills ^rial'Counselowas

ineffective

because of a

" Conflict Of Interest between [ petit-

(3>,ioner ] and his Defense Attorney ", USCA Constitutional amendment 6th. Detailed in Issue #3,

( Cl.391-94 ).

(4),His Counsel was

ineffective

for failing to impeach Destiny Johnson and Shirley Pearson,

violation of the Due process clause under the 14t]i, amendment of the united states

and

the 5th, amendment of the illinois constitution and the 6th, amendment of the illinois

constitution. Detailed in Issue #3, ( CE.391-402 ).

(5),He was

Actually innocent,

under both the federal and illinois constitution, u.s.const;

amend; 8, VI, XIV, ILL. const; art; 1 § 8. Detailed in Issue #4, ( CI.402-12 );

(65),Trial counsel was ineffective for failing to call Alibi Witness and Eye-Witness'es, Die process clause is

the 5th, and 14th, amendment to the U.S. constitution. Detailed in Issue #5a, ( CE.-412-23 ).

(7),petitioner was

Insane

at the time of the misconstrued allegation made and at his

Fit­

ness Evaluation Hearing, the 5th, amendment of the illinois and united states constitu­

tion. Detailed in Issue #1, and #6a, ( CE.423-30 ).

(8),That the

Offense Of Predatory Criminal Sexual Assault

was invalid, the 5th, and 14th,

amendment of the united states constitution, retailed in Issue #7, ( d.439-43 ).

(9),That the Petitioner

Due process Rights

was violated. Due Process clause is the 5th

and 14th., amendment to the U.S. constitution, retailed in issue #8, ( ci.439-43 ).

(10),Post-Conviction Counsel Ms.Elizabeth Ribbeck, prove Ineffective for not shaping petitioners ocmplaint into ' Appropriate Legal Ftrm ', and causing an ' Extrane And tragic ' lcrg delay error, the 6th,

ansnchent of the illinois constitution, retailed in Issue #9, ( St.Br.41,citing C,148 ), ( CP.Br.22-21 ),and

( St.Br.35 ) .

2.

LIST OF PARTIES

1.) The accused defendant Douglas Lemon.

2.) An defenseneye-witness,' Johnny Lemon.

3.) An defense eye-witness/ Joseph Wilkins<

4.) An defense eye-witness, Lady Candy.

5.) An defense occurance witness, Calvin Lemon.

6.) An defense occurance witness, Decorion Jackson.

7.)

8.)

9.)

An defense occurance witness, Janel Gi Gi Atkins.

An defense occurance witness, Arzefeterv Davis.

An defense occurance witness, Marchella Winters.

-10.) An gfeate witness allege victim,Destiny Johnson.

11.) An defense occurance witness,Delores Johnson.

12.) An state witness, Shirley Pearson.

13.) An state witness, Willie Dennis.

14.) An neutral witness, Doctor Steve Ross.

15.) An neutral witness, Nurse Sarah Applehoff Conroy.

16.) An neutral witness, Forensic psychiatrist Dr.Andrew-Segovia-Kulik.

17.) An neutral witness, Forensic psychiatrist AndMDihecteoS,MBrkMathews S.Markos.

18.) An neurral witness, C<fciai6ai Psychiatrist Dr.Sharon L.Coleman.

19.) An neutral witness, D-N-A Forensic Technician.

20.) An neutral witness, Chicago P7D. Officer Robert Rentner.

21.) An neutral witness, Chicagb P.D. Detective Jose Cardo.

22.) An neutral witness, Chicago P.D. Detictive Traeynfanning.

23.) An States Attorney, Ms.Amado-Chevlin, And Kimberly M.Foxx.

24.) An States Attorney, Mr.Dombrowski.

25.) An States Attorney * Daniel Piwowarczyk.

26.) An states Attorney, Enrique Abraham.

27.) An States Attorney, Gina Savini.

28.) An Public Defender, Ms.Sophia Atcherson, And James E.Chadd, Appellate Defender.

29.) An public Defender, Ms.Spivy, And Mr.Douglas R.hoff, Deputy Defender.

30.) An Public Defender, Ms.McCarthy, And Ms.Elizabeth Ribbeck, Post-Conviction P.D.

31.) An Appellate Defender Supervisor, Ms.Carolyn R.Klarquist.

3.

TABLE OF CONTENTS

OPINIONS BELOW

JURISDICTION..

CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED

STATEMENT OF FACTS

REASON FOR GRANTING WRIT

CONCLUSION

INDEX TO APPENDICES

APPENDIX A

Petition submitted timely and in good faith...

I was informed of a limit of 40 pages required of this Writ Of

Certiorari Petition, but i was'nt able to obtain whether or not

is exhibits included with the 40 pages limit, court document's,

transcript's, affidavit's, etc; or due to this information of

document(s) already attached to my submitted Post-Conviction

Petition, filed in the clerks record, that the clerk will re­

quest the clerk of the court having possession of the record

to clerify and transmit it to the clerk of the Writ Of Certio­

rari??

APPENDIX B

People V.Lemon 130415 dated; 1-25-2024, is

in re;

attached, Petition for Leave to Appeal document.

APPENDIX C

People State of Illinois V.Douglas Lemon,

In re;

Leave to appeal, Appellate Court, First District. 130415.DDytED.

DENIED date; 3-27-2024, document is attached.

APPENDIX D

See;

Petitioners

4.

Comment.

TABLE

OF

AUTHORITIES

CASES

# Drope V-Missouri, 420 U.S. 162-171-72 ( 1975 ). fg.#9.

# Brady V-Maryland, 373 U.S. 83, 835, CT, 1194, 10 Led.2d 21, s ( 1963 ),

Pg.#9. #10.

#-Strickland V-Washinqton, 466, U.S. 668, 104 S.CT. 2052, 80 Led 2d 674 ( 1984 ). Pg.#9.#12.

# Flaugher, 174 act 598,. pg.#10.

# Jencks V-U.S., 353 U.S. 657, 77 S.CT. 100, 74, 1 Led 2d 1103, ohio L-abs. 465 ( 1957 )JF&#10.

# People V-Gibson, 244 Ill. App- 3d 700. Pg.#10.

# People V-Washington, 665 N-E. 2d 1330. Pg.#10 / 11.

# People V-Carpenter, 13 ILL. 2d 470, 150 N.E. 2d 100 ( 1958 ). Pg.#12.

# Johnson V-Edqar, 680 N.E. 1372 of P-A- 89-428. Pg.#12.

# People V-Moore. 279 III. App- 2d 152, 160 ( 5th Dist. 1996 ).Pg.#13.

# People V-Turner, 187 Ill. 2d 406, 410 ( 1999 ). Pg,#13.

# Jams A.Evans V-Wills Anthony, 21-1704, dicided April 27-2023. Pg.#13.

# Mucie V-Missouri State Dept. Of Corr., 543 F.3d 633, 636 ( 8th, Cir. 1967 )- Pg.#13.

JLt o

# Beople V-Lemon, 2012 IL App. ( 1st ) 102932-U. r & *7r-‘

*

CONSTITUTIONAL

PROVISIONS

United States Constitution.

STATUTES

Amendment V, VI, XIV.

28 U.S.C. 1257 (3)

28 U.S.C. 2101 (c)

28 U.S.C. 2255

720

ILCS 5.0 / 12-14-A-l, Count # 1.

720

ILCS 5.0 / 12-14-A-l. Count # 2.

720

ILCS 5.0 / 12-14-A-4. Count #3.

720 ILCS 5.0 / 10-2-A-3.

Count # 4.

720 ILCS 5.0 / 12-13-A-l. Count # 5.

5.

.

IN

THE

SUPREME COURT OF THE UNITED STATES

PETITION FOR WRIT OF CERTIORARI

Petitioner respectfully prays that a writ of certiorari issue to review the judgment

below.

OPINIONS BELOW

( unpublished order Pursuant To The Illinois Supreme Court Rule 23 )

1.) Arrest Date; 11-15-2005.

2.) indictment Date; 12-9-2005.

3.) Bench Trial Guilty Verdict Date; 8-10-2010.

4.) Sentenced And Notice Of Appeal Date; 9-21-2010.

5.) Conviction Affirm Date; 4-29-2012.

6.) Direct Appeal filed 6a£i;-25i29-2012.

7.) Filed ( PLA ) Petition For Leave To Appeal To The Illinois Supreme Court Date; - ;

8-28-2012.

8.) The Illinois Supreme Court Denied ( PLA ) Review Date; 11-28-2012.

9.) Mandate Of The Appellate Court Date; 1-9-2013.

10.) Did Not File The United States Supreme Court Writ Of certiorari Petition Due Date;

2-28-2013.

11.) Petition For Post-Conviction petition Filed Date; 8-28-2013.

12.) petition For Post-Conviction Petition Relief Written order Summarily Dismissed Date;

. 11-19-2013.

13.) Theccircuit Courtj.App9intssS&afee©AppellMe=De£enderrofr.Appeal.!Date,24742014414.) On-Date;; (5-30p2016:,oBetAtioner’.s:;Case WasoBlaieeebBacfc On,.Trial. CalTcop i^eafeider'Rulinglihng.

15.) petition ..fot ^ost-cohvi;ctieril,pet'i;ti'ohfeseeohd®S€agebDismi-s4edFDafce;r'6s94g022v': V-'-Fc.ii’-g.l-if.-UcTM: 5

16.) Fiiedd( ( PEA A ) 'Pe.t;itibmogoroEeavevToTAppealspost'5Genvlet£bheThi£aistageiDate';.el42542024.iyi,

■,v:"

• .

6.

17.) Denied ( PLA’ )' Petition For Leave To Appeal Post-Conviction Petition Third Stage

Date; 3-27-2024.

6.

JURISDICTION

Douglas Lemon, petitioner-appellant, appeals /

files a writ of certiorari from the third-stage dismissal of

his post-conviction petition on March 27-2024, ( 130415 ).

The judgment being appealed was entered on June 1-2024. Writ

of certiorari was timely filed on June 1-2024. Jurisdiction

therefore lies in this Court pursuant to Article VI, Section

6, of the Illinois Constitution, and $fais Courtis jurisdiction

is invoked under 28 U.S.C. Section 1257(3).

7.

I

STATEMENT

OF

FACTS

Douglas Lemon was convicted after a bench trial of five counts of

aggravated criminal sexual assault and one count of aggravated kidnaping.

(C- 292-293)He was sentenced to consecutive terms of eight ypaEsraniprisonon

for each count for a total of 40 years imprisonment. (C.292-293). craidirect

appeal, this Court rejected Lemon's claim that the evidence against him

was insufficient where the complainant's testimony was contrary, incon­

sistent, and improbable and affirmed his convictions and sentences.

People V-Lemon, 2012 IL App (1st) 102932-U- He now appeals the thirdstage dismissal of his post-conviction petition "s^h®^h&®rga^lj£ahpaiat

that trial counsel was ineffective for failing to call two exculpatory

eyewitnesses, who would have impeached the complainant's testimony

that Lemon sexually assaulted her.

8.

REASON

FOR

GRANTING

WRIT

Issue #1, and lA,

The Fitness Hearing Examination, ( EEE14-36 ), see also Exhibit #1,

Petitioner exhibit's #3, 5, and 6, would also asked the court to review the Conflict of

Interest between [ petitioner ] and his original trial Judge Tomothy J.Joyce, was invol­

ved in a Physical Altercation in court room 500, on 3-6-2009, during an Mental Illness

Fitness hearing for the defendant petitioner. U.S. Const; Amend; XIV; ILL. Const.( 1970 )

Art. 1, § 2; issue #lA, This Petitioner ves on Psychotrophic drugs during fitness hearing and trial.

The defendant was unfit to stand trial and his rights to due process was violated under

the 14th, amendment of the united states and the illinois constitution art. 1, §

2/ •

Drope V- Missouri, 420 U.S. 162, 171-72 ( 1975 ).

Issue #2,

The duty to Disclose Evidence to defense is upon the prosecution to come forword with

the information even though it has not been requested. TtejppasecutichidisclosuKecfeiluce in

violation of the defendants rights to due process under the 5th and 14th amendment of

illinois and federal constitution and a violation of the discovery rules and the dic­

tates of Brady V- Maryland, 373 U.S. 83, 835, CT. 1194, 10 Led.2d 21, S ( 1963 ).

( AAAA114 ) See; Exhibit's #7, 8, and 9, of 9A.

Issue #3, 3A, and 3B,

Ineffective Assistance Of Trial court Attorney and thee 6th, amendment right to the

Effective Assistance of counsel; which his defense counsel performance fell below an

objective standard of reasonablenesssand that this substandard performance prejudice

ed the defendant by creating a reasonable probability that, but for counsels arrors,

the trial results would have been different. See U.S.C.A, constitutional amendment

6th and Strickland V- Washington, 466, U.S. 668, 104 S.CT. 2052, 80 Led 2d 674 (119

84 ). That defendants trial attorney Ms.Sophia Atcherson, had ano serious Conflict

Of interest between them during pre Trial Prosedures what caused me the defendant to

file numerous ARDC complaints against his trial attorney and at the time of the trial

existed an irreconcilable conflict between the defendant and his attorney. Imthis case

the defendant consistently reminded the court and the proper disciplinary authorities

that he could not have had conflict free representation with his trial attorney and had

her disnissed from his case on 2, occassions, but vras reinstated over defendant objection, see Ex­

hibit #20, sent to trial court Judge, and also see Exhibit #10.

9.

Issue #3A/

The trial court Attorney Ineffective for failing to Impeach Destiny Jchnscn and Shirley Pearson.-

K

The defense attorney had subpoenaed Destiny Johnson Mom Delores Johnson to court to testify

to Destiny Johnson calling her mom phone from the defendant Douglas Lemon phone the night

of the alleged incident of the fact that Destiny had lied to her mom, that she was with

Shirley Pearson, when infact Shirley was there with delores at that time and numerous of

other obvious lies Destiny told, but this attorney fail to secure Delores appearance for

for trial and never perfected the impeachment of Destiny with all her lies.

By this attorney not impeaching Destiny Johnson, who was the states chief occurance wit­

ness and without her credibility being impeached, this Defendant had no chance of winning.,

This case was based on his credibility against Destiny and it was fatal to his defense

not to complete the impeachment. That trial court attorney ineffective, for not bringing

to the trial court attention Destiny Johgson prior bad acts; evidence of an arrest may be

used to show bias or motive Flaugher, 174 act 598, see; ( AAAA22-29-30-33 ), Exhibits # 7,8,9,

10,11, of 9A.

Issue #3b,

Defense Attorney failure to impeach Shirley pearson, both with her GrandJury testimony

and trial testimony which she did. This defense attorney never perfected the impeach­

ment of Shirley Pearson, with the Jencks material. This defense attorney allowed the

state to violate the rules of Discovery and the Rules of Jencks and rule supt.CT.R 412

(a) (i), Jencks V-U.S • / 353 u.S. 657, 77 S.CT. 100, 74, 1 Led 2d 1103, 75 Ohio L.abs.

465 ( 1957 ). it is axomatic and Due Process requires that the state discloserallabyidence that is relevant to an accused guilt or punishment, see; Brady V-Maryland, counsel

can provide ineffective assistance for failure to produce exculpatory evidence, People

V-Gibson, 244 Ill. App. 3d 700.

Issue #4,

Claim of 1 Actual Innocence;1 based on an important goal of the Criminal Justice Pro­

cess is the protection of the innocent accused against an erroneous conviction.

The hospital found that there was no evidence of the defendants DNA testing of Mentis

fied on the Oral Swab, which the defendant was infact convicted and sentenced for,( R.

BBBB61 ). This defendant is seeking DNA testing based on 725 ILCS 5 / 116-3 ( wast 1998 ),

A defendant may make a motion before the trial court that entered his case for the per­

formance of finger prints or and DNA testing of evidence that was secured in his trial

which resulted in his conviction. The Chicago police violated my due process right by not

finger printing the allege knife the defendant vas accused of using which was declared to be false, and

i request iry trial attorney several tines to have the knife finger printed for rry trial defense but she fail

to do so.

10.

This defendant requested that this court grant him a Genelex DNA drug sensitivity test­

ing that has the potential to prove. (1;)-'Actual innocence (2) that at the time of trial

he was unfit to stand trial, the result of the testing has the scientific potential to

produce new non-cumulative evidence materially relevant to the defendants actual inno­

cence. The defendant asserts that because of the side effects from used psychotrophic

Medication, he was mentally ill, and unfit to stand trial. That it was Destiny JChhson

who drugged this defendant with a drug thought was suspected ecstasy who was not re­

sponsible for his actions at the time of the allege case. That the following defense

witness'es; Johnny Lemon, Joseph Wilkins, Decorion Jackson, calvin Lemon, Marchella

Winters, Arzestery Davis, Candy, Delores Johnson and the defendant Douglas Lemon, all

would dia-metrically paint a contradictory story of what happen on 11-14-2005, cn into

11-15-2005, between the defendant and Destiny Johnson and does supportsthbsdefendantss

claim of actual innocence. That Destiny lied about being of legal age.

Witness Johnny Lemon, states that the knife he witnessed destiny used the night of 1115-2005, was infact his Jjohnny Lemon Martial Arts souvenir replicate knife. dhat:. Johnny

lemon, Joseph Wilkins and Candy all witnessed Destiny Johnson give;±he defendant a. white

powder drug substance put in his alcohol drink and witnessed Destiny voluntarily take

off both her and the defendants clothes to ignitiate a series£.of sexual acts while the

defendant was incoherently unconscious in and out of conscious would definitively con­

tradict Destiny Johnson in trial testimony and the state theory of the case.

The defendant contends that it is a violation of due process under the 14th amendment

of the united states and the 5th and 6th, amendments of the illinois constitution to

convict a person who is actually innocent see; People V-Washington, 665 N.E. 2d 1330.

Exhibits # 6,12,13,14,15,16,17, and 18.

issue #5a,

inneffective Assistance of Trial Counsel, for failure to call alibi witness'es to the

alleged sexual assault; in this case, this Petitioner contends that his trial attorney

was ineffective for failing to call Decorion Jackson ( an accurance witness ),Johnny>

Lemon (aan eye-witness ), Joseph Wilkins and Candy ( are eye-witness'ess), Arzestery

Davis ( an occurance witness ), Calvin Lemon ( an occurance witness ), these affiants

testimony could have established that it was Destiny Johnson and Shirley Pearson were

the antagonists in this encounter who prompted the entire incident to drug sedate and

sexually engaged in activity with the defendant that Destiny Johnson was the sexual

predator, and who robbed the defendant, who called her aoocrrplish boyfriend Willie Dennis for

advice vhai her Destiny clean get away exit was blocked by three ^e-witness'es Johnny Laicn, Joseph

Wilkins and Candy, why Willie Dennis told her to call CPD crying addamsel in distress.

Ineffective for failure t'o call Delores Johnson to testify that her dangh^ Destiny lied

about the case.

11 .

Defense counsels failure to present any of these witness'es testimony was arguably un­

reasonable for the same reason that it was prejudical because the alibi witness'es was

exculpatory for not giving the affiant an opportunity to testify is not sound strategy

and failure to present exculpatory evidence of which she is aware is ineffective assi­

stance of counsel, under both the federal and illinois constitution. U.S. Const;AAirend;

8, VI, XIV ILL. Const, art; 1 § 8; Strickland V-Washington, 466 U.S. 668, 104 S.CT.

2052, 80 Led 2d 679 ( 1989 ) see Exhibits # 12,13,14,15,16,17, and 18, combine connec­

tion with; Issue #3, 3a, and 3B.

Issue #6a,

Was This Defendant insane At The Time of The Accused Alleged Assault or At His Fitness

Hearing And During The Trial.

It is proper to have a mental examination of an accused who has put in thevissue ques­

tion of sanity; 725 ILCS 5 / 104-13; People V-Carpenter, 13 ILL.2d 470, 150 N.E.2d 100

( 1958 ). The defendant in support of his mental health an ingestion of prescribed psychotrophic medication and that the defendant has a long history of mental illness exacer­

bated by psychotrophic medication. This defendant has a question of sanity a few times,

at the time of the alleged accused assault incident when he may have been involuntarily

intoxicated by flestiny Johnson, and on 3-6-2009, the defendant experienced being beat-'down

and shackled by the court Judge Timothy J.Joyce and cook county sheriffs, during a mental

illness fitness hearing, and also unfit during trial, see; ( EEEl, to 65 ), and Exhibits

#1,2,3,4,10,11,12,13,14,15,16,17,18, and 19.

Issue #7,

Whether the offense of Predatory Criminal sexual assualt ia a valid offense and does this

offense violate the Single Subject Rule of the~state!j0crstitetKxua^ the >:^e‘'pr6eesscclaBseu3f «

the united states and illinois constitution. The defendant was convicted of izedatory crim^itinal sexual assault ofsacchild-in violation of 720 ILCS 5 / 12-14,1 (a) (1) 2005.

The offense of predatory criminal sexual assault was created by Public Act 89-428, and

became effective on 12-13-1995, and was held unconstitutional on 5-22-1997, in Johnson

V-Edgar, 680 N.E.1372, because the P.A. 89-428, was passed in violation of the single

sunject rule, this Public Act was held to be unconstitutional in its entirety.

The defendant Douglas Lemon, also would assert to this court that it is a violation of

the 5th, amendment of the illinois and united states constitution te be tried and con­

victed under an invalid indictment.

12.

Issue #8,

The States Attorney in the case at bar violated this defendant Douglas Lemon right to

due process under the united states and illinois constitution. It is fundamentally un­

fair to be charged, tried and convicted and imprisoned under a statute that never exist­

ed as a valid statute, and it is also a violation of an accused criminal defendant right

to due process as enunciated by the 5th,and 14th, amendment of the united states consti­

tution.

Issue #9,

Theres substantial showing of prejudice due to trial counsels failure to call Johnny

Lemon and Joseph Wilkins, where the " Evidence At Trial Was Overwhelming ", ( St.Br.35 ),

see; People V-Moore, 279 III. App. 2d 152, 160 ( 5th Dist. 1996 ) here it should con­

clude that Post-Conviction Counsel provided unreasonable assistance where she failed

to secure an up dated affidavit from Joseph Wilkins, stating that he was wBliingc 'testify

testify at trial ( OP. Br. 22-21 ). " It is evident that Post-Conviction Counsel vss

not the person who procured his affidavit." ( St. Br. 41, citing c. 148 ). This, of

course, makes clear that since counsel did not " procure " the original affidavit,

which had an obvious omission counsel had a duty to obtain a new affidavit attesting

to Wilkins willingness to testify at trial. Here it should hold that Post-Conviction

Counsel rendered unreasonable assistance by failing to seek an amendment to conclude

this requisite statement in accordance with supreme court rule 651 (c), Ill. Sup. Ct.

R. 651 (c); People V-Turner, 187 Ill. 2d 406, 410 ( 1999 ) ( Post-Conviction Counsel

Must Shape Petitioners Complaint Into " Appropriate Legal Form " ).

Furthermore, its an ' Extreme And Tragic ' long delay error, overall to adhere to

Eyans_V-Wills, ;(22023 ) United States Court Of Appeals, seven circuit. James A.Evans,

Petitioner-Appellant V-Wills Anthony, Respondent-Appelle No. 21-1704, decided April2742023. A long delay is unjustifiable, see; Mucie V-Missouri State Dept.Of Corr • / 543

F.2d 633, 636 ( 8th, Cir. 1967 ), ' Extreme And Tragic ' 10 F 4th at 716, at an ' Ele­

ven Year Wait ' and counting, is to be allowed to proceed straight to federal court

under § 2254. Id at 716, 723, for relief. Post-Conviction pledings substantially

showed Trial Counsel was ineffective, as so was Post-Conviction Counsel as well.

The 6th, amendment of the illinois constitution.

13.

CONCLUSION

Wherefore, for the foregoing reason Douglas Lemon,

petitioner respectfully requests that a Writ Of Certiorari to

be granted.

Respectfully Submitted

) son\ffy

/ S 1

Subscribed And Sworn To Before Me

This

n

Notary

Day Of hut. 20 M

Public

14.

SCOTT GREGORY

OFFICIAL SEAL

PETITIONERS

COMMENT

The Writ Of certiorari Petition/ is subject to periodically

change the many technical rule's, that it makes my mental health disorder and

my dyslexia condition spin with a migraine. As much as i want to prove that im

wrongly convicted, im not at all qualified to address merits of the law as an

certified attorney.

I tried hard to apply the rule's every; petition of the way

from the trial vertict on up to this point for relief but the tferial Judge 1

refuse to go against her ruling.

This Writ of Certiorari Petition, is the most hardest, dif­

ficult, complicated of all Petition's. I pray that this court review my case.