Supplemental Appendix — Cramer v. State Bar of Michigan

Supreme Court brief1984

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Text

Volume IL

NO,

IN THE SUPREME COURT OF THE UNITED STATES

OCTOBER TERM, 1983

VIRGINIA CRAMER,

Petitioner, Plaintiff and Appellant

STATE BAR OF MICHIGAN;

JOHN D. O'HAIR;

WILLIAM LEO CAHALAN;

RICHARD D. KUHN;

H, ROLLIN ALLEN, and All

Members of the State Bar

of Michigan similarly

situated,

Respondents, Defendants and Appellees

PETITION FOR A WRIT OF CERTIORARI

TO THE COURT OF APPEALS

SIXTH CIRCUIT - (No. 82-1855)

AND

DISTRICT COURT, ED MICHIGAN

SOUTHERN DIVISION - (No. 81-73926)

AND

REQUEST FOR JURY TRIAL, MONETARY DAMAGES,

INJUNCTIVE, AND DECLARATORY RELIEF

Virginia Cramer

Pro se Petitioner

27314 Clairview

Dearborn Heights,

Michigan 48127

February 1984 (313) #0797286

YoLume JE

TABLE OF CONTENTS

QUESTIONS PRESENTED FOR REVIEW

LIST OF RESPONDENTS, DEFENDANTS,

APPELLEES

OPINIONS BELOW

JURISDICTION

CONSTITUTIONAL AND STATUTORY

PROVISIONS INVOLVED

STATEMENT

REASONS FOR GRANTING THE FETITION

CONCLUSION

VOLUME II

EXHIBIT A Injunctive Order 1/5/73

EXHIBIT AA Remittitur of Discon-

tinuance 1/20/77

EXHIBIT AAA Docket Entries, State

Case No, 72-218-571-CZ

EXHIBIT AA-1 Ex Parte Motion

Filed 2/17/81

EXHIBIT AA-2 Ex Parte Order

Filed 2/17/81

EXHIBIT AA-3 Ex Parte Motion

Filed 3/13/81

EXHIBIT AA-4 Ex Parte Order 3/13/81

EXHIBIT AA-5 Ex parte Order 3/13/81

True Copy

page

1-20

20-21

EXHIBIT

AA-6

AA-7

Bel

B-2

Warrant 4/29/81

Order for Bond 6/5/81

Special and Limited

Appearance in pro per

Filed 7/13/81 - Notice,

Motion to Quash, Brief

Letter 2/24/76 to Judge

Kuhn and others

Letter 10/5/81 by

H. Rollin Allen

Proposed Judgment,

Not Signed

Affidavit of W.Neville

Filed 11/13/81

No. 81-73926

Docket Entries

Seaholm v Seaholm

Horn v Horn

Judge Kuhn

Ex Parte Order 4/4/75

Return

No filing date

Order for Bench Warrant

issued 4/9/75

Order for Cancellation

of Bench Warrant

Filed 5/19/81

Ex Parte Order

Filed 5/9/75

Return on Service If

Not Found 5/16/75

Order for Substituted

Service - filed 6/3/75

page

103

104

107

111

112

114

116

117

119

EXHIBIT B-10

EXHIBIT Bell

EXHIBIT BB

VOLUME III

TRANSCRIPT

Lili

Order for Bench Warrant

no filing date

Order for Cancellation

of Bench Warrant

Issued yy Aa

Filed 6/19/81

Letter to R. Hadley

3/13/81 from

H. Rollin Allen

Proceedings 1/25/82

U. S. District Court

No. 81-73926

page

125

127

128

129 -

190

EXHIBIT A = attached to and referred to in

Petitioner's "Complaint" -

See, Petitioner's Appendix.

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY

OF WAYNE

THE STATE BAR OF MICHIGAN Civil Action No.

A Public Body Corporate,

72-218-571-CZ

Plaintiff,

-VS-=

HAROLD GRAHAM, MICHAEL ISSUED

GORDON, VIRGINIA CRAMER, Jan. 5, 1973

Individually and d/b/a

Gordon-Graham & Cramer

Associates,

Defendants,

JUDGMENT FOR PLAINTIFF AND

INJUNCTIVE ORDER

At a session of said Court held in

the City-County Building, Detroit,

Michigan on JANUARY 5, 1973

PRESENT: HONORABLE JOHN D, O'HAIR

Circuit Court Judge

This matter having come on to be heard

upon the plaintiff's complaint for an Order

to Show Cause against the defendants requir-

ing them to Show Cause why they should not be

punished for their contemptuous conduct of

practicing law illegally and for temporary

restraining Order and permanent injunction

restraining and enjoining them from practic-

ing law, the defendants having filed answers

to the complaint and the Court having heard

the testimony and considered the evidence

presented in open Court, the Court having

heard the arguments of counsel and consid-

ered their respective briefs, and the Court

being fully advised in the premises:

NOW THEREFORE,

THE COURT DOES ADJUDGE that there are no

genuine issues of fact for adjudication in

‘these proceedings and final judgment in this

cause be and the same is hereby entered, as

follows;

IT IS HEREBY ADJUDGED that said defend-

ants, individually and d/b/a Gordon-Graham &

Cramer Associates be and they are hereby

permanently restrained and enjoined from the

unauthorized practice of law and more specific-

ally they are hereby permanently enjoined from:

(1) Holding themselves out to the public

as qualified to render advice and service to

persons interested in obtaining a divorce in

the courts of Michigan;

(2) Rendering counsel and service to per-

sons seeking to dissolve a marital relation-

ship by obtaining a judgment of divorce in

the courts of the State of Michigan; and,

(3) Furnishing or offering to furnish

kits, forms or documents with assistance in

their completion or execution, to persons

seeking to dissolve a marital relationship

by obtaining a judgment of divorce in the

courts of the State of Michigan.

IT IS FURTHER ADJUDGED that said indivi-

dual defendants shall immediately notify, in

writing, all customers, patrons or clients

of said individual defendants and of Gordon-

Graham & Cramer Associates, whose divorce

cases are still being processed, that further

action by said defendants has been permanent-

ly enjoined by the Wayne County Circuit Court;

IT IS FURTHER ADJUDGc.) that said defend-

ants, Harold Graham, Michael Gordon and

Virginia Cramer individually and d/b/a Gordon-

Graham & Cramer Associates shall for*t«awith

TT TT

refuna to the aforesaid customers, patrons or

clients, monies heretofore paid to individual

defendants and to Gordon-Graham & Cramer

Associates by their customers, patrons or

clients;

IT IS FURTHER ADJUDGED that the actions

of said defendants, Harold Graham, Michael

Gordon and Virginia Cramer individually and

d/b/a Gordon-Graham & Cramer Associates

constitute the unauthorized practice of law

in violation of the provisions of MCLA 600,

916 and said defendants are hereby adjudged

to be guilty of contempt of the Wayne County

‘Circuit Court.

IT IS FURTHER ADJUDGED that the Court

expressly reserves jurisdiction to perform

all acts leading towards or necessary for the

enforcement of this Judgment and Injunctive

Order and that the Court withholds imposition

of penalties for contempt of Court as found

herein, unless necessary to obtain defend-

ants' immediate, full and good faith compli-

ance with the provisions :.of this judgment.

Entered 1/5/73 /s/ JOHN D, O'HAIR

Circuit Court Judge

EXHIBIT AA

SESSION OF THE SUPREME COURT OF THE STATE OF

MICHIGAN, Held at the Supreme Court Room, in

the City of Lansing, on the 30th day of

December in the yéar of our Lord one thousand

nine hundred and seventy-six,

Present the

THE STATE BAR OF Honorable

MICHIGAN, THOMAS GILES

KAVANAGH, Chief

Plaintiff-appellee, Justice

G. MENNEN WILLIAMS

Vv 56413 CHARLES L. LEVIN

MARY S, COLEMAN

VIRGINIA CRAMER, JOHN W,. *ITZGERALD

Defendant-Appellant,. LAWRENCE B, LINDEMER

i a JAMES L, RYAN,

Associate Justices

This cause having been brought to this

Court by appeal from the decision of the Court

of Appeals and having been argued by counsel

and deliberation had thereon by the Court,

IT IS HEREBY ORDERED that the judgment of the

Court of Appeals is AFFIRMED IN PART and

REVERSED IN PART As follows:

The injunctive order of the Circuit Court

for the County of Wayne dated January 5, 1973

and the findings of contempt on April 23,1973

are AFFIRMED, The convictions of contempt of

December 19, 1973 and October 15, 1974 are

REVERSED,

STATE OF MICHIGAN - ss,

I, Harold Hoag, Clerk of the Supreme Court

of the State of Michigan, do hereby certify

that the foregoing is a true and correct copy

of an order entered in said court in said

cause; that I have compared the same with the

original, and that it is a true transcript

therefrom, and the whole of said original

order.

IN TESTIMONY WHEREOF, I have hereunto

set my hand and affixed the seal of said

Supreme court at Lansing, this 20th day of

January in the year of our Lord one thousand

nine hundred and seventy-seven.

/s/ Corbin R, Davis, Deputy Clerk.

Entered: Jan. 20, 1977

Filed: Jan. 20, 1977

.NOTE: See companion case, State Bar v. Cramer

399 Mich 116-161, holding only that,

"To the extent that the defendant (Cramer)

provides personal advice peculiar to the

dissolution of a specific marriage, sne is

engaged in the unauthorized practice of

law. (emphasis added)

EXHIBIT AAA

State Bar v Cramer - Wayne County Circuit

Court, Civil Action No, 72-218-571-CZ,

"Cramer" alone appealed,

Michigan Court of Appeals, Docket No,.'s

21921, 19075 and 16168 (effecting Wayne

County Circuit Court # 72-218-571-CZ (Judge

John D. O'Hair) transmitted to the Michigan

Supreme Court, June 5, 1975.

State case docket entries involved:

December 30, 1976, Docket No. 56413, State

Bar v Cramer, reported at: 399 Mich 116-161,

1-20-77 See companion case, State Bar v

Cramer, 399 Mich 116-161 and see Exhivit

AA Order and Remittitur of discontinu-

ance, Docket No, 56413. NOT REMANDED

to any other jurisdiction,

2-17-81 Exhibit AA-2, Ex parte motion for

order to show cause, initiated by State

Bar of Michigan and H. Rollin Allen, in

Wayne County Circuit Court, filed

2-19-81, No, 72-218-571-CZ,.

2-17-81 Exhibit AA-2, Ex parte order to

show cause, initiated by State Bar of

Michigan, issued by Judge O'Hair. Not

served upon "Cramer", # 72-218-571-CZ.

3-13-81 Exhibit AA-3, Ex parte motion for

order to show cause, initiated by State

Bar of Michigan and H. Rollin Allen, in

Wayne County Circuit Court, filed

3-13-81, No. 72-218-571-CZ.

3-13-81 Exhibit AA-4, Ex parte order to

show cause initiated by State Bar of

Michigan, issued by Judge William Leo

Cahalan for before Judge O'Hair, Wayne

County Circuit Court, #72-218-571-CZ.

4-29-81 Bench Warrant, Exhibit AA-6,

issued by Judge O'Hair, #72-218-571-CZ,

for "Cramer's" arrest for "failure to

voluntarily appear",

6-5-81 Exhibit AA-7, Order for Bond $1,000,

issued by Judge O'Hair, #72-218-571-CZ.

6-12-81 See APPENDIX T, Transcript of 6/5/81

and APPENDIX U,.Transcript of 6/12/81

Wayne County Circuit Court #72-218-571-CZ,

Judge O'Hair., "Cramer" arrested and

forcibly brought before Judge O'Hair for

"failure to voluntarily appear".

6-12-61 "Cramer" deposited $1,090. cash

with Wayne County Sheriff's Dept., for

her release pending date set by Judge

O'Hair as June 17, 1981.

6-12-81 "Cramer" not released after posting

$1,000. cash "bond", and instead jailed

in the Wayne County Jail to await the

arrival of the Oakland County Sheriff's

deputies who later transported "Cramer"

to the Oakland County Jail in Pontiac,

Michigan,

6-12-81 "Cramer" arrested and jailed on two

(2) bench warrants issued by Judge Kuhn

(Oakland County Circuit Court) divorce

cases #74-114-277-DO and #75-121-954-Do,

"Ww of

"Cramer" "failed to voluntarily appear”.

(See, docket entries of Seaholm v Seaholm

and Horn v Horn, Oakland County Circuit Court,

EXHIBIT B-2, infra, )

6-15-81 "Cramer" released by Oakland County

Sheriff's Dept. at rear of Oakland

County Jail, approximately 3 P.M.

"Bond" EXKIBIT

6-17-61 See conditions of

AA-7 and Transcript of June 12, 1981,

APPENDIX U for restitution of $1,000.

cash "bond" to "Cramer", No restitution

made,

7-13-81 Special and Limited Appearance In

Propria Persona, Notice of Hearing for

July 17, 1981, Motion, Brief in Support

of Motion to Quash Service and to Dismiss,

filed, ‘See, EXHIBIT B-l et seq,

7-17-81 Judge O'Hair refused to hear

"Cramer's" motion, and sent.her a letter

denying her motion,

8-11-81 $1,000.00 "cash bond" deposited by

"Cramer" on June 12, 1981, refunded to

"Cramer",

7¢

EXHIBIT AA@1

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY

OF WAYNE

THE STATE BAR OF MICHIGAN, Civil Action

A Public Body Corporate,

Plaintiff 72-218-571-CZ

-VS-

VIRGINIA CRAMER, FILED

Defendant, Feb.19,1981

~ j

(Ex Parte) MOTION FOR ENTRY OF AN ORDER TO

SHOW CAUSE

Now comes the State Bar of Michigan, a

Public Body Corporate, by H. Rollin Allen,

its Attorney, and files this Motion for the

Entry of an Order to Show Cause why Defend-

ant, Virginia Cramer, should not be held in

contempt, and says as follows:

1. A Judgment and Injunctive Order was

entered by this Honorable Court on the 5th

day of January, 1973, enjoining and restrain-

ing Defendant, Virginia Cramer, from the

further unauthorized practice of law,

2. Upon information and belief, Affiant

believes that Virginia Cramer has violated

the provisions of the Injunctive Order,

3. On fise with the Court, are trans-

cripts of proceedings in the circuit courts

of the State of Michigan which indicate that

the Defendant, Virginia Cramer is continuing

to render legal advice and continuing to be-

come involved in misconduct contrary to the

provisions of the Injunctive Order.

WHEREFORE, it is prayed that an Order to

Show Cause be entered directing Defendant

Virginia Cramer to appear and show cause why

sne should not be held in civil or criminal

contempt for violating the Injunctive Order

of this Court,

THE STATE BAR OF MICHIGAN, a

Public Body Corporate,

Plaintiff

By: /s/ H. Rollin Allen

(P-10113)

FILED: KIEFER, ALLEN AND CAVANAGH

2/19/81 Attorneys for Plaintiff

EXHIBIT AA-2

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY

C¥ WAYNE

THE STATE BAR OF MICHIGAN, Civil Action

A Public Body Corporate, '

Plaintiff, 72-218-571-CZ

-VSse

VIRGINIA CRAMER, ISSUED

Defendant. y Feb.17, 1981

(Ex Parte) ORDER TO SHOW CAUSE

At a session of said Court held in

—~the City-County Building in the

City of Detroit, Wayne Seger

Michigan, on FEBRUARY 17, 1961

PRESENT: HONORABLE JOHN D,. O'HAIR

Circuit Judge

Upon and reading and filing a Motion for

the Entry of an Order to Show Cause filed

herein,

IT IS ORDERED that VIRGINIA CRAMER

appear before this Court at 1413 City-County

Building, in the City of Detroit, County of

Wayne, State of Michigan on the 13th day of

March 198] at 2:00 O'clock in the afternoon,

and show cause why she should not be punish-

ed for contempt for violating the Judgment

and Injunctive Order heretofore entered in

this matter on January 5, 1973, and more

specifically: continuing to hold herself out

to the public as qualified to render advice

and service to persons interested in obtain- -

ing a divorce in the Courts of Michigan;

continuing to render counsel and service to

persons seeking to dissolve a marital rela-

tionship by obtaining a Judgment of Divorce

in the Courts of the State of Michigan; and

continuing to furnish kits, forms and docu-

ments with assistance in their completion

and execution to persons seeking to dissolve

a marital relationship by obtaining a Judg-

“ment of Divorce in the Courts of the State of

Michigan,

/s/ John D, O'Hair

Circuit Judge

Entered

2/17/81

EXHIBIT AA-3

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY

OF WAYNE

THE STATE BAR OF MICHIGAN, Civil Action

@ Public Body Corporate, ,

Plaintiff, 72-218-571-CZ

-VSe-

VIRGINIA CRAMER, FILED

Defendant,

/ Mar.13, 1981

(Ex Parte) MOTION FOR ENTRY OF AN

O1DER TO SHOW CAUSE

Now comes the State Bar of Michigan,

a Public Body Corporate, by H. Rollin Allen,

its Attorney, and files this Motion for the

Entry of an Order to Show Cause why Defend-

ant, Virginia Cramer, should not be held in

contempt, and says as follows:

1. A Judgment and Injunctive Order wes

entered by this Honorable Court on the 5th

day of January, 1973, enjoining and restrain-

ing Defendant, Virginia Cramer, from the

further unauthorized practice of law,

2. Upon information and belief, Affiant

believes that Virginia Cramer has violated

the provisions of the Injunctive Order,

53. On file withn the Court are transe-

cripts of proceedings in the Circuit Courts

of the State of Michigan which indicate that

the Defendant, Virginia Cramer, is continuing

to render legal advice and tontinuing to be-

come involved in misconduct contrary to the

provisions of the Injunctive Order,

4, An Order to Show Cause was entered on

February 17, 1981, directing Defendant to

appear on March 13, 1981, at 2:00 P.M. This

Order and the Motion were delivered to the

Wayne County Sheriff for service but service

was not effected. [etitioner requests that

another @rder to Show Cause be issued,

WHEREFORE, it is prayed that an Order to

Show Cause be entered directing Defendant,

Virginia Cramer, to appear and show cause why

she should not be held in contempt for violat-

ing the Injunctive Order of this Court,

THE STATE BAR OF MICHIGAN

Plaintiff,

By: /s/ H. ROLLIN ALLEN

(P-10113)

FILED:

3/13/81

EXHIBIT AA@-4

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY

OF WAYNE

THE STATE BAR OF MICHIGAN, Civil Action

A Public Body Corporate,

Plaintiff, 72-218-571-CZ

-Vs-

JOHN D. O'HAIR

VIRGINIA CRAMER, LED

Defendant,

/ Mar. 13, 1981

(Ex Parte) ORDER TO SHOW CAUSE

At a session of said Court held in

the City-County Building in the

City of Detroit, Wayne County,

Michigan on March 13, 1981

PRESENT: HONORABLE WILLIAM LEO CAHALAN

Circuit Judge

Upon the reading and filing a Motion for

the Entry of an Order to Show Cause filed

herein,

IT IS ORDERED that VIRGINIA CRAMER

arpear before this Court before Honorable

John D, O'Hair at 1821 City-County Building,

in the City of Detroit, County of Wayne,

State of Michigan, on the 24 day of April

1981, at 2:00 O'clock in the afternoon, and

show cause why she should not be punished

for contempt for violating the Judgment and

injunctive Order heretofore entered in this

matter on January 5, 1973, and more specific-

ally: continuing to hold herself out to the

public as qualified to render advice and

service to persons interested in obtaining

a divorce in the Courts of Michigan; continu-

ing to render counsel and service to persons

seeking to dissolve a marital relationship by

obtaining a Judgment of Divorce in the Courts

of the State of Michigan; and continuing to

furnish kits, forms and documents with

assistance in their completion and execution

to persons seeking to dissolve a marital

relationship by obtaining a Judgment of

Divorce in the Courts of the State of Michigan.

/s/ WILLIAM LEO CAHALAN

Circuit Judge

Entered

3/13/81

EXHIBIT AA-5

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY

OF WAYNE

THE STATE BAR OF MICHIGAN, Civil Action’

&@ Public Body Corporate,

- Plaintiff, 72 -218-571-CZ

-VS=

FILED

VIRGINIA CRAMER,

Defendant. Mar.13, 1981

nail

(Ex Parte) ORDER TO SHOW CAUSE

At a session of said Court held in

the City-County Building in the

City of Detroit, Wayne County,

Michigan on March. 13, 1981

PRESENT: HONORABLE JOHN D. O'HAIR

Circuit Judge

Upon the reading and filing a Motion for

the Entry of an Order to Show Cause filed

herein,

IT £S ORDERED that VIRGINIA CRAMER

appear before this Court, HON. JOHN D, O'HAIR

at 1821 Siey-County Building, in the City of

Detroit, County of Wayne, State of Michigan,

on the 24 day of April 1981, at 2:00 o'clock

in the afternoon, and show cause why she

should not be punished for contempt for violat-

ing the Judgment and Injunctive Order hereto-

fore entered in this metter on January 5,

1973, and more specifically: tontinuing to

hold herself out to the public as qualified

to render advice and service to persons

interested in obtaining a divorce in the

Courts of Michigan; continuing to render

counsel and service to persons seeking to

dissolve a marital relationship by obtaining

a Judgment of Divorce in the Courts of the

State of Michigan; and continuing to furnish

kits, forms and documents with assistance in

their completion and execution to persons

seeking to dissolve a marital relationship

by obtaining a Judgment of Divorce in the

Courts of the State of Michigan,

/stamped with rubber stamp/

JOHN D. O'HAIR, CIRUIT JUDGE

A TRUE COPY

JAMES R, KILLEEN, CLERK

By /s/ Richard G,. Horn

Deputy Clerk

Entered » 1 13, 1981

EXHIBIT AA-6

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY

OF WAYNE

STATE BAR OF MICHIGAN, CIVIL ACTION

a Public Body Corporate,

Plaintiff, 72-218-571-CZ

-VS=

VIRGINIA CRAMER, FILED

Defendant.

¥ APR.29, 1981

H. ROLLIN ALLEN ( P-10113)

KIEFER, ALLEN AND CAVANAGH

Attorney for Plaintiff

1565 City National Bank Bldg.

Detroit, Michigan 48226

(313) 361-8080

WARRANT

IN THE NAME OF THE PEOPLE OF THE STATE OF

MICHIGAN

TO THE SHERIFF OR DEPUTY SHERIFF OF THE

COUNTY OF WAYNE:

WE COMMAND you to arrest VIRGINIA CRAMER

and bring her forthwith personally before the

Wayne County Circuit Court, Honorable John D.

O'Hair, to answer to the Court for contempt

in not obeying an Order to Show Cause issued

out of this Court on the 13th day of March,

1981, and duly served upon her, commanding

her to appear on the 24th day of April, 1961

at the City of Detroit, Room 1821 City County

Building, and to testify and to give into

evidence in this cause to be tried between

the State Bar of Michigan, a Public Body

Corporate, Plaintiff, and Virginia Cramer,

Defendant, on the part of the State Bar of

Michigan.

YOU ARE FURTHER COMMANDED to detain

VIRGINIA CRAMER in your custody until she

shall be discharged by the Wayne County

Circuit Court.

/s/ dJonn D, O'Hair

CIRCUIT JUDGE

Dated: Detroit, Michigan

Apr 29 1981, at 12:05 P.M.

EXHIBIT AA-/

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY

OF WAYNE

STATE BAR OF MICHIGAN, CIVIL ACTION

a Public Body Corporate,

Plaintiff, 72-218-571-CZ

-VsS-

VIRGINIA CRAMER, FILED

Defendant.

/ dune 5, 1981

ORDER FOR BOND

At a-session of said Court held in the

City-County Building, City of Detroit,

County of Wayne, Michigan

on JUNE 5, 1981

PRESENT: JOHN D. O'HAIR

This matter having come on for hearing

before the Wayne County Circuit Court, Honor-

able John D, O'Hair, presiding, and the Court

being advised in the premises and an outstand-

ing warrant having issued against Virginia

Cramer to bring her forthwith before the Wayne

County Circuit Court,

NOW THEREFORE IT IS ORDERED that Virginia

Cramer be permitted to post a $1,000.00 bond

following her arrest and that said bond be

posted at the Wayne County Jail, 525 Clinton,

* . . . y nals 2 . . +

~~ a »} ; ’ ca - - _ - .

Cua OL 3 a”3 AStTs Sal @) on oe ©) CO TIC 1 ,LONe a UD mh ney

appearing in Court on tne first full day that

this Court is in session.

/s/ dohnn D. O'Hair

CIRCUIT COURT

EXHIBIT B-1l

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY

OF WAYNE

THE STATE BAR OF MICHIGAN, CIVIL ACTION

A Public Body Corporate, _

and Judge John D, O'*tair, 72-218-571-CZ

Judge William Leo Cahalan,

H. Rollin Allen, members of

the State Bar of Michigan, NO JURISDICTION

et al, IN WAYNE COUNTY

Plaintiffs, CIRCUIT COURT

VIRGINIA CRAMER (no case

pending in Wayne County

Circuit Court No. 72- 218- 571-CZ

without a remand by the Michigan FILED

Supreme Court) P 7/13/81

H, ROLLIN ALLEN (p-10113)

Attorney for Plaintiffs

VIRGINIA CRAMER, In Propria Persona

s5e- case pending (Wayne) No. 72-

18-571-CZ )

(continued next page)

SPECIAL AND LIMITED APPEARANCE

IN PROPRIA FERSONA

TO THE COURT CLERK:

PLEASE TAKE NOTICE that special and

limited appearance of Virginia Cramer, IN

PROPRIA PERSONA, is herewith filed in Civil

Action No, 72-218-571-CZ; that the Wayne

County Circuit Court lacks jurisdiction in

said action 72-218-571-CZ, lacks jurisdiction

of said person and/or property of Virginia

Cramer, In Propria Persona; that the said

Virginia Cramer is not a party to this sham |

proceedings initiated by the State Bar of

Michigan, H. Rollin Allen and Judge John D.

O'Hair; that the Wayne County Circuit Court

lacks jurisdiction of the subject-matter

where, after the decision and opinion by the

Michigan Supreme Court (Docket No. 56413),

reported at 399 Mich 116, without a remand

the lower court has no jurisdiction; that the

said Judge John D, O'Hair has robbed Virginia

Cramer of her personal property of One Thous-

and ($1,000.00) Dollard and which is not a

oond where the Wayne County Circuit Court has

no jurisdiction in Civil Action No, 72-2lt-

571-CZ 7

Short Jurat /s/ Virginia Cramer

Dated:

July 13, 1981 In Propria Persona

TO THE PLAINTIFFS:

PLEASE TAKE NOTICE that Virginia Cramer,

In Propria Persona, has filed the above

"SPECIAL AND LIMITED APPEARANCE" and that you

are required to furnish and/or provide the

said Virginia Cramer with a copy of any and/

or all papers occurring for whatever purpose

in this matter, Also, you are required to

notify the said Virginia Cramer, in advance,

of any and/or all ex parte communications

which have occurred, which may occur or which

will occur relative, remotely or otherwise,

the reasons and the results therefore, and

where the Judge involved, directly and/or

indirectly, is a member of the party-plaintiff

The State Bar of Michigan,

Dated: /s/ Virginia Cramer

July 13, 1981 In Pro Per

Retroactive to and

including Dec. 31, 1976

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY

OF WAYNE

THE STATE BAR OF MICHIGAN, CIVIL ACTION

A Public Body Corporate,

and Judge John D, O'Hair, 72- 218-571-0Z

Judge William Leo Cahalan,

H. Rollin Allen, Members of :

the State Bar of Michigan, NO JURISDIC-

et al, TION IN WAYNE

Plaintiffs COUNTY CIRCUIT

vs COURT

VIRGINIA CRAMER (no case

pending in Wayne County -

Cireuit Court No. 72-218-

571-CZ; without a remand

by the Michigan Supreme FILED

Court )

/ 7/13/81

NOTICE OF HEARING

TC THE ABOVE -NAMED PLAINTIFFS :

and Attorney for Plaintiffs, H. Rollin Allen,

(P-10113) 1565 City National Bank Bldg.

Detroit, Michigan 48226

PLEASE TAKE NOTICE that MOTION TO QUASH

SERVICE OF PROCESS will be heard by the

Honorable John D, O'Hair, Wayne County Circuit

Court, 18th floor, City-County Building,

Detroit, Michigan, on FRIDAY, July 17, 1981,

at the opening of Court, in the above-capticone

ed matter,

Dated: /s/ Virginia Cramer

July 13, 1981 In Propria Persona

Ye omy A! ; REeat i abe

dae 2 Seeds COLNV LU

Virginia Cramer, in propria persona,

having filed a special and limited appearance

in propria persona, moves the Court to quash

service of the process of "Order to Show

Cause" dated March 13, 1981, and to Order

restitution of One Thousand ($1,000.00) Dol-

lars cash to said Virginia Cramer, on the

grounds that said service of process was

invalid, and to dismiss the Amended Motion for

Entry of An Order to Show Cause, for the

following reasons;

le That the so-called "Judgment for

Plaintiff and Injunctive Order" entered on

January 5, 1973, is invalid since it orders

nothing; that the Court speaks only through

its written "Orders,"

2. That the Michigan Supreme Court deci-

sion and opinions of December 30, 1976, cap-

tioned State Bar of Michigan vs Cramer, re-

ported at 399 Mich 116, and also the "Order of

Remittitur" entered on January 20, 1977,

affirmed the "Judgment" of January 5, 1973,

and which said Judgment for Plaintiff and

Injunctive Order orders nothing,

3. That the Michigan Supreme Court did

not remand the matter to the trial court and

the Wayne County Circuit Court does not have

jurisdiction to take further proceedings,

4, That the "Order to Show Cause" entered

in the Wayne County Circuit Court on March 13,

1981, Civil Action No, 72-218-571-CZ, is

invalid and service of process is invalid

where without a remand by the Michigan Sup-

reme Court the lower court has no jurisdiction.

5. That the "Warrent" issued on April 29,

1981, and executed on June 12, 1981, arrest-

ing the said Virginia Cramer, is invalid for

the same reasons and grounds that the "Order

to Show Cause" issued on March 13, 1981, and

served upon Virginia Cramer is invalid where

the Wayne County Circuit Court has no juris-

diction, without a remand by the Michigan

Supreme Court.

6, That on said June 12, 1981, the said

Judge John D, O'Hair illegally and unlawfully,

in tie wbsence of jurisdiction withou’

remand by the Michigan Suprene Court, Ordered

that Virginia Cramer post a $1,000.00 cash

bond following said illegal and unlawful

arrest,

7. That the said Judge John D, O'Hair

flagrantly and maliciously robbed said

Virginia Cramer of said One Thousand ($1,000)

Dollars in cash, which is not a bond,

8, That the cash amount of $1,000, was

paid by Virginia Cramer for her immediate

release from the Wayne County Jail on the

condition that she appear in the Wayne County

Circuit Court on June 17, 1981, as stated by

Judge John D, O'Hair,

9. That said Virginia Cramer appeared in

propria persona in Judge John D, O'Hair's

courtroom on said June 17, 1981, at approxi-

mately 9:00 A.M. and, by fraud and deceit,

the date was changed to August 11, 1981, and

for the reason that H. Rollin Allen did not

have Subpeonas served, as misrepresented to

the said Virginia Cramer,

10. ‘That tne invalid "Order to Snow Cause"

served and the illegal arrest of Virginia

Cramer and robbing her of $1,000.00 are

despicable, contemptible, dirty tactics,

WHEREFORE Virginia Cramer in propria

persona prays that the Court grant her motion

by special and limited appearance, to quash

service of process of Order entered on March

13, 1981, and dismiss plaintiff's Amended

Motion for Order to Show Cause, and Order

restitution of One Thousand ($1,000.00)

Dollars,

Dated: /s/ Virginia Cramer

July 13, 1981 In Propria Persona

BRIEF IN SUPPORT OF MOTION

TO QUASH SERVICE AND TO DISMISS

A special and limited appearance of

Virginia Cramer, in propria persona, filed

herein is for the sole purpose of objecting

to the jurisdiction of the Wayne County Cir-

cuit Court,

The Michigan Supreme Court's decision

and opinions rendered on December 30, 1976,

reported at 399 Mich 116, did not remand the

matter to the lower court for further pro-

ceedings. Also, the order of remittitur

entered by the Michigan Supreme Court Clerk,

and/or as directed by that Court, did not

remand the case or any matter to the lower

court. If a case has not been remanded to

the trial court after a decision by the

Michigan Supreme Court, the trial court does

not have jurisdiction to take further proceed-

ings. Morris v Radley, (1943) 11 NW 2d 291,

306 Mich 689,

See copy of "remittitur" entered on

January 20, 1977, in this case (attached here-

to). Where the Michigan Supreme Court affirm-

ed the "Judgment" of the trial court, and

which said "Judgment and Injunctive Order"

orders nothing, and there was nothing to

re-instate the case in the lower court on

remand, therefore, there was no remand, The

Plaintiff-State Bar of Michigan did not re-

quest any "remand", Defendant-Cramer did not

request any "remand", Without a "remand" the

lower court has no jurisdiction, See 5B CJS

Appeal and Error, at 1958. The word "remitti-

tur" is used to denote the order issued by an

Appeliate court on the decision of Cause on

appeal, directing the action to be taken or

the disposition to be made of the cause by the

lower court, as stated in Appeal and Error,

5B CJS at 1958, * * * "and it is now of the

same nature as a discontinuance, and is gov-

erned by the same rules," (emphe.sis added)

The Wayne County Circuit Court was with-

out jurisdiction to enter "Order to Show Cause"

on February 19, 1981, and on March 13, 1961.

The "Judgment and Injunctive Order" of the

Wayne County Circuit Court, affirmed by the

Michigan Supreme Court, is invalid and orders

nothing. Therefore, there was nothing to

remand,

/s/ Virginie Cramer

July 13, 1981 In Propria Persona

BXHIDIT b -° Letter dated February 24, 1976

TO: Judge Richard D, Kuhn

Oakland County Circuit Court

1200 N, Telegraph Rd,

Pontiac, Michigan 48053

TO: Sheriff Johannes Spreen,

Oakland County Sheriff's Dept,

1201 N, Telegraph Rd,

Pontiac, Michigan 48053

TO: Prosecutor, Brooks Patterson

Oakland County

1200 N, Telegraph Rd,

Pontiac, Michigan 48053

In re: Invalid Bench Warrants signed by Judge

Richard D, Kuhn against Virginia

Cramer, Request to recall the same,

Dear Sirs:

This is a request that each of you take

the proper and immediate action to recall the

invalid bench warrants pending against Vir-

ginia Cramer, for the following reasons:

On/for about April 4, 1975, the above-named

Judge Richard D, Kuhn took illegal action

against this writer, Virginia Cramer. Shortly

thereafter, said Judge Kuhn illegally issued

two (2) bench warrants against the said Vir-

ginia Cramer, Said bench warrants are

invalid,

abecquentiy, the OAdkland County sheriff's

Uept. made three or four (perhaps more)

attempts to arrest and incarcerate the said

Virginia Cramer based upon the illegal action

and invalid and improper issuance of said

bench warrants on the part of Judge Richard

D. Kuhn.

Recently, I checked with the Oakland County

Sheriff's Dept. and I was given information

that said illegal and invalid bench warrants

against Virginia Cramer are still outstanding.

This is shocking, to say the least in view of

the grievances that were filed with the Michi-

gan Judicial Tenure Commission against Judge

Richard D. Kuhn, Judge Kuhn should have seen

fit to recall the said invalid bench warrants,

solely on the basis of propriety. Inasmuch as

he has not yet recalled the said invalid war-

rants, it is now necessary for me to draw

further attention to the illegal conduct of

said Judge Kuhn, to various and several other

persons, as shown in this letter. My concern

is also based upon the potential of being

101

wrongfully arrested, detained, or imprisoned

because of said invalid bench warrants illegal-

ly issued by said Judge Kuhn, If such unfor=

tunate incident should occur, I would have no

recourse except to institute a suit for false

arrest and/or false imprisonment. It would,

indeed, be unfortunate for others to become

victimized by the negligence and illegal

conduct of Judge Kuhn,

The law is very clear on this in Michigan,

In De Kuyper vs. De Kuyper, 113 NW 2d 604,

the Michigan Supreme YVourt held "a party

cannot be subjected to jurisdiction of a

court except by issuance (of summons) and

service of process," In that case, the courts

decision lent itself to the principle of the

law, and in the absence of an amended compl-

aint to allege facts relief upon to support

the relief sought against one not a party to

the suit, an ex parte order adding a party-

defendant in the said proceedings, did not

subject said 'party-defendant' to the court's

jurisdiction,

As to the invalid bench warrants by Judge

Kuhn against Virginia Cramer, the court

records will show conclusively that (1) no

party has amended any pleadings to add Vir-

ginia Cramer to any suit, (2) no party has

alleged a cause of action against Virginia

Cramer in Judge Kuhn's courtroom, (3) no

Summons was issued for service of process on

Virginia Cramer, and (4) therefore, Judge

Kuhn was without jurisdiction to sign said

bench warrants and that Virginia Cramer has

not voluntarily entered her appearance in any

case before Judge Kuhn.

Yours truly,

/s/ Virginia Cramer

CC: Chief Justice Thomas G, Kavanagh

Justice G. Mennen Williams

Justice Charles L, Levin

Justice Mary S. Coleman

Justice John W, Fitzgerald

Justice Lawrence B, Lindemer

Justice James L, Ryan

103

FAHIELTT C - Letter dated October 5, 1961

Virginia Cramer

27314 Clairview Drive

Dearborn Heights, Michigan 48127

Re: The State Bar of Michigan

Vinginie Cramer, et al

Dear Ms, Cramer:

Enclosed please find a proposed Judgment

which we intend to submit for entry by Judge

O'Hair, If the proposed Judgment enclosed

herewith is satisfactory, please approve for

entry by signing above your typewritten nam,

and return in the enclosed self-addressed,

stamped envelope. If I do not receive the

“proposed Judgment within seven (7) days from

your receipt of same, I will then assume you

do not approve the Judgment and I will bring

the matter for hearing before Judge O'Hair,

Respectfully yours,

KIEFER, ALLEN, CAVANAGH & TOOHEY

/s/ HH. Rollin Allen

EMHIBIT D - Proposed Jucgment submitted by

H. Rollin Allen - October 5, 1981

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY

OF WAYNE

THE STATE BAR OF MICHIGAN, HONORABLE

@ Public Body Corporate, JOHN D, O'HAIR

Plaintiff,

-VSs- No.

72-218-571-CZ

VIRGINIA CRAMER, et al,

Defendants.

JUDGMENT

At a session of said Court held in

the City-County Building in the

City of Detroit, Wayne County,

Michigan, on

PRESENT: HONORABLE

Circuit vudge

WHEREAS a Judgment and Injunctive Order

was entered by this Honorable Court on the 5th

day of January, 1973 enjoining and restraining

Defendant, Virginia Cramer, from the unauthor-

ized practice of law; and

WHEREAS, a Motion and Amended Motion for

Entry of an Order to Show Cause was filed, and

an Order to Show Cause was issued on the 13th

day of March, 1981, directing Defendant, Vir-

ginia Cramer, to appear and show cause why she

105

Should not be punished for contempt for viol-

ating the Judgment and Injunctive Order

entered January 5, 19733; and

Testimony was taken on Tuesday, August

11, 1981; and

The Court having had benefit of argument

by Defendant and the Attorney for the State

Bar of Michigan, Plaintiff,

NOW, THEREFORE, it is the finding of the

Court that the Defendant, Virginia Cramer

violated the Court's Order of January 5, 1973

as set forth in the Court's findings of that

date, and she is in contempt of Court therefor,

IT IS FURTHER ORDERED that Defendant may

purge herself of the contempt by total future

abstention from the unauthorized practice of

law, and more specifically from rendering

counsel and service to persons seeking to

dissolve a marital relationship in the Courts

in the State of Michigan, and from furnishing

forms with assistance as to their completion

to individuals seeking to obtain any éisselu-

tion of marital relationship in the Courts in

the State of Michigan,

106

Iv IS FURTHER ORDERED that Defendant

shall forthwith pay into the Wayne County Cir-

cuit Court the sum of Ninety Five Dollars

($95.00), which sum was charged William W,

Neville.

IT IS FURTHER ORDERED that the Clerk of

the Court shall forward Forty Five Dollars

($45.00) of that sum to William W. Neville at

5016 Orchard, Dearborn, Michigan,

IT IS FURTHER ORDERED that if, after

August 11, 1981, the Defendant engages in the

unauthorized practice of law in violation of

the January 5, 1973 Order and is so adjudice

ated by this Court, she will be required to

spend thirty (30) days in the Wayne County

Jail,

IT IS FURTHER ORDERED that such thirty (30)

days imprisonment will be imposed as a deterent

to the further unauthorized practice of: law

and not as punishment.

IT IS FURTHER ORDERED that if Defendant,

Virginia Cramer, does not pay the sum of

Ninety Five Dollars ($95.00) to the Wayne

County Clerk on or before August 16, 1981,

107

- a eee geet ae . S$4enq 4 nh a:

pefendant snall e COmMmMmLtTLTeGWd to tne wayne

County Jail.

NOT SIGNED

NOT ENTERED

NOT FILED Circuit Judge

EXHIBIT E - Filed November 13, 1981

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION-DETROIT

VIRGINIA CRAMER, Action No,

Petitioner-Plaintiff

Vs 81-73926

THE STATE BAR OF MICHIGAN;

JOHN D. O'HAIR; WILLIAM LEO Filed

CAHALAN; RICHARD D,. KUHN; 11-13-61

H. ROLLIN ALLEN; et al.

Respondents-Defendants,

State of Michigan

County of Wayne Ss.

AFFIDAVIT OF WILLIAM W, NEVILLE

WILLIAM HW, NEVILLE, being first duly

sworn, on this 13th day of November, 1981,

personally appeared before me a Notary Public,

who made oath that he has read this Affidavit

by him subscribed, knows the contents thereof

and that the same is true of his own personal

Knowledge except as to those matters stated to

108

be upon information and belief and as to those

matters he believes them to be true, as

follows:

1. That he is the William W, Neville who

was subpeonaed by H. Rollin Allen as the

attorney for the State Bar of Michigan for

proceedings held in the Wayne County Circuit

Court, State of Michigan, before the Honorable

John D, O'Hair on August 11, 1981.

2. That he appeared and gave testimony on

said date of August 11, 1981, in the said ae

ceedings before the said Honorable Jonn D,

O'Hair.

3. That he has read the transcript of the

proceedings of August 11, 1981, before the

Honorable John D,. O'Hair as appears to be sub-

mitted and filed in the United States District

Court Docket No, 81-73926 attached to the

pleadings of H. Rollin Allen under date of

October 30, 1981.

4, That pertinent herein is the Honorable

John D. O'Hair's statement on pages 7 and 8 of

the heréin aforementioned transcript of August

109

ll, 1961, as follows: (quotation)

"She is also to forthwith pay into the

Court, a sum of $95. That fee that she

charged Mr, Neville for rendering service,

immediately. The $45 will be immediately

forwarded to the clerk by Mr. Neville.

(sic, 777?) If Mrs, Cramer appears in —

court in the initiation of State Bar pro-

ceed s, it is established and the court

is satisfied that she has continued in

her unauthorized activity, she will spend

30 days in the Wayne County Jail. *

"She is on fair notice that she will spend

time in jail, 30 days specifically, if she

continues her activities, Thirty days of

imprisonment is simply imposed as a deter-

rent not as punishment. She has the

ability to stay out of jail if she wishes

to do so.

"Prepare a proposed order, Mr. Allen.

"If the $95 is not paid within the five

days as ordered, Mrs. Cramer is to ,be

committed to the - Wayne County Jail"

(Proceedings concluded,)"

5. That your affiant herein noticed that

the said herin described transcript of August

11, 1981, as submitted and attached to the

copies of pleadings by H. Rollin Allen, omits

the testimony of said William W, Neville,

affiant herein,

6. That your affiant did not request any

refund of any moneys as pertaining or relative

to or involving this matter; that he does not

110

want any repayment or refund or reimbursement

of any moneys pertaining or relative to or

involving this matter,

7. That your affiant did not authorize

anyone to request any refund to him of any

moneys involving this matter,

8. That your affiant believes that the

attorney-H. Rollin Allen has unduly imposed

upon and harassed your affiant; that your

affiant did not and has not engaged the

services of H, Rollin Allen; and further,

that no attorney, especially not H. Rollin

Allen, has been authorized to represent the

said William W, Neville, affiant herein.

/s/ WILLIAM W, NEVILLE, affiant

3045 Monroe

Dearborn, Michigan 48124

Short Jurat

Dated: November 13, 1981

111

EXHIBIT B-2

OAKLAND COUNTY CIRCUIT COURT - Judge Kuhn

Seaholm v Seaholm, No. 74.=114-277-D0

Docket Entries

8-5-74 Complaint for Divorce, filed.

Summons issued,

9-4-74 Defendant's (Terry Lee Seaholm)

Appearance signed, notarized, filed.

11-8-74 Default and Affidavit of Default,

filed. Proof of Service, filed.

2-17-75 Defendant-Terry Lee Seaholm's waiver

(military) signed, filed.

2-17-75 Plaintiff-Linda Carol Seaholm's

Praecipe, filed. Hearing date set

for March 26, 1975.

2-17-75 Notice of hearing to Defendant,

Proof of Service, filed.

3-26-75 Divorce granted, Default Judgment

of Divorce dated March 26, 1975,

Signed by Judge Richard D. Kuhn,

4-475 Ex Parte Order to Show Cause against

Virginia Cramer, issued, by Judge

Kuhn. (no affidavit, no complaint

no summons, no motion, no notice of

hearing) "Cramer" not served.

4.7-75 "Return" filed. (shows incorrect—-

address for "Cramer" and no named-

document as "served" on said "return")

49-75 Bench Warrant issued for "Cramer's"

arrest, by Judge Richard D, Kuhn, .

Writ # 75-604 for failure to appear,

4-10-75

Seven (7) government vehicles dis-

patched, with an abundant personnel

4-10-75

6-12-81

6-15-81

: (1. pTeon) &

112

(Oakland County Sheriff's deputies

and Dearborn Heights city police and

detectives) to execute said one (2)

bench warrant issued for "Cramer

Lien antezaae for Statewide pick-up,

on Bench Warrant for failure to ‘

; pppene as ordered by court;

sdemesnor Warrant for Failure to

Appear - re: Virginia Cramr,

"Cramer" arrested and jailed June 12,

13, 14 and 15, 1981. Oakland County

Jail.

"Cramer" forcibly brought into court-

room handcuffed, shackled and chained,

approx. 11A.M. before Judge Kuhn,

"Cramer" not examined by Judge Kuhn,

but, Cramer er reminded Judge Kuhn that

she "had written him a letter, dated

February 24, 1976.

"Cramer" taken back to Oakland County

Jail, and released approx. 3 P.M. at

rear of said jail.

Bench Warrant cancelled, entered

June 19, 1981.

- - - eo" - - - - - -

Horn v Hor ny, No. 75-121954-Do

Docket Entries ay

2-25-75

Compla int for a: Tate, filed.

Summons issued.

Defendant -Daniel Robert Horn served

reonaily ¥ Oakland County

heriff's Dept

Sheriff's return of service, filed,

3-26-75

4-30-75

5-8-75

5-16-75

7-24-75

6-12-81

6-15-81

11-23-77

6-15-81

113

Default and Affidavit of Default,

filed. Praecipe filed, Date set for

April 30, 1975.

Divorce granted, Default Judgment

of Divorce signed by Judge Kuhn, «

Ex Parte Order to Show Cause against

ginia Cramer, issued by Judge

Kuhn. (no affidavit, no complaint,

no summons, no motion, and "Cramer

not served}

Sheriff's return shows not personally

served upon Cramer,

Order for Substituted Service,

issued by Judge Kuhn, Substituted

service not completed. Mail not

delivered and returned to Oakland

County Clerk's office, undelivered.

Order for Bench Warrant issued for

failure to "Cramer" to appear on

May 2l, 1975 .

Lien entered, for Statewide pick-up.

Misdemeanor flarrant for Contempt of

Court, Bench Warrant/failed to

appear,

"Cramer" arrested and jailed on

June 12, 13, 14 and 15, 1981.

"Cramer" forcibly brought into Court-

room, chained, shackled and handcuffed

approx, 11 A.M. before Judge Kuhn.

Bench Warrant cancelled by Judge Kihn, —

ps # 75-1220, entered on June 19,

1981...

"Cramer" not examined by Judge Kuhn,

but Cramer reminded Judge Kuhn as to

her February 24, 1976 letter and

114

cited: DeKuyper v. DeKuyper, (Mich)

113 Nw e = no erTealet san

6-15-81 "Cramer" released at rear of said

Oakland County Jail, approx. 3 P.M.

eeanrereeeeeeeREHEEARHREHEHAeEHEHHAEH EA

EXHIBIT B-3

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY

OF OAKLAND

LINDA CAROL SEAHOLM, No. 74-114-277 DO

Plaintiff,

TERRY LEE SEAHOLM, FILED

Defendant.

_/ Apr. 4, 1975

(EX PARTE) ORDER TO SHOW CAUSE

At a session of said Court, held in

the Courthouse, City of Pontiac,

County of Oakland, State of Michigan,

on this 4th day of April, A.D. 1975

PRESENT: THE HONORABLE RICHARD D, KUHN,

Circuit Judge

Linda Carol Seaholm having appeared In

Propria Persona in the above entitled cause,

and it appearing from her testimony under oath

that Virginia M, Cramer has been engaged in

the unauthorized practice of law,

IT IS HEREBY ORDERED that Virginia M.

115

Cramer appear before this Court on Weinesday

April 9, 1975 at 2:30 in the afternoon, and

show cause, if any she have, why she should

not be punished for the contemptuous acts

more fully described as follows:

The selling of legal advice to Linda

Carol Seaholm in regard to the insti-

tution and prosecution of divorce pro-

ceedings against Terry Lee Seaholm,

Said advice was first sold between

July 27 and August 5, 1974, and contin=

ued on various subsequent occasions up

to February of 1975.

Said advice consisted of the explane-

tion of how to fill out forms, also

sold by Virginia M, Cramer, Said forms

constitute the majority, if not all, of

the pleadings filed in the above entitl-

ed cause,

Additionally, Virginia M, Cramer's fee

included advice on how to appear before

this Court, what to say, how to serve

papers, and where to file them.

iT IS FURTHER ORDERED that a true copy

of the Order to Show Cause be personally

served on Virginia M. Cramer on or before

April 5, 1975.

/s/ Richard D, Kuhn

Circuit Judge

EXHIBIT B-4

STATE OF MICHIGAN Civil Division

COUNTY OF OAKLAND No. 74-114277

I HEREBY CERTIFY AND RETURN, That on the 4th

day of April A.D. 1975 at 27314 Clearview,

Dearborn Hgts. in the State of Michigan, I

served the attached

personally on Virginia Cramer

named in said

by then and there, at the place and on

a true copy of said

Fees: - Service

Travel Sheriff

Copies

Total By /s/ Cpl. Velat

Deputy Sheriff

NO FILING DATE

NOTE: In the above, no document named; no

document served; wrong street name,

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR. THE COUNTY

OF OAKLAND

LINDA CAROL SEAHOLM, NO. 74-114277 DO

Plaintiff,

vs.

TERRY LEE SEAHOLM, ISSUED

Defendant. Apr 9, 1975

IN THE MATTER OF VIRGINIA M, CRAMER

ORDER FOR BENCH WARRANT

At a session of said court, held in

the Courthouse, City of Pontiac,

County of Oakland, State of Michigan,

on this 9th day of April A.D. 1975

PRESENT: THE HONORABLE RICHARD D, KUHN,

Circuit Judge

The Court having ordered on the 4th day

of April, A.D. 1975, that Virginia M, Cramer

appear before this Court on Wednesday, April

9, 1975 at 2:30 in the afternoon and show

cause, if any she have, why she should not be

punished for Contempt of Court;

The case having been called in open Court

and the said Virginia M. Cramer having failed

to appear as ordered;

The Court having noted that the Sheriff's

Return of service wis Gully filed s hie that

Virginia M, Cramer was served with the Urder

to Show Cause on the 4th day of April, A.D.

197535

IT IS HEREBY ORDERED that a Bench

Warrant be issued by the Clerk of the Court

commanding the arrest of the said Virginia M,

Cramer and commanding that she be brought be-

fore this Court for disposition according to

law.

/s/ Richard D, Kuhn,

Issued Circuit Judge

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY

OF OAKLAND

LINDA CAROL SEAHOLM, NO, 74-114277 DO

Plaintiff,

Vv WRIT # 75-604

TERRY LEE SEAHOLM, FILED

Defendant,

J Jun 19, 1981

IN JHE MATTER OF VIRGINIA M, CRAMER/

ORDER FOR CANCELLATION OF BENCH WARRANT

At a session of said Court held in

the Courthouse, in the City of Pontiac,

County of Oakland, State of Michigan,

on this 15th day of June A.D. 1981

PRESENT: THE HONORABLE RICHARD D, KUHN

CIRCUIT JUDGE

IT IS HEREBY ORDERED AND ADJUDGED that

the Bench Warrant for the arrest of Virginia

Carmer on April 9, 1975 be and the same is

hereby cancelled,

/s/ Richard D, Kuhn

Circuit Judge

Filed

June 19, 1981

. Tr ‘

WF Se PR Rap b-/

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY

OF OAKIAND

DEBRA KAY HORN, NO. 75=-121954 Do

Plaintiff,

DANIEL ROBERT HORN, FILED

Defendant,

_/ May 9, 1975

IN THE MATTER OF VIRGINIA CRAMER

(EX PARTE) ORDER TO SHOW CAUSE

At a session of said Court, held in the

Courthouse, City of Pontiac, County of

Oakland, State of Michigan, on this

Sth day of May, A.D. 1975

PRESENT: THE HONORABLE RICHARD D, KUHN,

Circuit Judge

Debra Kaye Horn having appeared in Propria

Persona in the above entitled cause, and it

appearing from her testimony given under oath

on April 30, 1975, that Virginia Cramer has

been engaged in the unauthorized practice of

law;

IT IS HEREBY ORDERED: that Virginia Cramer

appear before this Court on Wednesday, May 21,

1975 at 2:00 o'clock in the afternoon, and

Show cause, if any she have, why she should not

be punished for the contemptuous acts more

121

fully described as follows:

The selling of legal advice to Debra

KayeHorn in regard to the institution

and prosecution of divorce proceedings

in the Circuit Court for the County of

Oakland, against Daniel Robert Horn.

Said advice was sold over a period Senine

ning on or about February 21, 1975 and

continuing to on or about April 28, 1975.

The fee for said advice was $55.00, which

fee was paid on or about February 21, 1975.

Said advice consisted of the explanation

of what proceedings to go through to

obtain a judgment of divorce in the Circuit

Court for the County of Oakland,

Additionally, for the fee charged, Virginia

Cramer provided Debra Kaye Horn with a

typed paper constituting the "litany"

which Debra Kaye Horn should recite to

put in proofs for her case,

For the fee charged, Virginia Cramer also

prepared all pleadings in the above om

titled cause,

IT IS FURTHER ORDERED that a true copy of

this Order to Show Cause be personally served

on Virginie Cramer on or before May 17, 1975.

/s/ Richard D, Kuhn

Filed Circuit Judge

May 9, 1975

EXHIBIT B-8

RETURN ON SERVICE IF NOT FOUND

STATE OF MICHIGAN FILED

COUNTY OF OAKLAND Ss MAY 16, 1975

I do hereby certify and return that after

diligent search and inquiry I have been unable

to find the within named Defendant Virginia

Cramer will not answer door

in my bailiwick,

JOHANNES F, SPREEN, Sheriff

/s/ GUY E, KESSLER

Deputy Sheriff

Pontiac, Mich.

May 16, 1975

== - =? >

123

EXHIBIT Be9

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY

OF OAKIAND .

DEBRA KAY HORN, NO. 75121954 DO

Plaintiff,

Vv;

DANIEL ROBERT HORN, FILED

Defendant.

f June 3, 1975

IN THE MATTER OF VIRGINIA CRAMER

ORDER FOR SUBSTITUTED SERVICE

At a session of said Court, held in

the Courthouse, City of Pontiac,

County of Oakland, State of Michigan,

on this 16th day of May, A.D. 1975

PRESENT: THE HONORABLE RICHARD D, KUHN

Circuit Judge

The Court being advised that diligent

efforts to personally serve Virginia Cramer

with the Order to Show Cause filed May 9, 1975,

in this cause, have been in vain 4s appears

from the Sheriff's return;

IT IS HEREBY ORDERED that service of said

Order to Show Cause on Virginia Cramer may be

had by pos ting a true copy of it, together

with a true copy of this Order, on the front

door of her residence located at 27314 Clair~=

124

view, Learborn Heights, Michigan 48127; and

in addition by mailing of same to said resi-

dence by registered mail, return receipt

requested,

/s/ Richard D, Kuhn

Circuit Judge

Entered

May 16, 1975

Filed June 3, 1975

A copy of this order served

as directed on 5/16/75 at

6.55 FM attached to the

front door,

Sheriff's Complaint #75-8368

Served by Cpl John F, Taylor

C.C.S.D.

/s/ John F, Taylor

NOTE: There was no registered mail and/or

"return receipt" connected with the

above,

125

EXHIBIT Be-10

STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY

OF OAKLAND

DEBRA KAYE HORN, NO, 75-121954 DO

Plaintiff

DANIEL ROBERT HORN, FILED

Defendant, NO DATE

IN THE MATTER OF er aes CRAMER

ORDER FOR BENCH WARRANT

At @ session of said Court, held in

the Courthouse, in the City of Pontiac,

County of Oakland, State of Michigan,

on this 24th day of July, A.D. 1975

PRESENT: THE HONORABLE RICHARD D, KUHN

P Circuit Judge

The Court having ordered on the 8th day

of May, A.D. 1975, that Virginia Cramer appear

before this Court on Wednesday, May 21, 1975

at 2:00 o'clock in the afternoon and show

cause, if any she have, why whe should not be

punished for Contempt of Court;

The Court having Ordered Substituted

Service of the Order to Show Cause, due to the

inability to obtain personal service, as is

more fully shown by the file in this cause;

"ne file reflecting further that the

Order for Substituted Service was complied

with;

The case having been called in open Court

on the day and date set for hearing, and the

said Virginia Cramer having failed to appear;

IT IS HEREBY ORDERED that a Bench Warrant

be issued by the Clerk of the Court commanding

the arrest of the said Virginia Cramer and

commanding that she be brought before this

Court for disposition according to law,

/s/ Richard D, Kuhn

Circuit Judge

Date Filed: NONE

127

EXHIBiT Beli

STATE OF MICHIGAN

_ iN THE CIRCUIT COURT FOR THE COUNTY

; G@ OAKLAND ;

DEBRA KAYE HORN, NO, 75121954 DO

Plaintiff,

v WRIT # 75-1220

DANIEL ROBERT HORN,

Defendant, F ILED

f Jun 19, 1981

IN THE MATTER OF VIRGINIA CRAMER

ORDER FOR CANCELLATION OF BENCH WARRANT

At a session of said Court held in the

Courthouse, in the City of Pontiac,

County of Oakland, State of Michigan,

on this 23rd day of November, A.D. 1977

PRESENT: THE HONORABLE RICHARD D. KUHN

Circuit Judge

IT IS HEREBY ORDERED AND ADJUDGED that

the Bench Warrant issued for the arrest of

Virginia Cramer on July 24, 1975 be and the

same is hereby cancelled,

/s/ Richard D, Kuhn

Circuit Judge

Issued: November 23, 1977

Filed: June 19, 1981

KIEFER, ALLEN & CAVANAGH

Attorneys & Counsellors

1565 City National Bldg,

(Penobscot Building

Detroit 48226

March 13, 1981

CERTIFIED MAIL

RETURN RECEIPT REQUESTED

Ms. Rosetta Hadley

486 Ditmar

Pontiac, Michigan 48053

Dear Ms. Hadley:

Upon receipt of this letter, would you please

contact the undersigned concerning problems

connected with your Divorce Judgment?

Very truly yours,

KIEFER, ALLEN & CAVANAGH

HRA :md /s/ H. Rollin Allen

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This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.