# Supplemental Appendix — Cramer v. State Bar of Michigan > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385011_1355%3A5 ## Record - **Collection:** Supreme Court brief - **Document type:** Supplemental Appendix - **Published:** January 1, 1984 - **Citation:** 466 U.S. 974 ## Text Volume IL NO, IN THE SUPREME COURT OF THE UNITED STATES OCTOBER TERM, 1983 VIRGINIA CRAMER, Petitioner, Plaintiff and Appellant vs 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 EXHIBIT EXHIBIT EXHIBIT EXHIBIT EXHIBIT EXHIBIT EXHIBIT EXHIBIT EXHIBIT EXHIBIT EXHIBIT EXHIBIT EXHIBIT 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 86 88 89 99 103 104 107 111 112 114 116 117 119 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 66 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 67 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 68 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 69 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 70 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 71 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) 72 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 73 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". 74 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. - 75 "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, 77 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 78 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 79 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 80 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, cl / 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 62 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 G4 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- 8& 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 86 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 ws 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 87 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. 86 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 VS 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 ) a (continued next page) 90 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 92 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, a affirmed the "Judgment" of January 5, 1973, gl 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, 96 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- 97 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 Qe 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 99 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 6-15-81 6-15-81 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. [ere ora © See See eee eee & - - - eo" - - - - - - Horn v Hor ny, No. 75-121954-Do Docket Entries ay 2-25-75 2-25-75 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 5-16-75 7-24-75 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, Vv 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, Vv 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 RR 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 Vs 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 en ~ nn 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 r 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 (THIS PAGE INTENTIONALLY LEFT BLANK) --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385011_1355%3A5. Public record. Not legal advice.