Appendix — Loubser v. Thacker

No. 05-3058 11

tional violation by the court reporters, and | would affirm

the dismissal of the claims against them.

The allegations against the staff counsel for the Indi-

ana Judicial Qualifications Commission are wholly insuf-

ficient to state a constitutional claim. The amended com-

plaint alleges that the attorney, Meg Babcock, was “in-

formed ... by mail” that Thacker “used his knowledge from

outside of the court room to decide the division of assets in

the court room” and “turned a blind eye to it.” Loubser has

not alleged that Babcock personally participated in a

constitutional violation, nor has she alleged any proper

alternative basis for liability on the part of the attorney. See

Sanville v. McCaughtry, 266 F.3d 724, 740 (7th Cir. 2001);

Chavez v. Ill. State Police, 251 F.3d 612, 651 (7th Cir. 2001). I

would affirm the dismissal of the claim against Babcock.

Finally, the largest category of defendants consists of the

numerous private actors: Loubser’s ex-husband; the at-

torneys and the paralegal; the witnesses in the divorce

case; some of their friends and relatives. The allegations

about the conduct of these defendants comprise almost

the entire amended complaint. Section 1983 can reach

private citizens only where a plaintiff adequately alleges

that they conspired with a state actor to deprive that

plaintiff of a constitutional right. See Brokaw v. Mercer

County, 235 F.3d 1000, 1016 (7th Cir. 2000). Specifically, a

plaintiff must allege in her complaint that: “(1) a state

official and private individual(s) reached an understand-

ing to deprive the plaintiff or his constitutional rights,

and (2) those individual(s) were willful participants in

joint activity with the State or its agents.” Id. (internal

quotations and citation omitted). A generalized allegation of

conspiracy that fails to identify the timing, scope, and terms

of the agreement between the private person and one or

12 No. 05-3058

more state actors will not satisfy even the minimal require-

ments of notice pleading under FED. R. CIv. P. 8. See Ryan v.

Mary Immaculate Queen Ctr., 188 F.3d 857, 860 (7th Cir. 1999).

For all its length and meandering density, the amended

complaint contains only generalized allegations of con-

spiracy. Although Loubser has identified a basic time frame

and conspiratorial purpose, she has not alleged that each of

the private citizen defendants entered into an agreement

with one or more state actors to deprive her of her constitu-

tional rights, nor has she clearly alleged their individual

participation in joint activity with state agents. To be sure,

the amended complaint purports to describe some of the

activities of some of these defendants during the course of

the divorce case, but it does so mostly incoherently. The

more readily decipherable allegations do not assert the

existence of an agreement or understanding as between each

of the individual private citizen defendants and a state

actor. Instead, Loubser has pleaded a jumbled collection of

alleged misdeeds by some of the private citizen defendants

during the state court divorce proceedings, together with a

generalized allegation of conspiracy. This is insufficient to

state a § 1983 claim against the private citizen defendants.

As noted by the majority, the purpose of federal plead-

ing -requirements is to provide notice to the defendant

to facilitate the preparation of a response. But another

equally important purpose is “to allow the court to deter-

mine at the outset of the litigation, before costly discovery is

undertaken, whether the plaintiff has any tenable theory or

basis of suit, so that if he does not the case can be got rid of

immediately without clogging the court’s docket and

imposing needless expense on the defendant.” Ryan, 188

F.3d at 860. Loubser’s amended complaint does not ade-

quately allege a tenable basis for a § 1983 civil

No. 05-3058 13

rights conspiracy claim against the private citizen defen-

dants.” We should not put them to the needless expense

of continuing to defend against it, nor should we burden the

lower court by returning a meritless case to its docket. I

would affirm the judgment dismissing the case in its

entirety.

* Leave to replead is not warranted here. The amended com-

plaint is Loubser’s second try at pleading a civil rights conspiracy

by the defendants; she has not succeeded in filing a short, plain,

and actionable claim.

14 No. 05-3058

A true Copy:

Teste:

Clerk of the United States Court of

Appeals for the Seventh Circuit

USCA-02-C-0072—3-8-06

APPENDIX

Parties to the Court of Appeals Seventh Circuit

Alexander R. Pala; R. Dennis Hoover, William B. Weist:

Roth Jewelers, aka Roth Brothers; William Roth; Candace

A. Roth aka Candace Roth aka Candy Roth; Gregory

Roth aka Greg Roth; Rusty Roth; Kindra Roth; Jillian

Roth aka Jill Roth; David Diener; Diener Supply and

Hardware; Douglas Radersdorf; Radersdorf and

Associates, PC; Thomas Grzesik; Thomas Grzesik &

Associates Inc.; Lawrence Culp; Terry Smith; Sondra

Rumple; Courtney B Justice; Halsen Brothers Sheet Metal

Heating and Air Conditioning; Ronald N. Halsen aka Ron

Halsen, aka Ronnie Halsen; Michael Hamilton, aka Mike

Hamilton, Frederick Henney, MD; Indiana Abstract and

Title Co; Theresa Lepper; White County Title and

Abstract Company; Steven Fishel; Kathy Fishel; Justice

Law Office; Corina Montine; Meg Babcock; Kathy J.

l'reeman; Brendt Dechert; David W Stone IV; Charles

Traylor.

United States District Court Decision, dismissal of the

case

United States District Court

Northern District of Indiana

ANNARE L LOUBSER

Plaintiff

V. JUDGEMENT IN A CIVIL ACTION

Case No. 4: 04cv75

UNITED STATES OF AMERICA

ROBERT W. THACKER;

REX W. KEPNER; ALEXANDER R PALA

R. DENNIS HOOVER; WILLIAM B. WEIST;

ROTH JEWELERS, a/k/a Roth Brothers:

WILLIAM ROTH, CANDACE ROTH, a/k/a

15

C. Roth,a/k/a Candace Roth, a/k/a Candy Roth;

GREGORY ROTH, a/k/a Greg Roth; RUSTY ROTH

KINDRA ROTH; JILLIAN ROTH, a/k/a Jill Roth;

DAVID DIENER; DIENER SUPPLY & HARDWARE;

DOUG RADERSFORF; RADERSDORF &

ASSOCIATATES PC; THOMAS GREZIK; THOMAS

GRZESIK & ASSOCIATES INC; LAWRENCE CULP;

TERRY SMITH, Deputy Prosecutor; SONDRA

RUMPLE; COURTNEY B JUSTICE; HALSEN

BROTHERS SHEET METAL HEATING AIR

CONDITIONING; RONALD HALSEN, a/k/a Ron

Halsen, a/k/a Ronnie Halsen; MICHAEL HAMILTON,

a/k/a Mike Hamilton; FREDERICK HENNEY, MD;

INDIANA ABSTRACT & TITLE CO; THERESA

LEPPER; WHITE COUNTY TITLE & ABSTRACT

COMPANY; STEVEN FISHEL; KATHY

FISHEL; JUSTICE LAW OFFICE; CORINA MONTINE;

MEG BABCOCK; KATHY J FREEMAN; BRENDT

DECHERT; DAVID W STONE IV; CHARLES

TRAYLOR;

Defendants

{ | Jury Verdict. This action came before the court

for a trial by jury. The issues have been tried and the jury

has rendered its verdict.

[X] Decision by Court. This action came to trial ,

hearing or consideration before the Court. The Issue have

been tired, heard or considered and a decision hs been

rendered.

IT IS ORDERED AND ADJUDGED that Pursuant to

Rule 12 of the Federal Rules of Civil Procedure, all

claims against all the defendants are dismissed, and the

defendants’ motions to dismiss are GRANTED. The

plaintiff's motion to strike defendant’s motion to dismiss

is DENIED. The plaintiff's motion to dimiss as

defendant the United States of America is GRANTED.

The motions for sanctions are DENIED. This is to be

16

considered a final appealable judgment and this case

should now be considered closed.

Stephen R. Ludwig, Clerk

By_s/ Monica Clawson

Deputy Clerk

This document entered pursuant to Rules 79 (a) and 58

Of the Federal Rules of Civil Procedure on July 6, 2005.

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF INDIANA

SOUTH BEND DIVISION

ANNARE LOUBSER

Plaintiff,

v.

UNITED STATES OF

AMERICA, et al

)

)

)

)

) Case No. 4: 04cv0075AS

)

)

)

Defendants. )

)

MEMORANDUM, ORDER AND OPINION

The plaintiff, Annare Loubser, filed a complaint against

more than 40 defendants claiming that her constitutional

rights were violated by a dissolution of marriage action

involving her and her former husband Alexander R. Pala,

in White County Circuit Court Indiana. Magistrates

Judge Andrew P. Rodovich entered an order denying as

moot numerous motions filed by parties, including

various amendments and clarifications filed by the

plaintiff and multiple motions for a more definite

statement, motions to dismiss the complaint, and motions

17

to strike all of the allegations in the complaint filed by the

defendants. In that order magistrate Judge Rodovich

indicated that the plaintiffs’ complaint appeared to be a

collateral attack on the state court divorce proceeding.

Though he allowed the plaintiff to amend her complaint,

he warned her that she may be subject o sanctions if she

were to file a complaint that violates the so called Rooker

Feldman doctrine. Rooker v. Fidelity Trust Co., 263

U.S.413( 1923). The plaintiff subsequently filed and

amended complaint and the defendants have filed various

motions to dismiss and motions for sanctions. Those

motions are now before the Court.

Discussion

Ms. Loubser has sued almost every party even marginally

involved in her state court divorce proceeding including ,

among others, two trial judges, her former husband, her

attorneys, two court reporters, most witnesses and the

United States of America’. She claims that she was

deprived of equal protection of the laws, she was

deprived of substantive and procedural due process, state

judges conspired against her and refused to disqualify

themselves from her case, her first amendment rights

were violated, she was placed in a state of involuntary

servitude to her ex- spouse, she was discriminated against

based on her age and lack of disability, she was denied the

right to confront witnesses against her, she was denied the

right to compulsory process to secure the attendance of

witnesses, she was denied the right to assistance of

counsel, there were ex parte communications between a

judge and some of her ex- spouse’s witnesses, transcripts

was latered, there were derogatory remarks made about

her by a deputy prosecuting attorney, and that counsel to

the Indiana Judicial Qualifications Commission refused to

do anything about the alleged violations of her rights. Ms.

L.oubser appealed her state court case, and it was affirmed

by the Indiana Court of Appeals. 798 N. E. 2d 567( Ind.

Ct. App.2003) The Indiana Supreme Court Denied

certification.

This court will not attempt to recite all of the

18

plaintiff's factual allegations here, but it is clear upon

examination of those allegations that she is attempting to

undo the results of her state court divorce proceeding.

This attempt is futile in light of the familiar Rooker-

Fledman doctrine. That doctrine prohibits the federal

district courts from reviewing state court civil judgments,

including all claims that are intertwined with those

judgments, including all claims that are inextricably

intertwined with those judgments. District of Columbia

' Plaintiff subsequently filed a motion to dismiss the United States

as a defendant in this case( Docket No. 137). That motion is GRANTED.

Court of Appeals v. Feldman, 460 U.S. 462(1983);

Rooker v. Fidelity Trust Co.,263 U.S.413( 1923). In

Feldman, the Supreme Court held that all federal claims

which were “inextricably linked” with the state court

judgment were precluded from relitigation in Federal

Court. Feldman, 460 U. S. at 486. Furthermore, and

unsatisfied party may not seck reversal of state court

judgment simply by casting its complaint as a civil rights

action. Wright v. Thackett, 39 F. 3d 155, 158 ( 7 Cir.

1994). The merits of the estate court ruling are beyond

the jurisdiction of this court. /d. The nature of Ms.

Loubser’s allegations and the supporting materials

submitted by her clearly demonstrate that she is in no way

seeking a new, independent claim. Rather, she is

dissatisfied with the state court ruling and is attempting to

undermine the state court judgment.

Therefore, this court lacks subject matter jurisdiction over

this claim.

In addition to the Rooker-Feldman doctrine, the “

domestic relations exception” to federal jurisdiction also

bars Ms. Loubser’s claim. Ankenbrandt v. Richards, 504

U.S.689, 703 ( 1992). That exception prevents federal

courts from issuing decrees in domestic relations cases

such as divorce, child custody and alimony disputes. /d.

The plaintiff is asking this Court to review and overturn

the state court orders and to award damages for the

19

issuance of those orders, thereby effectively changing the

dissolution decree entered by the state court. This Court

lacks jurisdiction to do. In light of the foregoing, Ms.

Loubser’s claim must be dismissed pursuant to Rule 12 of

the Federal Ruled of Civil Procedure.

Finally, the Court at this time declines to impose

sanctions against Ms. Loubser. If she insists on

proceeding improperly in this matter, however, she wil]

be subject to sanctions. She must abide by the rules and

proper procedure of this Court.

Conclusion

Pursuant to Rule 12 of the Federal Rules of Civil

Procedure, all claims against all defendants are dismissed,

and the defendants’ motions to dismiss are GRANTED.

The plaintiff's motion to strike defendants’ motion to

dismissed is DENIED. The plaintiffs’ motion to dismiss

as defendant United States of America is GRANTED.

The motions for sanctions are DENIED. This is to be

considered a final appealable judgment and this case

should now be considered closed.

IT ISSO ORDERED.

Date: June 30, 2005 s/ ALLEN SHARP

ALLEN SHARP, JUDGE

UNITED STATES

DISTRICT COURT

20

P&S

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF INDIANA

HAMMOND DIVISION AT LAFAYETTE

ANNARE L. LOUBSER

Plaintiff,

)

)

)

)

)

v. ) CIVIL NO: 4: 04CVOO7SAS

)

UNITED STATES OF AMERICA etal }

)

)

Defendants,

AFFIDAVIT OF SELF-AUTHENTICATION

1. That at the time of the tial of this cause on a October 17, 2002 | wimessed

Judge Robert W. Thacker engaging in communications outside of his courtroom on the

third floor of the White County Court House in his judicial robe. | saw Judge Robert W.

Thacker shaking the hand of 2 witness, William Roth, for the petitioner, Alexander R.

Pala, and then hugging another witness, David Drener, for the petitioner Alexander R.

Pala

2. On October 17* , 2002 Sondra Rumple, the court reporter for Judge Robert W.

Thacker, in the courtroom, commented to Alexander R. Pale that her and her husband had

dinner with Joe and Nancy Pala, and that they haven't been out with them in a long time

unt this week, which happened to be the same week of the Pala marriage dissolution.

Joe Pala is the brother of Alexander R. Pala.

3. On October 18* , 2002, | observed Alexander R. Pala joking with Candace

BEST AVAILABLE COPY

Roth, walking around in the court room wile testimony was taking piace. Then, |

witnessed at the conclusion of the tial Alexander R. Pala joking with Judge Robert W.

Thacker saying “goodbye judgee wadgee, | wil! see you around town” before he left the

court room.

4.0 December 31, 2002 while at the Tippecanoe County Club, I witnessed Judge

Robert W. Thacker engaging in conversation with Alexander R. Pala’s personal Social

Secunty representative Candice Roth. Candice Roth has becn documented in this case as

Mr. Pala’s Social Security representative. I took pictures of Judge Robert W. Thacker

and Candace Roth to document the Judge showing impartiality to the pettvozer,

Alexander R. Pala in # public setting.

5. Jill Roth and Dana Thacker graduated in 2002. Jil] Roth ond Dana Thacker

also were the student editors of the yearbook thei senior year. Jill Roth ts the daughter of

Candice and William Roth. Candice Roth is AJ Pala’s close fend and Social Secunty

Representative. William Roth is also a close friend of Al Pala and was a witness on the

behalf of Al Pala. Dans Thacker is the daugiter of Judge Robert Thacker.

6. During the summer of June or July of 2004, | went to the White County

Court House to look for the Balvich divorce file. Annere Loubser had told me her

knowledge of the case and that it would be one to Jook into. The clerks, Paula Lance end

Mary Reid, at the White County Court House were able to direct me to the books on the

shelf to start looking through. | located the case umber in the book and asked one of the

clerks, Mary Reid, for the file. She coud not locate the file, but she called Judge

Thacker's court reporter, Sondra Rumple, end asked bes if she had amy knowledge of that

+

-

case and or file. We had to wait a few minutes for Sondra to call Mary Reid, the clerk

back. Mary then relayed the message to me, that Sondra had made 3 mental note of this

case aod that it had been transferred to Rensselear’s Court House. Mary wrote on 8

paper, “Transferred Whole File 12-1-86, Clerk of Jasper Circuit Court” and the phoae

number “219-866-4927”. | then called the Jasper Clerk’s and asked about the Balvich

file. The clerk said that she could not find the file and asked that I call back in s couple

of days, that it could be on microfiche. | waited couple of days and then called Jesper's

Clerk beck. The clerk then proceeded to tel] me that the case was over and that it had

been destroyed and was not on microfiche. She stated that there was not any record of the

case at the Jasper Court House. | told Agnare Loubser about my experience at the White

County Court House and what the Jasper Clerk had told me.

Further Affiant Sayeth Not

Affiant's Signature

Ptenssa *- Imer

Affiant’s Typed or Printed Name

2s

State of (NDtXNA )

)SS:

County of CLATIN )

Before Me Notary Public, in and for said County and State, personally appeared the

aforesigned, who acknowledged the execution of foregoing A ffadavit of Self-

Authentication, and who having first been duly swom, stated the representation therein

contained are true.

Witness my hand and Noterial Seal tis 4 __ day of DOCENP L204

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Abie Loubser

From: “Abie Loupse”

To: <justlow@age.com>

Sent: Tuesday, February 18, 2003 5:30 PM

"Subject: piigetp

able@mbury new 60.73

Sent: Monday, February 17, 2003 4.44 PM

Subject: reply

February 14, 2003

Via E-Mail

Ms. AnnasreL.Loubser = _

abie@mbury.new,co.za

RE: Pala Dissolution of Marnage

White Circuit Court =

Cause No. 91C01-0108-DR-147 : -

Deat Ms. Loubser:

The attached letter was sent thus aftemoon to Mr. Hoover. We will be lodging our

Appeal in the next week and of bankruptcy is indicated, we will proceed on that basis under

your instructions.

The issues you have brought up in your ¢-man! of February 12, 2003, are those

which Mr Sicne will want to direct his attentron on the ments of the Appeal.

| do not intend to file a Motion to Correct Errors because after full consideration |

believe Judge Thacker will not change his Order in our direction in any respect. Worse, if]

pout out to him his errors, he may correct his Order to elimmate those potential errors but

to polish his findmgs up to make them appeal-proof in the Court of Appeals. | believe it 1s

the better course to file a direct appeal to the Indiana Appellate Court and intend to do so

barnng your specific instructions to the contrary

It us umportant to remember finally, that all ervors can be raised for the first time in

- } appeal and is not necessary — in this case unadvisable | believe ~ to file a Motion to Correct

Errors.

| am glad the weather is fair and hope that you are enjoying your time in South

Afnca

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Cano Yours faithfully,

|

Courtney B Justice

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; 4 Lune OTS B60 D Fe Dew of hy tacwtesge and babe! 2b Pun Comect are compen: Or. erste — cide the

Sign © precores (ate! PUA Uarayar 4 Reved Gt af OROTRERCA Of AC OPED TE: has 39 LTONedge Yer bem 28 rage F? Sires No |

Here nite we | Pres ident

| U Annare Pal. ne

—_ -——-~----—, -—-- ————— -

Prope e's SSA > lm

———

‘ a

raid | gene J 4 . ae utero ||| MBB BI85

Preparers | Fevimnewimn 7 Rader stort Rocpetes 7 Sate E ee

Use Only | esererpc an, 303 North Main eet, P.O. Box 706

A woes veto Monticello, IN 47°50 _1.238-583-504)

Bow Peremast Betton Sri Mo ce cer the cepa ve eehucthons z4 (oP ts- 11208 :=

C C

UNITED STATESDISTRICT COURT

NOTHERN DISTRICT OF INDIANA

HAMMOND DIVISION AT LAFAYETTE

ANNARE L, LOUBSER

Plainoff,

)

)

)

)

v. ) CIVIL NO: 4: 04CV0075AS

)

UNITED STATES OF AMERICA, etal =)

)

)

Defendants,

AFFIDAVIT OF SELF-AUTHENTICATION

The undersigned, being first duly- sworn upon oath, now says:

1) On March 30, 2004 between 2:00 and 3:30 p.m., a meeting was held between

Annare Loubser, Attorney Charles Traylor and me regarding vanous financial

issues. Specifically discussed was the following:

a. Possibility of filing bankruptcy - determined not in Annare’s best interest

and more than likely she wouldn't be able to qualify even with the reduced

level of income that the business eaming.

b. The move to Indianapolis area and starting work at a different Physical

Therapist location

i Including the sale and its related ramifications of the Monticello

practice (i.e. how much could it se! for, what would she be able to

retain, how much goes to ex-husband).

i. Possibility of hiring 2 full-time Physical therapist to operate the

Monticello practice while Annare gets situated in Indianapolis

area.

The attiomey recommended that Annare siay in Monticello and continue to try and

grow that practice versus the above ideas of selling the practice and moving to

Indianapolis to start anew. The reason being, per the attorney, is that the court

would not look favorably upon Annare getting rid of her business operation to

Start afresh at a much reduced pay and income source. He indicated the courts

could possibly not alter the payments being required to go to Annare’s ex-

husband (j.c. payments would be calculated sti!! at the old level of income versus

new reduced level of income) and therefore leaving Annare with nothing to live

on.

2) In accordance with Annare's moving to suburbs of Indianapolis, her individual

tax return was mailed to the following address which was indicated to us as her

new location: 3 rey

CO er a

ee

Annare Loubser

14614 Bach Drive #533

Carmel, IN 46032-7068

Further A ffiant Sayeth Not.

“fier —

sat &. lon

Affiant’s Typed or Printed Name

sae of_Indiana. )

) SS:

County of Haus Von}

Before Me Notary Public, in and for said County and State, personally appeared the

aforesigned, who acknowledged the execution of foregoing Affidavit of Self-

Authentication, and who having first been duly swom, stated the representation therein

contained are truc

Witness my hand and Notarial Seal this is* dayof Dec. . 2004.

My Commussion Expires:

pl Sc ME

County of Residence:

Homi \torn

PETITIONER/RUSBAND’S WITNESS - DAVID DIENER (CROSS)

seen in that chair, but - okay.

THE COURT: It’s easier than him being over a ten foot

putt. That’s when he’s really uncomfortable.

WITNESS: Yeah, and particularly when the Judge says,

“We need this to tie.”

MR. HOOVER: I have no more questions. Thank you, Mr.

| Diener.

THE COURT: Mr. Justice, cross examine.

MR.. JUSTICE: Just a couple of short questions, Judge.

THE COURT: Okay.

\ CROSS EXAMINATION

BY MR. JUSTICE:

}Q Uh, you testified you knew the parties. You knew Annare

and you knew Al?

a Correct

@ Both good people?

& Correct.

Q Hard working?

A Yes.

Q Intelligent?

| A Yes.

Q Truthful?

A To the best of my knowledge, yes Sir.

Q Goes for both of them?

A That‘s correct.

Q And what - you described Al as a hard worker when he was

$2

46

R. Dennis Hoover

Attorney

128 South Main Svreet Maiino Address

Mondcallo, indiana P.O. Bax 926

Ta (219) 583-0784 Monticalio, IN 47960-0626

Fax (775) 206-6848 E-Mal_rohoovenf@tawyer.com_

July 10, 2002 BY FAX

Brent R. Dechert, Esq. Re: Pala Dissolution

Dechert Law Office : White Gircuis Court

217 N. Main St. - P.O. Box 667 Cause No. 91 001-0108-DR-147

Kokomo, Indiana 46903-0667

Tel 765-459-0764

Fax 765-452-3673

Deer Mr. Dechert:

Subject to SSA approval (if necessary), this ts my proposal concerning handling of the SSA records:

1. Al will sppoint Candice Roth as his SSA representanve.

2. Mrs. Roth (and 1) will make arrangements and an appowiment for her © go to the SSA office and copy

the files.

3. We will notify you at least 7 days in advance of the date and time of the eppoiniment.

4. Mrs. Pala’s representative will meet Mrs. Roth at the SSA office (10 S. 2™ St, Lafayene) at the

appointed (ime.

5. Mrs. Roth and Mrs. Pala’s representative will:

a Copy the entire SSA file

b. Place the file in one of more cavclopes, and seal and mitie) item,

C. {Candice Will) uaiisport the enveiopéd directly wo a copying service (preferably Copicrs Plus in

Moniicello), where Mrs. Pala's representative may moet ber;

_ 6. Have two (2) copies of the file made by the copying service;

¢. Fach pay half (4) of the copying cost; and

{. Pach sign sn original and two (2) copies of s swatement previously approved by you and me to the

effect chat “this is a true and complete copy of Al's SSA file.*

6. Mis. Pala’s representative will retain (for delivery to you) one of the capies of the file and statement.

. Mrs. Roth will retain (for delivery to me) the onginal 20d the other copy

8. You and | will prepare and submit 2 stipulation that the file is a joint exhiba, is auchenuc. ts mawnal

to the issues in the case, and is admissibic.

~

Please advise whether this is acceptabie.

Kundest regards

Sincerely.

« = ‘

‘ew

R. Dennrs weer |] LL,

Enc es indwakd if ED)

“ Mc Pale { er

Mrs. Roth Jui 28 ce

33 js a & ct 2 ;

t CLLEA Wil CRS CouRT

itl,

(15)

f ey

Date |} Description Rate | Time | Amoant }

ie |

0624 | Review letter from Dar)! Carson, Peoples S&L Study rea! estate and loan 180 430 C4500

Cocuments and notes. Make entries inio chronology. Telephone conference

with and fax to Theresa Lepper. Fonish-fax-mari addiucnal imterrogatonies

Phone conference wh chent Re-fax 3d party ciscovery reques's to opposing

counsel

Se}

9625 | Receiwe/study 21-page fax from Prudential re icsurance values. Phone 130; 200 309.60

conference and office conference with client. Skim new documents

presented bv chent. Client will obtain info from Diener, has been promised

appraisals by Cindy Duff, ts obtaming closing statements from White Co

Abstract. Copies of recent pleadings to client. Deliver subpoena e:¢. to

accoumant Raderstorf

0626 | (After Spm} Receipt-study of LF Amy Dechert with copies of discovery 190; 120] 18000

| requests (29 cages). Prepare-faa letter to Atty Dechert: copy for client

0526; Work 07 organizing exhirits 40 030 2.00

0627 | Tsiephone conferences with accountant Raderstorf. Prepare letter to 10 2.30 3450

Redersior! Telephone conference with accountant Debson. Lette: oy fax to

Dobson

(627 | Re-do Table of Contents for Discovery. Mzke copies of new documents 40 110 43.00

provided by <!ient (abel copies. Scan portions of new documents.

9628 | Office cowference with Larry Culp Prepare outiines re 2882 Baers Court 150 2.10 31500

0629 | Rev-review papers from Monts Banking Center 1% 6.20 3000

lead Naa nA ct

COOL | Prepare setup fur client's responses to Respondent's Motron to Produce tees 1.00

G7Ol | Prepare cheat’s cespanses to Respordent’s interrogaiones. Telephone 130 710 1065 50

sontcrence with Any Dechert, scheduled depasiuons Phone conference

with cheat Conference wth chent af his home

—y

O70) | Further conference wita chent zt his home D} 9.70 ow

—_+—— —+ ——

0702 | Otfice conierence wrh Cicot Review loner from Dechert to Lavin. Fax to "Sd 2.20 330.00

q Laver,

0703 | Lener to oppesing counset wth cory of filed agreement Fax from Atty 150 060 9 OC

= | Dechert with W's 3" set of intertags 2nd requests for production '

0708 | Prepare copies of (2) appraisals Work on marshaling data for sending 40 3.80 152.00

discover; and for presentation of evidence

L708 | Teieprone conference with Raderstorf. Office con‘erence with Larry Culp, 180 0.50 78.00

retumed zppraisals, says his 2nd apprarsal and Cindy Duffs did rot include |

all prope-ty i

= seme T

(709 | Telephone cor ‘ererce with Mes C Roth Prepare SSA representative form 1} 0.40 60 00 l

LL for C. Roth. | +

i = |

S¥

~

Ney,

Date | Description Rate {| Time | Amonst

0710 | Werk on stipulation ideas for SSA records Attempted cails to SSA. Lenerto | 150 §% 1305.00

SSA. Receive-review W's 3% set of interrogs and requests for production,

mecical releases. (Hard copy.) Letcer to opposing counse! Dechen.

Prepare- fax-mail netice of dep. Arrange court reporter Fax notice of dep to

coun reporter (M. Jones). Phone ard office conferences with staff az

| Raderstorf office Office conference with Client and Roger Harmon; review

| things to do including bank statements-checks project, .nterropetories,

physician wisit, SSA records. Work on answers to W's 2rd set of interrogs

O711 | Receive-ceview W's notices of Ceposition Pick up data from Acct 180 3 80 570.00

Raderstor!. Fax to Raderstorf Begm work on ‘indings of fact and

conclusions of law

—= —_

0712 | Lemerto SSA Telephone conference with Chent. Office conference wth C. | 150 2.80 420.00

Ruth Office conference with Cheri, Roger Harmon. Telephone conference

with opposing counsel Dechert. Telephone conference with Radesstorf, Rev

datz from Radersterf.

ES

0715 i neiel chent’s answers to 2nc set of interrogs Conference with Larry Culp. | 150 3.00 450.00

Return 4/26/02 appratsais to L. Lavin. Prepare memos for mal testunony.

File organization. Telephone conference with Del Principe

717 } Telephone message from Atty Dechert. Telephcne conference with Maryann | 150 1.30 195.00

| Fleruung, dectires to exarune client Telephone coniereyee with

} SSA-Lafayene; will order file from Kansas, here in 2 wecks, will call when

a’s ready, copy of decision may be af OLA-Indy Te‘ephone conference with

OH A-Inds, ‘hey purge records every 2 years. Letter from Atty Dechert with

Orford Bark cocerés. Do reply fax to Atty Dechert re deposiisons.

O718 | Prepare copies of arpraisals. Organization of new exhibits 25 120 30.00

ita yn sista Sencaes (eeer nate)

O78 | Phone conference and office conference with L Lavin, receive and discuss 150 { 090 135 00

New eppransa! Rece:we new bill Telephone conference with oppasing }

counse! Dechert, agreement to Jo ATs cep frst m exchange tor receiving |

computer disks 2530 | }

— 4 —_— -—-—— - - . 4

: rant

C719 | Office conference with Chent, Roger Hlaimon. Work on answers to W's Ord 130! 640 960.00 |

set of merrogs. t

) C719 } Addinonal uncharged work 0 300 ocr]

| 0720 | Cominue work on imterzog answers. Office conference with client 150 3.80 570.00

0720 | Type revisions to intertng answers frum client conference. Prepare final 25 110 2750

1

ee “ draft for clent signarure pies

0720 , Ademonal uncharged work 0 290 | 000

0721 | Prepare bulling staternent 6} 20] co

— 4p

O72) | LT Rehewe Therapy requesting paver: records, fax copy to of postng 180 0 80 | 120.00

| | course! Prepare revised nance of deposition, f2x'mail to opposing course! | }

} Review LF Chace re $50K martgree a |

5

-~

STATE OF INDIANA ) WHITE CIRCUIT COURT

COUNTY OF WHITE ) 2004 TERM

INRE: THEMARRIAGEOF )

ALEXANDER R. PALA, )

Petitioner )

ad )

)

ANNARE L. (PALA) LOUBSER )

Respondent =)

CAUSE NO.: 91001-0108-DR-147

|AYIT OF ANNARE L. LOUBSER

1. On October 17, 2002 first recess of above trial, on the third floor of White County Court house, outside

courtroom door, Defendant Robert W. Thacker was observed engaging in ex parfe communication with Wiltiam

Roth witness in oppesition , who was still swom in to testify after recess and husband of Candace Roth SS]

Representative of Alexander R. Pala. Defeodamt Robert W. Thacker was dressed in his black judicial cloak

2. Defendant Robert W. Thacker engaged in ex parte Commusications with witeess in apposttion, Devid Diener, a

recess at the above mentioned location in official dress, before he testified. On October | 7*, 2002

3. Sondra Rurople Court Reporter in cowrt room stated to Alexander Pala that her and her husband had dinner with

Nancy and Joe Pala, Alexander R Pala’s Brother and wife , just before trial. Sbe commented that they have not been

Ont for a long time till chis week of trial. October 17*, 2002

4. On October 1$* , 2002 Alexander R. Pala walked around in court room during plaintiff's professional witness

testimony on business valuc and engnged in taughter with Candace Roth. la court room Alexander engaged in

taughter with defendant Robert W. Thacker who was on the bench yet, #s he walked acrass the courtroom floor

saying” goodbye judgee wudgee | will see you around town”

5. Plaintiff observed Candace Roth SS] representative and relative of Alexander R. Pals engaging m ex parte

communication with defendant Robert W. Thacker at the Tippecanoe Country Club on December 31" , 2002

Melissa Kilmer documented this ever with pictures she took Defendant Robert W. Thacker used his knowledge

ot plaintiff socializiog with friends he obtaised outside of courtroom oe this night, as fact for equal standard of living

determination” both parties continue to socialize with fnends”

Defendant Robert W. Thacker’s behavior in and out of cowtroom conveyed the impressioe of partiality ,of the

judge, to Alexander R. Pala, while “under color of law”.

| affirra under penalties of perjury that the above information is ve to the best of my knowledge and the

representations are true.

October 12, 2004 s

Corr. } LS Sa

PROPER ANNARE L. LOUBSER

years and can reasonably be expected to earn in that range during her working ife over

the nex! 20 years. The parties were married for approximately seven years, which was

a first mariage for each party. The parties have no children. The parties have no

dependent persons to support. The parties lived well during the marriage, enjoying

many vacalions, and spent a great deal of time together and with friends, especially on

the weekends. The parties enjoyed many summer and winter recreational activities.

The parties enjoyed a social life The parties enjoyed entertaining their friends and

being entertained. ‘The parties have many friends in the community. The Wifehasa - «

normal life expectancy of approximately 40 years. The Husband does not have a

normal life expeclancy due to dwarfism and the expected deterioration of his physical . .

health. Duzing the penod of separation trom August 6, 2001 to the date of the final

hearing on Cctober 18, 2002, the parties have had a difficu't time adjusting. The parties .

continue to be angry toward each other. Dunng this lengthy separation period of time,

the Husband was abie to continue to reside in the marital home, due to the terms of the

Provisional Crcer which required the Wife to pay from her eamings the nanny 4 F [i

household expenses including the mortgage, homeowner's insurance and real estate, wi

taxes, and to maintain the Husband's health insurance including dental, and his Ife _

pore TS

eat ta eget ht

- insurance. During that period of time, the Wile had sufficient earnings fo mainiain the ©

manila’ home for the Husband and a!so to provide a rented residence for herself During

that period of time, both parties continued to socialize with their frends. During that

pefiod of time, both parties aiso expended much time, effort, and expense in

aggressively pursuing the representation of thei interests in the dissolution. Based on

the foregoing factors, the Court determines thal is fair, just and reasonable that a

31

1?

es

STATE 0° INDIANA } WHITE CIRCUIT COURT

SS:

COUNTY OF WHITE ) 2004 TERM

INRE: THE MARRIAGE OF )}

ALEXANDER R. PALA, )

Petitioner )

and )

)

AXNARE L. (PALA) LOURSER ) CAUSE NO.: 91C01-0108-DR-147

Respondent =)

AFFIDAVIT OF MELISSA R. KILMER

Ib. That at the tine of the trial of this cause ona October 17, 2002 | witnessed Judge Robert W.

- Thacker engaging in communications outside of his courtroom on the third floor of the

‘White Cousty Court House ta his judicial robe. | saw Judge Robert W. Thacker shaking the band

of a witness, Wiltiam Roth. for the petitioner, Alexander R. Pala, and thea hugging another

witness, David Diener, for the petitioner Alexander R. Pala

2... On October 17 2001 Sondra Rumple, the court reporter for Judge Robert W. Thacker, in the

Courtroom, commented to Alexander R. Pala that her and her husband had dinner with Joe and «

Nancy Pala, and that they haven't been out with them in a long time until this week, which

* » happened to be the same week of the Pala marriage dissolution. Joe Pala is the brother of

Alexander R. Pala.

3. On October 18* , 2001. | observed Alexander R. Pala joking with Candace Roth, walking around

in the court room while testimony was taking place. Then, | witnessed at the conch:sion of the tial

Aleaandes R. Pals joking with Judge Robert W. Thacker saying “goodbye judgee wudgee, | will

see you around town” before he left the court room.

4 On December 3), 2002 while at the Tippecanoe County Club, | witnessed ludge Robert W.

Thacker engagms m conversation with Alexander R. Pala’s personal Socal Security representative

Candice Roth Candice Roth has been documented ia this case as Mr. Pala’s Social Security

representative, | took pictures of Judge Robert W. Thacker and Candace Roth to document the

Judge shownng impartiality 10 the petitioner, Alexander R. Pala wn a public settimg

| affirm ender penalties of perjury that the above information is true to the best of my knowledge and the

representations are true

October 12, 2004

Mshin Rely

Melissa R. Kidmer

3B

to the mamage. The parves lived at such residence unti the separation in August,

2001. Soon after the marnage, the Wite changed employment. She left White County

Memonal Hospital and became employed at the Kokomo Orthopedic C:tnic in 1995. in

1996, the Wile returned to Monticello to become employed at Twin Lakes Rehabilitation.

During the mamage, in 1999, the Wie started her own physical therapy business in

Monticello known as Relief Therapy Services, Inc. The business consists of a rented

office space with two denical staff, a physical therapy assistant, and the physical

therap st Wile. For tax purposes, the business operates on a fiscal year basis

beginning on August 1* For the tax year August 1, 2001 to July 31, 2002, the business

had net earnings of approx:mate!y $200,000.00. Dunng the tax year beginning August

1, 2652, *he Wife's bus.ness has contawed to perform wei financially, except there has

deen.sane business decrease due to a slowdown in the fecal economy wih afew -

indusinal lay-offs and closures which have resulled in a decrease of physical therapy

ielerais trough group health msurance providers. During the mariage, with ragara to

the parties’ residential teal estate, the parties made improvements and refinanced the

Husband's onginal residence resu ting im an increased value at the time of the fikng of

the disso'uison of $241,CO0 00 wath an increased morigage balance of $160,000.00. In

addition. during the marmage. the partes acquired an adjacent rental property in Apn .

1998 at a cos! of $78,500 00 with a morigage of approximately $50,000.00 The current

ait enlace nsec kt

month on the adjacent rental ;

™ mn AN D3 DE

«*

ed RS

A

1S

Courtney) B Jusce *

Sasancah M._ Halbbusnce **

Mart Brown (1% | -2002)

“de eter’ te the Ree of

ee te

“ale adel ee te af

om Se @ Cece

Ms. Annare L. Loubser

1415 Main Street

Monticello, Indiana 47960

Dear Ms. Loubser:

627 E Marker &

Lognasport_ IN 46947

Telephoac 574-722-2866

Toll Free” $77-447.4220

FAX: $94-722-3502

Come leg om

October 5, 2004

By Fax

574-583-995 |

At your request and for your immediate review, | am faxing the following:

|. Motion To Correct Exrors (T.R. 59). (Due October 15, 2004)

Ld

October | 5, 2004)

Motion For Leave To File !nteriocutory Appeal {Appellate Rule 14) (Due

3. Motion To Reconsider (T.R. 53.4) No deadline.

4. Motion For Entry finding No Just Reason For Delay and Entry of Judgment.

(Trial Rule $4(B) No deadline.

Each of the foregoing deals with the Order of September 15, 2004, and the

Court's determination that Mr. Pala receive $3,611.65 out of 2002 the tax refund.

You bave asked me to file a Motion To Correct Errors. I repeat in this letter

what I told you on at least two occasions since August 26°: | do not believe it is in

your best interest to challenge Judge Kepner’s Order on this issue. | know you feel

strongly that his decision on the tax refund was incorrect, and that a motion to

correct errors should be filed. 1 recommend against that action, however. because

of the positive results this Order represents overall, and because the Court is

unlikely to change its mind

Avera Locaors |

___ SIRE Mam $+ Deip, ON 40923 «Fol Free 77847-4033 + FAX. TOS. S64-148 j

ee

BEST AVAILABLE COPY

Respectfully submitted,

cee Bs

Annare |. Loubser Pro Se

1415 N Main Street

Monticello, IN 47960

5$74-583-9950

CERTIFICATE OF SERVICE

| hereby certify thaton _|O day of May, 2006 a true 2nd

complete copy of the foregoing was served upon each of

the following individuals by dépositing a copy of same to

each in the United States mail with sufficient first class

postage affixed thereto.

Robert W. Thacker

4543 E. Fairway Court

Monticello, IN, 47960

Rex W. Kepner

706 E. Fifth Street

Fowler, IN 47944

Steve Carter

Attorney Genera! of Indiana

Elizabeth Rogers

Deputy Attorney General

Office of the Attorney General -

Indiana Government Center South Fifth Floor

302 West Washington Street

Indianapolis , IN 46204-2770

; "age?

Cay