Wednesday, December 31, 2014

BACK TO THE BUSINESS AT HAND. CORRUPT MEDINA COUNTY PROSECUTOR DINO HOEMAN CAUGHT LYIN' & DENYIN' IN SPITE OF THE EVIDENCE!

Having taken a time-out to at this blog celebrate the Christmas holiday with LAPDOG "PUBLIUS" COLLIER and HIS MAIN SQUEEZE, DONNA "HAVE IT YOUR WAY" GARRITY, it is now time to return to the business at hand.

Shown below is the ninth installment of the MOTION TO DISMISS WITH PREJUDICE ON THE GROUNDS OF PROSECUTORIAL AND JUDICIAL BAD FAITH AND MISCONDUCT, which LAPDOG "PUBLIUS" COLLIER and the Republicrats at the Medina County Courthouse, Mosque & Railroad Station do not want you, the citizens, to see.  You can cross-reference any exhibits to the List of Exhibits by "CLICKING" on the link shown directly below "PAGES" at the upper right-hand corner of the web page:

Not surprisingly, CORRUPT MEDINA COUNTY PROSECUTOR DINO HOEMAN and his surrogates at the Cuyahoga County Prosecutor's Office are continuing in their futile attempts to shield LAPDOG COLLIER, their puppet in the truest sense of the word, from the consequences of his MISCONDUCT AND UNLAWFUL CONDUCT.

The text below demonstrates the manner in which CORRUPT MEDINA COUNTY PROSECUTOR DINO HOEMAN has been caught lyin' & denyin'  attempting to conceal the unlawful conduct of LAPDOG COLLIER and "HAVE IT YOUR WAY" GARRITY.



Mr. Hartman has extensively briefed the issue of the materially altered and corrupted transcript to Trial Court II in support of his Petition for Post-Conviction Relief.  Those briefs are best summarized in a footnote to Mr. Hartman’s Appeal Brief III (9th Dist. No. 13CA0018-M, 2014-Ohio-2226):
This Court, in deciding Mr. Hartman’s first appeal, remarked, “This Court has reviewed the transcript of testimony of Mr. Leighton and Deputy Telatko and is unable to find any place at which the trial court prevented Mr. Hartman from asking Mr. Leighton about what he told the arresting deputies, prevented him from asking Deputy Telatko about what he said after his arrest, or prevented him from asking the deputy about his knowledge of the law.  Considering that Mr. Hartman has not provided any page number in his brief, we must conclude that those alleged errors did not occur.”  [Emphasis added.]  State v. Hartman, 2012-Ohio-745, ¶ 24
. 
This Court [of Appeals] has been unable to locate the cited passages, and others, because they have been unlawfully deleted from the “official” transcript of proceedings. The filing of materially altered transcripts constitutes a fraud upon this Court and on Mr. Hartman. During the post-conviction hearing conducted on December 12, 2009, the Trial I court winced noticeably as defense counsel articulated the trial violations of Davis v. Alaska, 415 U.S 308, 318 (1974) (holding Petitioner was denied the right of effective cross-examination which "'would be constitutional error of the first magnitude and no amount of showing of want of prejudice would cure it.' Brookhart v. Janis, 384 U. S. 1, 384 U. S. 3."). (Trial I, Hearing on Post-Conviction Motions, Tr. at 12-15.)
Although the transcripts were altered, other briefs remained in the record further documenting the errors raised on appeal of Trial I. See November 23, 2009 Motion for Acquittal; Motion for New Trial; Motion for Arrest of Judgment; Motion to Suspend Execution of Sentence; And Motion For Bail Pending Appeal at 12-13;   December 17, 2009 Additional Authorities in Support of Defendant’s Motion for Acquittal; Motion for New Trial; Motion for Arrest of Judgment; Motion to Suspend Execution of Sentence; And Motion For Bail Pending Appeal at 33-37;   January 4, 2010 Post-Hearing Rebuttal Memorandum With Exhibits at 37, 45;   August 4, 2011 Petitioner’s Motion to Correct Transcripts;   August 29, 2011 Petitioner’s Supplement to Motion to Disqualify the Office of the Medina County Prosecutor at 14;   September 28, 2011 Petitioner’ Reply to State’s Opposition to Correct the Record; Opposition to State’s Motion to Disqualify Petitioner’s Counsel at 20-26;   November 28, 2011 Petitioner’s Update to Further Support His Pending Motion to Disqualify the Medina County Prosecutor’s Office at 5-6;   April 16, 2012 Defendant’s Supplement to Motion to Correct Transcripts and exhibits; May 14, 2012 Motion to Bar Successive Prosecution of Defendant in Violation of the Fifth Amendment’s Double Jeopardy Clause at 10, 151-154 and Exhibit 2; The missing passages from the “official” transcript of Mr. Hartman’s first trial, documenting the contentions that the Trial I court deprived him of his constitutional safeguards, did not mysteriously vanish from the “official” transcript of the proceedings by mistake or accident.  Nor was the material alteration of the record of the suppression hearing testimony of Deputies Telatko and Clinage mere typographical mistakes or accidents.
Specific references to Mr. Hartman’ briefs, cited in the above-footnote, are set out below for the Court’s convenience.

Monday, December 29, 2014

LAPDOG "PUBLIUS" COLLIER TAKES ADVANTAGE OF POST-CHRISTMAS SHOPPING BONANZA!


Insiders report that DONNA "HAVE IT YOUR WAY" GARRITY so delighted HER MAIN SQUEEZE, MEDINA LAPDOG JUDGE "PUBLIUS" COLLIER with her Christmas Gift Bag, previously previewed at this blog, LAPDOG "PUBLIUS" COLLIER became so inspired that he sprung into action!

As most shoppers know, some real bargains can be had in clearance sales on the days immediately following Christmas day as merchants are eager to clear out remaining stocks of merchandise in anticipation of the new year.

LAPDOG "PUBLIUS" COLLIER. despite the fact that he really is a big dummy, has learned that those bargains can be had while DONNA "HAVE IT YOUR WAY" GARRITY was reading the latest edition of the Medina Gassette to him.

LAPDOG "PUBLIUS" COLLIER suddenly realized that, by seizing upon the opportunities presented by these clearance sales, to return the favor to "HAVE IT YOUR WAY" GARRITY, much to her delight.

Accordingly, LAPDOG "PUBLIUS" COLLIER marched right out of the Medina County Courthouse, Mosque and Railroad Station, hopped in his ride, and drove directly to his favorite"ADULT" NOVELTY AND "BOOK" STORE.

AFTER THOROUGHLY BROWSING THE CLOSE-OUT STOCK, AND ELIMINATING SEVERAL OPTIONS, LAPDOG "PUBLIUS" COLLIER MADE HIS FINAL SELECTION.

LET'S TAKE A LOOK AT JUST WHAT COLLIER CHOSE TO PLEASE  HIS MAIN SQUEEZE, DONNA "HAVE IT YOUR WAY" GARRITY . . .




AN EXCELLENT CHOICE!  NO ONE CAN DENY THAT LAPDOG REALLY KNOWS HOW TO PLEASE HIS "LADY."  ALL OF THOSE RUFFLES WILL CERTAINLY DELIGHT GARRITY AS SHE AND LAPDOG PRANCE AROUND HIS CHAMBERS AFTER HOURS. LAPDOG MOST CERTAINLY KNEW HIS CHOICE OF A MATCHING OUTFIT WAS SURE TO DRIVE GARRITY WILD WITH PASSION AND DESIRE !!!

OF COURSE, AS WE ALL KNOW, ALL GOOD THINGS MUST MOST ASSUREDLY COME TO AN END.

LET'S TAKE A LOOK AT THE MATCHING OUTFITS THAT LAPDOG "PUBLIUS" COLLIER AND DONNA "HAVE IT YOUR WAY" GARRITY, LAPDOG'S MAIN SQUEEZE, WILL SOON BE WEARING TO THE MEDINA COUNTY CHARITY BALL . . .

                                                     HERS






     


                                                   HIS





Wednesday, December 24, 2014

GARRITY'S CHRISTMAS "AFTERNOON DELIGHT"FUL GIFT FOR LAPDOG "PUBLIUS" COLLIER

As the celebration of Christmas is now upon us, and we are in the very eve of the celebration, we need to acknowledge the fact that DONNA "HAVE IT YOUR WAY" GARRITY is not ungrateful to LAPDOG "PUBLIUS" COLLIER for his gracious and thoughtful Christmas Gift Bag, shown in the prior post at this blog, celebrating the Christmas Season.

Needless to say, GARRITY "knows" LAPDOG COLLIER as well as anyone, and, in fact, better than most, considering all those "intimate" moments they've shared over all of these past years. both "in and out, in and out, in and out" of the Medina County Courthouse, Mosque, and Railroad Station.

As we, the citizens of Medina County well know, LAPDOG "PUBLIUS" COLLIER subscribes to the untenable belief that he stands above the common folk, and above the law as well.  In fact, LAPDOG WISHES HE WERE KING, SO THAT HE COULD SUBJUGATE ANYONE AND EVERYONE BENEATH HIS STATION IN LIFE, WHICH, OF COURSE, WOULD BE EACH AND EVERY CITIZEN OF MEDINA COUNTY.

FORGET, FOR THE MOMENT, THAT LAPDOG COLLIER APPEARS TO BE THE LOW-LIFE, LOW=RENT, THIRD-RATE, GRAVE-ROBBING, AMBULANCE-CHASING SCUMBAG MEDINA LAWYER WITH THE CHARACTER OF A BLOWFLY MAGGOT, HIDING BEHIND THE ALIAS "PUBLIUS."

WITH THAT THOUGHT TEMPORARILY ASIDE, PERHAPS WE SHOULD TAKE A PEEK INTO GARRITY'S CHRISTMAS GIFT BAG FOR LAPDOG "PUBLIUS" COLLIER WHICH GARRITY WILL MOST CERTAINLY DELIVER TO HER MAIN SQUEEZE OVER THE CHRISTMAS HOLIDAYS.

LET'S LOOK AND SEE . . .




 WHAT A GREAT GIFT IDEA.  A PAIR OF RAT SLIPPERS!  A PERFECT CHOICE GIVEN LAPDOG'S CHARACTER.  IT CAN'T BE SAID THAT GARRITY DOESN'T KNOW HER MAN.  LAPDOG CAN SLIP INTO HIS ONE-OF-A-KIND PAIR OF RAT SLIPPERS ON A COLD WINTER NIGHT AS HE SNUGGLES UP NEXT TO GARRITY AND THEY BOTH BASK IN THE ROMANTIC GLOW OF GARRITY'S BARBEQUE GAS GRILL!  PERFECT!

LET'S LOOK AND SEE WHATEVER ELSE WE MIGHT DISCOVER IN GARRITY'S CHRISTMAS GIFT BAG OF DELIGHTS FOR LAPDOG "PUBLIUS" COLLIER . . .

WOW! LOOK AT THIS!






ISN'T THAT JUST THE PERFECT GIFT TO LAPDOG?  GARRITY CAN PRANCE AROUND LAPDOG'S CHAMBERS BEFORE AND AFTER COURT, AND MODEL THIS LITTLE NUMBER!  GARRITY CAN TREAT LAPDOG LIKE THE KING HE THINKS HE IS.  GARRITY LOOKS SO VERY SEXY IN THIS LITTLE NUMBER, DOESN'T SHE?

TO ADD TO THE TITILLATION THAT LAPDOG WILL MOST CERTAINLY RECEIVE FROM SEEING GARRITY PARADING AROUND HIS CHAMBERS IN THIS LITTLE NUMBER, GARRITY INTENDS TO SLIDE THE FOLLOWING ENTICING "ADVERTISEMENT" UNDER LAPDOG'S CHAMBER DOOR BEFORE HE SHOWS UP FOR "WORK" IN THE MORNING AFTER CHRISTMAS . . .




IT LOOKS LIKE IT IS GOING TO BE A VERY MERRY CHRISTMAS SEASON FOR BOTH LAPDOG COLLIER AND DONNA "HAVE IT YOUR WAY" GARRITY.

MERRY CHRISTMAS TO ALL THE READERS OF THIS BLOG!




Monday, December 22, 2014

IT MUST WORK! LOOK AT LAPDOG "PUBLIUS" COLLIER!



'Tis the season to be merry!  As we approach the Christmas holiday, most of us are busy with last-minute shopping, trying to figure out just what gifts to buy for family members and close friends.

NOT SO FOR LAPDOG "PUBLIUS" COLLIER.  COLLIER, IT IS SAID, HAS GIVEN THE SAME GIFT BAG, YEAR AFTER YEAR, TO HIS MAIN SQUEEZE, DONNA "HAVE IT YOUR WAY" GARRITY.  LAPDOG WILL DROPPING THIS LITTLE GIFT BAG UNDER GARRITY'S TREE WITH GLEE!

WHAT DO YOU SAY WE TAKE A PEEK INTO LAPDOG "PUBLIUS" COLLER'S GIFT BAG FOR DELIVERY BY SANTA CLAUS TO DONNA "HAVE IT YOUR WAY" GARRITY.

 PERHAPS AN ASSORTMENT OF JAMS AND JELLIES FROM SMUCKER'S IN ORVILLE?

LET'S JUST SEE . . . 

 
 NOPE! JUST PLAIN OLD HIS AND HERS MATCHING JARS OF JELLY.  NOT SURE OF THE FLAVOR, THOUGH.  WONDER IF IT'S ANY GOOD ON RYE TOAST DURING HIS DAILY "COFFEE BREAK" WITH GARRITY BACK IN LAPDOG'S CHAMBERS?

 THERE MUST BE MORE IN LAPDOG'S CHRISTMAS GIFT BAG FOR GARRITY.

LET'S S TAKE ANOTHER LOOK . . .


Trojan Vibrating Twister


WELL WHAT DO YOU KNOW?  TROJAN ADVERTISES THIS PRODUCT "WILL BLOW YOUR HAIR BACK."

THIS CERTAINLY MUST WORK.  JUST LOOK AT LAPDOG COLLIER.  IN FACT, IT APPARENTLY WORKS SO WELL THAT IT HAS BLOWN LAPDOG'S HAIR INTO THE NEXT COUNTY!

PRUDENCE DICTATES AGAINST LONG-TERM USE.  LAPDOG COLLIER APPARENTLY OVERLOOKED THAT CAUTIONARY WARNING!

IT LOOKS LIKE LAPDOG "PUBLIUS" COLLIER IS LOOKING FORWARD TO A VERY HAPPY NEW YEAR, AND BEYOND, WITH DONNA "HAVE IT YOUR WAY" GARRITY, HIS MAIN SQUEEZE !!!

Friday, December 19, 2014

TIME OUT AS LAPDOG COLLIER PONDERS THE END OF HIS LEGAL "CAREER"

The blogger has taken a time-out from presenting the remainder of the MOTION TO DISMISS, WITH PREJUDICE, ON THE GROUNDS OF PROSECUTORIAL AND JUDICIAL BAD FAITH AND MISCONDUCT.  The blogger has taken the time-out to permit LAPDOG COLLIER, THE VILLAGE IDIOT AND TOWN WHORE, a little more time to PONDER THE LOOMING END OF HIS LEGAL "CAREER."

For the past five years, CORRUPT MEDINA COUNTY PROSECUTOR DINO HOEMAN has been protecting  LAPDOG COLLIER by filing numerous denials of the material alterations to transcripts, in which HOEMAN is clearly complicit.

Until recent times, LAPDOG COLLIER has been fat, dumb, and happy, confident he and his MAIN SQUEEZE DONNA "HAVE IT YOUR WAY" GARRITY were going to get away with it after all of these years. 

LAPDOG COLLIER  and DONNA "HAVE IT YOUR WAY" GARRITY were further buoyed by the fact the MIKE DEWINE swept the unlawful tampering under the rug following a purported "investigation" conducted by ASSISTANT to the ASSOCIATE to the ASSISTANT ATTORNEY GENERAL MAGGIE (short for MAGGOT) TAMALE (a not-so-"hot" TAMALE at that) and "Special" BCI Agent Richard "Warn 'Em Dick" ( a real "Dick" in the fashion of Judge Richard (the) "Dick" Markus) who actually CONDUCTED NO INVESTIGATION AT ALL, FOR THE SAKE OF SHIELDING LAPDOG COLLIER, A PUBIC CRONY OF DEWINE, FROM THE CONSEQUENCES OF HIS UNLAWFUL AND ETHICAL MISCONDUCT.

BELOW IS A PICTURE OF LAPDOG COLLIER, TAKEN FROM A RECENT ARTICLE IN THE MEDINA GASSETTE, DEPICTING LAPDOG COLLIER, FAT, DUMB, AND HAPPY 




Readers will notice the chubby little cheeks and the point at the top of LAPDOG COLLIER'S egg-shaped noggin.

THE WATERSHED MOMENT ON NOVEMBER 10, 2014 HAS CHANGED ALL THAT!

Indeed, there came a WATERSHED MOMENT on November 10, 2014 that has forever changed the life, times, and crimes of CORRUPT MEDINA LAPDOG JUDGE CHRISTOPHER CALAFATO-COLLIER, who has been in the hip pocket of CORRUPT MEDINA COUNTY PROSECUTOR DINO HOEMAN for the past 15 years.

THAT WATERSHED MOMENT OCCURRED AT THE PRECISE MOMENT THAT THE MOTION TO DISMISS, WITH PREJUDICE, ON THE GROUNDS OF PROSECUTORIAL AND JUDICIAL BAD FAITH AND MISCONDUCT WAS FILED AT THE OFFICE OF THE CLERK OF THE MEDINA COUNTY COURT!  THAT WAS THE MOMENT THAT MARKED THE DEATH KNELL OF LAPDOG'S DOUBLE LIFE AND LEGAL "CAREER" AS HE KNEW IT!  THE EVIDENCE PRESENTED IN THE BRIEF PRESENTED OVERWHELMING AND INCONTROVERTIBLE EVIDENCE OF HIS CORRUPT AND UNLAWFUL CONDUCT, NEVERMORE TO BE CONCEALED AND SWEPT UNDER THE RUG BY DINO HOEMAN OR MIKE DEWINE.  ALL OF THE EVIDENCE OF LAPDOG'S UNLAWFUL CONDUCT IS NOW A MATTER OF PUBLIC RECORD! 

IN THEIR ARROGANCE, NEITHER LAPDOG COLLIER NOR DINO HOEMAN EVER SAW IT COMING!!!

SHOWN BELOW IS A PHOTO OF LAPDOG COLLIER, PUBLISHED IN THE MEDINA GASSETTE ON DECEMBER 16, 2014, TEMPORARILY SEATED ON THE BENCH, SHOWING THAT, IN THE PRESENT, LAPDOG COLLIER IS NO LONGER FAT, STILL DUMB AS ALWAYS, AND SO VERY UNHAPPY GIVEN THE PROOF OF HIS UNLAWFUL CONDUCT AND HIS NOT-SO-SECRET LONGSTANDING SORDID SEXUAL RELATIONSHIP WITH HIS COURT REPORTER.


Readers can plainly see the change in the appearance of LAPDOG COLLIER.  Gone are the chubby cheeks.  The point on his egg-shaped head has been deflated.  He appears to have lost 30 pounds and has aged 20 years.  All of these remarkable changes are due to the fact that LAPDOG COLLIER has been publicly exposed, at long last, and THERE IS NO WAY OUT, AS HE WELL KNOWS.

Most certainly, LAPDOG COLLIER has faced numerous sleepless nights, can't stand the sight of food, and the acid in his stomach is eating away at his ulcer.  GOOD FOR HIM!!!

The blogger can only hope that LAPDOG COLLIER experiences the full weight of the agony and misery he has doled out to innocent citizens and their families over all of these 15 years by his unethical and unlawful conduct, ALL DONE TO ASSURE HIS LIFETIME APPOINTMENT TO THE MEDINA COUNTY COURT OF COMMON PLEAS.  THAT GOAL, FOR WHICH HE COMMITTED ALL HIS EVIL DEEDS, HAS GONE UP IN SMOKE, ALL FOR NAUGHT!

LAPDOG COLLIER CANNOT SURVIVE THE EVIDENCE OF HIS UNLAWFUL CONDUCT.  NOT ONLY DOES HE FACE THE PROSPECT OF BEING PERMANENTLY DISBARRED FROM THE PRACTICE OF LAW, BUT HE MAY VERY WELL BE LOOKING AT A "VACATION" AT THE GRAY BAR HOTEL!  THIS COMMUNITY WILL BE ALL THE BETTER FOR IT! 

Thursday, December 18, 2014

JUST THE FACTS ABOUT LAPDOG COLLIER'S SORDID SEXUAL RELATIONSHIP WITH COURT REPORTER DONNA "HAVE IT YOUR WAY" GARRITY


Shown below is the eighth installment of the MOTION TO DISMISS WITH PREJUDICE ON THE GROUNDS OF PROSECUTORIAL AND JUDICIAL BAD FAITH AND MISCONDUCT, which LAPDOG "PUBLIUS" COLLIER and the Republicrats at the Medina County Courthouse, Mosque & Railroad Station do not want you, the citizens, to see.  You can cross-reference any exhibits to the List of Exhibits by "CLICKING" on the link shown directly below "PAGES" at the upper right-hand corner of the web page:

Not surprisingly, CORRUPT MEDINA COUNTY PROSECUTOR DINO HOEMAN and his surrogates at the Cuyahoga County Prosecutor's Office are continuing in their futile attempts to shield LAPDOG COLLIER, their puppet in the truest sense of the word, from the consequences of his MISCONDUCT AND UNLAWFUL CONDUCT.

PRESENTED BELOW ARE THE FACTS, JUST THE FACTS, AND ONLY THE FACTS




































OF COURSE, AS YOU THE READERS WILL LIKELY SUSPECT,  LAPDOG COLLIER AND CORRUPT MEDINA COUNTY DINO HOEMAN, THROUGH THE OFFICES OF CUYAHOGA COUNTY PROSECUTOR TIMOTHY McGINTY, HAVE EXPRESSED SHOCK AND DISMAY THAT THE BLOGGER HAS BEEN SO BOLD AS TO EXPOSE LAPDOG COLLIER'S LONGSTANDING SORDID SEXUAL RELATIONSHIP WITH HIS COURT REPORTER, WHICH EXPLAINS HOW AND WHY DONNA "HAVE IT YOUR WAY" GARRITY HAS BEEN FILING ALTERED TRANSCRIPTS WITH THE NINTH DISTRICT COURT OF APPEALS THAT LAPDOG HAS EDITED AND CHANGED TO DEPRIVE VARIOUS DEFENDANTS OF FAIR HEARINGS IN APPEAL, CRIMES UNDER THE LAWS OF THE STATE OF OHIO.

Wednesday, December 17, 2014

THIS IS WHAT LAPDOG "PUBLIUS" COLLIER REALLY DOES NOT WANT THE PUBLIC TO KNOW, PHILANDERING HYPOCRITE THAT HE IS!

Shown below is the seventh installment of the MOTION TO DISMISS WITH PREJUDICE ON THE GROUNDS OF PROSECUTORIAL AND JUDICIAL BAD FAITH AND MISCONDUCT, which LAPDOG "PUBLIUS" COLLIER and the Republicrats at the Medina County Courthouse, Mosque & Railroad Station do not want you, the citizens, to see.  You can cross-reference any exhibits to the List of Exhibits by "CLICKING" on the link shown directly below "PAGES" at the upper right-hand corner of the web page:



A.  Judge Collier is Involved in a Longstanding

Sexual Relationship With His Court Reporter Donna Garrity.


Inspector Hartman publishes a blog, found at medinacorruption.blogspot.com, which is primarily dedicated to exposing the corruption endemic in the Medina County Justice System.  As a feature of his blog, Inspector Hartman invites comment and information from the public.  As a result, he has received relevant information and has developed a number of confidential sources, who have provided information pertaining to the public corruption in Medina County government, including the courts.  Two of Inspector Hartman’s independent confidential sources have provided information that Judge Collier is involved in a longstanding sexual relationship with his court reporter Donna Garrity.  The sexual relationship between the judge and Garrity is reported to have been ongoing for the past eight years.

Moreover, those same independent confidential sources have reported that the ongoing sexual relationship between the judge and Garrity is “common knowledge” among members of the Medina Bar.

Inspector Hartman’s Affidavit, detailing information her received from his confidential sources pertaining to the sexual relationship between Judge Collier and his court reporter, Donna Garrity, is attached as Exhibit Nine.
THERE YOU HAVE IT.  LAPDOG "PUBLIUS" COLLIER DOES NOT WANT THE CITIZENS OF THIS COUNTY TO KNOW THAT HE HAS BEEN BEDDING DOWN HIS COURT REPORTER, WHICH EXPLAINS FULLY DONNA "HAVE IT YOUR WAY" GARRITY'S MOTIVATION FOR PERMITTING "PUBLIUS" TO REVIEW, EDIT, AND ALTER TRANSCRIPTS BEFORE SHE FILES THEM IN THE NINTH DISTRICT COURT OF APPEALS.  TOO LATE NOW, "PUBLIUS," OR IS IT "PUBICus?"  THIS CAT HAS LONG BEEN OUT OF THE BAG, CONTRARY TO YOUR BEST EFFORTS TO CONCEAL YOUR SORDID SEXUAL RELATIONSHIP WITH YOUR "MAIN SQUEEZE," YOUR COURT REPORTER DONNA "HAVE IT YOUR WAY" GARRITY.

Tuesday, December 16, 2014

LAPDOG "PUBLIUS" COLLIER MUST BE A REALLY SLOW READER

Shown below is the sixth installment of the MOTION TO DISMISS WITH PREJUDICE ON THE GROUNDS OF PROSECUTORIAL AND JUDICIAL BAD FAITH AND MISCONDUCT, which LAPDOG "PUBLIUS" COLLIER and the Republicrats at the Medina County Courthouse, Mosque & Railroad Station do not want you, the citizens, to see.  You can cross-reference any exhibits to the List of Exhibits by "CLICKING" on the link shown directly below "PAGES" at the upper right-hand corner of the web page:



3.  Trial Court I [LAPDOG "PUBLIUS" COLLIER]  and the Court Reporter Deliberately Edited, Tampered With And Materially Altered the “Official” Transcript of the Proceedings in Trial I.


Defendant’s first trial (Trial I) was heard before Medina County Common Pleas Judge Christopher Collier. [aka "PUBLIUS"]

Court reporter Donna Garrity,  under contract with Judge Collier, recorded the Trial I proceedings.  Ms. Garrity is the President of Medina Court Reporters, Inc.  A copy of the business name registration, obtained from the website of the Ohio Secretary of State identifying Garrity as the President of Medina Court Reporters. Inc. is attached as Exhibit Six.

Mr. Hartman timely filed an appeal of his first unconstitutional conviction.  Attorney Robert Dixon, Defendant’s first appellate attorney served court reporter Donna Garrity with a Praecipe on March 18, 2010.  After requesting and receiving no fewer than seven extensions of time, Garrity filed the edited and materially altered transcript of the “official” proceeding in Trial I on December 27, 2010, more than thirteen months after the jury returned its verdict.  A copy of the case docket in Mr. Hartman’s first appeal, 9th Dist. No. 10CA0026-M, documenting Garrity’s extensions of time to file the transcript, is attached as Exhibit Seven.

Suspicious of the inordinate delay in filing the “official” transcript of Trial I, Inspector Hartman reviewed and analyzed cases pending on the docket of the Ninth District Court of Appeals.  Inspector Hartman discovered that, between the dates of Defendant’s verdict in Trial I and the time that Garrity filed Defendant’s corrupted transcript on December 27, 2010, Garrity filed no fewer than transcripts of nine proceedings held before Judge Collier, including two jury trials, after the date of Mr. Hartman’s verdict.  A copy of Inspector Hartman’s analysis of court reporter Donna Garrity’s workload, obtained from the docket of the Ninth District Court of Appeals, is attached as Exhibit Eight.

The only reasonable and rational explanation for the inordinate time Garrity required to file Mr. Hartman’s corrupted transcript is that she afforded ample time to Judge Collier to edit and materially alter Mr. Hartman’s transcript.[1]




[1] Court reporter Donna Garrity lacks the knowledge to understand the legal concepts that would otherwise form the grounds for the Defendant to prevail on appeal and, therefore, could not, independently, determine which material alterations to make to the transcript to deny Mr. Hartman a fair hearing on appeal.

LAPDOG "PIBLIUS" COLLIER, WHO HAS BOASTED THAT HE WAS A "C" STUDENT IN SCHOOL, IS OBVIOUSLY A VERY SLOW READER.  IT TOOK HIM 13 MONTHS TO READ, EDIT, AND ALTER THE TRANSCRIPTS IN THIS CASE IN AN ATTEMPT TO DEPRIVE THIS INNOCENT CITIZEN OF A FAIR HEARING ON APPEAL FOLLOWING THE KANGAROO TRIAL BEFORE "PUBLIUS."

Monday, December 15, 2014

LAPDOG "PUBLIUS" COLLIER TO SELEAZEBURY DURING PROHIBITED EX PARTE DISCUSSION: "i'll HELP YOU" (VIOLATE THE RULES)!

Shown below is the fifth installment of the MOTION TO DISMISS WITH PREJUDICE ON THE GROUNDS OF PROSECUTORIAL AND JUDICIAL BAD FAITH AND MISCONDUCT, which LAPDOG "PUBLIUS" COLLIER and the Republicrats at the Medina County Courthouse, Mosque & Railroad Station do not want you, the citizens, to see.  You can cross-reference any exhibits to the List of Exhibits by "CLICKING" on the link shown directly below "PAGES" at the upper right-hand corner of the web page:

 
 
C.  During a Heated Ex Parte Discussion in Chambers, Pertaining to This
Case, Between Judge Collier and the Assistant Prosecutor, The Judge Was Overheard  to Shout at the Prosecutor, “I’ll Help You!”

 

On December 18, 2009, as the undersigned counsel and Inspector Hartman sat in the courtroom immediately prior to a “hearing” on the Defendant’s post-trial motions, they could clearly hear an ex parte discussion between Judge Collier and the assistant prosecutor pertaining to this case in chambers.  They had been discussing the improper denial of the spousal privilege despite multiple assertions of the privilege by Defendant’s wife on numerous occasions prior to trial, and despite Mr. Hartman’s assertions of his privilege.  At one point in the ex parte discussion of this case, Judge Collier yelled at the assistant prosecutor, “You compelled the wife to testify.  But I’ll help you.”

Inspector Hartman memorialized this ex parte discussion between Judge Collier and the assistant prosecutor in a November 19, 2010 affidavit, which the undersigned attached to her affidavit to disqualify Judge Collier that she filed with the Ohio Supreme Court.  In the undersigned counsel’s affidavit to disqualify Judge Collier, she also memorialized the ex parte discussion between Judge Collier and the assistant prosecutor.

The undersigned’s affidavit to disqualify Judge Collier, with Inspector Hartman’s supporting affidavit attached, is appended hereto as Exhibit Five.

LAPDOG "PUBLIUS" COLLIER HAS BEEN "HELPING" SLEAZEBURY AND CORRUPT COUNTY PROSECUTOR DINO HOEMAN TO FRAME AND CONVICT INNOCENT CITIZENS FOR YEARS.  NOTHING NEW HERE, EXCEPT  THAT "PUBLIUS" GOT CAUGHT  BY RUNNING HIS MOUTH ON THIS OCCASION.  HOEMAN AND "PUBLIUS" BELIEVE THEY ARE UNTOUCHABLE.

Friday, December 12, 2014

VISITING JUDGE RICHARD (the) "DICK" MARKUS, CHIEF AMONG MORONS, PLAYS "HIDE THE EVIDENCE"

Shown below is the fourth installment of the MOTION TO DISMISS WITH PREJUDICE ON THE GROUNDS OF PROSECUTORIAL AND JUDICIAL BAD FAITH AND MISCONDUCT, which LAPDOG "PUBLIUS" COLLIER and the Republicrats at the Medina County Courthouse, Mosque & Railroad Station do not want you, the citizens, to see.  You can cross-reference any exhibits to the List of Exhibits by "CLICKING" on the link shown directly below "PAGES" at the upper right-hand corner of the web page:


B.  Trial Court II [RICHARD (the) "DICK" MARKUS] Was Prejudiced by an Ex Parte Letter From Adversarial Third Parties In Unrelated Civil Litigation,
                     Which Ex Parte Letter The Court Deliberately Withheld from the Defense.

 

Trial Court II withheld an ex parte letter that adversaries of Inspector Paul M. Hartman, in unrelated civil litigation filed in the U.S. district Court, Southern District of Indiana, sent to the Trial Court II immediately prior to Defendant’s second trial.  The ex parte letter made false and fraudulent claims of unspecified wrongdoing against Inspector Hartman and the undersigned.  Trial Judge II [RICHARD (the) "DICK" MARKUS] never disclosed the ex parte letter to Defendant or his counsel, who only inadvertently learned of the letter several months after Trial II.  A copy of the ex parte letter sent by Kevin McCarthy (an Indiana attorney fired by the U.S. Justice Department for cause) and Alan Kershaw (an Italian attorney suspended from the practice of law for one year during the period May 2012 and May 2013) is attached as Exhibit Four.

The ex parte letter prejudiced Defendant and his defense team, as evidenced by the following finding of the Ninth District Court of Appeals in its decision in Mr. Hartman’s second appeal, State v. Hartman, 9th Dist. No. 12CA0057-M, 2013-Ohio-4407:

Ultimately, it was the State’s repeated comments about lies and mischaracterization of the evidence that led defense counsel to finally object during a sidebar.  Defense Counsel correctly pointed out that “it is improper to say an attorney is lying or misleading.”  Nonetheless, the trial court, while expressing concern that the prosecutor was possibly making references to matters that were not in evidence, overruled the objection and the assistant prosecutor’s inappropriate comments continued.  [Emphasis added.]  Id, at 10.
 

Defense counsel made no subsequent objections during closing argument.  Given the trial court’s response to her initial objections. It is possible she viewed the act of further objection as futile.  To the extent that this Court should view any remaining comments under the plain error standard, we conclude that the totality of the improper comments constitutes plain error.  [Emphasis added.]  Ibid., n.1.
 
["PLAIN ERROR" IS AS BAD AS IT GETS AT TRIAL !!!]

This and other actions by the State and the Judiciary reach far beyond prosecutorial misconduct and demonstrate the State’s and the Trial Courts’ bad faith throughout these proceedings.  The Ninth District Court of Appeals has, in circumstances markedly similar to Matthew Hartman’s first and second trials, held that retrial is barred in the case of an accused who “has been sufficiently harassed by unlawful government procedure as to invoke the prohibition against unwarranted successive criminal prosecutions within the meaning of the Double Jeopardy Clauses of the federal and state Constitutions.”  State v Daugherty, 9h Dist. Nos. CA7076, CA7083, 41 Ohio App. 3d 91 (1987).

In Daugherty, the Court of Appeals held:

In summary, we consider it to be fundamental that:
1. It is grounds for a mistrial when a lawyer in a jury case rests his case, having failed to adduce any admissible evidence of information harmful to his adversary that he has, in the presence of the jury, asserted to be true in a question to and that was denied by an adverse witness where the information is not otherwise in evidence.
2. It is professional misconduct where the information is put before the jury in such form that it appears that the lawyer is putting his own personal credibility into the balance for the jury to consider.
3. Accordingly, where a trial lawyer, under the pretext of putting a question to an adverse witness upon cross-examination, actually asserts to a jury the truth of unproved information substantially harmful to his adversary, the denial by the witness requires the lawyer to produce proper proof thereof. His failure to do so entitles his adversary to a mistrial.
4. The constitutional right to a fair trial in criminal cases makes the above rules applicable to lawyers engaged in a public prosecution. See Berger v. United States (1935), 295 U.S. 78.
In the case at bar, the prosecution "rubbed it in" in final argument, arguing the credibility of the accused and challenging the jury to consider "of what time she did work that day." The record contains other examples of prosecutorial misconduct, probably the result of inexperience, but condoned by the trial judge who was not inexperienced.
Finally, we have considered the entire record of this case in the light of the precedent of United States v. Dinitz (1976), 424 U.S. 600, and conclude that this accused has been sufficiently harassed by unlawful government procedure as to invoke the prohibition against unwarranted successive criminal prosecutions within the meaning of the Double Jeopardy Clauses of the federal and state Constitutions.  [Emphasis added.]  Id., 93-94.
 

Daugherty is precisely on point. The Medina County assistant prosecutor has equaled and exceeded the bad faith conduct for which the Court of Appeals criticized the State in Daugherty, which had been a sufficient basis as a bar to retrial under the Double Jeopardy Clauses of the federal and state constitutions.[1]

Mr. Hartman has already been tried twice. The Ninth District Court of Appeals has overturned each of his prior convictions and also commented on the weakness of the State’s case.

In the second reversal of Mr. Hartman’s unconstitutional conviction, Judge Moore aptly observed, “I find it impossible to say that in a close case such as this one, a jury would have found the defendant guilty even without the improper comments.”  State v. Hartman, 9th Dist. No. 12CA0057-M, 2013-Ohio-4407, ¶36.




[1] The State repeatedly asked witnesses to comment on other witness’ alleged testimony, often misstating the actual testimony. This practice is not permissible. See Douglas v. Alabama, 380 U.S. 415, 419 (1965). The prosecutor told Melissa Hartman that Al Leighton apparently saw a weapon (Tr. at 103), and that “other people” saw Petitioner with a gun around the children. (Tr. at 107).  The prosecutor told Melissa Hartman that Al Leighton said, “Not here. It’s not going to go down this way in my house.” (Tr. at 196). The prosecutor told Steven Hartman that “Melissa testified” that Petitioner “physically assaulted” her that day. (Tr. at 565).  In fact, it was the prosecutor who “testified” that Petitioner assaulted Melissa Hartman “that day.” (Tr. at 89, 113).  Melissa Hartman actually denied that Petitioner had assaulted her.  (Tr. at 113).  Melissa Hartman testified that it was she who had assaulted the Petitioner. (Tr. at 115).  Defendant’s June 29, 2011 Petition for Post-Conviction Relief, at 146.  The prosecutor repeatedly and continuously interjected himself as a witness into the case. (Tr. at 72-73, 75-77, 83-84, 86-91, 93-94, 110, 111, 113, 114, 115, 119-20, 131-32, 138, 172-74, 188-89, 194-96, 198, 200-02, 283, 334-35, 553-55, 592, 854-55). Id., at 147.  The prosecutors repeatedly expressed their personal belief or nonbelief in the witness’ testimony. (Tr. at 102, 103, 106, 107, 118, 177-78, 181, 189, 194-95). Id., at 148.
 
VISITING JUDGE RICHARD (the) "DICK" MARKUS, CHIEF AMONG MORONS, PROVED HIMSELF TO BE JUST AS DISHONEST AT TRIAL AS LAPDOG "PUBLIUS" COLLIER, AS THE NINTH DISTRICT COURT OF APPEALS HAS CONCLUDED.  AFTER ALL, "DICK" MARKUS. WHO WAS REAL CHUMMY WITH CORRUPT MEDINA COUNTY PROSECUTOR DINO HOEMAN DURING THE TRIAL, TURNED OUT TO BE JUST "ONE OF THE BOYS!"
 

Thursday, December 11, 2014

LAPDOG COLLIER AND SCOTT SLEAZEBURY JOIN TOGETHER TO VIOLATE THE RULES OF CRIMINAL PROCEDURE

Shown below is the third installment of the MOTION TO DISMISS WITH PREJUDICE ON THE GROUNDS OF PROSECUTORIAL AND JUDICIAL BAD FAITH AND MISCONDUCT, which LAPDOG "PUBLIUS" COLLIER and the Republicrats at the Medina County Courthouse, Mosque & Railroad Station do not want you, the citizens, to see.  You can cross-reference any exhibits to the List of Exhibits by "CLICKING" on the link shown directly below "PAGES" at the upper right-hand corner of the web page:


A.  The Prosecutor Introduced Inadmissible Alleged Other Acts

“Evidence” at Trial, After Acknowledging Its Inadmissibility and

After Assuring Defense Counsel and the Court That He Would Not Do So.

 

In Mr. Hartman’s Trial I, after assuring the court and defense counsel that he had no intention of presenting alleged forbidden acts to the jury (Motions in Limine Tr. at 8-9), the prosecutor called Mr. Hartman’s wife, as his first witness, over her repeated assertions of spousal privilege.[1]  The prosecutor, himself, on direct exam, then placed Mr. Hartman’s character at issue and presented the forbidden acts evidence to the jury, upon which he relied in closing argument. In fact, at a sidebar conference when the defense objected, the prosecutor “justified” his introduction of the forbidden acts, with his first witness on her first direct examination, by expressly stating, “I don’t have any other witness to testify to” the forbidden acts “evidence.”  (Tr. at 122).

The prosecutor, with the Court’s blessing, thus deliberately violated R.C. 2945.42, Evid.R. 404(b), 601(b), 608(a), as well a whole host of the provisions of the Ohio Rules of Professional Conduct and the ABA Standards of Conduct for Prosecutors, all with the bad-faith intent to prejudice Mr. Hartman.  (Juror comments after the trial confirmed that the inadmissible allegations did in fact prejudice the jury.)  The Court of Appeals reversed the conviction because of other evidentiary violations by the prosecutor and cautioned him not to repeat the other misconduct raised on appeal.

During Trial II, also subsequently reversed on appeal, expressly on grounds of prosecutorial misconduct, the prosecutors assured the judge that they had removed prejudicial remarks from the 911 call pertaining to false claims by Kim Leighton that the Hartmans were separated.  Again, the Assistant Medina County Prosecutor assured the court that he had reviewed the decision of the court of appeals and, in light of that decision, had removed the untrue allegation of separation.  Because the prosecutors had missed a reference, they had to prepare a corrected tape during the trial to play to the jury.  This process confirms that the prosecutors were well-aware that innuendo about the non-existent separation were prohibited during the retrial.  Yet, in closing argument, both prosecutors argued that the couple was separated, contrary to the sworn testimony and the express admonition of the Court of Appeals on this issue. See State v. Hartman, 9th Dist. Nos.  10CA026-M, 10CA0031-M, 2012-Ohio-745, ¶17, 19, 22.

During the appellate phase, the State continued to offer factual misrepresentations, misstating the testimony adduced at trial, even after Mr. Hartman briefed the precise cites in the record refuting the State’s invented “facts.”  See Appellant’s Reply Brief, 9th Dist. No. 12CA0057-M, pp. 1-2, attached hereto as Exhibit Three.




[1]  The alleged “forbidden acts” failed to qualify as legitimate Rule 404(b) evidence.  It was not like and similar to the charged offense of aggravated burglary, nor was it otherwise admissible under the Rules of Evidence.  The court did not conduct a balancing test of any kind, and the prosecutor offered it for exactly the purposes the Rules prohibit – to show alleged propensit1.  The admission of this “evidence,” over defense objections, was reversible error in and of itself and the manner of its introduction further demonstrates bad faith by the prosecutor and the court.
 
 
LAPDOG "PUBLIUS" COLLIER AND SCOTT SLEAZEBURY JOINED TOGETHER TO VIOLATE THE RULES OF CRIMINAL PROCEDURE AND DELIBERATELY, AND UNLAWFULLY, PREJUDICE THIS INNOCENT CITIZEN, ALL FOR THE SAKE OF LAPDOG "PUBLIUS" COLLIER'S UNOPPOSED LIFETIME APPOINTMENT TO THE MEDINA COUNTY COURT.

Wednesday, December 10, 2014

LAPDOG "PUBLIUS" COLLIER DENIES THE FOURTH AMENDMENT TO THE UNITED STATES CONSTITUTION

Shown below is the second installment of the MOTION TO DISMISS WITH PREJUDICE ON THE GROUNDS OF PROSECUTORIAL AND JUDICIAL BAD FAITH AND MISCONDUCT, which LAPDOG "PUBLIUS" COLLIER and the Republicrats at the Medina County Courthouse, Mosque & Railroad Station do not want you, the citizens, to see.  You can cross-reference any exhibits to the List of Exhibits by "CLICKING" on the link shown directly below "PAGES" at the upper right-hand corner of the web page:



2.         Trial Court I Denied Defendant’s Motion to Suppress On the Disingenuous

Rationale That an Indictment Cures Violations of the Fourth Amendment by Police.

 

Matthew Hartman filed a Motion to Suppress in Trial Court I [LAPDOG COLLIER] on July 30, 2009, requesting an evidentiary hearing.  Mr. Hartman filed his Supplement to Defendant’s Motion to Suppress on August 20, 2012.

As a preliminary matter, the criminal complaint in support of the arrest warrant did not contain a statement of essential facts, as the Fourth Amendment and Ohio Crim.R. 3 require.  Moreover, Deputy Douglas Clinage did not swear to the criminal complaint, also in violation of the Fourth Amendment and Ohio Crim R. 3.  Deputy Clinage conceded in his suppression hearing testimony that he  had not  sworn to the criminal complaint. (Suppression Hearing Tr. at 242).  The unsworn criminal complaint, the arrest warrant, and the seizure of any purported evidence flowing directly therefrom are constitutionally defective and invalid. Copies of the unsworn criminal complaint and arrest warrant are attached as Exhibit Fifty-Five.  Page 242 of the transcript of the suppression hearing testimony of Deputy Douglas Clinage conceding that he had not sworn to the criminal complaint is attached as Exhibit Fifty-Six.

Moreover, the State failed to meet its burden at the suppression hearing and demanded that the defense present its case prior to the time that the State produced its witnesses. (Suppression Hearing Tr. at 5).  A copy of Page 5 of the transcript of the suppression hearing is attached as Exhibit Fifty-Seven.

Following the suppression testimony of Deputy Frank Telatko and during the cross-examination of Deputy Clinage, who was the only witnesses the State belatedly produced at the suppression hearing after Judge Collier granted several continuances to accommodate the State, defense counsel properly argued the law to Judge Collier:

MS. CRAMER:          But at the time of arrest, he [Matthew Hartman] was arrested without probable cause.  The testimony corroborates the arresting officer didn’t even know what he [Matthew Hartman] was being arrested for.

THE COURT:             What you’re saying - -

MS. CRAMER:          Matthew Hartman is asking what the charge is.  Now, We’re looking at the stage - -  they did it wrong every step of the way.  Now we’re looking at the stage of obtaining the arrest warrant and what was - - what was done to have a warrant issued.  And to have a warrant issued there has to be a sworn affidavit under the Fourth Amendment.  There has to be a sworn affidavit under Ohio Rule 3.  I believe it has to be an affidavit with the specific facts - -

THE COURT:             Right.

MS CRAMER:           - - and there was no affidavit.

THE COURT:             What’s your remedy?

MS. CRAMER:          The remedy is that it’s an invalid warrant.

THE COURT:             And - -

MS. CRAMER:          So that everything incident to the arrest - - incident to the arrest has to be thrown out. . . The subsequent indictment can’t validate an illegal arrest warrant, an illegal arrest before that ….

(Suppression Hearing Tr. at 241-242).

Matthew Hartman, in his briefs, cited to controlling authorities including, but not limited to,  Illinois v. Gates, 462 U.S 213, 215 (1983) (Under the ‘totality of the circumstances’ analysis, corroboration of details of an informant’s tip by independent police work is of significant value); California v. Hodari D, 499 U.S. 621, 625 (1991) (it has been long understood that the Fourth Amendment’s protections  against unreasonable seizure include seizures of the person); Wong Sun v. United States, 371 U.S. 471, 479 (1963) (It is basic that an arrest with or without a warrant must stand upon firmer ground than mere suspicion); Terry v. Ohio, 392 U.S. 1, 8-9 (1968) ( the Fourth Amendment right against unreasonable searches and seizures protects people, not places and applies as much to citizens on the streets as well as at home); Whitely v. Warden Wyoming State Penitentiary, 401 U.S. 560, 565-569 (1971) (criminal complaint consisting of no more than the complainant’s conclusion that the individual named in the complaint perpetrated the offense identified therein could not support a finding of probable cause); Giordenello v. United States, 357 U.S. 486,  (1958) (judicial officer should not accept without question the complainant’s mere conclusion that the person whose arrest is sought has committed a crime); Kalina v. Fletcher, 522 U.S. 118, 119 (1997) (the evidentiary component of an application for arrest  is a distinct and essential predicate for a finding of probable cause).  Even properly trained and competent law enforcement officers,[excluding Medina County sheriff's deputies who have no comprehension of the Fourth Amendment jurisprudence] who are not lawyers or trained extensively in the law, are aware of the holding in Mapp v. Ohio, 367 U.S. 643 (1961) and its progenitors, barring admission of evidence that has been seized in violation of the Fourth Amendment.   See also Matthew Hartman’s Motion to Suppress.

Moreover, the State failed to file any opposition to Mr. Hartman’s briefs and his motion to suppress had, therefore, gone unopposed.

Notwithstanding the extensive briefing on the controlling law and the evidence adduced at the suppression hearing, and in spite of the deliberately altered transcript of the suppression hearing, infra, there is no question that Trial Court I erred when it improperly denied  Mr. Hartman’s motion to suppress.

The denial of Mr. Hartman’s motion to suppress by Trial Court I, all the while turning a blind eye to the testimony of the State’s witnesses (whose testimony failed to support probable cause for the arrest) and deliberately ignoring the most basic and common tenets of longstanding Fourth Amendment jurisprudence presents incontrovertible evidence of bad faith by trial Court I [LAPDOG COLLIER].

LAPDOG COLLIER, WHO IS IN DINO HOEMAN'S HIP POCKET, COMPLETELY IGNORED THE FOURTH AMENDMENT TO THE UNITED STATES CONSTITUTION, AS IF IT DID NOT EXIST, AS WELL AS THE CONTROLLING LAW DECIDED BY THE UNITED STATES SUPREME COURT.  THAT IS THE WAY HE MAINTAINS AN UNOPPOSED, LIFETIME APPOINTMENT TO THE MEDINA COUNTY COURT OF COMMON PLEAS, COMPLIMENTS OF DINO HOEMAN AND THE MEDINA REPUBLICRATS.