motion to declare vexatious litigator metropolitan … was fraud upon by a illegal business...

IN THE SUPREME COURT OF OHIOCASE NO. 2009-1518

SAINT TORRANCE

Relator,

vs.

ATTORNEY ANGELA STEARNS, et al.

Respondents.

RESPONDENTS, ATTORNEY ANGELA STEARNS AND CINCINNATIMETROPOLITAN HOUSING AUTHORITY'S

MOTION TO DECLARE VEXATIOUS LITIGATOR

JEFFREY C. MANDO (# 0043785) (COUNSEL OF RECORD)JENNTFER L. LANGEN (# 0069751)ADAMS, STEPNER,WOLTERMANN & DUSING, PLLC40 West Pike StreetP.O. Box 861Covington, KY 41012-0861(859) 394-6200(859)292-7263 Faxjmando a)aswdlaw.comiangeng)aswdlaw.com IT

Attorneys for Respondents, Angela Stearns andCincinnati Metropolitan Housing Autllority

(:f.^vP^4E pI^"4;^dl^t)s^1^^^^1^^

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Jeri Bealer, Mr. Vater, Lisa Isham, Angela Stearns, Joy Gazaway, and Director, CMHA,

all of whom are Respondents in Case No. 09-1497; Angela Stearns and CMHA, both of whorn

are Respondents in Case No. 09-1518; and Lawrence Brinkmeyer, Joy Gazaway and Director,

Cinciimati Metropolitan Housing Authority, all of whom are Respondents in Case No. 09-1709;

by and through counsel and pursuant to Rule XIV §5 of the Rules of the Practice of the Ohio

Supreme Court, respectfully move the Court to declare Relator, Saint Torrance a vexatious

litigator.

THE PARTIES AND THEIR RELATIONSHIP

The Cincinnati Metropolitan Housing Authority ("CMHA"), is a public housing authority

that provides subsidized housing and other services to low-income residents of Hamilton County,

Ohio. CMHA administers federal housing subsidies through a variety of prograins that are

authorized by the U.S. Department of Housing and Urban Development and subject to strict

federal regulation. One such program is the Housing Choice Voucher ("IICV") Program, which

is subject to the federal regulations located at 24 C.F.R. Part 982.

Under the HCV Program, an income-eligible individual identifies a private rental

property in wlrich to live, and enters into a lease contract with the owner of that property. The

individual cati request a federal subsidy to help him meet his rent obligation by submitting a

completed Request for Tenancy Approval to the local public housing authority.' If the local

public housing authority determines that certain requirements are met, it approves the tenancy2,

and enters into a Housing Assistance Payment ("HAP") Contract with the landlord.3 Under the

IIAP Contract, the public housing authority agrees to pay a federal subsidy directly to the

' See 24 CFR § 982.302.2 See 24 CFR § 982.305.3 See 24 CFR § 982.451.

landlord, and the landlord agrees to apply the subsidy to the arnount the individual is obligated to

pay the landlord for rent.° The landlord is also required to maintain the property in such a way

that it meets minimum housing quality standards.s

The public housing authority, however, is prohibited from paying a subsidy that exceeds

the "reasonable" aniount of rent for the property. Therefore, as part of its IICV Program, CMHA

determines the amount of rent that is reasonable for the property in question, taking into account

all of the factors that are required by federal regulation to bear on that issue, including the

location, size and age of the rental property, the amenities and utilities the landlord is required to

provide under his lease contract with the individual.b

Relator, Saint 1'orrance, is a landlord wlio occasionally rents properties to individuals

who receive subsidies as part of CMHA's HCV Program. 1'orrance is dissatisfied with the

amount of rent that CMHA has deterniined, using federal regulations as a guideline, to be

"reasonable" for a property lie rents to William Aleu and a second property he to rents to Ashley

Morgan. Following his dispute with CMHA over the reasonableness of the rent on the Alcu

property, Torrance filed a suit against CMHA in Hamilton County Municipal Court .' After

extensive briefing, the Municipal Court issued a thorough and well-reasoned decision granting

summary judgment in CMHA's favor. Torrance then appealed the Municipal Court's decision to

the First District Court of Appeals, where it is now pending as Case No. C-081292.

4 id.' See 24 CFR § 982.401.'S'ee 24 CFR § 982.305(a)(4) and § 982.507.' That case was styled Saint Torrance v. Cincinnati Metropolitan HousingAuthority, Hanzi1ton

Co. Mun. Ct. Case No. 08-CV-14222.

2

Althougli his appeal is still pending, Torrence filed a second action in Common Pleas

Court against CMHA regarding the sanie facts, which the Court ultimately dismissed.g

Having been unsuccessful against CMHA in the lower courts of this state, Torrance

began to file original actions directly in this Court.

TORRANCE HAS MISUSED THIS COURT'S JURISDICTION(AND THE JURISDICTION OF OTHER COURTS) TO ASSERT

FRIVOLOUS CLAIMS AGAINST CMHA ITSEMPLOYEES AND OTHERS

Torrance has initiated three original actions in this Court in the last six weeks against

CMIIA andlor its employees, all of which are frivolous.

First, on August 18, 2009, Torrance filed an original action in this Court against several

CMI-IA employees, inchrding Jeri Bealer, Mr. Vater, Lisa Ishani, Angela Stearns, Joy Gazaway

and a person identified only as "Director." The action - styled Torrance v. Bealer et al., Ohio

Supreine Court Case No. 2009-1497 - was initiated by a document entitled "Mandatory

Administrative Notices; Writ of Mandamus, Prohibition, Preemptory & Back Pay, ADA

Violations of a Protected Class with Conditions (PCWC) & as a Pro Se Litigant with Conditions

(PSLWC) Constitutional Violation of Due Process and Equal Protection of the 14"' Amendment

Setion [sic] 1& 3 13°i Amendment 'Neither Slavery nor Involuntary Servitude Also an

Indefiniate [sic] Mandatory Protection Order for All (PCWC) & Especially (PSLWC) & Saint

`Torrance," and followed by four more documents with equally bizarre captions. None of these

pleadings make any sense whatsoever in terms of factual or legal allegations, and instead rant

about mistreatment that Torrance, who considers himself a "protected class with conditions,"

8 That case is pending in the Hamilton County Court of Common Pleas, and has been assigned

Case No. A0901028.

3

perceives he has suffered froni society in general and CMI-IA specifically. For example,

Torrance claims that 11e:

was fraud upon by a illegal business [Torrance], chose mine was Bankruptcy, inthis American, [Torrance], downfall was not based on greedy, did not get greedy,but was set up to be greedy, with a nickel of money and other investor, lendersbankers hand niillions and the disabled, handicap, and the retarded gets a nickel,showed a triple citizen standard that is not acknowledge and GOD will interveneonce again to clean up ignorance to benig equal is a constitutional violation of aProtected Class with conditions (PCWC) to ever experience that means thatsomebody is still tormenting, torturing (PCWC) and making the (PCWC) becomethird class citizen and that is a unconstitutional, non-human, unarmed, helpless,aggravation of ones conditions, down right not an American and did not evenknow it because you had a disability too and its nioney is your down fall, thefallen shall rise up and tvn American once again.y

On August 20, 2009, Torrance filed a second original action in this Court, styled

Torrance v. Stearns et al, Ohio Supreme Court Case No. 2009-1518, naining Stearns (again) and

CMIIA as Respondents. The two pleadings that Torrance has filed thus far in Case No. 2009-

1518 make no fach.lal or legal sense. While it is clear in this second action that Torrance is upset

that Steams filed a motion in the Court of Cotnmon Pleas to have Torrance declared a vexatious

litigator, the pleadings in this second original action complain mostly about "name ca.lling froni

all otliers like Honorable Judge Ralph E. Winkler, Judge Demris S. Helmick, Judge William L.

Malloty, Judge Lisa C. Allen, Judge Jerome J. Metz, Jr. Judge Melba D. Marsh, and any other

Judge willing to fight a (PCWC) entraps you to be the comnion criminal that you are" and a

"bigger gate of deception" that he believes exists throughout "Hamilton County [and] around the

world."lo

On September 22, 2009, Torrance filed a third original action in this Court, naming as

Respondents Joy E. Gazaway, CMHA's Senior Legal Counsel; Director, Cincinnati Metropolitan

y Wlille similar sentiments are expressed in all five of the pleadings Torrance has filed in Case No. 2009-1497, thiss^ecific quotation is taken from the pleading he filed on September 10 in that case.

Whi le similar sentiments are expressed in botli of the pleadings Torrance has flled in Case No. 2009-1518, thedirect quotations are taken from the pleading he filed on September 14 in that case.

4

Housing Authority; Lawrence Brinkmeyer, a housing inspector for CMI-IA; the United States

Department of Housing and tJrban Development; and Ashley Morgan, Torratice's own tenant.

The initiating document makes numerous non-sensical assertions, including references to the

"integrity of GOD laws" and warnings about the "secret gate, that has already been revealed to

the public (Hint) there are people in high places in reality and in spirituality is watching if no

help in reality courts, then (Heaven Courts) comes to play for one thousand years in reverse,

sending this owned, army of 144,000,000 and if summoned for help, they will locked down the

whole world and start judgment before Thee Holy One and I will be the first one judged by my

fathers of all the bad I have done and tlien your turns, this is the last warning LastSaint, then

Jesus and God conies to judge for eternity, now that is something you do not want that actives,

the last battle, for person, place, and things in the world to happen." Reading between those

assertions, however, the third original action appears to coniplain about CMHA's determination

that the property Torrance wishes to rent to Ashley Morgan did not satisfy Housing Quality

Standards required for participation in the HCV Program.

All thrce of these actions are frivolous.

All three of these actions seek a writ of mandatnus, but none of the pleadings that

Torrance has filed to date atternpt to establish that Torrance is entitled to such a writ. A writ of

mandamus is an instruction from a higher court to a lower court, or from a court to a government

official, to take a specific action because: (a) a litigant has a right to have that action taken; (b)

the lower coiut or govermnent official in question has a corresponding duty to take the action;

and (c) the litigant has no adequate legal remedy otherwise in the course of the law. State ex rel.

Couch v. Trimble Local Sch. Dist. Bd. nf L'duc., 120 Ohio St. 3d 75, 896 N.E.2d 690 (2008);

O.R.C.§2731.05.

5

Given the nature of a writ of mandamus, Torrance is obligated to identify an action that

he has the right to expect a government official will take, demonstrate that the government

official has not taken that action, and establish that he has no adequate legal remedy to ensure

that the official takes the action in question. None of Torrance's pleadings in any of the three

original actions he has instituted against CMHA and its employees identify any such action,

much less demonstrate that'Torrance lacks an adequate legal remedy to ensure that the action is

ultimately taken." Indeed, the "facts" alleged in the documents that Torrance has filed in each

of the original actions neglect to address rights or duties in the context of Torrance's

participation in the HCV Frogram. Rather, they serve primarily as a platfomi for "I'orrance to air

delusional and paranoid grievances about the manner in which he believes he is treated by

society and government generally and by the judges in the Hamilton County Court system

specifically, with CMHA and its employees receiving only incidental mention.

Nor is Torrance following the appropriate procedures for seeking a writ of mandamus in

this Court. Under O.R.C. §2731.04, a petition for a writ of mandamus must be brought in the

nanie of the state on the relation of the person applying for the writs. None of' the three original

actions have been brought in the name of the state on the relation of Torrance.

To the extent that 'I'orrance seeks remedies other than mandamus - such as damages for

alleged breaches of contract and violations of the Americans with Disabilities Act and federal

and state Constitutions - this Court does not have original jurisdiction to entertain those claims.

TORRANCE HAS MISUSED THIS COURT'S JURISDICTIONTO HARASS NUMEROUS OTHER PARTIES

1'orrance also inisuses the original jurisdiction of this Court to air grievances against

many other parties unrelated to CMHA. In that respect, Torrance has invoked the original

°'I'hese argiunents are made inore futly in the Motions to Dismiss that Respondents have filed in each of the

respective original actions,

6

jurisdiction of this Court no fewer than 13 tirnes in the last six weeks, seeking writs of

niaudamus against munerous elected officials, government employees and private persons.

Many off the original actions that Torrance has initiated appear to have been preceded by

unsuccessful actions Torrance pursued in either Haniilton County Municipal Court or the Court

of Common Pleas. (See Exhibit A)

For example, Torrance was engaged in litigation against Ali M. Alhaj and Hook Fish &

Chicken, Inc. in both Municipal Court and the Court of Comtnon Pleas, According to the

Hamilton County Clerlc of Cowis' docket, Torrance initiated Case No. 08CV10993 against those

defendants in Municipal Court on April 3, 2008, wrd voluntarily disniissed it without prejudice

on January 14, 2009, only to refile the action against the same defendants in the Court of

Common Pleas on January 30, 2009. According to the Clerk's records, Comn-ion Pleas Judge

Ralph E. Winkler dismissed the case, which had been assigned Case No. A0900952, on August

6, 2009. Shortly thereafter, on August 24, 2009, Torrance filed an action, styled Saint Torrance

v. Honorable Judge Ralph E. Winkler et al, Ohio Supreme Court Case No. 2009-1529, against

Judge Winkler, Ali M. Alhaj, I-Iook, Fish & Chicken, and Nationwide Property and C'asualty.

Altlzough the content of Torrenee's complaint is diffficult to decipher, he appears to take issue

with the fact that Judge Winkler dismissed his claims rather than granting default judgment in his

favor, and he seeks a writ of mandamus. Of course, he is clearly not entitled to a writ of

mandamus in that action because he has an adequate legal remedy; that is, if he is aggrieved by

Judge Winkler's decision, he can certainly pursue an appeal with the First District Court of

Appeals.

Similarly, '1'orrance filed an original action -styled Saint Torrance v. Court of Appeals,

Firsi Appellate Distr•ict of Ohio, Case No. 2009-1538 - in this Court on August 25, 2009, against

7

the First District Court of Appeals; Court of Appeals Judge Patrick Dinkelacker; Municipal

Court Judge Julia Stautberg; Municipal Court Magistrates Amy Searcy and Alan Triggs;

Hamilton County Assistant Prosecutor Arica Underwood; and two attorneys in private practice,

R. Michael Phebus and F. Harrison Green. While Torrence's eomplaint is not clear, it appeai:s he

is complaining that extensions of time to answer complaints and respond to discovery were

granted to entities he sued in two separate lower court cases. 12 He seeks a writ of mandamus and

other relief to which he is not entitled because he has an adequate legal remedy; that is, if he is

aggrieved by decisions that granted extensions of time, then he niay appeal those decisions to the

First District Court of Appeals,

On September 22, 2009, Torrance filed Saint Torrance v. Monorable Judge Lisa C. Allen

et al, Case No. 2009-1710, seeking a writ of mandanius and other forms of relief against

Common Pleas Judge Lisa Allen; Prosecutor Joseph T. Deters; Assistant Prosecutors Charles

Anness and Christian J. Schaefer; Clerk of Courts Patricia Clancy; the First District Court of

Appeals; and Court of Appeals Judges Penelope Cunnitigham, Patrick T. Dinkelacker, Sylvia

Sieve Hendon, Leo H. Hildebraaidt, Mark P. Painter, and Joseph H. Sundermami. Based on his

complaint, it appears that Torrance has filed this original action because a previous writ of

mandamus he filed in the Court of Common Pleas - styled Saint Torrance v. Lisa C. Allen, Case

No. C0900493 - was dismissed, and Torrance's appeal to the First District Court of Appeals was

unsuccessful.

On the same day, Torrance filed Saint Torrance v. Monor•able 73etli A. Meyers et al, Case

No. 2009-1711, seeking a writ of tnandamus and other forms of extraordinary relief against

12 The cotnplault in tkie original action refers to the fact that Toirence had tiled actions against "Street LethalMotorspnrts" and "Car-D-Ology " Records of the Hamilton County Clerk of Clerks indicate that Torrence

maintained an action styled SaintTavence v. Street Lethal Motorsports, Hamilton County Municipat Court Case

No. 08CV10953, as well as an action styled Saint Torrance v, Car-D-Olo^y, Hatnilton County Court of'Common

Pleas Case No. C0900059.

8

Common Pleas Judge Beth A. Myers; a party he identifies as "Civil Law Clerk Jeff Nye";

Permanent General Assurance Corporation; and Josephine V. Prokop and Gregory L.

Williamson, who are apparently affiliated in some way with Permanent General Assurance

Corporation. According to his complaint, Torrance filed this original action because he is upset

about events that transpired at a case management and about entries Judge Myers has niade in an

action he has filed in the Court of Common Pleas. Although 'Torranee's complaint does not

specifically identify the case below, records of the Hamilton County Clerk of Courts show that a

case styled Saint Torrance v, Permanent General Assurance Company, Common Pleas Case No.

A090095I, is currently pending before Judge Myers.

Torrance also filed Saint Torrance v. I-Ion. Judge YVilliam Mallory et al, Case No. 2009-

1712, on September 22, 2009. By way of that original action, Torrance seeks a writ of

niandarnus and other forms of relief against Harry Cappel, Dulce Energy Ohio, Inc., Fifth Third

Bank, Graydon Head & Ritchey LLP, Deniiis Hurtt, Judge Williani Mallory, Judge Melba

Marsh, '1"hoinpson Hine LLP and Andrew Turseak. On information and belief, this original

action arises out of a case Torrance had filed against Fifth Third Bank, styled Saint Torrance v.

F'ifth Third Bank, Case No. A0906021, wliich was ultiniately dismissed.

Torrance also t3led another original action - Saint Torrance v, Honorable Jasdge Norbert

Nadel et al, Case No. 2009-1713 - on September 22, 2009. By way of that original action, he

seeks a writ of mandamus and other forms of relief against Common Pleas Judge Nadel and

aspirecard.com. It appears from his Complaint that Torrance has filed this original action

because aspirecard.com has not filed an answer in an action Torrance filed in the Cour-t of

Common Pleas and Judge Nadel has not as yet granted him a default judgment. On information

9

and belief, the action below was styled Saint Torrance v. Aspirecard.com, Common Pleas Case

No. A0907335, and the action is still pending in the lower court.

The fifth original action that Torrence filed in this Court on September 22, 2009 is styled

Saint Torrance v, HSBC Auto Finance, Inc. el al, Case No. 2009-1714, and names as

Respondents, C'1 Corporation Systeni, HSCB Auto Finance, Inc., HSBC Auto Finance, hic.,

Collections Department, Tracey Kent, Andrew Korte, A.T. Tankersley. According to the

complaint, Torrance wants this Court to require HSBC to reactivate his internet access, and also

wants damages from HSBC for alleged violations of the Fair Credit Reporting Act and the U.S.

Constitution.

Torrance filed an original action styled Saint 7'orrance v. Honorable Judge Ethna Cooper

et al, Case No. 2009-1720, on September 23, 2009, against Allstate Insurance Company, Charlie

Broxterman, Phil Cook, Comn-ion Pleas Judge Ethna Cooper, Penn Mabin, Sparkle McGee, J.

Patrick Schomaker, Carol J. Schroer, and Smith Rolfes & Skavdahl, According to the complaint,

this original action arises out of Torrance's dissatisfaction with the claims service he received

after an automobile accident, and also from decisions made by Judge Cooper in comiection with

an apparently related civil action.

Torrance filed an original action styled Saint 7'orrance v. Honorable Jiidge Jerome J.

Metz et al, Case No. 2009-1721, on September 23, 2009, against Mi.chael L. Bachman; Clerk of

Courts Patricia Clancy; the Legal Aid Society of Southwest Ohio, LLC; Nicholas J. DiNardo, a

Legal Aid attonley; and Common Pleas Judge Jerome J. Metz. According to the complaint, this

original action arises out of "Torranec's dissatisfaction with rulings he received in litigation

uivolving his tenant William Aleu. On information and belief, Aleu was a defendant in an action

10

Totrance filed in the Court of Cotnmon Pleas, styled Saint Torrance v. Angel Hill et al, Case No.

A 0902496.

1'orrance filed an original action styled Saint Torrance v. Flonorable Judge Ralph E,

Winkler et al, Case No. 2009-1722, in this Court on September 24, 2009, seeking a writ of

mandamus and other extraordinary relief against Clerk of Courts Patricia Clancy; Vehicle

Information Services, Inc.; and Common Pleas .Iudge Ralph E. Winkler. According to the

complaint, Torrance filed this original action in order to challenge Judge Winkler's decisions

dismissing a civil action Torrance had filed against Vehicle Information Services and another

civil action Toi-rance had filed against Ali Alhaj and Hook Fish & Chicken, Inc.

Torrance filed an original action styled Saint Torrance v. Honorable Judge Ralph E.

Winkler et al, Case No. 2009-1723, in this Court on September 23, 2009, seeking a writ ot'

mandamus and other extraordinary relief against Conimon Pleas Judges Ralph E. Winkler and

Dennis Helmick; Court of Appeals Judges Lee Hildebrant, Mark Painter, Howard Sundermatin,

Sylvia Hendon, Penelopc Cumiingham and Patrick Ditikelacker; Clerk of Courts Patricia Clancy;

Prosecutor Joseph T. Deters; and Assistant Prosecutors Christian Schaefer and Charles Amiess.

The Complaint does not make clear why exactly these parties are named as Respondents;

however, Torrance requests the "restitution of my credit report beuig restore and better,

Defendant-Relator, also request money back froin Duke Energy and Fifth Bank making iny

account current, fi-om this Gartushment of a federal exempted funds and my checking debit

account attached to my savings account, conipensatory and punitive damages with a trial of my

peers, and an indefinite Protective Order, attorney fees being a (Pro Se Litigant (citizen), with

conditions (PSLCWC)."

l1

Torrance filed an original action - styled Saint Tor•rance v. Judge John A. West et al.

Case No. 2009-1749 - on September 29, 2009. Accord'nrg to his complaint, he seeks a writ of

mandamus and other extraordinary relief against Common Pleas Judge Jolm A. West; Dwayne

Stewart, an individual against whom Torrance apparently has litigation pending in a lower court;

and Barry L. Speaks, who apparently submitted an affidavit in support of Stewart in the

litigation. The complaint suggests that Torrance filed the original action because Stewart has not

responded to discovery requests in the lower court action; Judge West has not issued discovery

sanctions; and Speaks' affidavit was "very damaging to my reputation, character, mode of living

and placed on a public docket to give the people a bias, prejudice to a(PCWC) is un human, not

impartial and based on peoples thoughts of attitudes of hate full this situation, this intrusion of

my US constitutional rights and other laws under Defamation of Character, Reputation, and

spiritual beliefs is forcn of bias, prejudice towards a (PCWC)."

Torrance's most recent original action - styled Saint Torrance v. Judge Fannon A.

Rucker et al, Case No. 2009-1750 - was also filed on September 29, 2009. By way of that

action, Torrance seeks a writ of mandamus and other extraordinary relief against Municipal

Court Judge Fanon A. Rucker; Car-D-Ology, Ltd., an entity that Torrance has sued in a lower

court; and Robert M. Phebus, au attorney who apparently represented Car-D-Ology in the lower

court litigation. Based on a reading of the complaint, the basis for this original action is far from

clear, but the following is typical:

Trail (Judge Fanon A. Rucker) court, had takeri on it own violation of law anddoing what you want to do gives the nation to do what they want in (St. Torrancevs. Hon. Judge Julia Strautberg ET Al., in the Suprenie Cotut of Ohio) shouldhave shown not only US & Ohio Federal State violations but it showed commoncriminals against a (PCWC) where equal protection was the law but who failed tofollow the law against a (PCWC) is very devil related not GOD related and youknow what that means who is really the thief of America people, they were rightup under your noses and Patricia M. Clancy placing this on the docket show a

12

group of sound minds really showing there own disabilities in sound mind of notfollowing the law and had gotten orders from my thoughts, watch it is a deepergame then you thing you know, scranibling and doing some thing with the lefthand and the right hand hut failed to place both hand behind your backs is abeautiful set up to work with in a cell and still given out orders now that flawless,by giving orders from another authority figtire, which failed to se ownershipbeyond your thoughts above these two will answer to me not just in reality butalso in "Heaven Court" which failed to believe, and see based on sound mindsurvival but forgotten unsound mind survival wakes up a group of Ark Angelsyou would never believe in a thousand years.

Like the original actions he filed seeking writs of mandamus and other extraordinary

relief against CMHA and its employees, none of these 13 other original actions Torranee has

filed since August 24, 2009 appears to have any merit.

CONCLUSION

Torrance is using this Court's original jurisdiction as a substitute for ordinary process of

civil litigation. Any legitimate claims Torrance believes he has against CMHA with regard to

the determination of reasonable rent, the inspection of rental properties to determine whether the

Housing Qnality Standards set by federal regulation are satisfied, and any other dispute related to

his participation in the HCV Program must be brought in the trial courts of this state. If Toi-ranee

believes he is aggrieved by a decision of a trial court in adjudicating those claims, the

appropriate fon.im in which to resolve those grievances is a court of appeals (in this case, the

First District Court of Appeals) pursuant to that court's appellate jurisdiction. He must follow

that same process of civil litigation to pursue any legitimate claims he has against other parties as

well.

Instead of following the ordinary process of civil litigation, liowever, Torrance contuiues

to file original actions directly in this Court. His primary purpose in doing so, it seems, is to air

paranoid and delusional grievances for which this Court can offer no redress. In short, Torrance

is misusing the origitialjurisdiction of this Court and the resources of all of the parties involved.

13

Consequently, Jeri Bealer, Mr. Vater, Lisa Ishan7, Angela Stearns, Joy Gazaway, and

Director, CMIIA, all of whom are Respondents in Case No. 09-1497; Angela Stearns and

CMIIA, both of whom are Respondents in Case No. 09-1518; and Lawrence Brinkmeyer, Joy

Gazaway and Director, Cincinnati Metropolitan Housing Authority, all of whom are

Respondents in Case No. 09-1709; respectfully request that the Court declare Saint Torrance to

be a vexatious litigator and prohibit him from continuing the original actions he has already filed

in this Court and from instituting any furtlier proceedings in this Court, without first obtaining

leave to do so.

Respectfully submitted,

JEF C. MANDO (N043785)JE iF'ER L. LANGEN ( 06975 1)ADAMS, STEPNER,WOLTERMANN & DUSING, PLLC40 West Pike StreetP.O. Box 861Covington, KY 41012-0861(859) 394-6200(859)292-7263 Fax

Attorneys for Respondents, Angela Stearns andCincinnati Metropolitan Housing Authority

14

CERTIFICATE OF SERVICE

I hereby certify that a true and accurate copy of the foregoing was sent by U.S. mail,IN^

postage prepaid, this ^_ day of October, 2009 to:

Saint Torrance3182 Werk Road, #2Cincinnati, OI-I 45211

400155.1

15

Supreme Court of Ohio - Results by Party Name^h ^u reme Court of Ohio & The Ohioouc^tcaa^System

Clerk's Office

65 South Front Street, 8th Floor

Columbus, Ohio 43215-3431

800.826.9010

614,387.9530

Search Results: Party Last Name = Torrance, First Name = Saint

Party Name Search Criteria

Party Last Name:Torrance

Party First Name: Saint

Records 1 to 17 of 17

Page 1 of I

Kristlna D. Frost

Qerk of Court

View Case Case Number Party Name Party Type Case Type

View Case 2009-1497 Torrance, Saint Relator Original A<tlon in Mandamus and Prohibition

View Case 2009-1518 Torrance, Saint Relator Original Action In Mandamus

View Case 2009-1529 Torrance, Saint Relator Original Action in Mandamus and Prnhlbition

View Case 2009-1538 Torrance, Saint Relator Origlnal Action in Mandamus and Prohibition

View Case 2009-1709 Torrance, Saint Relator Original Action In Mandamus and Prohibition

View Case 2009-1710 Torrance, Saint Relator Original Action in Mandamus and Prohibition


View Case 2009-1712 Torrance, Saint Relator Original Actlon in Mandamus and Protlibition


View Case 2009-1714 Torrance, Saint Relator Original Action In Mandarnus and Prohibition



View Case 2009-1722 Torrance, Saint Relator Original Action in Mandanius and Prohibition

View Case 2009-1723 Torrance, Saint Relator Original Action In Mandamus and Protiibition

View Case 2009-1749 Torrance, Saint Reiator Original Action in Mandamus and Prohibition

View Case 2009-1750 Torrance, Saint Relator Origini Action in Mandamus and Prohibition

view Case 2009-1810 Torrance, Saint Reiator Original Actlon in Mandamus and Prohibition

Records 1 to 17 of 17

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