DISTRICT PROBATE COURT – # 2011 – P -00050; Courtnet Docket Sheet for Keith’s District Court Probate Case.
October 23rd, 2006 – The purported Will of Harold Keith Chandler
July 9th, 2011 — Moore Subitted a Motion to appoint Temporary Executor.
July 20th, 2011 — Chandler’s Motion Opposing the copy of will to probate, including objection on the ground that his brother was unduly influence to make the will, and he lacked the mental capacity, with allowed to strangers, that worked him to take advantage him, after their father passed away. Chandler further set out within his Motion informing the Court that 50% of all personal property on the Two-Hundred Year, Seven (7) generation family homestead, legal belonged to Chandler, pursuant to their mother’s Mary Katherin’s Will.
July 20, 2011 — July 20, 2011 Transcripts from court, where Judge clearly places the estate under Order to no disburse any money, and provide the court with a complete accounting a.s.a.p.
September of 2011 — After Judge Heady issued an additional Order, Moore submitted a limited inventory of the Estate.
WILL CONTEST
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January 6, 2012 — Chandler’s Memorandum in Opposition to Moore’s Motion to Strike
January 11, 2012 — Moore’s Memorandum in Support of her Motion to Strike
A Motion to Strike was neither supported by Kentucky case law or statute. Kentucky Rules of Civil Procedure Rule 12.06, provides that “the court may order stricken from any pleading any insufficient defense or any sham. redundant, immaterial, impertinent, or scandalous matter.¹⁶ Unlike the federal counterpart, relevancy is not amongst the list. The Plaintiffs position throughout has been consistent and not changed in the least. Steve Chandler hereby asserts that his brother was duped and taken advantage of by the Defendants to defraud him in order to gain access and control of Keith’s farm which consist of prime hunting land in Crittenden County, Kentucky.
Controlling case law has made it clear that motions to strike are disfavored under Kentucky laws because of their dilatory character.17 Moreover, Kentucky Supreme Court determined the effect of “striking” material from a Complaint or Answer requires, not merely a lack of consideration of the material by the Court, but complete removal or expungement of the material from the record.¹⁸ CHANDLER’S BRIEF On Page (7); Paragraphs 2 &3.
July 13, 2012 — Brucie Moore’s Memorandum in Opposition to Chandler’s Motion to Dismiss
July 17, 2012 — Chandler’s Memorandum in Support of his Motion to Dismiss Counterclaim
August 9, 2012 — ORDER of Judge Williams Denying Motion to Dismiss
Break Down of Federal Case filed against Union County Attorney Brucie Moore.
DURING THE DECEMBER 2012 HEARING, BRUCIE MOORE THREW JUDGE WILLIAMS UNDER THE BUS…. later you will see where she did the same thing to Steven Downey, during a probate hearing in Harold Keith’s Estate, she announces to the Court that her law firm hasn’t taken any money from the Estate.
December 8, 2012 — Order of Judge Williams– setting out a Scheduling Order for Trial
June 3, 2013 — First Motion to Recuse Judge Rene Williams, with attached Memorandum in Support
June 11, 2013 — Moore’s Response to Chandler’s Motion to Recuse Judge Rene Williams
October 1, 2013 — Moore’s Motion to Compel the production of RJPOUTDOORS
October 21, 2013 — Chandler’s Second Motion to Recuse Judge Williams to the Ky Supreme Court
AROUND THIS SAME TIME, I BEGAN MY FIRST SET OF CORRESPONDENCE WITH THE JUDICIAL CONDUCT COMMISSION, CHANDLER ALSO FILED JUDICIAL CONDUCT COMMISSION COMPLAINT AGAINST JUDGE RENE WILLIAMS, AND A KENTUCKY BAR ASSOCIATION COMPLAINT AGAINST ATTORNEY BRUCIE MOORE. I CONTINUED TO CORRESPOND WITH THE JCC AND WAS SENDING THEM ADDITIONAL INFORMATION, THAT THEY REQUESTED, UNTIL FEBRUARY 2014. AT WHICH TIME, I INFORMED THEM THAT JUSTICE MINTON DENIED THE MOTION TO RECUSE. (By way of signature stamp.) SINCE JUSTICE MINTON WAS THE ULTIMATE STOP ALL BE ALL, IN KENTUCKY’S JUSTICE SYSTEM, THE JCC SEEMED TO LOSE COMPLETE INTEREST, AT THAT POINT. These documents can be seen on the 2013 & 2017 KBA & JCC Complaint
January 23, 2014 — Moore filed a Summary Judgment Motion on behalf of the Defendants.
February 26, 2014 — Chandler filed a Response to Moore’s Summary Judgment Motion
March 13, 2014 — What was supposed to be the FINAL PRETRIAL HEARING, for the first time, Moore verbally made an objection to Chandler’s Motion to include additional witnesses. During said hearing, Rene Williams acknowledged that by filing the second Motion to Recuse with the Supreme Court, the case was automatically held in abeyance. However, Judge Williams seems to have forgotten the actual law, when she issued an Order on March 25, 2014, Denying, Chandler’s request to Amend witness list.
At the close of the Hearing, Brucie Moore announces since it now appears that the case would be going to trial, she has spoken with Steven Downey, a Bowling Green Attorney, who would be signing on as Defense counsel for the Defendants. Judge Williams then of her own accord, set an additional Pre-trial hearing, because in her words, she was sure Downey would have Motion in Limines to submit.
COMBINE AND ADD SCREENSHOTS
March 28, 2014 — Entry of Appearance of Steven Downey
April 1, 2014 — Pretrial Hearing with Steven Downey, the hearing was scheduled in Union County, where Brucie Moore is the County Attorney. (The video is too large. It was an unexpected ALL DAY HEARING, so it’s too large to post. I will break down the ridiculous comedic clips.)
April 1, 2014 — Downey filed Motion in Limine to Exclude Time Clock Entries
Brucie Moore submitted those time clock entries in support of her Motion for Summary Judgment. Once Chandler filed his Opposition to Summary Judgment, pointing out how Keith clocked in and out, at the exact same time every day, because it was a part of his necessary routine to function. Now Downey and Moore are fighting to exclude them. It should be noted, that Moore’s Motion in Limine to preclude mentioning of autism or Aspergers, was the direct result of Chandler’s Response.
This became a common theme throughout the Circuit Court Proceedings, with Judge Rene Williams. If evidence benefited Chandler’s arguments, it was excluded. If evidence supported Moore and Downey, it was admissible.
Recall Judge Williams canceled a hearing, on her own accord, on Moore’s Motion to Compel RJPOUTDOORS, in October 2013, instead she simply issued an Order on October 7, 2013, wherein she DENIED Chandler’s Motion to Recuse, and simultaneously slipped two sentences on the last page, that said Chandler had to comply with Discovery Requests made by Moore. Regardless, I submitted an additional Response to Moore’s verbal Motion to exclude RJPOUTDOORS during the January 16, 2014, Hearing, which I was unable to attend.
April 9, 2014 — Chandler’s Motion to Reconsider the exclusion of RJPOUTDOORS, specifically asserting that it directedly shows motive of the defendants. As you will soon see, during Downey’s first preliminary hearing, he kept beating a dead horse by repeatedly proclaiming in a loud, I am the big man in the room, tone, (paraphrasing here, but … She can’t use them. She Can’t have them. It’s plain and clear she deliberately and intentionally denied your order to produce those documents to Brucie Moore. It’s too late for her to claim otherwise, now.) In reality, I am certain, Downey’s tyrant was far harsher.
April 9, 2014 — Chandler’s Response to Downey’s Motion in Limine
April 11, 2014 — Hearing – an additional all day pretrial hearing to accommodate recently retained counsel. While arguing over the relevancy of certain information, and how it pertains to the Unnatural Disposition of the will, and actions taken by the Defendants immediately after discovering his body, goes to their credibility and the fact that they were not close to Keith at all.
Downey makes a verbal announcement that the Counterclaim was being dismissed. I objected to the dismissal, since it has been hanging over Chandler’s head for two years, and most definitely been responded to, including multiple memorandums filed in the matter. But more importantly, Downey’s decision to verbally dismiss counterclaim, only came after I pointed out the actions of the defendants after Keith’s body was discovered, as well as the counterclaim that they filed and held over my clients head for two years, makes it all relevant.
With or without the Counterclaim, the actions of the Defendants once Keith’s body was discovered, was relevant concerning whether it was an unnatural disposition of the will. As in why would a grown man at the age of 42, who never lived on his own, or even had a single bank loan / credit card, car payment, NOTHING…, choose as his only act of independence to create a will, leaving anything he owned or could own to a co-worker’s four year old son, he knew less than a year. The Defendants entire case was that Keith hated his brother. Their word only. In a will contest, purported hearsay testimony of the deceased is admissible. They could have said anything that they wanted to say, that Keith told them. (You will see how their testimony changed drastically from their deposition to their deposition at trial.) The two other witnesses were day shift supervisors of the plant where Randy worked with Keith and William. All three worked on the night shift.
Regardless I repeatedly argued with the Court the importance of the fact that these individuals are going to say that Keith hated his brother yet had no problem with Keith handling all of the funeral arrangements. If my “best friend” despised her sister, and I had a will that gave me authority, to act on my friend’s behalf, that sister might be permitted to sit towards the back. This is the type of information that Judge Williams, purportedly excluded due to the dismissal of the counterclaim. She also would not let me discuss how the two men went to two police officers, family neighbor and finally forced to call Chandler, back to the family home, hours after his body was discovered, because they had trucks and trailers and wanted to start packing things out. Chandler informed them there was no electricity, Randy slapped his recorder and said that is okay, I have night vision. Chandler had every reason to file immediately in District Court an action to preserver his family’s personal property.
April 14, 2014 — Limine Order tendered by Downey and signed by Judge Williams, prompted a telephone conference between all parties, due to Downey falsely padding the record by stating that an agreement was reached between the parties that, Chandler agreed to not mention undistributed property from Mary Katherines estate, in exchange for dismissal of Counterclaim. PAGE 18 of Tendered Limine Order- First paragraph!
I don’t want to go into much about the trial, because it is a comedy show in of itself. Kangaroo Court at it’s finest. Chandler DID NOT APPEAL the Jury Verdict. Downey’s over the top theatrics, and Judge Williams non-sensical bias rulings, will make for great unbelievable entertainment, soon enough.
DreamWorks Animation of the BEE Movie — is funny, but also a fair representation of Downey’s over the top theatrics.
After trial Steven Downey, Brucie Moore, and Judge Williams proactively tried to keep the Court of Appeals from learning about all the evidence that was presented from the start of the case, and was unjustly excluded throughout.
Immediately following trial, I sought to submit all the information that was improperly excluded during trial so the Court of Appeals Judges could determine whether or not the information would have made a difference at trial.
April 23, 2014 — Motion To Set A Date To Make An Avowal / An Offer Of Proof Of The Excluded Testimony And Evidence For The Court Of Appeals.
May 2, 2014 — Downey filed a RESPONSE TO CHANDLER’S MOTION TO PRESENT PROOFER OF THE EXCLUDED TESTIMONY AND EVIDENCE DURING TRIAL.
May 8, 2014 — Chandler’s Reply to Downey’s Response.
Judge Williams allowed Steven Downey an opportunity to obtain a double-objection of my evidence and proposed testimony during the May 28, 2014, Hearing.
May 30, 2014 — Chandler’s Memo in Support of Proffer
June 4, 2014 — Downey’s Response to Chandler’s Proffer, (with his two and half week involvement in the case) he falsely stated a great deal of the information was never submitted in the first place and/or was never excluded for the purpose that was listed within Chandler’s Proffer.
June 5, 2014 — Reply to Downey’s Response and Tendered Order
June 7, 2014 — Tendered Order by Downey for Judge Williams’s
With June 13, 2014, being the deadline to file Chandler’s Notice of Appeal, I went ahead and filed Chandler’s Appeal, stating all Orders that are included in the Record, and any subsequent Orders issued by Judge Rene Williams, concerning Chandler’s Proffer of testimony and evidence.
June 12, 2014 — ORDER from Judge’s Williams DENYING Chandler’s Proffer issued an order on Chandler’s pro offer and began swapping out the terms, general order and lemonade order which directly reflects bias in favor of defense counsel.
June 12, 2014 — Notice of Appeal submitted to the Court of Appeals; included all Orders, including the June 12, 2014 Order just signed by Judge Williams.
The Judge signed the Avowal Order on June 12, 2014 but I did not receive it until June 19, 2014. Ironically, I filed my Notice of Appeal on June 12, and received Circuit Court Clerk Confirmation on June 16, 2014. But somehow, something that was supposedly mailed out on June 12, 2014, did not arrive until June 19, 2014. The purpose of this would be that Judge Williams, Moore and Downey hoped that I would mistakenly wait around on Judge William’s Order, before filing Notice of Appeal and miss the Appeal Deadline altogether.
TWO ENVELOPES FROM JUNE 2014, it’s all about the timing. (Hold the eyeroll for now, the envelope issue gets much more interesting.)
POST TRIAL FILINGS IN HAROLD KEITH CHANDLER’S ESTATE
July 9th, 2014 — Moore submitted a Motion for Executor fees, neither myself or Chandler were ever served, on this motion and the Courtnet Docket and Judge Heady’s notes, correctly reflects it as being a Motion for Attorney Fees.
The Federal Bureau of Investigation began a lengthy investigation into the fraudulent purchases of stolen equipment by Union County, Kentucky Fiscal Court. To which Union County Attorney, Brucie Moore serves as the Court’s legal advisor. After the FBI investigation began, Moore or someone at her direction, began defacing envelopes to make it appear that the envelopes went through the mail, without going through the mail. i.e. MAIL FRAUD… Union County was under a Federal Investigation for the purchase of 1.5 million dollars in stolen equipment. Western District of Kentucky | Union County’s Judge/Executive Charged With Scheming To Defraud The Citizens Of Union County Of Their Right To Honest Services | United States Department of Justice
The State of Kentucky began an End Corruption now Campaign, which was prompted by a Harvard Study which ranked Kentucky amongst the top, corrupt states in the Nation. The FBI set up a telephone hotline, email links to receive tips, and asked the public to call in information to help with prosecution and prevention of corruption around the state. FBI Louisville Seeks the Public’s Assistance in Identifying Public Corruption within the Commonwealth of Kentucky — FBI
The FBI Special Agent in charge of cleaning up the Commonwealth, went so far as to say, “that the government corruption was an “open secrete” and “tolerated” and ingrained” in Kentucky’s political culture.” But this is what people need to realize. Corruption can only exist, if legal system fails to stop it by enforcing the anti-corruption law equally and justly throughout the state.
To put it another way, Congress can pass any law they want, but if the Justice System isn’t enforcing them, it doesn’t really matter.
Kentucky made the top three Harvard List, for the most corrupt state in the Nation. It was well known that governmental corruption was and is rampant, throughout the state. What truly are the odds, that the chosen attorneys and judges of the Kentucky Judiciary, all just rise above the fray. This is even more unlikely, when you realize the top positions are practically passed down, like a monarchy. https://www.lewrockwell.com/2016/05/saint-john-hunt/just-crooked-kentucky/
Crooked Politics in Kentucky – LewRockwell
March 30th, 2015 — Chandler’s Motion to Compel Accounting of the Estate, this was filed in conjunction with the Civil action against the named Defendants, and Attorney Moore and Downey, for misappropriation of funds, conversion of personal property among other counts, that must be filed within the one year statue of limitations.
June 10th, 2015 — Moore submitted an Accounting of the Estate, which showed the amount of money that had been paid to Steven Downey prior to the trial.
July 22nd, 2015 — Chandler filed an Exception to the Accounting submitted by Moore on behalf of the Estate.
LOCATE MOORE’S RESPONSE
July 22nd, 2015 — Chandler’s Reply to Moore’s Response to Chandler’s Filed Exceptions.
August 20th, 2015 — Moore submits Response, same as before… with one exception, this time she now includes an Affidavit of Steven Downey signed on July 28, 2015. Recall that a previous hearing was scheduled for Chandler’s Exception for July 29, 2015, but due to the unexpected death of my mother on the morning of July 27th, 2015.
Defense Counsel was no doubt hoping for a judicial approval of attorney fees, since I definitely was not able to attend that hearing.
September 2, 2015 — Reply to Moore’s Response that was received at my P.O. box just two day from the day of the hearing…. But more importantly… her certificate of services states that it was hand delivered, when it came in the mail, but never went through the mail.
After, and only after the Federal Investigation began in Union County, Moore or someone at her direction began driving defaced envelopes, two hours away to my P.O. Box, so it never went through the actual mail. Which would give the Federal Jurisdiction, to prosecute the egregious miscarriage of justice, in this case.
September 9, 2015 — Moore filed a Sur-Response in which this time she threatens me with Sanctions. This envelope did not go through the mail either. It had become pretty apparent at this point, every filing that contained fraudulent information and therefore was a direct obstruction of justice, was never placed in the mail. Instead, they would drive it two hours away, to my P.O. box, so it was never actually placed in the mail.
This Pattern also continued with Downey’s within his filings in the Court of Appeals
For the Record… I in NO WAY THINK THAT THIS WAS EVER IN RESPONSE TO A FEAR OF ME …, but of the ongoing Federal investigation into Union County, Kentucky, 1.5 Million Stolen Equipment Scandal that ended up with their very own Judge Executive being indicted on September 12, 2017. Western District of Kentucky | Union County’s Judge/Executive Charged With Scheming To Defraud The Citizens Of Union County Of Their Right To Honest Services | United States Department of Justice
A few short months later, he was tragically found deceased in his rental home, at the age of 44, on January 21, 2018.
Second Periodic Accounting Received December 4, 2015 — The filing was related to the Estate of Harold Keith. Moore or Downey did not want the FBI, to obtain Jurisdiction over their fraudulent conduct, which included knowingly, intentionally Obstructing Justice, throughout.
The point being is that Brucie Moore didn’t seem to have a problem using the actual US Postal Service, when it involved correspondence, and not actual filings with the District Court.
May 25, 2018 — After the Kentucky Supreme Court Denied Discretionary Review, after AUSA David Weiser, shut down a Federal Investigation into the case, and ongoing fraud involving Moore and Williams, after the Kentucky Bar Association – sent their first warning shot at me, Moore and Downey sought to be paid from the Estate of Harold Keith Chandler. Obviously, Moore failed to serve Chandler or myself, arguing that the Supreme Court Ruling, cut off any obligation or duty to serve Chandler. Theoretically, she wasn’t wrong, but in light of the ongoing and continuous fraudulent cover-up, all those Order are VOID, by law.
BUT PEOPLE ABOVE THE LAW ➡️➡️NEVER PLAY BY THE RULES, TO WHICH THEY EXPECT US PEONS TO ADHERE TO!