Chandler Briefs file with the Court of Appeals
September 1, 2015 — I submitted Chandler’s Brief, however the Court of Appeals noted it received on September 8, 2015. Since I specifically asked for, up to and including September 1, 2015, I telephoned Samuel Givens and sent him documentation and UPS Receipt of the date it was filed.
Below is the OUTLINE for the Chandler’s Brief. Chandler DID NOT APPEAL THE JURY VERDICT!!! Chandler APPEALED THE PRE-TRIAL RULINGS of JUDGE RENE WILLIAMS, which prevented Chandler from being able to present his case to the jury. Judge Rene Williams played the role of a GATEKEEPING RAINMAKER for Brucie Moore.
November 10, 2015 — Downey Filed a Motion for Extension of time to file his Response Brief. Recall that Steven Downey through a fit about not receiving my draft brief, he reluctantly agreed to a fifteen day extension for me.
November 19, 2015 — Chandler’s Response to Downey’s Motion for Extension.
I used the opportunity to reiterate the sequence of events, including the endless necessity to have to file subsequent Motions, with tendered Reply, due to Downey’s fabrications. Within my Response, I informed the Court that I would be out of town beginning December 23, 2015, through January 2, 2016, and respectfully asked the Court if they granted Downey’s extension, to grant an extension of time for submitting Chandler’s Reply Brief. (Also, I graciously gave Downey the same 15 days that he previously allotted me.)
December 22, 2015 — I picked up Downey’s Response Brief at my P.O. Box in Hopkinsville, KY. The Response Brief does not appear to have gone through the actual mail. Downey’s Brief, like many fraudulent filings, were being driven to my P.O. Box, and not actually placed in the mail. The Office Stamp in the corner showed that it was mailed on December 22, 2015, from Bowling Green, Kentucky. The Response Brief had the wrong zip code on it, and does not have any other markings, other than a red stamp stating First Class.
December 22, 2015 — DOWNEY’S ENVELOPE FOR HIS RESPONSE BRIEF
Both Requests were subsequently granted, by Judge Acree.
January 15, 2016 — I submitted Chandler’s First Reply Brief, with two additional pages. I submitted a Motion and tendered Reply, that included two (2) additional pages with Chandler’s Reply. Reply Brief also contained a number of EXHIBITS, that were included as direct result of the endless false assertions contained within Downey’s Response.
EXHIBITS submitted with Chandler’s Reply Brief — were the direct result of Downey’s Intentionally and repeated mischaracterizations and lies, he submitted within Response Brief.
January 26, 2016 — Downey’s Response to Chandler’s Motion to include two additional pages. Downey filed a Motion to Strike Chandler’s Reply, altogether.
Rather than denying or addressing arguments submitted within Chandler’s Brief, the Court of Appeal filings, and particularly Chandler’s Reply Brief, Downey asserted that Chandler’s Reply Brief, “does not contain page numbers; the brief is consistently spaced let alone double spaced; and most glaringly the Appellant (Chandler) continues to reference matters outside the record, all in violation of the briefing requirements in CR 76.12.”
February 8, 2016 — Response to Downey’s Motion to Strike Reply Brief
March 3, 2016 — ORDER OF COURT OF APPEALS – Judge Acree Granting Downey’s Motion to Strike my Reply Brief and Ordered the Reply Brief Returned to me. (This one was not.)
Chandler’s Second Reply was returned by the Court of Appeals, on it’s own accord, “allegedly” because two pages had a place where it was 1.5 space and not 2.0 spaced. This was a factual statement, it occurred each time after a heading, and I couldn’t fix it.
HOWEVER, I have a hunch, it was most likely returned because, I attached as an exhibit a copy of the envelope with the page containing the single post-it, as well as proof of employment of Cynthia Downey, and affirmatively asserted that every phone call with the Court of Appeals, has been recorded. All filings of that Reply were, in fact, mailed back to me. Interesting to note, the Court of Appeals Docket Sheets falsely asserts that the Reply Brief was scanned, but not the exhibits, because they had non-removable tabs. WHICH THEY DID NOT… THEY HAD THE EXACT SAME TABS THAT HAD BEEN PLACED ON ALL OF CHANDLER FILINGS! March 25, 2016 —
Chandler submitted his Third Reply Brief.
March 30, 2016 — Downey’s Second Motion to Strike Chandler’s Reply Brief in particular Downey wanted the following Exhibits stricken, as stated above, the exhibits were the direct result of Downey’s ENDLESS False Assertions contained within his Response Brief.
April 13, 2016 — Response to Downey Third Motion to Strike Reply Brief
May 20, 2016 — Order of Court of Appeals, Judge Acree stating that Downey’s Motion to Strike Reply Exhibits and Reply Brief, along with Chandler’s Response, appear to address the merits of the appeal, and therefore PASSED the Motion to the three-Judge panel assigned to hear the merits of the appeal.
Court of Appeals Judge, Jeff S. Taylor, had the entire case file in his possession for two months, and then Recused himself. I was NEVER given notice of his assignment, let alone the opportunity to discover who else was assigned to the merit panel with him.
If Judge Taylor recused himself because of the fraudulent nature of the case, then from my perspective, Judge Taylor was the only one who showed genuine integrity, for his role as a Judge, and for his duty as an elected official.
September 13, 2016 — Thereafter, I was sent NOTICE that the three Judges assigned to the Merit Panel would be Joy Kramer, Debra Lambert and James Lambert. The notice is given, so that if anyone has a reason to object to a particular Judge serving on the panel, they can submit their objection.
September 22, 2016 — I filed an Objection to Debra Lambert serving on the Merit Panel and included great details, as to why she should not be allowed to serve on the Merit Panel.
October 26, 2016 — Downey submitted a Response in Opposition to Chandler’s Objection to Debra Lambert serving on the merit panel.
November 7, 2016 — Order of Court of Appeals DENYING Recusal of Judge Debra Lambert.
February 15, 2017 — Order of the Court of Appeals, Striking Chandler’s Reply
February 17, 2017 — Order of the Court of Appeals, Affirming the Jury Verdict.
February 20, 2017 — Order of the Court of Appeals, Denying Chandler’s Motion to Amend Notice of Appeal
NEXT CAME THE NEFARIOUS PETITION FOR REHEARING
Nefarious only to those who FEAR THE TRUTH!!!
To truly understand, the insult it was for the Court of Appeals to Strike Chandler’s Reply, you have to realize that the Reply and all of its attached Exhibits were submitted as the direct result of Steven Downey’s Endless False Assertions, throughout his Response.
EXHIBIT 14 of Chandler’s Brief & Exhibit 5 of Chandler’s Reply
Reply Exhibit Chandlers testimony verses Downey footnotes in Brief
Reply Brief Exhibit – transcript of Bench conference – questioning Brucie Moore
Reply Exhibit Downey’s brief and fabricated footnotes
Reply Exhibit — Disputing Downey’s False Statements against Chandler
March 9, 2017 — Chandler’s Petition for Rehearing.
CHANDLER’s Petition for REHEARING is a MUST READ… ESSENTIALLY, that Petition caused 6 of the 14 Court of Appeal Judges to Recuse THEMSELVES, and ULTIMATLEY SIX YEARS later RESULTED IN MY SUSPENSION TO PRACTICE LAW IN THE STATE OF KENTUCKY. BECAUSE I WILL NOT NOW OR EVER SUBMIT, TO THE JUDICIARIES DESIRE FOR ME TO SAY THAT I WAS WRONG, TO EVER QUESTION THEIR INTEGRITY AND FOR ME TO REMAIN SILENT ON THE REAL EVENTS TAKING PLACE WITHIN THE KENTUCKY JUDICIARY!
March 22, 2017 — Downey’s Response to Petition for Rehearing
In other related action, On April 13, 2017, during a scheduled hearing that Judge Williams attempted to circumvent, I directly confronted Judge Williams with the decade long felony fraud, that was being carried out by her and Attorney Moore and insisted that she Recuse herself from all these proceedings. Instead of granting Chandler’s Motion, she issued a fraudulent Order on May 25, 2017, stating that I never served her personally or made her aware of Chandler’s Motion to Reconsider. All of which can be located on the CIVIL Action Page, include the video of the Court proceedings.
PLEASE NOTE: Chandler’s Petition for Rehearing did not request a new panel. In fact, it was clear that Chandler was trying to give the current sitting panel an opportunity to reevaluate, all the filings throughout. Certified Step Sheet as of January 2020,
August 24, 2017 — NOTICE OF COURT OF APPEALS
September 11, 2017 — Notice of Court of Appeals (Stumbo)
JUDGE JANET STUMBO’s, two day appearance, as Judge on the Chandler case is note worthy. At that time, Janet Stumbo was a member of the Judicial Conduct Commission. Janet Stumbo received and reviewed all the material that was submitted within the August 2017, Judicial Conduct Complaint. Then all of a sudden, she is place on the Merit Panel for the Petition for Rehearing. Just to make sure, I telephoned the Judicial Conduct Commission, on two occasions in August, once to make sure that everyone on the commission received the full complaint.
Second time, was simply to confirm that the Judicial Conduct Commission, was affirmatively stating that they saw no fault in the actions of Brucie Moore interchanging her entity names, (all for her personal benefit, and the benefit to the State Bank in town, that she has multiple levels of interest in), so she could serve as both counsel for the Plaintiff and the Defendant. Wherein, Judge Williams has signed off on this fraud for more than a decade. When County Officials use their position for personal private gain, or for the benefit of others, is known as Honest Service Fraud. The timing of these events can’t be overlooked.
September 13, 2017 — Notice of Court of Appeals adding Kelly Thompson
September 22, 2017 — Chandler’s Objection to Kelly Thompson serving on the rehearing panel.
October 4, 2017 — Downey’s Response to Chandler’s Objection
October 24, 2017 — Notice of Court of Appeals assigning Judge Nickell, Judge Denise Clayton and Judge Allison Jones
October 24, 2017 — Order of Judge Kelly Thompson, Recusing Himself.
October 24, 2017 — Notice of Court Of Appeals for Substitution of Judge on merit, rehearing panel.
Courtnet showed Judge Nickell Denise Clayton and Allison Jones
November 14, 2017– Order of Court of Appeals Denying Petition for Rehearing, signed by Judge Shea Nickell
Please NOTE: The Order Denying Petition For Rehearing reflects that Judge Nickell, Judge Clayton and Judge Jones were on the review panel.
However, as of January 2020, The Official Certified Step Sheet, still reflects Finality was ruled upon by Nickell, Stumbo and Jones. Moreover, the changes and deletions made from the online docket is noteworthy.
No Doubt, the Court of Appeals does not want anyone to know that when my mom passed away, the Court of Appeals, and or employees, attempted to get Downey an expedited dismissal, by taking advantage of the death of my mom.
January 19, 2018 — Chandler submitted a Motion for Discretionary Review with the Kentucky Supreme Court.
February 15, 2018 — Downey’s Response to Chandler’s Motion for Discretionary Review — with attached Briefs and Petition for Rehearing.
April 16, 2018 — Recorded visit to the Kentucky Supreme Court
April 18, 2018 — Order of Kentucky Supreme Court Denying Motion for Discretionary Review. With nothing more than Justice Minton’s signature stamp.
Testimony from Hearing against me. Andre Bergeron asked for me to read portions of my discretionary review. First, contrary to all the Orders, I NEVER SAID Judge Williams was Biased Against ME. I emphatically asserted, that she was BIAS in favor of Brucie Moore, and through, common interests of coverup and attempting to conceals the totality of this case, and their actions, Bias in favor of Downey.
As you will hear from my testimony, (audio, linked below), this was not an ordinary case, where the Kentucky Supreme Court can just deny Discretionary Review. Their decision to deny discretionary review, directly perpetuated the fraud, and thereafter, they have taken extreme steps to cover it up, by falsely prosecuting me.
Within two weeks of receiving the Kentucky Supreme Court Order Denying Discretionary Review, I received the first Kentucky Bar Association, “Investigation Letter” on May 4, 2018. I am now of the opinion that the Investigation Letter, was not to determine if I had done anything wrong …. It was sent, so that the Kentucky Bar Association and the Kentucky Judiciary, as a whole could determine whether I pose a threat to the unlawful members of the Kentucky Judiciary.