Case 3:19-cv-00872-DPJ-LRA Document 17 Filed 12/31/19 Page 1 of 2
BETTY NORMAN PLAINTIFFS
and ALFRED NORMAN
VS. CIVIL ACTION NOL 3:19-cv-872-HTW-LRA
GEICO INSURANCE, DEFENDANTS
GEORGE’S PLACE, INC.
and JOHN DOE COMPANY
and JOHN DOE
____________________________________________________________________________
PLAINTIFFS MOTION FOR THE DISTRICT COURT JUDGE
ASSIGNED TO THIS CASE COURT TO
RECUSE HIMSELF OF THIS CASE
____________________________________________________________________________
COMES NOW, Plaintiff by and through their attorney and files this motion for the District
Judge in this matter to recuse himself from this case. Plaintiff’s motion comes in all due respect
to the court. As such, Plaintiff will show to wit:
(1) Plaintiff while searching the rules to seek the district court judge intervention in this case as
it relates to the non-response to emails from Plaintiff’s counsel, of the Magistrate judge,
Plaintiff, today, has realized that the district judge in this case is the honorable Judge Henry
Wingate, the district court judge that Plaintiffs counsel has served as a clerk for. Albeit,
several years ago, Plaintiff is concerned that this district court judge may not be impartial to
parties as it relates to this matter. It follows that it might be inappropriate for this district
court judge to be the judge of record in this matter.
(2) Plaintiff further avers that the district court lacks jurisdiction in this entire matter and that
this matter should be remanded back to the state court where it was properly filed because
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Case 3:19-cv-00872-DPJ-LRA Document 17 Filed 12/31/19 Page 2 of 2
there is a state tortfeasor as a defendant in this action. Plaintiff further joins the replies and
motions as filed in this matter with this request for recusal.
Therefore, Plaintiff respectfully ask that the district recuse himself in this matter at once for
the foregoing reasons above and Plaintiff’s memorandum of law to follow this motion.
RESPECTFULLY SUBMITTED THIS THE 31st day of December
Plaintiffs’:Betty and Alfred Norman
/s/Abby Robinson (MBN. 105157)
ABBY ROBINSON LAW FIRM PLLC.
227 E. Pearl Street
JACKSON, MS 39201
PH. 601-321-9343
FAX. 601-487-6326
EMAIL: arobinsonlawfirm@yahoo.com
EMAIL: abby@askabbylaw.com
James C. Martin esq.
Martin Law Office, LLC
106-B W. Leake Street
Clinton, Mississippi 39056
email: jmartinlaw@comcast.net
David Lee Gladden Jr.
455 Pebble Creek Drive
Madison, Mississippi 39110
lgladde@gladdeingram.com
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Case 3:20-cv-00418-DPJ-FKB Document 19 Filed 09/03/20 Page 1 of 7
IN THE UNITED STATES DISTRICT COURT OF
THE SOUTHERN DISTRICT OF MISSISSIPPI
NORTHERN DIVISION
BETTY NORMAN PLAINTIFFS
ALFRED NORMAN
VS. CIVIL ACTION NOL 3:20-CV-418-DPJ-FKB
GEICO INSURANCE, DEFENDANTS
GEORGE’S PLACE, INC.
and JOHN DOE COMPANY
and JOHN DOE
_______________________________________________________________________
PLAINTIFFS’ OBJECTION FOR THE RECORD REGARDING
THE COURT’S ORDER DOC.[18]
_______________________________________________________________________
COMES NOW, Plaintiffs by and through their attorney of record and files this
objection to the honorable chief Judge Daniel Jordan.
BACKGROUND
In the instant case, the honorable judge Jordan filed an Order of denial of Plaintiff’s
motion for reconsideration of Plaintiffs motion to remand back to state court. Doc. [18].
There the Court provided it’s reasoning for the denial provided numerous passages as to
why the Court denied the motion to reconsider, and since Plaintiffs filed a second motion
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to remand question the Court’s discretion on piercing the pleadings, there will not be any
reason for Plaintiffs to mention that here.
However, Plaintiff’s attorney respectfully is forced to make this record for the benefit
of Plaintiffs since the Court stated remarks that might cause Plaintiffs to assume their
lawyer might be illiterate or otherwise, and the record is also made so all readers
including the higher courts, if necessary can follow Plaintiffs issues before the district
courts.
On page (3) of the Court’s Order in foot note 2, the stating: “Nearly ever statement
from Plaintiffs’ briefs that is quoted in this Order contains multiple grammatical and/or
typographical errors. Rather than highlighting each mistake, the Court will simply insert
a single “sic” after each quote containing such errors .”
As a result, Plaintiffs’ attorney feels that for the cautious of Plaintiffs thinking in a
negative light about their legal representative and possibly causing harm to any Plaintiff’s
cases, Plaintiffs attorney holds these truth to be facts.
First, we seem to be in an age where the court chooses to dismantle the lawyer before
them with harmful comments as the one cited in the above aforementioned paragraph. It
appears that such comments are not provided to help the attorney understand nor know
what is expected by the court, but rather vicious words to attempt to dissuade the lawyer
from working/arguing law before such court.
The issue in this weird mean hearted statement is that it is likely true that Plaintiff’s
counsel has several grammatical errors within her pleading[s], but even with such errors
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it appeared that the court understood the argument and that the law as cited, likely had
grammatical errors as well, and Plaintiff’s counsel can only copy and paste the cited case
law.
Plaintiff’s attorney makes this record that she has absolute no power no authority
when it comes to how the court desires Plaintiff’s attorney to write. It is true that the
court, with a strike of his pen can hold Plaintiff’s attorney in contempt for anything the
court desires and there is nothing a practicing attorney can do about it other than take
such matters to the highest court of the land.
Plaintiffs’ must know that this attorney has done all that she can on their behalf in
bringing their issues before the court, but it appears, by the mean spirited comments
found in footnote 2, nothing Plaintiff’s attorney can say yet alone write change the
opinion of the court toward the attorney. It would seem like the court should welcome
attorneys whom fight vigorously has sworn by the oath to practice law. Not sure why
that is not the case in this matter as well as other district courts.
As such, Plaintiff’s attorney wants to make sure that everyone involved in legal
courtroom arguments with this attorney understands what they are seeing. Plaintiffs’
attorney is a black woman, a freedom fighter of the 21st century. Yes, the writing and
grammatical errors as stated by the court is a result of Plaintiff’s lawyer going to public
schools where children had to be more concerned about a meal and not being attacked
while walking home from school than learning all the ways to punctuate a paragraph.
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Another reason that this court along with other courts will find Plaintiffs lawyer a bit
different than other practicing attorneys that comes before the honorable judge, is that
this attorney has been through many attacks by racist, mean hearted and despicable
people. This attorney even this year has had to fight against racism just to live in her
personal home with her family. And as far as this attorney can tell, that is all because
there are some people whom are not African American, that will like very much for their
neighborhood to remain all white. However, this attorney, as I have taught my children,
would like to know that the system works, that the laws of the U.S. Constitution works
for all people, and not some.
Plaintiffs’ counsel takes such mean spirited remarks from this court serious and as a
method for the court to stop the very fighting that Plaintiffs counsel swore to vehemently
uphold in the courtroom.
Plaintiffs’ counsel has always upheld the district court as a court of equality among all
people. Never had this lawyer believed that this court would not be respectful toward all.
In fact, Plaintiff esteemed this court as a honorable authority and has always respected the
same. However, Plaintiffs’ lawyer has no different feeling about the court even after it is
clear that the court desired the mean spirited words to humiliate and embarrass Plaintiff’s
attorney before the opposing counsels. Plaintiffs are sure that the defendants attorney
feel wonderful about the court’s order, specifically the harmful words that the court
wrote. Plaintiffs have been made abreast of these facts and they were asked if they would
like this lawyer to withdraw from their case based on the court suggesting that Plaintiffs
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counsel is illiterate. Plaintiffs’ said, no, they respect the fact that a black woman is
helping them in spite of the opposition from the court as well as the defendants.
Plaintiffs’ counsel believe that the court designed such ridiculed words to put
Plaintiffs’ counsel in awe of receiving denial and possibly a loss of Plaintiffs’ case which
is why this lawyer went over the order with Plaintiffs and offered to withdraw as counsel.
However, Plaintiffs counsel still says to the world that she is a freedom fighter no
different that strong black women such as Harriet Tubman, who fought forward in the
opposition of strong forces. Plaintiffs attorney contend that just as Harriet made it, I will
too with misspelled words and grammatical errors.
CONCLUSION
Plaintiffs file this document as an objection to the court’s order regarding the court’s hard
words in the court’s footnote number two.
Plaintiffs’ attorney is in on wise being disrespectful to the chief judge of the Southern
District, instead making a record for possibly appeal and/or for the benefit of the readers.
Respectfully Submitted this the 3rd day of September, 2020
/s/Abby Robinson (MBN. 105157)
ABBY ROBINSON LAW FIRM PLLC.
227 E. Pearl Street
JACKSON, MS 39201
PH. 601-321-9343
FAX. 601-487-6326
EMAIL: arobinsonlawfirm@yahoo.com
EMAIL: abby@askabbylaw.com
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CERTIFICATE OF SERVICE
I the undersigned declare that on August 25, 2020, I have filed this document with the
court, electronically, and such system will deliver a copy to all parties.
/s/Abby Robinson (MBN. 105157)
ABBY ROBINSON LAW FIRM PLLC.
227 E. Pearl Street
JACKSON, MS 39201
PH. 601-321-9343
FAX. 601-487-6326
EMAIL: arobinsonlawfirm@yahoo.com
EMAIL: abby@askabbylaw.com
James C. Martin esq.
Martin Law Office, LLC
106-B W. Leake Street
Clinton, Mississippi 39056
email: jmartinlaw@comcast.net
Attorney for Defendant George’s Place Auto
David Lee Gladden Jr.
455 Pebble Creek Drive
Madison, Mississippi 39110
lgladde@gladdeingram.com
Attorney for GEICO Insurance
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