COMMONWEALTH OF KENTUYCKY
COURT OF APPEALS
CASE NO. 2005-CA-000411
STEVEN REDMON APPELLANT
V. APPEAL FROM JEFFERSON CIRCUIT COURT
ACTION NO. 03-CI-006808
LOUISVILLE AND JEFFERSON COUNTY APPELLEES
HUMAN RELATIONS COMMISSION
APPELLEES MOTION FOR COURT TO DENY ANY FURTHER EXTENSIONS TO APPLELLANT AND FOR THE COURT TO ENFORCE THE ORDER ISSUED MARCH 9, 2007 WHICH STATES: "It is further ORDERED that this appeal shall not be held in abeyance pending the remand. The record shows that appellant’s brief was due to be filed by March 5, 2007. Because this appeal has been pending for more than two years, appellant is hereby given no more than ten (10) additional days from the date of entry of this order in which to tender his brief to the Clerk of this Court for filing."
Comes now Jesse Garon, the real party in interest, and HATE CRIME VICTIM, of 7 years running now, still without justice stating: The Court having issued a very carefully worded ORDER of March 9, 2007 making it clear that Appellant was already past the March 5, 2007 filing deadline for briefs, and even stating further, the case having been pending for 2 years now that Appellant was to have "no more than ten (10) additional days" to file said brief. The Court was more than gracious to have extended the deadline of March 5, 2007 to March 19, 2007, considering the 2 years that has passed while this case has been on APPEAL, the 7 years that have passed since Steven Redmon began his HATE CRIME SPREE, and the violent nature of those crimes. Any further extension would make a mockery of the March 9, 2007 ORDER as issued by the Court and bring to question the authority of the ORDER in it’s entirety.
The issue of a jury trial Vs an administrative hearing is a very important one. If Louisville, Kentucky’s HUMAN RELATIONS COMMISSION is still unsure of how to proceed after the Jesse Garon case, then the next hate crime victim(s) can expect the same never ending Hell that has been life for Jesse Garon, his tenants, and family over the past 7 years. The KY COURT OF APPEALS has recognized the danger of leaving Louisville, Kentucky’s HUMAN RELATIONS COMMISSION confused and unable to prosecute a case. The Court has issued an ORDER that the case on APPEAL will go forward. It would be a gross injustice to now reverse, just the part of the ORDER, that does not suit counsel Jeffrey B. Skora’s schedule, and leave the next HATE CRIME victim(s) to suffer without justice.
Jesse Garon is not an attorney. Jesse Garon is a person trying to defend his civil rights, human rights, and interests from not only the Gay Bashers but from the very people who have claimed, when convenient, that they were representing Jesse Garon’s interest. This would be Mark Dobbins and William Walsh IV of TILFORD DOBBINS ALEXANDER BUCKAWAY & BLACK. The Court should be aware during this case one of Steven Redmon’s contractors became so concerned for Jesse Garon, his tenants, and family, because of things Steven Redmon was threatening to do, that the contractor came to the back door of the Jesse Garon house to let us know Steven Redmon was acting much more irrational than usual and that Steven Redmon was making many threats and was going to kill us after this case was settled. The HUMAN RELATIONS COMMISSION and TILFORD DOBBINS ALEXANDER BUCKAWAY & BLACK refused to take the witness’ statement of the new threats. The only excuse that was given for not taking the witness’ statement was that there would be plenty of time later for taking such statements. Does that sound like GROSS NEGLIGENCE to anyone other than Jesse Garon?
TILFORD DOBBINS ALEXANDER BUCKAWAY & BLACK informed Jesse Garon that if any additional criminal warrants were taken against Steven Redmon that it would once again stop the prosecution of Jesse Garon’s civil case against the Gay Basher and this case would drag on many more years.
TILFORD DOBBINS ALEXANDER BUCKAWAY & BLACK and the HUMAN RELATIONS COMMISSION have been kept informed of Steven Redmon’s repeated attacks. When Jesse Garon has requested an ORDER OF NO CONTACT be obtained (as is allowed by the HATE CRIMES ORDINANCE) The HUMAN RELATIONS COMMISSION has said they can have nothing else to do with this case once it is in the hands of the lawyers. The lawyers then claim they can do nothing in this case unless directed to do so by the HUMAN RELATIONS COMMISSION. For the victim(s) this going around in circles with everyone claiming they can do nothing is ridiculous and a seemingly perfect plan to exhaust the victim(s) in search of justice. Louisville Kentucky’s HUMAN RELATIONS COMMISSION has left the victim(s) unprotected, to fend for themselves for many years now.
Things have sometime gotten very violent and Jesse Garon is convinced that the only reason Jesse Garon is still alive is because Jesse Garon is licensed to carry a concealed weapon and one day when Steven Redmon and his conspirator Jerry Wheat blocked Jesse Garon’s vehicle, and Steven Redmon came at Jesse Garon with a box cutter knife, Jesse Garon by showing his gun, was able to stop Steven Redmon’s advance. Even when Steven Redmon stopped his advance Steven Redmon continued to brandish the knife and say things like "all fags had better carry guns if they want to live" and "all faggots should die" etc. Jesse Garon was able to make a retreat through a side alley. Steven Redmon chased Jesse Garon, continuing to say things and throw things. Jesse Garon called 911 for third district police who came to the location but refused to even make out a report on the incident.
Steven Redmon did not just attack once. It has been an ongoing thing from the year 2000. His menacing visits are looked upon as nothing more than humorous to the local law enforcement who have told us if we would act more like men this wouldn’t be happening.
The partial enforcement of an ORDER of the KY COURT OF APPEALS is absurd. The fact counsel Jeffery B. Skora would take it upon himself to just disregard the March 9 2007 ORDER and then dictate terms to the Court telling the KY COURT OF APPEALS what Jeffrey B. Skora is willing to do, shows a total lack of respect for the KY COURT OF APPEALS and the LAW. As a person and not an attorney might Jesse Garon ask the KY COURT OF APPEALS: Does an attorney get to disobey the March 9, 2007 ORDER and then tell the KY COURT OF APPEALS what the attorney will and won’t do? Just how does that work?
Jesse Garon objects to any further delay in the APPEAL before the KY COURT OF APPEALS. The delays in this case so far have destroyed Mr. Garon’s business, cost him his house, and his peace of mind. To now allow the attorneys to get together, again without consultation of the victim(s), and cut a little back door deal to go around the March 9, 2007 ORDER as Jeffery B. Skora admits: "Counsel for Mr. Redmon have spoken with the Commission’s attorney about the requests described above." would seem unethical and possibly illegal to Jesse Garon. If all it takes to get around an ORDER is for attorney’s to agree to disobey the ORDER, then tell the Court what they are willing to do instead, then what power does the KY COURT OF APPEALS have? Why not just "ask" the attorneys what they want to do in the first place? Why would Courts need to issue ORDERS if no one has to follow them?
Counsel for Steven Redmon has missed the deadline of March 5, 2007 and the graciously extended deadline in the ORDER of March 9, 2007. The KY COURT OF APPEALS’ ORDER of March 9, 2007 has been violated. Will the KY COURT OF APPEALS enforce the ORDER issued, as issued, or just the parts that please counsel for the HATE CRIME PERPETRATOR?
Counsel for Steven Redmon in the person of Jeffery B. Skora states in the Appellants Motion: "(Jesse Garon, in whose interest the Commission filed the underlying lawsuit against Mr. Redmon, has voiced his unhappiness with the settlement amount.) This is a blatant MISREPRESENTATION, by Jeffery B. Skora (commonly called a LIE by persons who are not attorneys). The HUMAN RELATIONS COMMISSION has filed no lawsuit against Steven Redmon. They have not even held a hearing in this case. It was Jeffrey Skora who filed the case that is on APPEAL. Jeffrey B. Skora’s statement that Jesse Garon was unhappy with the amount of the settlement is another blantant MISREPRESENTATION by Jeffrey B. Skora. Jesse Garon does not know what amount was offered as settlement, at the illegal, and unethical, meeting, held without Mr. Garon being present. Jesse Garon notified all parties prior to such meeting that Jesse Garon was not interested in another mediation session and just getting money from this. Money might make whole, the property destroyed, but it can never restore peace of mind. This case should proceed on record, in the proper venue, as decided by law, and Louisville, Kentucky should have to report the GAY HATE CRIMES to the FBI as the federal hate crimes statistics act requires. A monetary settlement would prevent the case from ever being reported as a GAY HATE CRIME. It would simply mean you can commit a HATE CRIME and then just pay off the victim to shut up.
Jeffery B. Skora states a settlement was reached. This is another MISREPRESENTATION to the KY COURT OF APPEALS by counsel for Steven Redmon. For a settlement to be reached all parties must be present and must have agreed to the terms of that settlement. Jesse Garon was not present and no legal settlement has been reached. Has anyone checked out the people in this case who are claiming to be attorneys to see if they really have a license?
Counsel for Steven Redmon, states : "This request is the first extension sought in this case by counsel for Mr. Redmon..." That is another MISREPRESENTATION by Jeffery B. Skora. Jeffery B. Skora has sought and been granted numerous deadline extensions in this case. If there had been no extensions the case would have been over in just a few months as the ordinance deadlines require and not now be in it’s 8th year.
Counsel for Steven Redmon states that counsel is just too busy to obey the court ORDER. Shall the Court enforce the ORDER of March 9, 2007 and take Jeffery B. Skora’s violation of that court ORDER as a serious matter, and a lack of respect for the KY COURT OF APPEALS, the law, and the HATE CRIMES victim(s)?
Peoples lives have been ruined by the violent HATE CRIMES in this case, but Jeffery B. Skora seems only concerned with his busy schedule and the KY COURT OF APPEALS’ ORDER of March 9, 2007 does not appear to have been on that schedule. It also appears that the original filing deadline of March 5, 2007 was also not on Jeffrey B. Skora’s schedule. Just how sure was Jeffery B. Skora that he, and Mark Dobbins, William Walsh IV, The HUMAN RELATIONS COMMISSION and the CITY OF LOUISVILLE PROSECUTORS OFFICE of Irv Maze, conspiratorial plan had gotten this case to disappear? He appears to have been sure enough that he did not take any deadlines seriously, even deadlines ORDERED by the Court. The victim(s) of Steven Redmon and his conspirators are still here. They are not invisible any longer, and they are seeking, and due some respect, and justice.
Jesse Garon would like to remind the court of the nature of the HATE CRIMES committed by Steven Redmon and his conspirators: Death threats, including with a weapon, tires flattened again and again, cut brake line, cut tire boots, menacing, witness tampering, windows broken out, and shot through, and more. These attacks have continued over a period of years. What advice have we gotten on dealing with Steven Redmon from the local government? "when you see him go inside your house and stay there until he leaves" or "why don’t you just move" NOTE: Steven Redmon travels to our location to harass us, moving would just increase his commute.
Another person, who has also filed a HATE CRIME COMPLAINT against Steven Redmon has become totally disabled due to a condition called social anxiety which causes victims to remain mostly housebound. This same person always kept a beautiful flower garden behind his house. It now lies abandoned and he must have a "safe" person accompany him outside the house. People such as Steven Redmon destroy lives and attorneys like Jeffrey B. Skora make it possible for them to continue to do so.
Since Jeffrey B. Skora offered the KY COURT OF APPEALS an alternative to him having to follow the ORDER of March 9, 2007, might Jesse Garon also make a suggestion. Enforce the ORDER of March 9, 2007 or issue an ORDER declaring Steven Redmon and his counsel truly above the law, declare open season on gay people, and declare the March 9, 2007 ORDER nullified, and the Court powerless to protect residents of Kentucky.
There was another court ORDER against Steven Redmon to have no contact with Jesse Garon, his tenants, or property. When Steven Redmon violated that ORDER the local 3rd district police refused to enforce the ORDER saying they "could not read the judges signature".
Christopher Stallings had Jesse Garon swear out more warrants for Steven Redmon and his conspirator Jerry Wheat. Christopher Stallings said that if we would swear out the additional warrants he would personally walk them to the judge for signing, and personally see to it that third district police served them. Christopher Stalling of the IRV MAZE county prosecutors office did take those warrants from the hand of Jesse Garon, in the warrant office but then Christopher Stallings never did what he promised. Those warrants were never served and according to, Nader Shunarah, another prosecutor for IRV MAZE’S office they have now disappeared.
Christopher Stalling of IRV MAZE’S office took a file containing many pictures and notes by POLICE OFFICER CONNIE FRACTION where she would come out to our location, and document the continued harassment by Steven Redmon and his conspirators. Now that file can not be found by IRV MAZE’S office. OFFICER CONNIE FRACTION was told by IRV MAZE’S office she can not take any more photos, or notes about this case. IRV MAZE’S office also told Jesse Garon to take down the video security cameras that have captured Steven Redmon, multiple times, during his HATE CRIME SPREE.
Mark Dobbins of TILFORD DOBBINS ALEXANDER BUCKAWAY & BLACK has said a staff attorney for the COURT OF APPEALS mediated what seemed like a reasonable settlement figure for this case. Mark Dobbins claims the reason for the necessity of doing this settlement without the victim being present is because Jesse Garon has been hard to reach. FOR THE RECORD: Jesse Garon’s phone number has not changed in over a decade, address has not changed, email has not changed. Jesse Garon is available to be contacted 24/7 by any of those means. Mark Dobbins is a LIAR. Mark Dobbins, William Walsh IV, the HUMAN RELATIONS COMMISSION and all attorneys in this case were well informed of the continued attacks and of the fact Jesse Garon is not just seeking compensation to restore what has been destroyed but also that the city of Louisville begin to report HATE CRIMES as required by law to the FBI.
Mark Dobbins has said he is in a difficult position and needing to finish this case in a reasonable way and in a way that is as vigorous as it needs to be. Are we to understand that Mark Dobbins and William Walsh IV are now claiming the right to decide what 7 years of terror, lived by persons other than themselves, is worth for settlement purposes? Are they also admiting to adjusting the level of legal representation according to their opinion of the seriousness of the crimes committed? HATE CRIMES are very serious no matter what opinion Mark Dobbins and William Walsh IV hold.
Mark Dobbins and William Walsh IV / TILFORD DOBBINS ALEXANDER BUCKAWAY & BLACK and the HUMAN RELATIONS COMMISSION never had any confusion over who was representing whom in this case until Jesse Garon refused to accept money to just go away and shut up. (Jesse Garon refused the 5 figure settlement offered years ago partly because if accepted, then the HATE CRIMES record vanishes)
The HUMAN RELATIONS COMMISSION was telling Jesse Garon that since they found probable cause against Steven Redmon it meant that the CITY OF LOUISVILLE was now furnishing legal representation to Jesse Garon for the civil claims. William Walsh IV confirmed this to Jesse Garon at the very first meeting of Jesse Garon with TILFORD DOBBINS ALEXANDER BUCKAWAY & BLACK LAW FIRM. When Jesse Garon later refused a monetary settlement and made it clear that this case was not about just paying Jesse Garon money to go away quietly, but that this case is about Louisville, Kentucky admitting to the HATE CRIMES and reporting the same to the FBI, as required by law, then, and only then did everyone begin to look for a way to separate the victim from his own civil case.
When Jerry Wheat, Steven Redmon’s brother in law, confessed (proudly, in a television interview) to also attacking the gay people in this case the HUMAN RELATIONS COMMISSION refused Jesse Garon’s request to amend the original complaint to include Jerry Wheat. TILFORD DOBBINS ALEXANDER BUCKAWAY & BLACK also refused Jesse Garon’s request to amend the complaint. NOTE: The ordinance says the complaint can be amended anytime before a judgment is entered. It is GROSS NEGLIGENCE by the HUMAN RELATIONS COMMISSION and TILFORD DOBBINS ALEXANDER BUCKAWAY & BLACK to refuse to amend the complaint. When the original complaint was filed there were numerous Steven Redmon conspirators who were unnamed because they were unknown to the victims and unidentified at that time.
When the attacks continued over several years Jesse Garon notified all concerned that another of the victim(s) was to be added to the complaint and the amount of damages were growing due to the ongoing harassment. The HUMAN RELATIONS COMMISSION and Mark Dobbins and William Walsh IV again refused to amend the complaint. This is GROSS NEGLIGENCE and in direct opposition to what the ordinance says.
The HUMAN RELATIONS COMMISSION and Mark Dobbins, and William Walsh IV / TILFORD DOBBINS ALEXANDER BUCKAWAY & BLACK have held up action on this case for years in an attempt to force the victims to settle. They have told the victim how poor Steven Redmon is and that you can not sue for the actual damages because Steven Redmon just does not have that kind of money. An examination of the very public property tax records for Steven Redmon and Jerry Wheat show the representations of poverty to be a lie.
The victims are not going away. In spite of the threats from Mark Dobbins about action if Jesse Garon continues to talk about this case. The truth will still be spoken. Jesse Garon has had his right to privacy destroyed by this case and the GROSS NEGLIGENCE of the very people entrusted by the HATE CRIMES ORDINANCE with the duty of obtaining justice for HATE CRIME VICTIMS. Perhaps they should read the MISSION STATEMENT of the ordinance.
Jesse Garon pleads with the court to enforce the duly issued ORDER of March 9, 2007 in it’s entirety, or to nullify it completely. We are at the mercy of IRV MAZE’S County Prosecutors office that failed to prosecute Steven Redmon and his conspirators in criminal court and now that same IRV MAZE’S county prosecutors office is trying to take over the civil case and exclude Jesse Garon from justice in that venue also.
Just how far will Louisville Metro go to keep GAY BASHERS and HATE CRIMES off the record.
Just how protected is Steven Redmon by Louisville, Metro and IRV MAZE’S county attorneys office?
Should not the KY COURT OF APPEALS now render a decision about the jury Vs administrative hearing case that is on APPEAL based on what is already in the record since counsel for Steven Redmon did not think it important enough to put it on his schedule, to file the briefs necessary, to meet the filing deadline of March 5, 2007or the extended deadline of March 19, 2007?
Please do not leave the next HATE CRIME VICTIM(S) to suffer this 7 year eternity of assault to human dignity.
Jesse Garon thanks the COURT for its consideration of this MOTION
Jesse Garon HATE CRIMES VICTIM and named party in this suit
P.O. Box 35361, Louisville, Ky 40232
phone (502) 638-0022
CERTIFICATE OF SERVICE
It his hereby affirmed that a copy of the foregoing was served on this _______day of __________, 2007 by U.S. Mail, postage pre-paid upon:
Michael R. Mazzoli
CO-COUNSEL FOR PETITIONER STEVEN REDMON
600 West Main St.,Suite 300
Louisville, Ky 40202
Mark W. Dobbins, William J. Walsh
TILFORD DOBBINS, ALEXANDER, BUCKAWAY & BLACK LLP
401 West Main Street Suite 1400
Louisville KY 40202
Jeffery B. Skora
600 West Main Street, Suite 300
Louisville, Kentucky 40202
Jesse Garon HATE CRIMES VICTIM
and named party in this suit
P.O. Box 35361
Louisville, Ky 40232