KGRKJGETMRETU895U-589TY5MIGM5JGB5SDFESFREWTGR54TY
Server : Apache/2.4.62
System : FreeBSD fbsdweb2.web.rcn.net 14.1-RELEASE FreeBSD 14.1-RELEASE releng/14.1-n267679-10e31f0946d8 GENERIC amd64
User : www ( 80)
PHP Version : 8.3.8
Disable Function : NONE
Directory :  /domains/justiceatwhatprice.c/archives/2010/04/

Upload File :
current_dir [ Writeable ] document_root [ Writeable ]

 

Current File : /domains/justiceatwhatprice.c/archives/2010/04/20100404.shtml
<!--#include virtual="/includes/archive.shtml"-->
 <div id="main"> <a name="#top"></a> <a name="#top"></a> 
    <h3 class="title">"Mr. Haddad, as you sit back and look at the past 6 years, what have you learned from this experience?"</h3>
    <h4 class="titlesmall">UPDATE: April 4, 2010</h4>
    <div id="print" style="border: 1px dashed #BBBBBB; padding: 0 0 0 0.5em; margin-top: 0.5em;"> 
      <p><a href="#" onclick="window.print();return false;"><img src="/images/print.gif" width="19" height="17" border="0" align="bottom"> 
        Print this page&#187;</a></p>
    </div>
    <p>Before I begin with specifics, "I believe God delights in setting up impossible situations � David against Goliath, Gideon with 300 men going into battle against 135,000 Midianites, eleven fearful apostles taking on the Roman Empire with the Gospel. In the midst of a society that values control, power, security, and human strength; it is no wonder we struggle to allow Christ to be formed in us through seemingly impossible situations."</p>
	<p>I have found that government and the Justice System in Massachusetts is broken; not so much due to the system itself, but clearly due to the lack of integrity of state employees, elected officials and those who are supposed to guaranty Liberty and Justice for all.</p>
	<p>Justices Lemire and Agnes of the Worcester Superior Court not only denied me "due process" in appealing the Flawed and Fraudulent Decision of the Massachusetts State Funeral Board, but further denied me "due process" and the opportunity to appeal Justice Agnes�s Decision(s) that are amass with statements supporting his decision(s) that are contrary to the facts in the case. Like the Massachusetts State Funeral Board Decision, the veritable facts in the Administrative Proceedings have no bearing or relevance to Justices of the Superior Court when it comes to readily disposing of cases that otherwise would have a major adverse impact on the "swamp of corruption" that has engulfed the Commonwealth of Massachusetts.</p>
	<p>I have decided to present (from the public record) the "Special Call to the Docket" I submitted to the Worcester Superior Court on February 25, 2010. Initially you will read my cover letter for the Special Call to the Docket followed immediately by the detailed "Call to the Docket". Please note: Every word presented in this "Call to the Docket" is supported by records, documents, and correspondences (and an audio tape of the conspiracy) in my possession. </p>
	<p>Read on and I will comment in the next update. Blessings all!</p>
	
	<h3 class="title">Philip G. Haddad, Jr.<br />9 Kenwood Avenue<br />Worcester, MA 01605-1321</h3>
    <h4 class="titlesmall">February 24, 2010</h4>
	
	<p>The Superior Court<br />
	Worcester Superior Court<br />
	225 Main Street, Room 1008<br />
	Worcester, MA 01608-1176<br />
	</p>
	<p>RE:  "SPECIAL APPEAL OF THE DOCKET"</p>
	<p>PHILIP G. HADDAD, Jr. v. BOARD OF REGISTRATION OF FUNERAL DIRECTORS AND EMBALMERS.<br />WORCESTER SUPERIOR COURT, C.C.07-0678-B</p>
	<p>Attached is the status of the appeals of Justice Agnes�s Decisions in Civil Docket <strong># WOCV2007-0678</strong> and Civil Docket <strong># WOCV2004-0390A.</strong></p>
	<p>As you will note on 23 January 2008, Justice Agnes requested and I consented to the transfer of <strong>WOCV2007-0678B</strong> to <strong>Session A</strong>; due to the relevance of the Administrative Appeal of the Massachusetts Funeral Board�s Decision to the Civil Proceedings in Civil Docket <strong># WOCV2004-0390A</strong>.</p>
	<p>Please note the fear and anxiety of the Assistant Attorney General (Reynolds-Martin) in Civil Docket <strong># WOCV2007-0678</strong> and that of Attorney Sinrich in Civil Docket <strong># WOCV2004-0390A</strong> to do everything in their power to persuade this court not to allow me the opportunity to subpoena witnesses � specifically Columbian Life Insurance Company representatives to include its former Regional Representative and Vice President of Pre-Need as well as families and Orthodox Clergy from Central Massachusetts � to testify to the truth and injustices in these matters.</p>
	<p>It is my fervent belief that the Court System, and Judges in particular, is to guarantee <strong>"fundamental fairness, justice, and liberty;</strong> and that <strong>"due process" is to protect the individual and to assure that no one is deprived of "life, liberty, or property" without a fair opportunity to affect the judgment or result.</strong></p>
	<p>As you take the time to read the attached, you will see that up to this point, "due process" has been denied me in the Administrative Proceedings as well as in the decisions made by Justices of this Superior Court.</p>
	<p>Respectfully,<br />Philip G. Haddad, Jr.</p>
	<h3 class="title">PHILIP G. HADDAD, Jr. v. BOARD OF REGISTRATION OF FUNERAL DIRECTORS AND EMBALMERS.<br />WORCESTER SUPERIOR COURT, C.C.07-0678-B</h3>
	<h3 class="title">RE:  "SPECIAL CALL OF THE DOCKET" STATUS OF THE APPEAL</h3>
	<h3 class="title">CHRONOLOGY -</h3>
	<ul>
	<li>On April 9, 2007 Plaintiff (Haddad) filed complaint and Civil Action with the Worcester Superior Court, paying a filing fee of $275.00 at that time purporting that "due process" was denied Plaintiff (Haddad) prior to and during the Administrative Hearing before the Division of Professional Licensure.</li>
	<li>Within days of the filing, Assistant Attorney General Reynolds-Martin (representing the Massachusetts Funeral Board) notified Plaintiff (Haddad) that he had filed the complaint in the wrong court. Assistant Attorney General Reynolds-Martin stated the complaint should have been filed in the Supreme Judicial Court, and that in three (3) days she would be filing for dismissal of the complaint for the incorrect filing.</li>
	<li>Plaintiff (Haddad) was scheduled to go on travel that next day, and cancelled his flight in order to file the complaint in the Supreme Judicial Court. The very next day Plaintiff (Haddad) contacted the Supreme Judicial Court, explained the situation to the Supreme Judicial Court and was informed Plaintiff (Haddad) had in deed filed the complaint properly in the Worcester Superior Court. Plaintiff (Haddad) so notified Assistant Attorney General Reynolds-Martin and re-scheduled his travel plans at an additional cost of $150.00 for the flight change.</li>
	<li>On July 12, 2007 Assistant Attorney General Reynolds-Martin filed Administrative Record Transcripts of Hearings (Volumes 1-7) � all of which were scheduled, arranged for, and paid for by Plaintiff (Haddad) � as the Division of Professional Licensure procedures called for the Administrative Hearings to be recorded on an audio tape. It should be noted that Plaintiff (Haddad) provided the Court Reporter Transcripts (7 volumes) to the Division of Professional Licensure at no charge. Plaintiff (Haddad) requested copies of the audio proceedings and was provided with 6 days of audio tapes (the 2nd day of the Administrative Hearing was lost) at a cost of $172.00. Come to find out the audio tapes for 6 days of the Administrative Hearings were inaudible, and the only record of the proceedings was the Administrative Record Transcripts of Hearings (Volumes 1-7) that Plaintiff (Haddad) had paid for and provided to the DPL.</li>
	<li>The Administrative Proceeding�s Record presented to the Worcester Superior Court was deficient, with pertinent information, documents, statements, and correspondence missing from the submission filed with the Worcester Superior Court by Assistant Attorney General Reynolds-Martin.</li>
	<li>On December 17, 2007 Plaintiff (Haddad) filed two (2) Motions with the Court alleging the Administrative Proceedings Record submitted by Assistant Attorney General Reynolds-Martin was incomplete. The first Motion was for the production of documents that were missing from the Administrative Proceedings Record, and would have had to exist in order for the Massachusetts Funeral Board to have made the decisions they did. For example, all investigative records of Investigator Bresnahan (DPL Investigator) were missing. Additionally Plaintiff (Haddad) had documents and an audio tape of the conspiracy initiated by the Chairman of the State Funeral Board on December 9, 2003 by and between the State Funeral Board Chairman (Kazlauskas), the DPL Investigator (Bresnahan) and the Mangsen�s (principal owners of Nordgren Memorial Chapel) and their attorney (Sinrich). The aforementioned documents and audio tape of the conspiracy were denied entrance into the Administrative Proceedings Record by Administrative Hearings Counsel, (Colleton).</li>
	<li>Unbelievably, Justice Lemire denied both motions without justification for his decisions. Plaintiff (Haddad) appealed both decisions of Justice Lemire only to be denied another time without a hearing. Hence the Administrative Proceedings Record before the Worcester Superior Court was and still is deficient.</li>
	<li>Since there was a direct relationship between Civil Docket <strong># WOCV2007-0678</strong> and Civil Docket <strong># WOCV2004-0390A</strong>, Justice Agnes requested that Plaintiff (Haddad) allow Civil Docket <strong># WOCV2007-0678</strong> to be transferred from Session B to Session A during a Trial Assignment Hearing on January 23, 2008. Plaintiff (Haddad), agreed to the transfer.</li>
	<li>On March 14, 2008, Plaintiff (Haddad) served upon the Worcester Superior Court �<br />
		<strong>Petition for Judicial Review, pursuant to Massachusetts General Law, Chapter<br />      
        112, Section 64 and Massachusetts General Law, Chapter 30A, Sections 14  &  <br />
        15. Decision of the Board of Funeral Directors and Embalmers dated March <br />
        13, 2007 and received on March 23, 2007 - Philip G. Haddad, Jr., License No. <br />
        5300  (Exhibit A). </strong></li>
	<li>If this court would take 15-20 minutes to review the content of this document, and cross reference the notations as prescribed; it would be clear to the court that Justice Agnes was ill-informed and was lied to as was the State Funeral Board by its Chairperson (Kazlauskas), by the Mangsen�s, and by their Attorney (Sinrich) as well as by Assistant Attorney General Reynolds-Martin.</li>
	<li>The Case Summary Civil Docket <strong># WOCV2007-0678</strong> is <strong>incorrect</strong> concerning entries on June 10, 2008. Plaintiff (Haddad�s) Motion for judgment on the proceedings was held before Justice Agnes and not Justice Lemire as stated on page three (3) of the  Case Summary Civil Docket <strong># WOCV2007-0678</strong>.</li>
	<li>The hearing on June 10, 2008 commenced at approximately 3:30 PM and abruptly concluded prior to 4:30 PM as the time was getting late for the court. Plaintiff (Haddad) submitted his opening remarks in writing for the record to the court.</li>	
	<li>Plaintiff (Haddad) was denied access to hostile witnesses (specifically representatives from Columbian Life Insurance Company of Binghamton, NY and its regional director and Vice President of Pre-Need (Klamkin) who were not required to honor Administrative Subpoenas during the Administrative Hearing�s Process, because they resided out of State. Indeed, the aforementioned parties would have had to honor subpoenas issued in civil proceedings. Not only was Plaintiff (Haddad) denied access to testimony by the aforementioned parties during the Administrative Proceedings, but Plaintiff (Haddad) was denied access to the aforementioned witnesses by Justices of the Superior Court. For you see, testimony by the aforementioned persons would, assuming they were to tell the truth, attest to the fact that not only did the State Board Chairman (Kazlauskas) and the DPL Investigator (Bresnahan) lie to the State Board Members and DPL prosecutors, but the Mangsen�s and their Attorney (Sinrich) were co-conspirators and they too lied to the State Board Members on December 9, 2003 and subsequently under oath during the Administrative Proceedings.</li>
	<li>Justice Agnes affirmed the decision of the State Board without allowing Plaintiff (Haddad) the "due process" denied him by the State Funeral Board.</li>
	<li>Justice Agnes further found for and made a decision for the Defendant�s (Nordgren Memorial Chapel) in Civil Docket <strong># WOCV2004-0390A</strong>, assessing a financial judgment against Plaintiff (Haddad) that Plaintiff (Haddad) did not have the opportunity to respond to either in writing or at a hearing. </li>
	<li>Justice Agnes further denied Plaintiff (Haddad) the opportunity to a jury trial in Civil Docket <strong># WOCV2004-0390A</strong>, that was agreed to by the courts and all parties and which was discussed during a hearing as to the number of witnesses to be called and number of days expected for the trial to take.</li>
	</ul>
	<h3 class="title">APPELLATE PROCESS & STATUS </h3>
	<ul>	
	<li>On August 25, 2008, Plaintiff (Haddad) filed notice to Court of Appeals, Worcester Superior Court, of Plaintiff (Haddad�s) Appeal of the decisions of Justice Agnes dated 31 July 2008, mailed on 5 August 2008, and received by Plaintiff (Haddad) on 12 August 2008 upon his return from travel in Civil Docket <strong># WOCV2007-0678</strong> and Civil Docket <strong># WOCV2004-0390A</strong> (Exhibit B).</li>
	<li>Plaintiff (Haddad) was advised by the Court that included in Plaintiff (Haddad�s) appeal needed to be copies of the 10 June 2008 Transcripts by the court reporter (Mr. David Roseboom) of the abbreviated hearing before Justice Agnes; at which time Justice Agnes took matters in both civil docket cases under advisement. Plaintiff (Haddad) immediately contacted Mr. Roseboom on 13 August 2008 and left a voice message on his telephone answering service concerning Plaintiff (Haddad�s) request.</li>
	<li>On 26 August 2008 (almost two weeks having passed without a response from Mr. Roseboom), Plaintiff Haddad wrote to Mr. Roseboom indicating Plaintiff Haddad was appealing Justice Agnes�s decisions in Civil Docket <strong># WOCV2007-0678</strong> and Civil Docket <strong># WOCV2004-0390A</strong> and that Plaintiff (Haddad) requested information in obtaining the applicable Transcripts of the 10 June 2008 Hearing before Justice Agnes. (Exhibit C).</li>
	<li>Two more months passed before my wife received a phone call from Mr. Roseboom (week of 24 October 2008) stating that the cost for the production of the 80 pages of Transcripts would be $240.00.</li>
	<li>On 28 October 2008, Plaintiff (Haddad) wrote to Mr. Roseboom stating Plaintiff (Haddad) had expended every dollar available to Plaintiff (Haddad) from any income source and that Plaintiff (Haddad) could not afford $240.00 for the Transcripts.  Plaintiff (Haddad) requested of Mr. Roseboom in the same correspondence the following � "My question to you and Worcester Superior Court! Is there another means of securing the transcripts via some means of public assistance? What standard is used to determine a cost of $3.00 per page? Can an exception be made under the circumstances? Please advise. I look forward to your timely response." (Exhibit D).</li>
	<li>In January 2009, Plaintiff (Haddad) received correspondence from Ms. Corrine L. Gorham, First Assistant Clerk, Worcester Superior Court, stating she was preparing the appeal packets in Civil Docket <strong># WOCV2007-0678</strong> and Civil Docket <strong># WOCV2004-0390A</strong> and would Plaintiff (Haddad) be forwarding Transcripts in the appeals?</li>
	<li>Desiring to be assured the information Plaintiff (Haddad) was relating was being understood and that Plaintiff (Haddad) understood the process, Plaintiff (Haddad) visited with Ms. Gorman at her offices in the Superior Court Office at the Worcester Court House. At that time Plaintiff (Haddad) made it clear to Ms. Gorman that no final decision could possibly be made in <strong>WOCV2004-0390A</strong> before an appeal was heard in Civil Docket <strong># WOCV2007-0678</strong>. On 27 January 2009, as requested, Plaintiff (Haddad) forwarded correspondence to Ms. Gorman explaining the situation for the record applicable for both Civil Docket <strong># WOCV2007-0678</strong> and Civil Docket <strong># WOCV2004-0390A</strong>. (Exhibit E).</li>
	<li>Here we are more than a year later, and Plaintiff (Haddad) has yet to receive an answer to Plaintiff (Haddad�s) request for an exception in the production of the Transcript of the 10 June 2008 Hearing before Justice Agnes made to Mr. Roseboom and related in great detail to (and with) Ms. Gorman.</li>
	<li>Plaintiff (Haddad�s) experience with the time it takes for the wheels of justice to function can be grueling and lengthy � for example, when Plaintiff (Haddad) was issued an Order to Show Cause by the Massachusetts Funeral Board on 29 June 2004, Plaintiff (Haddad) immediately requested a hearing. It took 19 months (19 January 2006) before the Administrative Hearing commenced � all the while Plaintiff (Haddad) was denied the opportunity to practice in his chosen profession. </li>
	</ul>
	<h3 class="title">SUMMATION �</h3>
	<ul>
	<li>Plaintiff (Haddad) states for and on the record that Plaintiff (Haddad) has open appeals in both Civil Docket <strong># WOCV2007-0678</strong> and Civil Docket <strong># WOCV2004-0390A</strong>.</li>
	<li>Plaintiff (Haddad) states for an on the record that Plaintiff (Haddad) has been denied "due process" in that the Administrative Proceeding�s Record as presented to the Court by Assistant Attorney General Reynolds-Martin on behalf of the Massachusetts Funeral Board was and is incomplete and intentionally deficient.</li>
	<li>Plaintiff (Haddad) states for and on the record that Plaintiff (Haddad) was denied "due process" by being deprived of the full record to include the investigative records of the Investigator (Bresnahan), DPL for subject appeals.</li>
	<li>Plaintiff (Haddad) states for an on the record that Plaintiff (Haddad) has been denied "due process" in that Plaintiff (Haddad) has been denied access to hostile witnesses from Columbian Life Insurance Company, Binghamton, NY to include its regional representative and Vice President of Pre-need (Klamkin) by both the Massachusetts Funeral Board and Division of Professional Licensure � as well as the Justices of the Worcester Superior Court.</li>
	<li>Plaintiff (Haddad) states for and on the record that it is patently clear to Plaintiff (Haddad) and it should be patently clear to the Justices of the Court of Appeals that the Massachusetts Funeral Board clearly violated Plaintiff (Haddad�s) civil and constitutional rights (See Exhibit A). To hear for yourselves the actual conspiracy in the words of the perpetrators, review the audio tape of the December 9, 2003 Meeting of the Massachusetts Funeral Board � said audio tape forwarded and included in the Motion to the court on 17 December 2007.</li>
	<li>The Commonwealth of Massachusetts � specifically the Massachusetts Funeral Board, Division of Professional Licensure, and the Office of the Attorney General are fearful that the testimony of hostile witnesses from Columbian Life Insurance Company, Binghamton, NY to include its regional representative and Vice President of Pre-need (Klamkin) will expose the conspiracy, corruption, and cover-up by the Massachusetts Funeral Board, it�s former Chairman, and it�s investigator; and that the aforementioned parties were aware that their actions were fraudulent and criminal in their intent and purpose leading to Civil Docket <strong># WOCV2007-0678</strong>.</li>
	<li>Nordgren Memorial Chapel and its attorney (Scott Sinrich) are fearful that the testimony of hostile witnesses from Columbian Life Insurance Company, Binghamton, NY to include its regional representative and Vice President of Pre-need (Klamkin) will expose their direct involvement in the conspiracy to include lies and distortions made to the Massachusetts Funeral Board in person and under oath leading to the conspiracy, corruption, and cover-up � with the sole purpose to find legitimate means to terminate Plaintiff (Haddad�s) employment at Nordgren Memorial Chapel.</li>
	<li>The aforementioned facts which will be proven during appeals and at trial will clearly demonstrate not only were lies perpetrated in the Administrative Proceedings by Nordgren Memorial Chapel principals (Kurt and Katherine Mangsen), but that their Attorney (Sinrich) outright lied to the Massachusetts Funeral Board and Division of Professional Licensure as well as Justices of the Worcester Superior Court. Each time Atty. Sinrich was about to be "found out", Atty. Sinrich would throw up a smoke screen to divert attention away from himself. Examples of this fact are � 
	<ul>
	<li>Attempts to shut down the web site www.justiceatwhatprice.com which details all elements of the issues before this court and Atty. Sinrich�s actions and false statements and those of his clients</li>
	<li>Atty. Sinrich, about to be exposed for his baseless statements and lies to the Massachusetts State Board with the ultimate release of the audio tape of the conspiracy during the Meeting of the Massachusetts Funeral Board on December 9, 2003, sought out a funeral industry trade publication and presented false statements and further lies to the editor of the publication which then viciously attacked Plaintiff (Haddad) in no less than 6 issues of its publication. In a cover letter to the publication�s editor, Atty. Sinrich stated � <strong>"And our conversation of November 3, 2004 is Off-The-Record!"</strong></li>
	<li>Atty. Sinrich filed a false and baseless criminal complaint against Plaintiff (Haddad) with the Office of the District Attorney (Joseph Early) stating that Plaintiff (Haddad) had made veiled threats against the lives of the Mangsen�s children. Massachusetts State Police found the complaint a personal attack on the Plaintiff (Haddad), baseless in its intent, and without merit</li>
	</ul>
	</li>
	</ul>
	<p>Plaintiff (Haddad) could go on and on, but Plaintiff (Haddad) believes you get the picture. Plaintiff (Haddad) was singled out, denied "due process", falsely accused of wrong-doings that were done at the hands of and at the direction of corporate officials at Nordgren Memorial Chapel� all in an attempt to terminate Plaintiff (Haddad�s) employment. The testimony of hostile witnesses from Columbian Life Insurance Company, Binghamton, NY to include its regional representative and Vice President of Pre-need (Klamkin) will expose the scandal that will rock the Commonwealth of Massachusetts at its very foundation to be heard and seen far and wide.</p>
	<p>Plaintiff (Haddad) looks forward to the Appellate Processes, to subpoenaing the appropriate witnesses, and to the trial guaranteed to Plaintiff (Haddad) under the constitution of the United States.</p>
	<p>Respectfully,</p>
	<p>Philip G. Haddad, Jr.</p>
	<p>(Pro Se)</p>
	<p>Dated -  February 24, 2010</p>
</div>
<!--#include virtual="/includes/footr.shtml"-->



Anon7 - 2021