IN THE SUPREME COURT
OF PENNSYLVANIA
MIDDLE DISTRICT
_____________________________________
No. 250 M.D. Misc. Docket 1999
_____________________________________
O'DONNELL, WEISS & MATTEI, P.C.,
Respondent
vs.
John Allan Granger,
Petitioner
_____________________________________
MOTION FOR RECONSIDERATION
_____________________________________
Pennsylvania Superior Court Appeal
Pennsylvania Supreme Court Petition
John Allan Granger
2820 Audubon Village Drive, Suite 339
Audubon, Pennsylvania 19403
(610) 287-2109
Justice requires that the sacred trust of the people which has been placed in the hands of the Supreme Court Justice's be properly used to uphold Constitutional Oaths of Office to God, international treaties pursuant to the Supremacy Clause and all God given inalienable Constitutional Rights of Citizens. Rights and statutes were constantly violated in this case, and may represent a pattern of abuse that appears to continue in spite of required plenary review and supervision.
No competent attorney would attempt to officially deny petitioner, petitioners Fundamental Rights in open court. Yet petitioners Fundamental Rights were repeatedly denied by a professional corporation and portions of the Unified Judicial System in open court and by the denial of the Superior Court and the Supreme Court to take plenary appellate review. Now it appears that the entire Unified Judicial System condones this type of activity to protect one of their own to the extent of written admissions to ex-parte's, denial of a Citizen of Constitutional unlimited original jurisdiction, violations of promulgated local rules, incomplete transcripts, and by the denial of the Superior Court and the Supreme Court to take plenary appellate review.
The historical powers and jurisdiction which this Honorable Court has, and even more importantly, that which it specifically reserved for itself, appears to be some of the rights that Governor Casey proclaimed as Citizen Rights permanently established as legal doctrine in Pennsylvania and America! How can this be? William Penn, our founding father, was the first beneficiary of "trial by jury". This right of "trial by jury" was the right of the people to question the King and win, even if the King disagreed. Please do not tellme our Constitutional Republic has been allowed a return to feudalism on your watch.
In the light of Cohens and Marbury, a Citizen petition laid on the Constitutional King's bench, appears to be ignorable if the King would prefer it.
Cohens implicitly states and requires that court's must decide cases brought before them. Marbury and more recently Paula Jones have proven that now even the President of the United States of America can be sued in office. What is in the nature of the office of O'DONNELL, WEISS & MATTEI, P.C. that protects them from action in a normal manner, not even available to a sitting president?
A double standard most surely exists when an attorney and the judiciary attempt to hold themselves to be above the law. Legislators have sunshine laws that force them to do things in public. Attorney ethics are supposed to prevent back room justice.
The Court of Common Pleas has unlimited original jurisdiction in all cases except as may otherwise be provided by law. Petitioner's rights were violated when the lower court denied petitioner the same jurisdiction, which it had offered to respondent for a breach of the same contract.
The Oath of Witness is a sworn oath to God on a Bible. (Affirmation for atheists is another option; however, rarely used.) How can this Honorable Court possibly show any respect to the Bible, which Congress has decreed as the "written word of God", that theUnified Judicial System routinely solemnly uses in court and allow 'similar' Holy Bible's to be unprovokedly physically attacked by an opposing counsel during a "trial by jury"?
The throwing of petitioner's Holy Bible (Old and New Testaments) by respondent shows more than disrespect for the "written word of God" and may be considered a 'hate crime'.
An agency of the government must scrupulously observe rules, regulations, or procedures which it has established. When it fails to do so, its action cannot stand and courts will strike it down.
Mason states that petitioner cannot be needlessly penalized for reliance on U.S. Supreme Court decisions. Inherent in Mason is that the Pennsylvania Supreme Court must follow U.S. Supreme Court decisions.
It will be an evil day for American liberty if the theory of a government outside of the supreme law of the land finds lodgment in our constitutional jurisprudence. No higher duty rests upon this court than to exert its full authority to prevent all violation of the principles of the Constitution.
The contract is binding. Petitioner was bound, respondent appears not to be bound only because of office.
The attempts to claim that petitioner "waived all rights" is a weak excuse in direct conflictwith even this Court's ruling case law and is prejudicial to petitioner and all other Citizens alike.
U.S. Supreme Court Justice Anthony M. Kennedy recently wrote, "... interest (that) has been manifest since the beginning of our republic and is now well established."
Constitutional Oaths of Office to God, case law, and statutes aside,
God given inalienable Constitutional Rights of Citizens to freedom of Religion and protection of Government require this Honorable Court to address the issue of "Holy Bible" throwing by a defense attorney during a "trial by jury" and to seize in a Kings Bench capacity, plenary and extraordinary jurisdiction to review and decide this pivotal case on a point by point basis as requested in eighteen separate and distinct questions in the Superior Court appeal or remanded for a retrial in a "trial by jury".
Most respectfully submitted,
Dated: March 10, 2000 _____________________________
John Allan Granger, Petitioner
2820 Audubon Village Drive, Suite339
Audubon, Pennsylvania 19403
(610) 287-2109
VERIFICATION
John Allan Granger hereby certifies that the facts set forth in the foregoing "Motion for Reconsideration" are true and correct to the best of my knowledge, information and belief, and that this Verification is taken; subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsifications to authorities.
Dated: March 10, 2000 _____________________________
John Allan Granger, Petitioner
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving the foregoing "Motion for Reconsideration" upon the persons and in the manner indicated below which service satisfies the requirements of Pa.R.A.P. 3309(a):
Service by certified mail addressed as follows:
David A Megay, Esq. 610-323-2800
O'DONNELL, WEISS & MATTEI, P.C.
41 High Street
Pottstown, Pennsylvania 19464-0285
(Counsel for O'DONNELL, WEISS & MATTEI, P.C.)
March 10, 2000 ________________________
John Allan Granger, Petitioner
2820 Audubon Village Drive, Suite 339
Audubon, Pennsylvania 19403
(610) 287-2109