Us Supreme Court Writ

Published on May 2016 | Categories: Documents | Downloads: 15 | Comments: 0 | Views: 265
of 20
Download PDF   Embed   Report



No: IN THE SUPREME COUT OF UNITED STATES Wells Fargo & Bank of America (mortgagees) vs Frances Endencia (mortgagor) Petitioner Vs Village of Streamwood, IL Dept of Financial & Professional Reg (IDFPR) & American Psychiatric Assn Illinois Licensees: **Alex Reynish Behavioral Health Care **Stafford Henry Respondents ) IL Supreme Court ) 1st Judicial District ) Case No 111783 ) ) Appellate Court ) 1st Judicial District ) Case No: 10-1319 ) ) Circuit Court, Cook ) County, Illinois ) First Judicial District Judge ) Case No 09 M3 0341 ) The Honorable Fink ) Trial Judge Presiding ) ) IDFPR ) Cook County, Illinois ) Case No 2005 01942 ) The Honorable Canavan ) Trial Judge Presiding )

Writ of Certiorari

Frances Endencia Petitioner in Pro Sec 222 Burnside Circle Bartlett IL 60103 630.823.8176

Issues Presented As a matter of fact: The Village of Streamwood Illinois Code Ordinance 907.14.14 and 510.2 requires business owners / building owners to provide keys keys to the fire department, so they can access all parts of the building any time they wish to come in, is a common ordinance throughout the Unites States. It is a violation to the USCA Constitutional amendment XIV 1 - Privileges. The code is opportunistic for crime, especially when there is a social relationship between the security company and the police & fire departments. These keys are placed in Knox Boxes or other key holders. Unethical government employees utilize the name of the law to be able to enter premises as an excuse. Illinois has state laws that provide immunity against lawsuits for any government employees' wrong doing. They are "immune" from lawsuits in 745 ILCS 10/2 209) (from Ch. 85, par. 2 -209) Sec. 2 - A public employee is not liable for an 209. injury arising out of his entry upon any property where such entry is express or implied, authorized by law. Because of state immunity laws, government employees are allowed to commit crime. For example, today's Illinois Department of Children & Family Services (DCFS) is an organization that profits by destroying families. Utilizing the services of psychiatrists and their teachings, their organization survives by their employees' work of inducing severe i

psychological hatred against their parents, so that children and their adopted care giver would attack their parents. Despite the severe financial, emotional, psychological (to the extent that they have killed an unborn child caused by the stress they induced) effects, they are not liable.(745 ILCS 10/2 -204) (from Ch. 85, par. 2 -204) Sec. 2 204. Except as otherwise provided by statute, a public employee, as such and acting within the scope of his employment, is not liable for an injury caused by the act or omission of another person. As a Matter of Law. In pursuant to 815 ILCS 510/2 (7) & (12) of the Illinois Deceptive Practice Act, psychiatrists do not use facts nor pathology, nor science to diagnose. They utilize hearsay, word and picture games to create medical conditions, then provide the public with psychiatric drugs to induce bio-chemical imbalance of the brain. Psychiatry is an art of creating a belief that psychiatric drugs are needed for a person to be ¡§normal¡¨.Medical malpractice is not the applicable law, since it is usual for psychiatrists to diagnose by fiction. IDFPR licenses psychiatrists. Due to lack of scientific basis, I am asking the court to allow the use of Illinois Consumer Fraud & Deceptive Practice Act theory.


Parties to the Proceeding The Petitioner in pro sec is Dr Frances Endencia, DVM, owner of The Pampered Pet Veterinary Service (8/1999 - 11/2007), located at 140 N Barrington Road, Streamwood IL 60107. Petitioner is also a mortgagor in foreclosure proceedings: Wells Fargo vs Endencia 2010 CH 000882, IL Appellate Court 2-11-0257 and 2010 CH 04350 IL Appellate Court 2-11-0256

Foreclosure is due to lack of sufficient income since the suspension of veterinary license caused by the State of Illinois' refusal to investigate criminal activity in the police department and support for the fictitious work of psychiatrists, Stafford Henry and Alex Reynish. I am requesting this court to combine the cases into one complaint, due to the domino effect activity. Respondents are: State of Illinois, Illinois Department of Financial & Professional Regulations, hereby referred to as IDFPR, American Psychiatric Association Illinois licensees: Stafford Henry & Alex Reynish and The Village of Streamwood.



Judgments Below IL Supreme Court Order Appellate Court Petition for Rehearing, denied 11/23/10 Endencia vs Behavioral Health Care Associates 09 M3 0341 moot decision. Notice of Appeal February 16, 2010 Case is a consolidation of several cases IDFPR vs Endencia, Case No 2005 01942 IDFPR vs Endencia Case No 08-3543, Administrative Review, denied Endencia vs IDFPR, Circuit Court Case No 08 CH 39067 Judge Epstein, case dismissed for lack of jurisdiction. Endencia vs IDFPR, Appellate Court 08 CH 39067 Endencia vs Village of Streamwood, ADT, Fred Mazur, Rachel Johnson, PMH Partners Drs John Coyne & Joel Prince Case No 08 L 000221 voluntarily dismissal except ADT - transferred to federal court Endencia vs ADT Security Services No 08 C 4541, Federal Circuit Court 7th Circuit, Judge Der-Yeghiayan, case was dismissed; Endencia v.ADT Federal Appellate Court No 08-4071, case was denied; Endencia v ADT, Village of Streamwood & IDFPR Case No 09 6579 as a Writ of Certiorari; Case against ADT Security Services was dismissed.

United States Supreme Court required cases against IDFPR & Village of Streamwood be brought to Illinois Courts PMH Partners vs Pampered Pet Veterinary Service, Frances Endencia Case No 03 L 5915 default judgment due to accounting fraud on the part of the seller plaintiff. Wells Fargo, mortgagee vs Endencia, mortgagor 10 CH 0882 IL Appellate Court No IL Supreme Court No Wells Fargo, mortgagee vs Endencia, mortgagor 10 CH IL Appellate Court No IL Supreme Court No Points Relied Upon Village of Streamwood, Sec 510.2 & 907.14.4 USCA Constitutional Amendment XIV 1 Privileges 815 ILCS 10/8: Social relationship with ADT 815 ILCS 510 / 1(3) 815 ILCS 510 / 2(7) & (12) 13 COA 2d 453 Causes of Action Negligence or Malpractice Action of Psychiatrists Diagnostic Statistical Manual for Mental Disorders, 4th Edition. American Psychiatric Association. 2005. pp 26-33; pp 92-93 (A p98) Dymek v Nyquist 128 Ill App 3d 859, 469 NE 2d 659, Ill App 1 Dist

1984, Sept 18, 1998 Frye v United States 54 App DC 46, 293 F 1013 CADC 192 Dec 3, 1923 09/01/2009 (p A 90) 08/21/2007 MV v Charter Terre Haute Behavioral Health System Inc 1999 WL 59812 (Ind Ct App 1999) Noto v St Vincent Hospital & Medical Center of New York, 142 Misc 2d 292, 537 NYS 2d 446 (Sup Ct 1988) 160 AD 2d 656, 559 NYS 2d 510 (1st Dist 1990) People v Cumbee 851 NE 2d 934 Ill App 2 Dist 2006 People v Sassu 502 NE 2d 1047 Ill App 1 Dist 1986 Vyanase Advertisement. Shire US Inc. Wayne PA 19087. 2 / 2007. Statement of Facts The Village of Streamwood has an ordinance requiring keys to be provided to the Fire department. The keys are placed in a ¡§Black Box¡¨ outside the building. Village of Streamwood, Section 510.2 & 907.14.4 Security Key Box. A few months after I bought the business, Streamwood Police Department contacted me saying they found stolen checks in their evidentiary unit. One of my original employees from Drs Prince & Coyne explained to me that there was an incident were the cash & checks were stolen, without forced entry. They left leaving the back

door open. From 1999 till today, I experienced break ins and blamed my employees / other people for the losses. Deliveries worth at least a thousand dollars would disappear overnight. There were no forced entries. ADT nor the cops never alerted me of presence of break ins. In March 2005, my business was vandalized. No one had the keys at that time except myself and the Fire Department. I filed a police report. Streamwood Police Department contacted IDFPR and made recommendations of Psychiatric Evaluation. IDFPR contacted me and referred me to Rush Behavioral Health Care Associates, led by their expert witness, Dr Stafford Henry. He & his staff created a medical condition out of the police report (p ) and abstract pictures. (p A-90) The report was not accurate. (p ) At trial court, IDFPR vs Endencia 2005 01942, I informed the court of the theft problems. IDFPR prosecuted the case as a psychiatric medical condition. The report led to the suspension of my veterinary license. (p A-8) A second opinion was sought through Dr Alex Reynish, of Behavioral Health Care Associates. (p A-69) He corroborated with the medical report I provided to him. I took his psychiatric diagnostic tests, which consisted of abstract pictures and words. (Rorschach test, Wechsler Abbreviated Scale of Intelligence & Personality Adjective List). Out of abstract pictures and words, he was able to generate a 10 page single line spacing personality profile one year later. These ¡§tests¡¨ are trivial games played by the public for fun. Psychologically depressed psychiatrists, such as Drs Alex

Reynish and Stafford Henry would put meaning in trivia and create medical conditions out of it. The actions of the defendants caused severe emotional & financial destruction to me and my family. The constant stress inflicted by the constant theft harassment that lead to: (1) fire own employees (2) suspension of my veterinary license that caused (a) my credit score rating go down from good rating to poor, which created a loss of credit resource (b) Foreclosure proceedings of my home 2010 CH 04350 (p A-51) Foreclosure proceedings of my apartment building 10 CH 8825 (c) Inability to financially and emotionally support my daughter that caused her to leave home due to lack of financial resources; (d) Defamation of personal reputation; Harassment of friends & family due to label given by psychiatrist; false imprisonment to a mental health facility. The incident caused me to lose a job application. In Noto v St Vincent Hospital & Medical Center of New York, 142 Misc 2d 292, 537 NYS 2d 446 (Sup Ct 1988) 160 AD 2d 656, 559 NYS 2d 510 (1st Dist 1990), plaintiff was detained in hospital that lead to claims of false imprisonment. Other cases are: MV v Charter Terre Haute Behavioral Health System Inc 1999 WL 59812 (Ind Ct App 1999) A moot order (p A-7) was given by presiding Hon Judge Fink regarding the issue of diagnostic tests provided by defendant, Behavioral Health Care

Associates. As in Frye v United States 54 App DC 46, 293 F 1013 CADC 192 December 3, 1923, it is usual and customary for psychiatrists to utilize unscientific methods to diagnose a psychiatric condition. Rehearing denied by 1st District Appellate Court on November 23, 2010. Argument Village of Streamwood. The Village Ordinance requiring keys to be provided to the Fire Department so they can access all parts of the building during emergency without forced entry damage or delay makes their job easier, in case of fire or medical alert. It helps save lives and property. There is a problem with said ordinance. It is opportunistic for their personnel or agents to enter any premises when closed (late at night) or vacant. Theft, vandalism and other crimes can occur. It is natural for owners to suspect own employees since the public views the police as protecting citzens. From 1999 till today despite having an ADT security system, I was never alerted when break ins occurred. The village of Streamwood was negligent in keeping keys in a safe & secure environment. I lost at least $30,000. According to the ADT Mail Tribune, ADT employs people that work for the state, federal and local government. They have a social relationship with government employees. ADT Security Services funded the National Retail Security Survey, which was conducted by the University of Florida. According to their survey, losses for 2008 alone totaled $36.5 billion, due to shoplifters, employee theft, etc.

The ordinance requiring business owners to provide keys to the fire department is a violation of USCA Constitutional Amendment XIV 1 Privileges. Since they are employees of the state, the public cannot sue them for injury, due to the immunity status provided by Illinois law Illinois Department of Financial & Professional Regulations. licenses the medical profession. The medical record of a medical professional is based on facts and science. Despite the findings of normal blood tests, urinalysis and MRI scans, they ¡§created¡¨ a series of diagnostic tests not relevant to the situation. Psychiatrists diagnose people based on trivia (pictures & words) & their overactive imagination. Psychiatry is an art of making people believe their services are needed and the drugs they provide is necessary to become ¡§normal¡¨. They create pathology and bio chemical imbalance of the brain. IDFPR and the American Psychiatric Association misrepresent to the public that: (1) Psychiatry is based on science and facts. (2) The psychiatric drugs are safe to use for long term, especially in growing children (3) The consequent behavioral problems (such as murder) and drug induced mental retardation is not caused by the bio chemical imbalance of the brain. American Psychiatric Association, Illinois Licensee Holders: Alex Reynish, (Behavioral Health Care Associates) & Stafford Henry . Mankind has a history of degrading fellow men, as a mindset and culture.

African slavery occurred stems from the belief & culture that white man was superior to other races. The victory of Hitler and murder of 6 million Jews came from a mindset and culture of racism. Islam has a mindset that suicide bombers are noble and rewarded in the next life. Psychiatry is an art of creating a mindset to degrade someone in the community by labeling into psychiatric medical conditions. American culture is medical dependent. Drugs are used to prevent pregnancy, and, in this scenario, drugs are used to train children. History of Psychiatry show medical abuse as normal & usual: electro- convulsive therapy, removal of brain tissue, insulin therapy and today, psychotropic drug therapy. Each treatment deals with altering the brain by creating pathology. Psychiatrists prey on the fragile: young children and people who are psychologically weak. Psychologically depressed psychiatrists are unable to create a positive impact in their patient¡¦s lives. Positive, happy psychiatrists / psychologists create positive drug free lives. To name one, Dr Vincent Van Peale is widely renowned for his writings and work by making people think and learn to change their mindset. (The situation varies for each patient).

Psychiatrists are transformational leaders. They are licensed to create unscientific medical conditions.

They are licensed to induce pathology in the brain. Psychiatrists earn a living by creating malicious labels, aka medical conditions, such as ADD, ADHD, bipolar disorders, etc. In their medical report, they create the illusion they wish to achieve. After the diagnosis, they prescribe drugs that cause brain tissue destruction and chemical imbalance of the brain. They misrepresent to the public that these drugs are safe to use for long term use. Consumers do not comprehend what is going on. Psychiatrists are utilized by the court and general public. Their services are highly respected and utilized. Traits of Psychological Medical Abusers 1. Creates events, normal behavior, character or habits into medical conditions. Utilize hearsay. 2. Uses the environment to support diagnosis / degradation. Uses drugs to control school and home environment. 3. Failure to refer issues to proper agencies. 4. Believes drugs are the solutions to life's problems. 5. Does not use facts and sciences for diagnosis. No investigations. 6. Enjoys labeling and degrading people. 7. People pleaser. Gives drugs to anyone who is subject to complaint. 8. Has full knowledge effects of drugs causing permanent brain damage. Socio-Economic Effects of Psychological Medica (Child) Abuse 1. Drop out of high school. 2. Frequently fired by jobs.

3. Sex earlier - teen age pregnancy. 4. Higher credit card debt. 5. Traffic collisions / traffic citations. 6. Experiment with illegal drugs. 7. Abandonment / ostracism by family and friends leading to physical, emotional, psychological abuse. 8. Provocative attacks by family, friends and society that lead to aggressive behavior, suicide or murder. 9. Mental disorders leading to more severe conditions due to increase in prescribed drugs. 10. Economic impact. In 1990, there were 900 American kids on it. Today, there are about 3 million Theoretical Economic Impact Cost of drug per month per year x 12 $100 $1,200 $50,000

Psychiatric / doctors' visits (diagnosis & treatment) lifetime (???)

Number of years (50 yrs x 12 mo/yr x 100 cost/mo) on medication, leading to drug dependency, constant psychological problems $60,000

Public aid / social security benefits @ $1,000 / mo (30 yrs x 12 mo/yr x $1,000 benefits / mo Total per lifetime $470,000 $360,000

multiply that with 3 million (current population on psychiatric drugs) $1,410,000,000,000 The above does not include loss of revenue of creating productive citizens, cost of crime, cost of pregnancies. Conclusion In Frye v United States 54 App DC 46, 293 F 1013 CADC 192 December 3, 1923, a systolic blood pressure deception test was utilized for a murder conviction. Frye appealed. The test is based on the belief that truth is spontaneous and come without conscious effort, which is reflected by increase in blood pressure. It did not hold scientific recognition among psychological communities to justify the court's admitting as an expert testimony on defendant's behalf deduced from experiments thus far made. While the courts will go a long way in admitting expert testimony deduced from a well recognized scientific principle or discovery, the thing from which deduction is made must be sufficiently established to have gained general acceptance in the particular field it belongs. The rule is that opinions of experts or skilled witnesses are admissible in those cases in which the matter of inquiry is such that inexperienced persons are unlikely to prove capable of forming a correct judgment upon it, for the reason that the subject matter so far partakes of a science, art or trade as to require a previous habit or experience or study in it, in order to acquire knowledge of it. When the question involved does not lie within the range of common experience or common knowledge, but requires special

experience or special knowledge, then the opinions of witnesses skilled in that particular science, art, trade to which question relates are admissible. Other cases such as People v Sassu 502 NE 2d 1047 Ill App 1 Dist 1986 and People v Cumbee 851 NE 2d 934 Ill App 2 Dist 2006 utilize scientific evidence in admitting expert testimony. In 13 COA 2d 453, Causes of Action Negligence or Malpractice Action of Psychiatrists, plaintiff must present evidence of: (1) Intentional or reckless conduct (2) Extreme, outrageous (3) Cause emotional stress (4) Severe In the schools of the American Psychiatric Association, they train students to provide abnormal evaluations & utilize pictures, words & hearsay to create psychiatric medical condition. To the public, these are trivia. To them, circumstances, events, facts, hearsay bad habits, or character become a medical disorder. In the practice of true medicine, 13 COA 2d 453, Causes of Action Negligence or Malpractice Action treatment is based on pathology. Psychiatrists induce pathology by treating and providing psychiatric drugs, which cause bio chemical imbalance of the brain leading to permanent brain tissue death, brain tissue removal, electro convulsive therapy and insulin therapy. These therapies lead to behavioral problems when therapy is discontinued. Bloom v Braum 317 Ill App 3d 720, 739 NE 2d 925, IL App 1 Dist 2000, Nov 1, 2007, psychiatrist misrepresented therapeutic recovered memories with a diagnosis of "Personality disorder as a result of satanic ritual abuse" plaintiff was injured as result of psychiatrist's psychotherapy, pre existing

maladies independent of things. In the above referenced case, Fraudulent Concealment of defendant psychiatrists, misrepresent scientific & medical nature of psychotherapy & deceived into therapy. Fraud occurred at the beginning of therapy; it did not occur after the injury. In Dymek v Nyquist 128 Ill App 3d 859, 469 NE 2d 659, Ill App 1 Dist 1984, Sept 18, 1998, Dr Nyquist & Rehte (wife) was to gain physical & mental custody & control of (Robert) and to maliciously, unlawfully injure plaintiff in mental & emotional well being by alienation and destroy affection of (Robert toward plaintiff) through unauthorized, unnecessary treatment. Since the nature of unscientific diagnosis & treatment in psychiatry is usual and customary by causing bio chemical imbalance of the brain, and other brain altering treatment, the IL Consumer Fraud & Deceptive Practice Act is the appropriate theory in pursuing this case. Summary I bought my business from Drs Joel Prince & John Coyne, I experienced numerous break ins: theft & vandalism. I had ADT security system that was in good working condition. During the break ins, I was never notified of their presence. In the Village of Streamwood, there was an ordinance

requiring business owners to provide keys to the Fire Department. In March 2005, my business was vandalized. I contacted the Streamwood Police Department, who in turn reported me to IDFPR. I was required to

have a psychiatric evaluation, which consisted of pictures and words that led to a psychiatric medical condition. For second opinion, I visited Dr Alex Reynish. Again the diagnostic test & treatment was based on abstract pictures. Psychiatrists are trained in American Schools of Psychiatry to provide abnormal evaluations to the public using words and pictures, which is deviating from the science of medicine. Plaintiff is asking this court to allow the use of Consumer Fraud & Deceptive Practice Act against defendants, Dr Alex Reynish & Dr Stafford Henry. Psychiatry is not based on facts or science. Psychiatry is a belief instilled in people that they need drugs to become "normal¨. This is how psychiatrists earn their livelihood. "Psychiatrists are transformational leaders. They are licensed to provide abnormal evaluations to the public. They are licensed to create brain pathology."

___________________________________________________________ _______ Frances Endencia Petitioner Vs Village of Streamwood IL Dept of Financial & Professional Regulations (IDFPR) & American Psychiatric Association Illinois Licensee Holders: Alex Reynish Stafford Henry Respondents APPENDIX IN THE SUPREME COURT OF ILLINOIS DECEMBER 2010 Frances Endencia Petitioner vs Village of Streamwood, IL Department of Financial & Professional Regulations, & American Psychiatric Association (licensee holder: Behavioral Health Care Associates Alex Reynish, Psy. D) Respondents ___________________________________________________________ ___ Appendix Table of Contents Amended Complaint A-1 Appellate Court Order, Rehearing Denied November 23,2010 A-4 Appellate Court Order, Strike Plaintiff¡¦s Brief & Rehearing Denied A-5 Notice of Appeal, 09 M3 0341 filed Feb 16, 2010 A-6 Trial Order: Endencia v Behavioral Health Care Assoc A-7 Appellate Order: Endencia v IDFPR, 1-08-3543 IDFPR Order: IDFPR v Endencia A-8 Administrative Law Judge Report & Recommendation A-18 Endencia vs IDFPR IL Appellate Court Order, 08 CH 39067 A-34 Endencia vs Village of Streamwoo, Fred Mazur, Rachel Johnson, ADT, Dr John Coyne & Dr Joel Prince Circuit Court No 2008 L 00021 Presiding Judge Larson for discovery. Voluntarily dismissed defendants except ADT Security System, who transferred the case to Federal Court A-37 Endencia vs ADT Fed Court 7th Circuit 08 C 4541, Judge Der Yeghiayan A-39 Endencia vs ADT Fed Appellate Court 08- 407, May 21, 2009 A-48

Writ of Certiorari: Endencia vs ADT, IDFPR & Village of Streamwood, ADT was dismissed A-50 Wells Fargo vs Endencia vs IDFPR, Judge Gibson foreclosure A-51 Dr Stafford¡¦s Multi-Disciplinary Assessment Programs A-52 Dr Alex Reynish Medical Report A-69 Village of Streamwood Security Key Box Ordinance A-83 Pictures Pampered Pet Vet Service A-85 Streamwood Police Report 3/12/2005 A-89 The Rorschach Test A-90 Vyanase Advertisement A-97 Multi-Axial Assessment A-98 Financial ties link some docs, drug companies A-105 Facebook friends A-108 IN THE SUPREME COURT OF ILLINOIS FIRST DISTRICT Frances Endencia | Appellate Court V | No: 10 ¡V 1319 Village of Streamwood, | IDFPR & | Behavioral Health Care Associates | c/o American Psychiatric Association | Amended Complaint 1) Tort. In pursuant to USCA Constitutional Amendment XIV 1 Privileges, the Village of Streamwood Ordinance 907.14.4 & Ordinance 510.2 Security Key Box required business owners keys to the Fire Department to be able to access all portions of the building. a) Since 1993, keys were provided to the fire department by Stacy & Casey Dukala, who owns Daisy Flowers of the same strip mall. b) Plaintiff dutifully complied in providing key on Oct 2004. c) The ordinance provide opportunity for their personnel or agents to commit crime. d) The Village of Streamwood was negligent in putting keys in a secure environment. The box with the keys was placed outside the building. Anybody can access the box. 2) Tort. In pursuant to 815 ILCS 10/8, the Village of Streamwood has a social relationship with ADT, my security provider. 3) Breach of Peace. 405 ILCS 5/1 ¡V 104.5 & 725 ILCS 5/110A-25. I lost at least $30,000 in theft from 1999 till 2007, without forced Entries and the security system never went off. A-1 a) I reported the incident to the Streamwood Police Department, who reported me to IDFPR, who required a psychiatric evaluation which I complied to. 4) Psychological Medical Abuse, under the Consumer Fraud & Deceptive Practice Act. In pursuant to 815 ILCS 510 / 1 (3), psychiatrists provide

Sponsor Documents

Or use your account on


Forgot your password?

Or register your new account on


Lost your password? Please enter your email address. You will receive a link to create a new password.

Back to log-in