BOBBY N. HARMON, CPCU, ARM
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Defendant, Pro Se
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF HAWAII
JAMES B. NICHOLSON, TRUSTEE, ) CASE NO. CV05-00030 DAE KSC
)
Plaintiff, ) MEMORANDUM IN ANSWER TO
) PLAINTIFF’S MEMORANDUM IN
v. ) OPPOSITION TO DEFENDANT’S
) MOTIONS TO RECUSE THE
BOBBY N. HARMON, ) HONORABLE DAVID A. EZRA AND
) THE HONORABLE KEVIN S. CHANG;
Defendant ) CERTIFICATE OF SERVICE
)
) Trial Date: None
)
)
MEMORANDUM IN ANSWER TO PLAINTIFF’S MEMORANDUM IN
OPPOSITION TO
DEFENDANT’S MOTION TO RECUSE THE HONORABLE DAVID A. EZRA AND
THE
HONORABLE KEVIN S. CHANG
I. ARGUMENT.
Plaintiff argues: “The substance of the presentation by Defendant in the Recusal Motions is illustrative of his conspiratorial thinking process and his failure to recognize that in order for a conflict to exist there must be an actual and direct relationship between the parties.” He then cites only two brief excerpts from the many factual arguments contained in my Motions to Recuse Judge Ezra and Judge Kevin Chang, and states his unsubstantiated OPINION that “Defendant has offered nothing which remotely approaches raising the color of a connection that any reasonable person could conclude justifies recusal. Judges preside over cases and attorneys litigate. The above examples illustrate the defect in the Recusal Motions.”
Clearly, the Plaintiff has COMPLETELY FAILED TO ANSWER, OR TO EVEN ADDRESS, the many factual connections that Defendant has shown to exist between the Honorable Judges Ezra and Chang, and parties who are financially, professionally, personally and politically related to this case and others – including EQ2048 – as substantially argued in my Motions to Recuse.
II. CONCLUSION.
Given the fact that Defendant has been denied a Hearing in this case; and given the fact that Defendant has been denied the subpoena of documents and witnesses which would give further evidence of fraud, racketeering, obstruction of justice and material conflicts-of-interest in this case; and given the fact that Plaintiff has not denied any of the alleged connections; and given the fact that Plaintiff has not provided any FACTUAL counter-arguments to any of Defendant’s facts as presented in his Motions, Defendant hereby requests that his Motions to Recuse the Honorable David A. Ezra and the Honorable Kevin S. Chang, be granted.
DATED: SPRINGFIELD, KENTUCKY, September 5, 2006.
BOBBY NORRIS HARMON,
Defendant, Pro Se
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www.the-catbird-seat.net/SLAPP.htm
www.the-catbird-seat.net/Freedom-To-Sing.htm
www.the-catbird-seat.net/Confessions.htm
www.the-catbird-seat.net/Whistler.htm
www.the-catbird-seat.net/Bad-Faith-Buzzards.htm
www.the-catbird-seat.net/School-Vultures.htm
www.the-catbird-seat.net/Broken-Trust-Book.htm
www.the-catbird-seat.net/Lost-Generations.htm
www.the-catbird-seat.net/ArbitrateThis.htm
www.the-catbird-seat.net/Bankruptcy-Buzzards.htm
www.the-catbird-seat.net/Insurance-Vampires.htm
www.the-catbird-seat.net/911-COVERUP-3.htm
www.the-catbird-seat.net/MarshBirds.htm
www.the-catbird-seat.net/ChubbGroup.htm
www.the-catbird-seat.net/GoldmanSachs.htm
www.the-catbird-seat.net/Bishop.htm
www.the-catbird-seat.net/Bishop6.htm
www.the-catbird-seat.net/KSBE-Pension.htm
www.the-catbird-seat.net/NestEggs.htm
www.the-catbird-seat.net/HIC.htm
www.the-catbird-seat.net/Vesta.htm
www.the-catbird-seat.net/TheMeadows.htm
www.the-catbird-seat.net/American-Savings.htm
www.the-catbird-seat.net/Bank-of-Hawaii.htm
www.the-catbird-seat.net/Hawaiian-Electric.htm
www.the-catbird-seat.net/Developers.htm
www.the-catbird-seat.net/YAKUZA.htm
www.the-catbird-seat.net/BrokenTrust.htm
www.the-catbird-seat.net/RICO-BH.htm
www.the-catbird-seat.net/CV05-00030-OUST-vs-Harmon.htm
www.the-catbird-seat.net/CV05-00030-OUST-Answer.htm
www.the-catbird-seat.net/CV05-00030-Docs-Subpoena.htm
www.the-catbird-seat.net/CV05-00030-Exhibits-Index.htm
www.the-catbird-seat.net/CV05-00030-Witness-Index.htm
www.the-catbird-seat.net/CV05-00030-Witness-Ezra-David.htm
www.the-catbird-seat.net/CV05-00030-Witness-Chang-Kevin.htm