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Motions on Appeal

These are excerpts and sic for Motions filed with the New Jersey Appellate Court filed February 27 2012 case IMO Robert Johnson A-003122-11T2. These were served on Judge Walter Koprowski Jr., Guardian Vanessa D. Johnson Taylor, Shawnda Navarro-Floyd, and  attorney James Boutillier of Brandley, Klepper, O'Conner & Boutiller.


Motion to Prohibit Payment of Attorney Fees

Local rule requires that an application for attorney fees must be accompanied by an affidavit of the attorney. The guardian and her attorney Shawnda N Floyd stated the application to sell the property is for paying attorney fees alleged. No affidavits have been supplied to the court. I faxed Judge Walter Koprowski Jr on Jan 15 2012 in part "There was no documentation of the attorney fees as I had requested. Your hearing failed to comply with R 4:42-9 (b) and (c) and RPC 1.5(a). No order to sell the property to pay attorney fees can issue without the required affidavits under rule 4:42-9."

Good cause exists to grant this motion. Appellant asks that this motion be granted for an order that since no affidavits have been filed with the Chancery court from said attorneys per R 4:42-9, the guardian is prohibited from paying any attorney fees out of any sale of the property of the ward.

Motion for Stay


I have previously in good faith requested a clerk entry of default, and docket case history, among other things, that I have not received to date. This failure of the courts brings into question the conduct of the court as it affects this case. At the hearing Jan 13 2012, as a beneficiary of the estate and entitled to all rights by law, I made reasonable, good faith, and required requests for documentation and full disclosure by all parties and attorneys and court; such requests essential to an appeal of this matter were ignored at the hearing. In accordance and based on the negligence and wrongful conduct of the court, I believe that there is sufficient and substantial evidence that this motion should stay the Jan 18 2012 order of the Chancery court and any subsequent actions of the Chancery court.


The guardian Vanessa D. Taylor in this matter alleged to have signed the contract to sell the property to Savio Figaro in July 2011. She did not file this contract with the court until October 2011, three months later, proving there was no sense of urgency.


The guardian Vanessa D. Taylor in this matter appeared at the Jan 13 2012 hearing in this matter. But she gave no testimony in support of her complaint to sell the property; she also provided no authenticated documentation of the alleged bills; her submitted papers show many if not all of the bills alleged are uncertain proving no sense of urgency on her part.

Motion for Clerk Entry of Default


I have previously in good faith requested a clerk entry of default, and docket case history, among other things, that I have not received to date. This failure of the courts brings into question the conduct of the court as it affects this case. At the hearing Jan 13 2012, as a beneficiary of the estate and entitled to all rights by law, I made reasonable, good faith, and required requests for documentation and full disclosure by all parties and attorneys and court; such requests essential to an appeal of this matter were ignored at the hearing.


Around April 25 2011 the clerk Tara Wilson received from me a SASE, check not to exceed $20, and request for the clerk’s entry of default. Rule 4:43-1. Entry of Default. The documents addressed to Wilson that were not responded to by Vanessa D. Taylor, James Boutillier, Lawrence E. Meyerson, and Shawnda N. Floyd were:


1) NOTICE OF MOTION AND MOTION TO ENFORCE NEXT OF KIN GEARY JUAN JOHNSON’S RIGHTS POST-JUDGMENT dated November 13 2010 and heard December 17 2010.

2) VERIFIED COMPLAINT FOR AMENDED JUDGMENT TO CLARIFY NEXT OF KIN GEARY JUAN JOHNSON’S RIGHT TO BE KEPT ADVISED filed Jan 13 2011.



Good cause exists to grant this motion. Appellant asks that this motion be granted for an order that Surrogate clerk will supply me, within 5 days of the signing of this order, the clerk entry of default documentation requested herein.



Motion for case history


Throughout 2011 I emailed and faxed the Surrogate as well as Judge Walter Koprowski and others that I had not received the case history requested. Next of kin are entitled to a copy of the docket index history according to local New Jersey rule.


I submitted a new request around December 2012 for a full copy of the docket index. Each time I have submitted the proper fees and a SASE.

At this date I have not received the docket index that is material to my proceeding with the appeal of this matter.

Good cause exists to grant this motion. Appellant asks that this motion be granted for an order that the Surrogate’s office and/or Judge Walter Koprowski Jr will supply me a copy of the docket index within 5 days of the granting of this motion.


Motion for Documentation


The Guardian as trustee the estate, has a duty to me of undivided loyalty and full disclosure. I reserve the right to again use such lack of documentation without limitation, as part of my opening brief. This is the authenticated documentation I have requested which I ask to become part of the order:


Authenticated  disclosure of medical records; disclosure of the police reports  regarding break ends  146 - 148 Fabyan Place;  disclosure annual report for 2011; authenticated  disclosure monies of Robert Johnson going to Vernell Johnson; disclosure authenticated spend down plan presented to Medicaid  Plainfield  New Jersey office; disclosure docket history; disclosure clerk entry of default; disclosure of contract with the Woodlands nursing home regarding Robert Johnson Care; disclosure of authenticated notice of tax returns owed; disclosure of authenticated copy of child support order; disclosure of authenticated copy of local taxes owed and tax Liens and to whom; disclosure of authenticated Savio Figaro  requests for credits re purchase of property;  disclosure of authenticated copy of state and Federal tax returns owed; disclosure of authenticated copies of documents for any and all other bills alleged by Vanessa D. Taylor  doctor's report; authenticated disclosure of how Medicaid was approved absent court approval of a spend down plan; authenticated proof of the oil tank remediation

"A trustee, as a fiduciary, is under a duty to make full and complete disclosure of all transactions in relation to his trust. He is permitted neither to conceal nor misrepresent, and if he fails in his duty to disclose the true facts...it amounts to fraud...."





Documentation Requested of Taylor and the Court






| Feb 27 Appeal Motions | Boutillier Brief |
| Judge Conceal and Embezzle | The Appeal | Reply Stay Motion |
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