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  • Report:  #1526723

Complaint Review: David Gotzh - Chicago IL

Reported By:
MM - Chicago, IL, United States
Submitted:
Updated:

David Gotzh
444 N Michigan Ave Ste 1200 Chicago, 60610 IL, United States
Phone:
(312) 957-8474
Web:
theroadlawyer.com
Tell us has your experience with this business or person been good? What's this?
Report Attachments

This attorney has committed multiple frauds and his license should be revoked.  He gives all lawyers a bad name and is full of lies.  There is a petition online to get him removed.  He should not be allowed as a GAL or around children at all.  There is a reason he left Chicago and now hides in Indiana because he is the laughing stock of the legal community.  Ask any judge about David Gotzh and they will tell you he has the intellect of a child and they feel sorry for any client that hires him.  He will take your money and run.  If you show up in court with him as your attorney be prepared to be laughed out of the court room.  He is the nerdy kid in school who got picked on and now he is an egomaniac that is harmful to society.  Here is an excerpt from the petition to remove him as GAL:

 

Attorney David Gotzh has committed fraud and lied to the probate court. Also, has a personal Relationship, and has been colluding with the Biological mother (who lost custody of the child when he was three months. That was 11 years ago) in the probate case and will not remove himself as the Gal for the minor.

Why is this important?

There is a DCFS History report of abuse to this Minor Child at the hands of the mother; that is why when this child was only three months DCFS step in to remove this child from the care of the mother, and that is how he got into the care of the family he has lived with. In the elven years of this child life, no other order or court has sought to give unsupervised visit because in the state of Illinois “best interests” of the child!

The year in a GAL report GAL Attorney David Gotzh said he does not know for a fact where the birth mother is living, he does not know for a fact anything about her as he DID NOT READ THE REPORTS IN THIS CASE. Now, the only factor he based his decision on to give unsupervised visit is the fact that he does not like it that they minor child calls his guardian mom and dad, and they are A Black family that is keeping this young boy out of jail and the system. This is the reason that he will turn over this minor to someone that he knows nothing about

At First GAL Attorney David Gotzh said that the only way the birth mother could get the young man back was if she won $10 million. This all change when the Guardians of the minor reported racist remarks and that Attorney David Gotzh had a personal dealing with the birth mother. He was asked to remove himself as the GAL; however, he has refused and CVLS will not take him off the case as it is their mission to have this little young black boy in up in the care of DCFS.

Attorney David Gotzh has misrepresented the facts to not only appellate court; however, he did the same thing in the probate court. On 4/30/18 he placed two phone calls to the minor in the school telling the story and trying to get personal information from them, he also had the birth mother called to get information by trying to pretend she was the mother and had custody and was afraid that the Guardians were doing things to the Minor. Attorney David Gotzh also had a woman call from a number that came up on the school phone as belong to Chicago Volunteer Legal Service asking a question about the said minor, both Attorney Gotzh, and the woman told the school that they were in fear that the guardians had run off with the minor.

Attorney David Gotzh has personal interfere in both Civil cases that have been file, he has crossed the line, and he is filing motions in the Probate case by passing the appeal court. It is the belief that Attorney David Gotzh is colluding with the birth Moher Joyce Washington to kidnap the said minor. He has violated his oath as an Attorney and has crossed the line to criminal actions. He is using his power over the parties; he has treated to have one of the Co-Guardians arrested.

The Co-Guardian have sent over 20 email and requested to CVLS to have them remove Attorney David Gotch from this case. However, all they have done is help him as someone from their office called the minor school and would not give their name; all three people that have called that school would not give a name, and it was only due to the fact that the school has Caller ID that they school knows who was calling.

Attorney David Gotzh will be a co-defendant in one of the civil actions, and he will be called as a witness in both. The birth mother has said that he is her Attorney, and this is a fact that he has denied; as it would have crossed the lines. Therefore he will be called as we need to get a copy of all the phone calls and emails and any communication that has taken place with the Birth Mother and Attorney David Gotzh to make a man do all this for a woman he just met three months ago.

  There are many more complaints online and lawsuits against him.  Look up Cook County case number 20196004314.  He is a con artist and must be stopped.  If you are his client or former client report him to the ARDC immediately to protect future clients who will be scammed by this charleton!!

       

 

Report Attachments


1 Updates & Rebuttals

Mahdee

Chicago,
Illinois,
United States
Lawsuite filed against David Gotzh in Chicago for being racist!

#2Author of original report

Wed, October 18, 2023

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

LAW DIVISION, SIX DISTRICTS

Mahdee Muhammad

Plaintiff,

v. No. 2019 M6 4314

CHICAGO VOLUNTEER LEGAL SERVICE (CVLS)

DAVID GOTZH

REBEKAH A. RASHIDFAROKHI

Defendant (s)

NOTICE OF Filing

TO: CHICAGO VOLUNTEER LEGAL SERVICE (CVLS)

DAVID GOTHZ

REBEKAH A. RASHIDFAROKHI

By their Lawyer; Jordan M. Heinz

300 North LaSalle

Chicago, Il 60654

On or Before 08/20/19, the attached Plaintiff Response to Defendant’s Motion to Dismiss will be E File

with the Clerk of the Circuit Court of Cook County

FILED

8/20/2019 10:19 PM

DOROTHY BROWN

CIRCUIT CLERK

COOK COUNTY, IL

20196004314

Return Date: No return date scheduled

Hearing Date: No hearing scheduled

Courtroom Number: No hearing scheduled

Location: No hearing scheduled

FILED DATE: 8/20/2019 10:19 PM 20196004314

______________________________

Mahdee Muhammad

Mahdee Muhammad

123 Indianwood Blvd #340

Park Forest, IL 60466

708-819-0619

Atty. No. Pro-Se 9500

FILED DATE: 8/20/2019 10:19 PM 20196004314

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

LAW DIVISIONS, SIX DISTRICTS

MAHDEE H. MUHAMMAD,

PLAINTIFF.

Vs. Case No. 2019 M6 4314

CHICAGO VOLUNTEER LEGAL SERVICE (CVLS)

DAVID GOTZH

REBEKAH A. RASHIDFAROKHI

———————————————————————-

The Plaintiff, Mahdee H. Muhammad, Pro-Se, Response to Defendant’s Motion to Dismiss

herein, respectfully request this court to denied defendants motion:

INTRODUCTION

This is an action for equitable relief and for redress for the violation of rights guaranteed to the

plaintiff Mahdee Muhammad by state and federal laws, including (a) damages for deprivations

by defendants acting under color of State law of plaintiff’s rights, privileges and immunities

guaranteed by the Fourth and Fourteenth Amendments to the United States Constitution pursuant

to 42 USC 1983 and 1988; (b) damages for deprivations by defendants of plaintiff’s rights.

This is a case that the plaintiff has taking to the Illinoi Attorney General Office, ARDC and

others. To be told each time that it was civil case one that needs to be taking to state court, as

such the plaintiff file a civil rights lawsuit based solo on the fact that the defendant actions were

done solo based on race as such, they can be sued for violating the plaintiff civil rights.

THE PARTIES

Plaintiff Mahdee H. Muhammad is a male, Black, African American citizen of the United States,

domiciliary of the State of Illinois and a resident of the County of Cook. As such he is protected

under the Constitution

Defendant David Gotzh is not only a lawyer licensed to practice in the State of Illinois. He is

also a RACIEST! Defendant David Gotzh is being sued personally, and in his individual

FILED DATE: 8/20/2019 10:19 PM 20196004314

capacity, at the times relevant to this complaint he just happens to be employed by Chicago

Volunteer Legal Service, under the Defendant Rebekah A. Rashidfarokhi who is also a lawyer

licensed to practice in the State of Illinois. Who is being sued personally and in her individual

capacity, at the times relevant to this complaint as the Defendant David Gotzh, it was her duty to

stop or investigate the complaint filed by the Plaintiff Mahdee Muhammad.

However, she turned a blind eye and gave Defendant David Gotzh the ok to cause harm and

violate Plaintiff Mahdee Muhammad Constitution Rights.

Chicago Volunteer Legal Service (CVLS) as an organization was also aware of Plaintiff Mahdee

Muhammad compliant on Defendant David Gotzh, and they also did nothing to stop or

investigate his actions.

Case Law

Per case law, a case should not be dismissed on the pleadings, if the pleader desires to amend

unless it is apparent that no cause of action can be stated. Dinn Oil Co. v. Hanover Insurance

Co., 87 Ill.App.2d 206, 211-12; Fanning v. Lemay, 78 Ill.App.2d 166,

Carmack v. Great Am. Indemnity Co., 400 Ill. 93, 96; Danville Producers Dairy v. Preferred

Risk Mut. Insurance Co., 33 Ill.App.2d 359, 362; S.W. Coe & Co. v. Douglass, 334 Ill.App.

195, 196-97),

The court have ruled that if the issues within a complaint is with wording, the plaintiff should

have been granted leave to amend as this would allow for an opportunity to cure the specified

objection by amendment. Central Ill. Elec. & Gas Co. v. Scully, 17 Ill.2d 348, 353.)

If the Trial court believes it is apparent that the plaintiff's pleadings could be amended so as to

cure objections, and that the defendant's motions to dismiss are inadequate for their purpose.

Weidner v. Midcon Corp., 328 Ill. App. 3d 1056, 767 N.E.2d 815, 2002 Ill.

In determining whether a cause of action should be dismissed for the failure to state a cause of

action, all well-pleaded factual allegations must be taken as true and all reasonable inferences

drawn in favor of the pleader.

The plaintiff should have been allowed to have discovered to see if in fact did the defendant (s)

know about the raciest views of Defendant David Gotzh. What was done to cover up anything

that was found or was any inquire done at all.

The appeals courts have ruled on this issue as is use a test to be applied in determining whether

the trial court's discretion was adequately exercised is whether the allowance of the amendment

would further the ends of justice. Ray Dancer, Inc., 230 Ill. App. 3d at 48, 594 N.E.2d at 1349.

As the appeals court feels that leave to amend should generally be granted unless it is apparent

that even after the amendment no cause of action can be stated. City of Elgin v. County of Cook,

169 Ill. 2d 53, 71, 660 N.E.2d 875, 884, 214 Ill. Dec. 168 (1995).

FILED DATE: 8/20/2019 10:19 PM 20196004314

Although pleadings are to be liberally construed, a complaint must, nevertheless, contain facts

necessary to state a cause of action. The complaint if clear; plaintiff Mahdee Muhammad civil

right were violated by Defendant David Gotzh. Hanson v. Hyatt Corp., 196 Ill. App. 3d 618,

620- 21, 554 N.E.2d 394, 395, 143 Ill. Dec. 459 (1990); B.T. Explorations, Inc. v. Stanley, 187

Ill. App. 3d 23, 26, 542 N.E.2d 1292, 1294, 134 Ill. Dec. 785 (1989).

A plaintiff cannot rely simply on mere conclusions of law or fact unsupported by specific factual

allegations, regardless of whether they generally inform the defendant of the nature of the claim

against him or her. From the start plaintiff Mahdee Muhammad has documented that Defendant

David Gotzh was a raciest and he was actions were based solo on race. Grund v. Donegan, 298

Ill. App. 3d 1034, 1039, 700 N.E.2d 157, 161, 233 Ill. Dec. 56 (1998); Hirsch, 299 Ill. App.

3d at 1081, 702 N.E.2d at 270.

To sufficiently state a cause of action, a complaint must set forth a legally recognized claim and

plead facts in support of each element that brings the claim within the cause of action alleged.

The plaintiff did such. Anderson v. Vanden Dorpel, 172 Ill. 2d 399, 408, 667 N.E.2d 1296,

1300, 217 Ill. Dec. 720 (1996); Betts v. Crawshaw, 248 Ill. App. 3d 735, 737, 618 N.E.2d

1262, 1265, 188 Ill. Dec. 692 (1993).

Chapter 735. Civil Procedure § 5/2-616. Amendments § 2-616. Amendments. (a) At any time

before final judgment amendments may be allowed on just and reasonable terms, introducing any

party who ought to have been joined as plaintiff or defendant, dismissing any party, changing the

cause of action or defense or adding new causes of action or defenses, and in any matter, either

of form or substance, in any process, pleading, bill of particulars or proceedings, which may

enable the plaintiff to sustain the claim for which it was intended to be brought or the defendant

to make a defense or assert a cross-claim.

(b) The cause of action, cross claim or defense set up in any amended pleading shall not be

barred by lapse of time under any statute or contract prescribing or limiting the time within

which an action may be brought or right asserted, if the time prescribed or limited had not

expired when the original pleading was filed, and if it shall appear from the original and

amended pleadings that the cause of action asserted, or the defense or cross claim interposed in

the amended pleading grew out of the same transaction or occurrence set up in the original

pleading, even though the original pleading was defective in that it failed to allege the

performance of some act or the existence of some fact or some other matter which is a necessary

condition precedent to the right of recovery or defense asserted, if the condition precedent has in

fact been performed, and for the purpose of preserving the cause of action, cross claim or defense

set up in the amended pleading, and for that purpose only, an amendment to any pleading shall

be held to relate back to the date of the filing of the original pleading so amended.

The Defendant’s argue that per Nichols v. Fahrenkamp, 2019 IL; that the Illinois Supreme Court

ruled that a guardian ad litem are absolutely immune from liability for damage when they are

acting in child best interest: “In 2004, Nichols, age 11, received $600,000 in a settlement for

injuries she suffered in a motor vehicle accident. The court-appointed her mother as her guardian

FILED DATE: 8/20/2019 10:19 PM 20196004314

to administer her estate and appointed attorney Fahrenkamp as guardian ad litem. In 2012

Nichols sued her mother, claiming that she used $79,507 of settlement funds for her own benefit.

The trial court ruled in Nichols’s favor but limited recovery to $16,365, a 2007 Jeep Compass,

and $10,000 in attorney fees. Nichols sued Fahrenkamp for legal malpractice in approving

expenditures that were not in Nichols’s interests. She claimed that Fahrenkamp never met with

her or consulted with her regarding her mother’s expenditures. The circuit court granted

Fahrenkamp summary judgment based on qualified immunity. The appellate court reversed,

reasoning that guardian’s ad litem have a duty to protect their wards’ assets and interests and that

immunizing guardians ad litem from tort suits would be inconsistent with this duty. The Illinois

Supreme Court reinstated summary judgment in Fahrenkamp’s favor, applying the “functional

test” and looking past the title attached to the position to look to the position holder’s role. In the

past, the guardian ad litem served in almost a trustee-like capacity, seeking to specifically

advocate the pecuniary interests of the ward, but a present-day guardian ad litem functions as a

representative of the court-appointed to assist in protecting the ward's best interests.”

Fact the Plaintiff is not suing the Defendants as gal’s; however as private citenzzees; now the

defendants cannot rewrite the plaintiff complaint to make it fit their motion. However, let look at

what the defendants did; they recommend that a 12-year-old African American male be

discharge from the care of the only family he knew for the past 12 years of his life (since he was

3 months). The defendants recommend that the guardians do not have any type of commutation

with them as they did not want the minor to tell them what issue he was having. They had an

issue with the fact that this child called the guardian mom and dad; once more they had him since

he was 3 months and grew up in the house with their other children.

Fact the gal said that this child who had just got accepted into 7th grade stem; was playing

baseball since he was 4; has never got a grade lower than a “A”; living in a 2 family educated

household; was better off living in a apt where 4 days out of the week he would be left from 5

P.M. to 7 A.M; to go live with a woman and get on public aid, to go too one of the worst school

in the CPS was in the “Best Interest” of that child.

No, this case is not about the fact that the judge in that probate case never had legal jurisdiction

over the parties, this case is not about the fact, that without legal jurisdiction there could not be a

clime to immunity. No! This case is about the fact that one of the defendants talk about how they

did not want “Niggas” coming to his town to shop. There is no immunity for being a Raciest!

Argument

Point of fact, this case is not about a GAL. This case is not about what the Defendant (s) did or

did not do in the probate case of Z.W. This is not about how the Defendant (s) lied; fake and

forge legal documents, talks wittiness into telling lies and not coming to court after being

subpoena speaks to what he did in that case.

No, this case is about a Raciest, and not just any type of racist; one that had the power to control

life and death; one that used that power to harm. ARDC said that it was Defendant David Gotzh

word against Plaintiff Muhammad and unless another lawyer came forward, it was nothing they

FILED DATE: 8/20/2019 10:19 PM 20196004314

could do. Well, in this case, Plaintiff Muhammad will have those lawyers in court to tell what

Defendant David Gotzh did; and each action done by Defendant David Gotzh was personal.

This case is about “n***a Time”

What is n***a Time or as it is called “CP” time? This is something that is used to describe laze;

late color people. it is something that some Racist think that all black people are always late and

has become a joke to describe them.

So on about February 8, 2018, I had a conversation with Defendant Davie Gotzh, and it was

during our first call he said to that the only way Joyce would get Zion back; is if “she won the

lottery”. I have an email about this conversation that can support that this was said; I wrote

about him in my first ARCD complaint about him. So, for Defendant Davie Gotzh to say that

what he said to me is in my head; well it was in my head before he tried to judicial lynch me.

Now, Defendant Davie Gotzh and I were talking about the motion I had filed to dismiss the case

as we were never giving service to anything and it was during this conversation he talks to me

about his background and it was in that talk that he wanted to meet Zion. Now during this talk,

Defendant Davie Gotzh talks about not coming on “CP”; he was an old school German and when

he says 3 P.M. that is 3 pm; not 3:10 or “CP” time.

Now, I am over 50 and a White man just told me over the phone not to come on “n***a Time”

and I was to say nothing? Well, that is not how I am built. The conversation ended with

Defendant Davie Gotzh saying to me that he and I will just meet “man to man”. Once more this

is all in my reports from day one; this is all the emails to CVLS. So, I had to have the

forethought that I was going to be at this point to make this up.

So, I have to ask the question what changes in 3 months; Joyce did not hit the lotto; she did have

a one on one with Defendant Davie Gotzh alone and it was during that meeting that he came out

with one job in life; to make me pay. He wanted to cause me harm; he wanted me to pay. Was it

personal due to what Joyce had told him; or done for him; or was it due to the fact that he was

upset that as I black man I dare to stand up to him?

I want to know why this happened; I want to know what was CVLS reason for supporting

Defendant Davie Gotzh; what did he tell them to make them overlook all that he was doing. Is

this the first time CVLS had fake paperwork in a case; is this the norm for them. How many

other black men have been destroyed by CVLS. Last how many other racists do they have

working under them. All these questions I want to get an answer to, as it is the only way I can

move on; I need to know WHY? And A jury can help me get these answers

Was Defendant Davie Gotzh hate for me based solo on the fact that I am black? Or was it a

hatred for a man that was a Muslim; he jokes about Plaintiff Muhammad religious, he made it

clear that he would and was going to do anything that he wanted to, as he is a lawyer and he is

White, and he will be believed over me.

FILED DATE: 8/20/2019 10:19 PM 20196004314

All these action’s and claims are issues that should go before a Jury as the defendants want to

make this case disappear because they knew that they had a raciest working for them and did

nothing to stop him.

During the first conversation that Plaintiff Mahdee Muhammad had with Defendant David

Gotzh; it was two things that Defendant Gotzh made clear, he was an Old-School German, and

he was a Racist. However, the defendants want to say that somehow a raciest has judicial

immunity; or that Plaintiff Mahdee Muhammad will not be able to prove that not only did he

personal suffer harm, however, but this harm was also solo based on race.

We are living in a time where parents are giving up their child so that they can go to school for

free; after Defendant David Gotzh made racist remarks to the Plaintiff, and his actions were

reported; the Defendant (s) did all that was in their power to hurt him. Defendant David Gotzh

made it clear that he was not going to let the Plaintiff adopt this little black boy as the life of

going to school, playing baseball and having life experience of love was not the best life for him.

It was better for him to be on the street, killing, selling drugs; after all, as Defendant David

Gotzh said all black boys are wanting to be gang members.

As for judicial immunity; the state laws allow for Judges to have immunity from being sued for

any legal actions that they do when it falls under the authorly as a judge. However, any actions

done by a judge when they do not have legal jurisdiction are not protected by immunity When a

judge knows that she/him lacks jurisdiction or acts in the face of clearly valid statutes expressly

depriving she/him of jurisdiction, judicial immunity is lost. Rankin v. Howard, (1980)

633 F.2d 844, cert den. Zeller v. Rankin, 101 S.Ct. 2020, 451 U.S. 939, 68 L.Ed 2d 326. In

Rankin v. Howard, 633 F.2d 844 (1980) the Ninth Circuit Court of Appeals reversed an Arizona

District Court dismissal based upon absolute judicial immunity, finding that both necessary

immunity prongs were absent; later, in Ashelman v. Pope, 793 F.2d 1072 (1986), the Ninth

Circuit, en banc , criticized the "judicial nature" analysis it had published in Rankin as

unnecessarily restrictive. But Rankin's ultimate result was not changed, because Judge Howard

had been independently divested of absolute judicial immunity by his complete lack of

jurisdiction. Some Defendants urge that any act "of a judicial nature" entitles the Judge to

absolute judicial immunity. But in a jurisdictional vacuum, (that is, absence of all jurisdiction)

the second prong necessary to absolute judicial immunity is missing. Stump v. Sparkman, id.,

435 U.S. 349. "Where there is no jurisdiction, there can be no discretion, for discretion is

incident to jurisdiction." Piper v. Pearson, 2 Gray 120, cited in Bradley v. Fisher, 13 Wall. 335,

20 L.Ed. 646 (1872) A judge must be acting within his jurisdiction as to subject matter and

person, to be entitled to immunity from civil action for her/his acts. Davis v. Burris, 51 Ariz.

220, 75 P.2d 689 (1938) Generally, judges are immune from suit for judicial acts within or in

excess of their jurisdiction even if those acts have been done maliciously or corruptly; the only

exception being for acts done in the clear absence of all jurisdiction. Gregory v. Thompson, 500

F2d 59 (C.A. Ariz. 1974) There is a general rule that a ministerial officer who acts wrongfully,

although in good faith, is nevertheless liable in a civil action and cannot claim the immunity of

the sovereign. Cooper v. O'Conner, 99 F.2d 133 When a judicial officer acts entirely without

FILED DATE: 8/20/2019 10:19 PM 20196004314

jurisdiction or without compliance with jurisdiction requisites he may be held civilly liable for

abuse of process even though her/his act involved a decision made in good faith, that her/he had

jurisdiction. State use of Little v. U.S. Fidelity & Guaranty Co., 217 Miss. 576, 64 So. 2d 697

Judge Susan Kennedy-Sullivan never had legal judication as such she never was protected under

jurisdiction immunity; as such, Defendant David Gotzh did not have any immunity for his

actions. With all that being said; the Plaintiff Mahdee Muhammad is suing Defendant David

Gotzh for his action’s as a lawyer not as a GAL.

The reason why the defendants even added the conversation about this judge was only done for

one reason and that was to bias this court. The actions of the judge in the probate court have no

bearing on this case; as the judge was only doing what defendant David Gotzh advise her to do

as he was her eyes and ears in her court. The problem she had was that she had a raciest leading

her; and everything he did was solo based on his White Nationalist beliefs.

Plaintiff Mahdee Muhammad is suing Defendant Rebekah A. Rashidfarokhi as she was

Defendant David Gotzh supervisory and did nothing to stop his actions or behavior; she is not

being sued for being a GAL, and CVLS is not either. Each argument made in the defendant’s

motion is an argument that should be made in a trial, not in motion based on no facts. Raciest do

not have the right to clime immunity, and the truth is that the Federal Court said this case should

be heard on the state level and that is why it was filed in the Law Division in 6th district.

The Defendants filed their motion under 735 ILCS 5/2-615 and the laws are clear:

(735 ILCS 5/2-615) (from Ch. 110, par. 2-615)

Sec. 2-615. Motions with respect to pleadings. (a) All objections to pleadings shall be raised

by motion. The motion shall point out specifically the defects complained of, and shall ask for

appropriate relief, such as: that a pleading or portion thereof be stricken because substantially

insufficient in law, or that the action be dismissed, or that a pleading be made more definite and

certain in a specified particular, or that designated immaterial matter be stricken out, or that

necessary parties be added, or that designated misjoined parties be dismissed, and so forth.

(b) If a pleading or a division thereof is objected to by a motion to dismiss or for judgment or

to strike out the pleading, because it is substantially insufficient in law, the motion must specify

wherein the pleading or division thereof is insufficient.

(c) Upon motions based upon defects in pleadings, substantial defects in prior pleadings may

be considered.

(d) After rulings on motions, the court may enter appropriate orders either to permit or require

pleading over or amending or to terminate the litigation in whole or in part.

(e) Any party may seasonably move for judgment on the pleadings.

However, the defendants have used their motion to augur their case; as such if they feel that the

plaintiff cannot prove his case; they should argue these facts before a Jury. As the plaintiff is

FILED DATE: 8/20/2019 10:19 PM 20196004314

ready to prove that the defendants acted willfully, maliciously, and/or with reckless disregard of

the consequences of their actions. Accordingly, the plaintiff is entitled to an award of damages.

The plaintiff complaint gives a background into how the plaintiff was injured and whom he feels

cause his injury and under 735 ILCS 5/2-603) (from Ch. 110, par. 2-603)

Sec. 2-603. Form of pleadings. (a) All pleadings shall contain a plain and concise statement of

the pleader's cause of action, as at fault that is all that is required under 735 ILCS 5/2-601) (from

Ch. 110, par. 2-601)

(735 ILCS 5/2-604) (from Ch. 110, par. 2-604)

Sec. 2-604. Prayer for relief. Every count in every complaint and counterclaim shall contain

specific prayers for the relief to which the pleader deems himself or herself entitled except that in

actions for injury to the person, no ad damnum may be pleaded except to the minimum extent

necessary to comply with the circuit rules of assignment where the claim is filed.

(735 ILCS 5/2-612) (from Ch. 110, par. 2-612)

Sec. 2-612. Insufficient pleadings. (a) If any pleading is insufficient in substance or forms, the

court may order a fuller or more particular statement. If the pleadings do not sufficiently define

the issues, the court may order other pleadings prepared.

(b) No pleading is bad in substance which contains such information as reasonably informs the

opposite party of the nature of the claim or defense which he or she is called upon to meet.

The Plaintiff, in his complaint, made it clear and precise as to what happens and if the defendant

wants to argue the facts; that should be done in a response or during the mandatory arbitration.

Not in a motion saying what the plaintiff listed in the background is not fractural.

(735 ILCS 5/2-616) (from Ch. 110, par. 2-616)

Sec. 2-616. Amendments.

(a) At any time before final judgment amendments may be allowed on just and

reasonable terms, introducing any party who ought to have been joined as plaintiff or

defendant, dismissing any party, changing the cause of action or defense or adding

new causes of action or defenses, and in any matter, either of form or substance, in

any process, pleading, bill of particulars or proceedings, which may enable the

plaintiff to sustain the claim for which it was intended to be brought or the defendant

to make a defense or assert a cross-claim.

Each point made in the defendant motion, not one of them addresses the central allegation in the

plaintiff complaint. That being Defendant David Gotzh is a White National Racist; who have

referred to all Black Males as “gang banger thugs”; and how he wanted to keep them out of his

all “White Town.” Defendant David Gotzh as a lawyer he uses the power giving to him by

CVLS and Rebekah A. Rashidfarokhi to cause harm to plaintiff Mahdee Muhammad an African

American, and this was solo based on RACE!

FILED DATE: 8/20/2019 10:19 PM 20196004314

The defendants want this court to think that this case is about a probate case, and how as the

GAL for a minor they did what was in the best for that minor. This case is far from that it is

about a Racist Lawyer. A raciest lawyer who said that it was better for a 12-year-old African

American male to be removed from the only home that he had known since he was three months.

Just because the plaintiff was a black man that file an ARDC report on him.

The defendant’s in this case felt that it was best for this 12-year-old to go live in a war zone

down on 89th street in the City of Chicago where there are 5 or more shooting a week. However,

they say that it is a up and coming neighborhood. These defendants said it was in the best interest

for a 12-year-old to go live with a woman who was not only still prostitution, however, had just

been evicted from last 7 plaice where she was staying within a year. This is just a little

background into that probate case that the defendants talk about.

Let me be clear this case is about lawyers; it is about a lawyer that condone perjury and perjury

themselves in a court. Lawyer that forges legal paperwork. The Defendant in their motion

address the First District Appellate Court decision of the probate case; once more I do not know

why; however, that decision was based on the fact that Defendant David Gotzh was able to make

the court feels that the case was about notice; as that case was never about notice. It was about

the fact that service was never done, and Defendant (s) knew this. However, the courts allowed

them the defendant (s) tell the story as that is how our systems is set up. Lawyers can lie in court

and nothing has been done. That is why the plaintiff is asking for a jury trial

This is what the defendants want to do in this case; they filed a book hoping this court would just

take their word as Lawyers. In that probate case, the court never got service on anyone, and this

is a fact that is before the Illinois Supreme Court, and the plaintiff will take it up to the U.S

Supreme court if need be.

The Defendants want to cloud this case with their motion. The Defendants want to play same

tricks that they played with the other courts. It wants this court to feel that the actions in the

probate court was in the best interest to that minor; and that a court can judicate a case without

having legal service and legal jurisdiction. When in fact those assumption is for a jury to

considers not, not grounds to bring or received a motion to dismiss.

It is 8/20/19 and I could wait and submit my response on the last day at the last second; however,

I choose this date as this is Zion 13th born day. My wife, children; nor I could call him and wish

him a happy Born Day; that is because Joyce Washington his birth mother phone is off; she is

once more living with someone. Zion has no clothes and he is living with the person that came to

court and lied under oath. She did this as she told me, Davide knew she was going to lie, and he

was ok with it.

To be honest the Judge in the probate case told me to my face that she did not care whom told

lies or not as she does not like me; nor does she trust me and this was all based on the fact that a

Racist had poisoned her mind. He told her stories about me because he could not put me in my

place.

FILED DATE: 8/20/2019 10:19 PM 20196004314

50 years ago, Davide could have just taken me out to the center and had my lynch, today he does

he lynching in a courtroom. I hired a private investigator during the probate case (David Gotzh

knew about this and he told Joyce Washington) and I did not only pay him to let me know about

Joyce; I wanted to know everything about David Gotzh; as he used “color people” time with me

as it was nothing and I wanted to know what type of man he was.

I found out that he was a racist, I found out that his father was a retired state police cop and got

away with ruining over a 12-year-old Hispanic girl and killed her. I reach out to Rebekah A.

Rashidfarokhi time after time to request that he remove him from that case, and she did nothing.

She knew that Joyce was telling lies and she had a choice to make; she was going to be against

racism, or she was going to be with it, and she chose to be with a raciest.

The probate case that the defendant’s talk about in their motion is in the hands of the Illinois

Supreme Court (125045 and 125042); and if they do not take the case, I am going to take it to the

U.S. Supreme court. I am going to fight in the courts to save that little black boy that CVLS toss

away his life like a dirty rag.

There is no case law that gives Raciest Immunity from being sued

I am coming before this case for one reason and only one; My rights were violated based solo on

race and there is no court in the land that has said A racist is immune for being a racist. I am

suing these parties for that reason and only that reason; as such:

The Plaintiff has a JURY TRIAL DEMANDED on Record;

WHEREFORE, plaintiff respectfully requests that this Court to Denied the Defendant’s Motion

and transfer this case for Trail.

Mahdee Muhammad

123 Indinwood Blvd # 340

Park Forest, IL 60466

708-819-0619

Statement of Verification

I have read the above response, and it is correct to the best of my knowledge.

Your signature

.

Pro-Se, Mahdee Muhammad

FILED DATE: 8/20/2019 10:19 PM 20196004314

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