Wanda Satterthwaite - Writ Certiorari ( History A Must See)

 

A.  Procedural History

The  Court granted Full Faith and Credit to a vacated/voided judgment that no longer exist of Robert Graves dated July 16, 2010.  A void judgment is a nullity from the beginning and is attended by none of the consequences of a valid judgment. Vacated Orders cannot be used as a final Order by any party as a defense. 

The Appellate Division erred in giving preclusive effect to July 16, 2010, Paternity Order that was later vacated by a Pennsylvania State Court on December 9, 2011. Moreover, the Appellate Division ignored the April 18, 2011 disestablishment, dispositive of Robert Graves's paternity and failed to grant Full Faith and Credit to the Pennsylvania Order vacating the July 16, 2010 Order. Contrary to the Appellate Court’s Opinion the issue of paternity is still in doubt in both Pennsylvania and New Jersey. When appeal is taken from a void judgment, the appellate court  must declare the judgment void, because the appellate court  may not address the merits, it must set aside the trial court's judgment and dismiss the appeal.

B.  Statement of Case

This case arises out of two jurisdictions in New Jersey and it begun in  Philadelphia, Pennsylvania Case of Wanda Satterthwaite vs Shawn Carter (a.k.a. Jay Z).

Beginning on April 18, 2011 not to exclude prior pleadings, Graves is Disestablished, Support Order Vacated and dispositive per Pennsylvania Court Order on paternity of Rymir.

On May 2011 Attorney Ned Hark illegally uses his sister-in-law a Family Court Supervisor in Philadelphia to help get the May 19, 2011 [of] Pennsylvania “Res Judicata Advisory Order” entered in by Judge Peckhrow by sending her fraudulent information about Graves which caused the PA Court to make an error. Wanda became sick and never appealed and Petitioners was not a part of any Pennsylvania actions at this time and unaware of this Pennsylvania Advisory Order. [Recusal of supervisor should have been made in light of relations.]

In New Jersey on June 14, 2011 Coley becomes Rymir’s legal guardian per a NJ per court order. New Jersey then becomes controlling state under Federal Law.

 In Pennsylvania on December 9, 2011 Graves paternity Order of July 16, 2010 was Vacated by Coley in PA; Graves is forever gone, as if he never existed as Rymir’s father;

Coley attempts to Vacate SHAWN CARTER’s May 19, 2011 Advisory PA Order that depended upon Graves which no longer existed as of December 9, 2011 as stated above which was New Information. However, Coley was colluded on by her then attorney James Rocco and Defense Attorney for CARTER, Ned Hark ultimately Coley was MOOT in PA based on Fraud and has no legal standing.

In New Jersey on August 2012 Coley uses Judge Doris Peckrow, in  Pennsylvania on June 14, 2012 Order of Relinquished Jurisdiction to pursue paternity matters in New Jersey. Attorney Ned Hark sends his wife Attorney Fisher to New Jersey to defend SHAWN CARTER’s case by stalling for time while Hark appeal’s in-part the PA Order of Judge Peckhrow regarding the vacate of orders. CARTER does NOT appeal the Relinquished Jurisdiction. Fisher and CARTER allegedly lied on Record stating CARTER does not have any contacts with the State of New Jersey regarding properties but he in fact has properties.

In New Jersey 2012 Attorney Lise Fisher's actions involving both FD-04-002874-12, Lillie Coley v. SHAWN CARTER & Wanda Satterthwaite and FD-04-00186-14, Rymir Satterthwaite v. SHAWN CARTER & Wanda Satterthwaite violated several Codes/ Rules of Professional Conduct as described below. An attorney should uphold the highest standards of conduct in the court and in their legal practice. However, Fisher did not uphold these standards and the court allowed it.

Fisher and CARTER continuously made false statements on record and in her filings. These lies prohibited the discovery of facts, an evidentiary hearing and caused continuous violations to occur.

Fisher gave false statements about her client, CARTER’s, minimum contacts with the State of New Jersey on at least two cases: NEW JERSEY # FD-04-002874-12 & FD-04-0000186-14 and over numerous litigation such as hearings August 13, 2012, December 12, 2012, and November 17, 2014. However, these false statements continued until now(2019). The record has never been corrected.

Robert Graves’s paternity was disestablished, support order vacated and dispositive on paternity of Rymir in PA on April 18, 2011. His name was removed from birth certificate in May 2011. New Jersey had exclusive and continuous jurisdiction of Rymir effective June 14, 2011, while he was still a minor, and NEW JERSEY then became the controlling State. Fisher made false statements regarding the subject jurisdiction at the August 13, 2012 hearing. Fisher stated that a child support order was still in effect in Philadelphia during this time and placed a closed/false child support number on her application and then gave that false information to Coley’s attorney and the NEW JERSEY court that relied upon it. However, thel previous child support order was voided when Graves’ was disestablishment and dispositive on paternity in April 18, 2011 PA Order which Fisher was fully aware of.

On June 14, 2012, Pennsylvania courts relinquished jurisdiction over this matter and this relinquished was never disputed or reverse. Therefore, no conflicts preclude New Jersey Courts to have jurisdiction. Not only does CARTER reside in New Jersey, but due to maintaining his properties and business CARTER assumed contacts with New Jersey. The Orders in June 14, 2012 depended upon Graves and have no legal value thus cannot be used a legal defense by anyone.

Fisher gave false information about both the Subject and Personal Jurisdiction to the Court. CARTER owned at least 3 residential properties in New Jersey and was a resident. CARTER was even served at one of his New Jersey properties. At the August 13, 2012, October 17, 2012 and December 14, 2012 hearings Fisher continued to lie about CARTER owning property in New Jersey even after seeing the Certified Deeds. Fisher kept these false statements going for years in order to prohibit the Court’s establishment of personal jurisdiction over CARTER

Attorney Fisher made Discriminatory [remarks] towards Wanda Satterthwaite on August 13, 2012 stating she did not want Wanda sitting next to her. Although it was clear Wanda was defendant in the case also, but Fisher believe she had authority in government facility. Judge Mc Bride told her “to knock it off”.

Attorney Fisher made false statements to Judge McBride at the August 13, 2012 hearing regarding the personal jurisdiction of CARTER She later said she misspoke at the December 14, 2012 hearing with Judge Mc Bride which was not true because she knew truth before court hearing based on Coley’s application, and she continued to repeat the false information at every [step of] litigation.

Support Orders under the UFISA Act require subject jurisdiction only and paternity under this act require personal jurisdiction only. Only personal jurisdiction is necessary in New Jersey to request paternity testing of CARTER since he owns properties in New Jersey and the Support Order after the testing would be guided under the New Jersey laws since Rymir lived in New Jersey. A person can request paternity while never seeking support and New Jersey absolutely had personal jurisdiction over CARTER, therefore genetic testing could have been ordered by the Court had they been able to establish jurisdiction.

Coley should have received her request for paternity and discovery in 2012 due to SHAWN CARTER's property ownership. Judge McBride agreed, stating on August 13, 2012, "So the issue then is whether there are enough contacts here for there to be general personal jurisdiction meaning the contacts are unrelated to what the subject matter of the lawsuit is. But if the contacts are sufficient enough, under the law and under the Constitution, it can be a case; it just depends on the facts, where a SHAWN CARTER can be required to answer in court to something that is unrelated to those contacts. And I think that's what we have here." August 13, 2012 Transcript Page 37 lines 6-13.

Coley and the New Jersey Court did rely on Fisher's false statements regarding SHAWN CARTER’s New Jersey properties. Again, the New Jersey Court relied upon false statements regarding subject matter when Fisher stated that a Pennsylvania Support Order of Graves was still active in Philadelphia which was false. She also placed this closed Graves’ Support Order on her application and gave it to Coley’s attorney who relied upon and placed it on his documents for Coley. “Be advised that Coley filed her initial application Pro Se then she obtained counsel and Coley did not have any information about Graves Closed Support Order on her application. On August 13, 2012 a ruling on subject and personal jurisdiction was made based on these false statements of Fisher. Coley at the minimum should have obtained personal jurisdiction and discovery due to CARTER’s New Jersey properties. This ruling prohibited the "evidentiary hearing to take place" as described by Judge McBride.

The May 15, 2012 Pennsylvania transcript shows the concealment of evidence by Attorney Fisher to the New Jersey Courts of the false statements made on record regarding Wanda requesting genetic testing from CARTER on April 27, 2012 in Pennsylvania and her knowledge that Coley had no legal standing at this hearing. [See] Pennsylvania hearing on May 15, 2012. Fisher conceal this information from New Jersey Courts from August 2012 to present.

Coley was unaware that she no longer had legal standing on Pennsylvania, [insomuch on] May 15, 2012 until fall of 2015, but Fisher was aware. Fisher concealed evidence of the Pennsylvania transcript and made statements on court records to the contrary of the transcript knowing the statements made were false. Statements made were such as: Coley having legal standing; and Mother requesting a genetic testing on April 27, 2012. Under New Jersey law, concealment of evidence and disrupting a plaintiff's civil action gives rise to liability for proximately caused damages. See, e.g., Hewitt v. Allen Canning, 321 New Jersey Super. 178 (App. Div. 199Ql; Fox v. Mercedes Benz, 281 New Jersey Super 476 (App. Div. 1999). New Jersey law in N.J.S.A. 2C:21-3.

Even during the 2012 Pennsylvania action Rymir was able to exercise the laws of paternity in New Jersey, but Fisher and her husband Attorney Ned Hark sought to try and keep the paternity matter in Philadelphia to hinder Rymir’s rights in New Jersey. 

In 2013 at Rymir’s Inheritance Act litigation Fisher now join with Attorney Kenneth L. Winers again gave false statements about Rymir’s paternity was still in PA and had been adjudicated to Judge Nan Famular. Fisher “Objected” and told the Court after Rymir stated Graves was no longer in the picture that, she stated “Rymir Don’t have any firsthand knowledge about this”, but Fisher had firsthand knowledge. Fisher again concealed another PA Order and in this case the Order of Graves being Vacated on December 9, 2011 demonstrating that Graves was “forever gone” from the PA system as Rymir’s father.

Coley’s November 17, 2014 Request for Hearing was due to this fraud, perjury, and mischaracterization of the documents and omitted attachments given to the Camden Court on August 13, 2012 and December 14, 2012 by Fisher as stated above. Fisher gave false statements in the 2015 brief to the Appellant Court such as stating that Judge Peckhrow vacated the Orders of June 14, 2012 but denied genetic. (PA May 15, 2012 Transcript Page 24 Lines 18-19;) demonstrates the truth of what the Judge Peckhrow stated that Mother did not request a genetic test. Judge Polanksy relied upon Fisher’s false statements and stated that mother had made a request for genetic testing and therefore could not request again. Therefore, the continuous lies of Fisher caused multiple violations against Coley and Rymir and prevented them from receiving a fair litigation. Judge Polansky also believed that Graves became Rymir’s father again based on PA opinion in 2013, but this also was false and caused by Fisher.

Also, at November 17, 2014, before Judge Stephen Polansky, Fisher made additional false statements regarding Rymir’s paternity. Fisher stated that Rymir requested genetic testing of SHAWN CARTER 2011 which is also false, so that it would appear Rymir was barred from requesting any relief in 2013 in New Jersey.

In December 2014, Coley became aware of Fisher filing one version of documents with the courts on November 17, 2014, but serving her with a different version, and requested discovery from Judge Polansky. Fisher stated Judge Dortch was “in her pocket” since SHAWN CARTER was rich client. This is improper conduct of an attorney. Also, per her inappropriate conduct, at the July 17, 2015 hearing see below, Fisher also made multiple offensive and insulting comments to Coley and Rymir to the extent that the court’s Clerk intervened in order for Fisher to discontinue the conduct.

On May 2016 Coley did not make any statements to, conduct any interviews with, or release any information to the media. Therefore, there is no evidence that she has [defied sealed order or the others of the same]. However, Fisher filed a Litigants Aid II Motion against Coley. In response, Coley filed a motion regarding CARTER’s frivolous claims. Coley requested an evidentiary hearing regarding the Litigants Aid II motion, which was granted. In response to the granting of the evidentiary hearing from Coley’s request Fisher withdrew the motion on July 21, 2016. So, there is no Order for this frivolous filing which wasted Coley’s time and money.

On May 1, 2015 the Litigant Aid I Relief filed by Fisher was unfounded and erroneous. This motion named Coley and Rymir although Rymir was not even party to the case. There is no proof in record or otherwise that actions of Coley lead to damages to CARTER since no records left the court. The Civil Law Court refused to seal the record per an emergent request from Fisher, and they also would not sanction Coley, because no violation occurred. So, Fisher then requested sanctions of attorney fees from the Family Court against Coley and received it from Judge Dortch, without any evidence other than statements made by Fisher, and a newspaper article. However, in 2012 Fisher had given the documents of concern to Coley’s attorney, and they became part of the public docket in Philadelphia. In addition, in 2013 a NEW JERSEY Civil Law Court Supervisor released the same documents to the public by way of giving them to an interested Rutgers University student. Attorney Leish, for the Daily News stated that the documents used by the National Enquirer were available and accessed from the online Philadelphia docket. (July 17, 2015 Transcript Page 38 lines 6-11 & Transcript Page 57 lines 24-25). And Fisher admits that the information was obtained from the docket website yet filed the following multiple motions for sanctions. (July 17, 2015 Transcript Page 42 lines 5-10)

On May 13, 2016 litigation changing the May 1, 2015 Order to a Judgment for illegal attorney fees. Fisher’s Motions demonstrate that Rymir was not a party to the action resulting in the May 1, 2015 Sanctions Order. Fisher submitted false documents to the court on May 13, 2016 under this docket no. FD-04-000186-14 asking court to join these cases which was illegal since this FD-14 docket had no underlying case.

Concluding May 28, 2016 & June 28, 2016 Fisher files a Motion to Show Cause which was delayed by the court for several weeks. The Motion was about a two(2) minute video Wanda did to support her son Rymir. All parties were required to respond which was waste of time and money since no Gag Order existed prohibiting anyone from talking about the case as was in the public since 2010. Coley and Rymir were not a part of Wanda’s video. However, Fisher essentially filed another frivolous Motion for money stating Wanda’s Video violated Judge Mc Bride Seal Order on August 13, 2012 at which it does not. After Wanda attorney’s argument on June 28, 2016 in this regard Judge Dortch created a new Order on June 28, 2016 saying no files to public and parties cannot talk about instant. However, the language in the Order was ambiguous and unconstitutional. Nonetheless, Judge Dortch still illegally sanction Wanda for attorney fees since Fisher kept begging him as she wanted to get paid. But, more importantly the new order dated June 28, 2016 proves that Judge Mc Bride Seal Order had no restrictions on parties regarding neither files nor free speech which is why a new one was created by Judge Dortch. This June 28, 2016 Order is on appeal since its unconstitutional and has ambiguous language. The Appellant Division already stated in July 2015 per court order that parties were NOT prohibited to Freedom of Speech since “these cases were already discussed, and files have been disseminated in public”. So, as stated Wanda did not violate any order and Fisher knew her filing was inappropriate.

In December 2016 - Fisher filed yet another Litigants Aid III Motion. After many months of requesting transcript audio of the November 17, 2014 hearing, it was finally received by Wanda. The CD was sent to Mr. Patel, an expert, for review. Patel also owns a UPS store in NEW JERSEY. Patel did not listen to the audio on the CD, he used his software to review the file. Fisher stated in this Litigants Aid III Motion that Patel “published” his analysis and information from the CD. However, Patel sent his analysis of the file directly to the court. He did not send his analysis directly to any parties. And again, Fisher named Rymir in this Motion although he was not involved with case after the CD was sent blank. Coley filed a Response to this Motion, however Fisher erroneously stated that they did not receive the Response. However, the filing was confirmed by the court clerk, and Coley has mail receipts of her service to Fisher.

In January 2017 - Amidst filing the multiple Litigants’ Aid Motions, Fisher advised CARTER to speak with the media. CARTER responded to the media that he “did not rape Wanda,” and that their sexual intercourse in 1992 was “consensual”. However, the other parties did not engage with the media, and Fisher filed multiple Litigants Aid Motions against them.

In June 2017 - An issue listed in the Litigants Aid III Motion regarded embedded links that allegedly lead to the August 13, 2012 hearing transcript on Rymir’s professional Facebook page. However, Fisher stated in court that she did not know where the links came from. And again, Rymir was not a party to this action regarding the transcript. No fact finding, discovery or evidence was ever provided for any of these Motions. This Motion, like the rest, was frivolous and filed to abuse the other parties.

Fisher continuously failed to conduct herself to the standards of Rules of Professional Conduct. Fisher made multiple and continuous false statements in order to obstruct justice, deny the other parties right to due process, intimidate the other parties and prohibit Rymir's right to learn his paternity. As stated Attorney Fisher also made Discriminatory towards Wanda Satterthwaite on August 13, 2012. Her conduct in these matters were unprofessional and some cases inhumane.

Around December or Fall 2018 Attorney Fisher and other attorneys Altered Documents and New Jersey Court Orders located in their client’s, CARTER’s Appendix in Response to Appeal A-229-15 see below.  This behavior was allowed by the Appellant Division Judges in their Fall 2019 opinion.  

The Courts are faced with the type of improper conduct by litigants and lawyers that tarnishes the justice system and makes for a dark day for all involved: the apparent forgery of documents presented to the Court. Previously on appeal, CARTER, the Respondent in Rymir Satterthwaite vs SHAWN CARTER & Wanda Satterthwaite, has added to Volume 2 of his Rymir Brief Appendix three official documents which formed the lower court record, and which now have information “whited out.” Respondent’s Appendix Volume 2 contains substantially-altered materials which contradict the Official Transcript and Official Court Orders in three specific instances – Transcript of a Motion Hearing, Order to Close the Courtroom and Seal the Record, and Order Setting Aside Pennsylvania Orders. In summation, three (3) critical documents which have been entered into the record by the Respondent are altered versions of the original documents filed with the Superior Court. Such conduct warrants the harshest of penalties, including striking the altered submissions from the Court’s record and imposing sanctions on the Respondent’s and his attorneys. However, none of this occur which allowed attorneys to continue.