RECORD NO.

07 - 1720

In The

UNITED STATES COURT OF APPEALS

For The Fourth Circuit

RE: 07 - 1720, Bond v. Blum

ON APPEAL FROM THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND,
NORTHERN DIVISION

----------------

INFORMAL BRIEF OF APPELLANT

----------------

William C. Bond, Pro Se

309 Suffolk Road
Baltimore, Maryland 21218
(410) 243-8152
 TABLE OF CONTENTS

Page

INTRODUCTION.............................................................................................. 1

JURISDICTIONAL STATEMENT................................................................... 4

ISSUES PRESENTED........................................................................................ 6

I. DID THE DISTRICT COURT ERR IN NOT GRANTING

PLAINTIFF’S MOTIONS TO RECUSE, FOR THE CASE TO BE
SPECIALLY ASSIGNED TO A VISITING JUDGE OR, IN THE
ALTERNATIVE, NOT GRANTING A CHANGE IN VENUE; AND
DOES THE CHIEF JUDGE OF A DISTRICT COURT HAVE ANY
EQUITABLE POWER OVER AN ASSOCIATE JUDGE OF A
DISTRICT COURT ON ISSUES THAT ARE SUBJECT TO WRITS
OF MANDAMUS?................................................................................... 6

II. DID THE DISTRICT COURT ERR IN NOT GRANTING

PLAINTIFF’S MOTIONS FOR RULE 60 RELIEF?.............................. 6

III. DID THE DISTRICT COURT ERR IN NOT GRANTING

PLAINTIFF’S MOTIONS FOR A TRO, PERMANENT
INJUNCTION, AND DISCOVERY?..................................................... 6

IV. DID THE DISTRICT COURT ERR IN NOT REOPENING THE

CASE TO GRANT SANCTIONS AGAINST THE DEFENDANTS?... 6

V. DID THE DISTRICT COURT ERR IN NOT DISQUALIFYING

THE ATTORNEYS AT THE BEGINNING OF THE RULE 60
MOTIONS?.............................................................................................. 6

VI. DID THE DISTRICT COURT ERR IN NOT REFERRING THE

ALLEGED CRIMINAL ACTS TO THE APPROPRIATE CRIMINAL
AND ETHICAL AUTHORITIES?........................................................... 6

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STATEMENT OF THE CASE........................................................................... 6

STATEMENT OF FACTS.................................................................................. 8

SUMMARY OF ARGUMENT........................................................................... 11

ARGUMENT....................................................................................................... 14

Statement of Applicable Standard of Review........................................... 16

I. DID THE DISTRICT COURT ERR IN NOT GRANTING

PLAINTIFF’S MOTIONS TO RECUSE, FOR THE CASE TO BE
SPECIALLY ASSIGNED TO A VISITING JUDGE OR, IN THE
ALTERNATIVE, NOT GRANTING A CHANGE IN VENUE; AND
DOES THE CHIEF JUDGE OF A DISTRICT COURT HAVE ANY
EQUITABLE POWER OVER AN ASSOCIATE JUDGE OF A
DISTRICT COURT ON ISSUES THAT ARE SUBJECT TO WRITS
OF MANDAMUS?................................................................................... 18

A) The Case in 2001................................................................................. 18

B) The Case in 2003 – 2007..................................................................... 23

C) The Case in 2007................................................................................. 24

D) Venue & Special Assignment............................................................. 26

E) The Chief Judge................................................................................... 28

II. DID THE DISTRICT COURT ERR IN NOT GRANTING

PLAINTIFF’S MOTIONS FOR RULE 60 RELIEF?.............................. 28

III. DID THE DISTRICT COURT ERR IN NOT GRANTING

PLAINTIFF’S MOTIONS FOR A TRO, PERMANENT
INJUNCTION, AND DISCOVERY?...................................................... 30

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 IV. DID THE DISTRICT COURT ERR IN NOT REOPENING THE
CASE TO GRANT SANCTIONS AGAINST THE DEFENDANTS?... 31

V. DID THE DISTRICT COURT ERR IN NOT DISQUALIFYING

THE ATTORNEYS AT THE BEGINNING OF THE RULE 60
MOTIONS?.............................................................................................. 33

VI. DID THE DISTRICT COURT ERR IN NOT REFERRING THE

ALLEGED CRIMINAL ACTS TO THE APPROPRIATE
CRIMINAL AND ETHICAL AUTHORITIES?...................................... 33

REQUEST FOR ORAL ARGUMENT AND INFORMAL REPLY BRIEF..... 33

RELIEF REQUESTED....................................................................................... 34

CONCLUSION................................................................................................... 35

CERTIFICATE OF COMPLIANCE

CERTIFICATE OF FILING AND SERVICE

ADDENDUM

Maryland Rules, Table of Contents

Maryland Rules, The Maryland Lawyer’s Rules of Professional Conduct,

Table of Contents

Maryland Rules, The Maryland Lawyer’s Rules of Professional Conduct,

Rule 3.1

Maryland Rules, The Maryland Lawyer’s Rules of Professional Conduct,

Rule 8.3

Maryland Rules, The Maryland Lawyer’s Rules of Professional Conduct,

Rule 8.4

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 INFORMAL BRIEF OF APPELLANT

INTRODUCTION

This is no ordinary Case, nor is Appellant any ordinary Pro Se Appellant. To

quote one of the main actor’s attorneys in the cases below, “. . . Reading like a bad

soap opera . . .” Yes, that is this Case.

This Case may be one of the most important cases concerning legal and judicial

ethics, 28 U.S.C. 455, and Fed. R. Civ. P. Rule 60 (b) to come before this Court in

some time, at least since Great Coastal Express, Inc., v. International Brotherhood

of Teamsters, 675 F. 2nd 1349 (4th Circuit 1982). The reason for this claim is

simple: the alleged “Fraud Upon the Court” was perpetrated and then continued

with the explicit expectation to deceive not only the District Court, but this Circuit

Court as well – certainly an important and novel issue for this Court.

Entertainment is the number one export of this country. Appellant makes no

apologies for his literary aspirations described in detail in his post judgment

Motions below. The decision by this Court below is being used as case law
throughout this country and is being taught in law schools like Georgetown

University. Copyright law is of supreme public importance. That this Court has

ruled, conned by the diversions and crimes committed by the Defendants in this

Case below, and has sanctioned, theft as a viable method to defeat a copyright

holder’s right to first publication is not right and should not stand a second review

entitled to Appellant under Rule 60.

While Appellant may very well want to modify his literary works for future

publication, he is handicapped by the totalitarian embargo upon his property and

the fear that no matter what further effort he puts into his literary efforts – efforts

that took more than nine years of hard work – that the Defendants here and their

ilk will sabotage his right to work in private to tell a literary story that no one

would deny his right to tell or the public interest in telling.

This, Court, was the primary intention of copyright law, not exceptions. Not some

self serving nonsense by the selfish and evil people below that somehow the

unconfirmed -- and this is a very key point -- and “highly embellished and

fictionalized” writings of a patricidal maniac’s literary aspirations were of some

legitimate merit and use in the collateral “custody case” involving these same

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actors as the Court shall meet anew.

This Pro Se Appellant is more than willing to put his integrity up against those

that not only have defiled this Court, but our entire justice system, and Appellant

himself. While, so far, the Court has turned the other cheek to these crimes,

Appellant has not, and will not. Pro Se litigation has its time and place in due

process. Clearly, this Case at Bar is a perfect example of its need.

Appellant prays that this honorable Court listens to Appellant’s claims and gives

him shelter from the terrible crimes perpetrated upon him by these Defendants.

Appellant comes to this Court with a simple request, “Shelter.”

Appellant prays for, “Shelter.”

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 JURISDICTIONAL STATEMENT

Jurisdiction of this Court is invoked pursuant to 28 U.S.C. 1291.

This Case concerns a complaint for copyright infringement which was filed by

Appellant on August 29, 2001 in the United States District Court for Maryland,

Northern Division (Civil Action No.: 01-CV-2600). This Court heard appeals from

that case and issued a Judgment on January 24, 2003. Appellant filed a Petition for

Rehearing and Suggestion for Rehearing En Banc, which was denied by an order

filed on March 26, 2003. The Supreme Court denied a Petition for Certiorari on

October 6, 2003. See: Bond v. Blum, 317 F. 3rd 385 (4th Cir. 2003), cert. denied,

540 U.S. 820 (2003). There have been numerous post judgment proceedings in the

District Court regarding the awards of attorneys’ fees to the Defendants by the

District Court.

Beginning on April 26, 2007, Appellant filed, Pro Se, various Motions alleging

violations of 28 U.S.C. 455, Fed. R. Civ. P. 60(b), and other Rules and Laws.

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Defendants countered with Motions to Strike and other defenses.

The Honorable Judge Marvin J. Garbis for the United States District Court for the

District of Maryland, Northern Division issued Orders on (1) May 1, 2007 (paper

no. 253); (2) May 15, 2007 (paper no. 267); (3) July 12, 2007 (paper no. 274); and

(4) July 26, 2007 (paper no. 278) dismissing all claims by Appellant.

It is these Orders Appellant appeals and seeks review of by this Court.

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 ISSUES PRESENTED

I. DID THE DISTRICT COURT ERR IN NOT GRANTING

PLAINTIFF’S MOTIONS TO RECUSE, FOR THE CASE TO BE
SPECIALLY ASSIGNED TO A VISITING JUDGE OR, IN THE
ALTERNATIVE, NOT GRANTING A CHANGE IN VENUE; AND
DOES THE CHIEF JUDGE OF A DISTRICT COURT HAVE ANY
EQUITABLE POWER OVER AN ASSOCIATE JUDGE OF A
DISTRICT COURT ON ISSUES THAT ARE SUBJECT TO WRITS
OF MANDAMUS?

II. DID THE DISTRICT COURT ERR IN NOT GRANTING

PLAINTIFF’S MOTIONS FOR RULE 60 RELIEF?

III. DID THE DISTRICT COURT ERR IN NOT GRANTING

PLAINTIFF’S MOTIONS FOR A TRO, PERMANENT
INJUNCTION, AND DISCOVERY?

IV. DID THE DISTRICT COURT ERR IN NOT REOPENING THE

CASE TO GRANT SANCTIONS AGAINST THE DEFENDANTS?

V. DID THE DISTRICT COURT ERR IN NOT DISQUALIFYING

THE ATTORNEYS AT THE BEGINNING OF THE RULE 60
MOTIONS?

VI. DID THE DISTRICT COURT ERR IN NOT REFERRING THE

ALLEGED CRIMINAL ACTS TO THE APPROPRIATE
CRIMINAL AND ETHICAL AUTHORITIES?

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 STATEMENT OF THE CASE

This Case is about whether a United States District Judge may deny recusal or the

vacatur of his underlying Judgment when it is discovered that he has repeatedly

concealed extrajudicial knowledge of Plaintiff from Plaintiff and his Attorney, and

whether the same United States District Judge may remain the fact finder in a post

judgement action when his conflicts include: that his college ‘roommate’ and good

friend was sued by Plaintiff and that the ‘roommate’ and friend was to be a witness

in the underlying case; that Plaintiff made criminal and ethical complaints about

the Judge and the friend; that the post judgement action concerns, as a primary

fact, the Judge’s own actions; that Plaintiff made criminal and ethical complaints

about one of the attorneys in the underlying case who was once law partners with

the Judge; that Plaintiff has sued under the FOIA the U.S. Attorney for Maryland

and the U.S. District Court for Maryland for, among other things, information

about Plaintiff’s criminal referral about the Judge’s actions and for the Judge’s

telephone records in question; and whether the Judge may continue to stay in the

case when his current ‘best friend’ and golfing buddy, whom the Judge also

collaborates with on books, is representing the primary witness in the underlying

case, and who has used the Judge’s underlying Opinion to defend the witness in

State Actions against her?

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This Case is also about whether the Defendants, Witnesses, Other Persons, and

Attorneys may commit perjury, suborn perjury, obstruct justice, and commit other

crimes to win a copyright case with the intention of using the literary works at

issue to take the minor children in the collateral custody case away from the

mother who raised them their entire lives so that a pathologically obsessed

grandfather and his lackey former son-in-law, himself a habitual crack cocaine

addict, may acquire custody of said children and, in the process, have the State of

Maryland, in a second collateral case, convict and imprison Appellant for ten years

for the act of possessing handguns in a locked safe?

This Case is also about whether these same Defendants, Witnesses, Other Persons,

and Attorneys may use their illegally gained Judgments and Orders to win

collateral State Tort Cases, using the underlying District and Fourth Circuit

Judgements, as Res Judicata, Estoppel, Issue Preclusion, or Judicial Notice, and

thus, making the District and Fourth Circuit Courts co-conspirators to their

racketeering?

STATEMENT OF FACTS1

1
Please see: Informal Appendix of Appellant (hereinafter “IAA”) Vol.1,
Tab 3, Memorandum in Support of Motion for Fed. R. Civ. P. 60 (b) Relief from
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It was not until discovery in one of the underlying State Tort Cases, William C.

Bond v. Gerald A. Messerman et al. (Grossbart), that Appellant (hereinafter

“Bond”) learned of the gross and total defiling of the District and Fourth Circuit

Courts and their Judgments/Orders by the crimes committed by Defendants and

their accomplices (hereinafter “Team Blum”). Team Blum and their accomplices

continued to use these defiled Judgments/Orders to defend State Tort Actions filed

by Bond to hold Team Blum and their accomplices responsible for the theft of his

manuscripts from the law offices of his deceased attorney and friend, and the

award of attorneys’ fees of more than $181,000.00 by the District Court. After

more than three years of litigation in the Maryland Circuit and Appellate Courts,

most claims by Bond were dismissed using the District and/or Fourth Circuit

Judgments/Opinions as either Res Judicata, Estoppel, Issue Preclusion, or Judicial

Notice. The final of these dismissals was in 2007.2 It is extremely important for

this Court to note and to understand that all of these State Tort dismissals came at

Summary Judgment before any discovery was allowed, except for the narrow

Judgment or Order, for a complete recounting of Appellant’s complaints.

2
William C. Bond v. Miriam Pessin et al. is still pending in the Maryland
Court of Special Appeals.
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discovery in Grossbart.3 Bond has been completely thwarted by Team Blum in his

efforts to further uncover their crimes.

In 2004, at the invitation of the U.S. Attorney for Maryland, Thomas M. DiBiagio,

Bond made a criminal referral to the U.S. Attorney for Maryland about the crimes

he alleges here in this appeal. Bond met with and supplied the U.S. Attorney

information to support his allegations. Bond was led to believe that the U.S.

Attorney was going to prosecute his allegations. Then, once DiBiagio was forced

out as U.S. Attorney and after a ten-month-long investigation, Bond’s referral was

declined out of “discretion.” On May 4, 2007, Bond filed a FOIA Lawsuit against

the United States Attorney for Maryland and the United States District Court of

Maryland for all information regarding Bond’s criminal referral in 2004, the

underlying District Court Judge’s telephone records, and the “attorney

disqualification motions” in the ‘Bromwell Case’ regarding Gerard P. Martin,

Esq., one of Team Blum’s lawyers in the case below, a former law partner of the

Judge in question, and the ‘architect’ of the “Fraud Upon the Court” alleged by

3
All the information Bond has on the misdeeds of Team Blum comes from
the discovery in Grossbart which was narrow and limited to the issues in that case.
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Bond.4 This Case is presently before Judge William D. Quarles, Jr., in the U.S.

District Court for Maryland, Northern Division. (WDQ-07-1188).

Bond also filed a Fed. R. Civ. P. Rule 60(b) “Independent Action” seeking

monetary damages and alleging racketeering by Team Blum, using these same

underlying facts as presented here on appeal, on May 24, 2007. Although Bond

asked the District Court to Join this Action with his other Rule 60 Actions, the

Court did not, instead assigning it to Judge J. Frederick Motz of the U.S. District

Court for Maryland, Northern Division. (JFM-07-1385). This Case is still pending

Reconsideration.

SUMMARY OF ARGUMENT

Copyright law has no per se rules, each case needing to be analyzed anew.

4
That the U.S. Attorney for Maryland sought fit to ask for and be granted
the disqualification of Gerard P. Martin, Esq., as counsel in the biggest political
corruption prosecution in Maryland by the Government in twenty years was what
led Plaintiff to believe that he finally had a chance to over come the complete
character assassination perpetrated upon him by Team Blum and the Court. Given
that information, which was important corroboration of wrongdoing, and the
dismissal of his Maryland Circuit Court claims in early 2007 against Team Blum
and their accomplices, it is Bond’s claim that these Rule 60 Actions are timely
filed and so done as soon as humanly possible. Bond can supply further proof that
his Rule 60 Attack Upon the Judgment is timely, including the fact that he was not
even aware of Fed. R. Civ. P. 60(b) until on or about December, 2006.
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Because of Team Blum’s and their accomplices’ actions below, the District and

the Fourth Circuit Courts were denied the opportunity to examine how the

manuscripts were obtained by Team Blum. This examination would have clearly

shown, as it does now, that all the hostile witnesses in the case below conspired to

mislead the Court using perjury, subornation of perjury, obstruction, and other

crimes to divert the Court from how they obtained Bond’s manuscripts and the

nature of Bond’s relationship with the deceased attorney who was entrusted with

their safekeeping.5

In the process, Team Blum was able to convince the District Court and this Court

that 17 U.S.C. 107 was not an exception to the law, but an entitlement under

“eminent domain.” Further, they were not only able to totally confiscate Bond’s

property, but to convince the Courts to Order that Bond pay for the privilege. The

Court should note that even the police would not have had such a right. It should

5
Whether or not Team Blum’s use of Bond’s manuscripts was “fair use” or
not, and Bond strongly believes that under the facts now known that it was not,
certainly Bond was entitled to have his property accounted for and returned to
him, which would have negated any claim by the District Court that Bond’s
actions were “frivolous” and any award of attorneys’ fees to the Defendants. Team
Blum did not go to a book store to purchase these items! If this simple act had
been done, and the law followed, years of litigation would have been saved. Team
Blum was wrong and guilty in 2001 and they are wrong and guilty today.

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also be noted that Team Blum hid their relationships, over and over again, that

they, in fact, had obtained Bond’s manuscripts at the direction of the Maryland

State Police. Team Blum also hid the fact that they circulated Bond’s manuscripts

to many people, including a reporter for The Washington Post who made Bond

and his manuscripts page one news on December 10, 2001 and who somehow was

able to obtain Bond’s manuscripts in order to publish an important and unavailable

quote from Bond’s manuscripts.

When one looks at this Case, the “poisoned tree” of all that has happened has

grown from the deception perpetrated upon Bond by the Court itself. There never

was an impartial fact finder in this Case. The result is all the evidence one needs:

How in this Country may one’s property be seized and one be forced to pay for the

privilege – even “eminent domain” does not go that far?

If Bond was a member of a minority or special interest group, the facts here would

be so gross as to warrant DOJ civil rights inquiry. But, as Bond has seen over and

over again, although he is now 43-years-old and has no criminal record, the legal

mentality of the Bar and its members thinks it is just dandy to continue to beat a

juvenile offender over the head, deny his rights, and to stick it to him because of

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his past rather than to look at the facts.6

ARGUMENT

It is not necessary to read all two hundred and fourteen (214) pages of the

Westlaw citations for 28 U.S.C. 455 for any reasonable person to believe that the

subject Judge in the case below would have questions as to his impartiality. In

fact, it is only attorneys who over complicate these types of issues by over reliance

6
Bond admits that the Bar has many fine, well educated and cultured
members. Unfortunately, it also has a majority consisting of arrogant, mono
educated people crippled by inferiority complexes. Unless you steal your client’s
money or do drugs, the Bar does a very poor job of policing itself, exactly the
same argument the Bar makes of the medical profession before slamming a doctor
with malpractice –“the peers should have done something about so and so . . . ”
Here, in Maryland, The Maryland Lawyers’ Rules of Professional Conduct, Rule
8.3, might as well go in the toilet. For example, in one of Bond’s State Tort Cases,
an attorney, David N. Pessin, the son of his deceased lawyer and friend, filed an
affidavit stating that he did not practice law in Baltimore City, while at the same
time, having some 30-odd cases before the Orphans Court. While the Judge in that
case laughingly denied that claim, do you think the Judge took the extra step in
that case and notified the Disciplinary Committee? Of course not, and one need
look no further than the fact that Mr. Pessin was represented by the attorney of the
former Governor who had appointed said Judge. There are odd numerous
examples of this type of behavior littered throughout Bond’s cases below. Bond’s
litigations have been totally corrupted by the relationships between the actors and
the Courts, the facts have never seen the light of day.
This Court should also note, despite the demonizing of Bond below, that
not only has Bond followed the law and rules explicitly, but that there are no dead
bodies in the street due to retribution and poor self control. Ironically, it is the
hypocritical attorneys in this Case, and others, below, who have manipulated the
law and the rules to their advantage, treating the Court like an ignorant child.
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upon case law or legal scholarship to excuse what is obvious to the naked eye and

what the law clearly states. It is impossible, once the facts in this Case are

reviewed, to come to any other conclusion than that the underlying Judge should

have recused himself at the beginning of the case in 2001, and at every point in

time afterward.

There has been no analysis of Bond’s claims for Fed. R. Civ. P. 60(b) relief in the

District Court whatsoever other than to use the underlying District Court and

Fourth Circuit Opinions as res judicata and estoppel as an excuse for not one iota

of further review. This is akin to a legal Catch-22, creating a circuitous,

continuing defilement of the underlying opinion. There can be no use of

underlying facts or opinions when one is making Rule 60 claims, and to do

otherwise would defeat the entire purpose of Rule 60. This is so self-evident that

one need not be a member of the Bar to ascertain its truth.

The subject Judge in the case below has stated in his Orders(s) that Bond’s claims

are “baseless” without any analysis or new discovery and continued on to say that

if the case went before another Judge that his opinions would automatically be

sustained by the new, unknown Judge. Clearly, a clairvoyant leap of faith. And,

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even if true, which Bond doubts, the process must be followed and the fact finder

allowed to come to his or her own conclusions based upon all the evidence. That

has not happened in this Case.

Therefore, Rule 60 analysis must begin at the District Court and with a new look

at the facts and evidence, and, generally, with renewed, post judgment discovery.

And this is exactly what the Supreme Court of the United States has said when

confronted with this exact issue. See: Standard Oil Co. of Cal. v. United States,

429 U.S. 17 (1976) which places the District Court as the proper place to hear a

Rule 60(b) “Attack Upon the Judgment.”

Statement of Applicable Standard of Review

Every court of appeals except the Seventh Circuit generally uses an “abuse of

discretion” standard for reviewing a trial court’s decision about recusal. The

Seventh Circuit employs de novo review.

Section 455 tells judges when recusal is required but does not spell out the

appropriate remedy for a failure to recuse. In Liljeberg v. Health Services

Acquisition Corp., the U.S. Supreme Court held that Federal Rule of Civil

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Procedure 60(b), authorizing relief from a final judgment, is an appropriate

remedy for a trial court’s improper failure to recuse. The Court cautioned that Rule

60(b)(6) relief is “neither categorically available nor categorically unavailable

for all § 455(a) violations.” Rather, “there is surely room for harmless error

committed by busy judges who inadvertently overlook a disqualifying

circumstance.”

In spelling out the factors to be considered in determining whether a new trial is

the appropriate remedy, the Court cautioned against too casual a finding of

harmless error:

[I]t is appropriate to consider the risk of injustice to the

parties in the particular case, the risk that the denial of
relief will produce injustice in other cases, and the risk of
undermining the public’s confidence in the judicial
process. We must continuously bear in mind that “to
perform its high function in the best way ‘justice
must satisfy the appearance of justice.’”

Quoted from: Recusal: Analysis of Case Law Under 28 U.S.C. §§ 455 & 144

Federal Judicial Center, 2002.

This Court further defined the standard of review for Fed. R. Civ. P. 60(b) in re

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GENESYS DATA TECHNOLOGIES, INCORPORATED, v. Genesys Pacific

Technologies, Incorporated, 204 F.3d 124 (4th Cir. 2000):

The Supreme Court has long recognized the inherent

equity power of courts to set aside a judgment whenever
its enforcement would be "manifestly unconscionable"
because of "fraud upon the court." See Hazel-Atlas Glass
Co. v. Hartford-Empire Co., 322 U.S. 238, 244-45, 64
S.Ct. 997, 88 L.Ed. 1250 (1944).

Courts and authorities agree that "fraud upon the

court" must be narrowly construed so that this
"otherwise nebulous concept" does not "overwhelm the
specific provision of 60(b)(3) and its time limitation
and thereby subvert the balance of equities contained in
the Rule." Great Coastal Express, Inc. v. International
Bhd. of Teamsters, 675 F.2d 1349, 1356 (4th Cir.1982)
(citing numerous cases). Because the power to vacate
a judgment for fraud upon the court is so free from
procedural limitations, it "is limited to fraud that
'seriously' affects the integrity of the normal process of
adjudication," 12 James Wm. Moore et al., Moore's
Federal Practice ¶ 60.21[4] [a] (3d ed.1999). For
example, fraud upon the court includes fraud by bribing
a judge, or tampering with a jury, or fraud by an officer
of the court, including an attorney. See id. ¶
60.21[4][a], [b].

I. DID THE DISTRICT COURT ERR IN NOT GRANTING

PLAINTIFF’S MOTIONS TO RECUSE, FOR THE CASE TO
BE SPECIALLY ASSIGNED TO A VISITING JUDGE OR, IN
THE ALTERNATIVE, NOT GRANTING A CHANGE IN
VENUE; AND DOES THE CHIEF JUDGE OF A DISTRICT

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 COURT HAVE ANY EQUITABLE POWER OVER AN
ASSOCIATE JUDGE OF A DISTRICT COURT ON ISSUES
THAT ARE SUBJECT TO WRITS OF MANDAMUS?

A) The Case in 2001

In 2001, The District Court concealed, repeatedly, from Plaintiff and his Attorney

the nature of the Court’s relationship with Plaintiff’s former juvenile attorney in

Cleveland, Ohio, Gerald A. Messerman, Esq., and the contacts that the Court must

have been having with Messerman. Messerman was the cause of Bond’s collateral

criminal prosecution by the State of Maryland by not having expunged Bond’s

juvenile record as he repeatedly told Bond, and stated to him in writing, that he

had, in fact, done so. At the exact moment in time that the underlying

copyright case was beginning, Messerman was having combative conversations

with Bond’s criminal attorney in Maryland who was defending the criminal

charges, Richard M. Karceski, about what testimony he was willing to provide to

assist Bond.

Messerman said several times to Karceski and Bond that he was worried about

being sued by Bond for malpractice, which, in fact, later, he was. Messerman not

only refused to testify truthfully as to his mistake in the juvenile case, but,

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importantly, he was made aware that he would need to be a fact witness in the

copyright case before the District Court because of conversations he had with

witness Robert N. Grossbart in 1988. It is Bond’s contention that the District

Court ignored the evidence and threw the case so that Messerman would not have

to come to Maryland to testify at Trial as a fact witness, including testifying as to

his malpractice against Bond, but also that the District Court threw the case to

spank Bond, to teach him a lesson, and to assist in his criminal prosecution so as

to help Messerman defend himself against Bond’s claims.7

The District Court, at the end of the Hearing on November 20, 2001, while making

its Oral Order, made a brief reference to knowing Messerman and complimented

his legal acumen.8 Soon after this hearing, in late November 2001, Bond flew to

7
If Bond had been found guilty of the State Gun Crimes, because of the
vagaries in legal malpractice litigation, Messerman would, most likely, have been
off the hook civilly.
8
Even that comment showed bias to Bond. One wonders what the Judge
would have thought about an attorney who had gotten him, or his child, charged
with a crime by dispensing wrong and negligent information? See: “When a trial
judge personally vouches for credibility of a witness, or states that he would not
believe any witnesses called by a particular party, recusal is appropriate.” Dee v.
Institutional Networks Corp., S.D.N.Y.1983, 559 F. Supp. 1282. See also:
“Reasonable person would have harbored doubts about judge's impartiality, so she
should have recused herself, in view of acrimonious relationship between
defendant and attorney whom she had charged with criminal actions and who,
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Cleveland, Ohio to beg Messerman to help with the defense of the criminal case.

At this meeting, Messerman told Bond that he and the District Court Judge had

been “college roommates” at Georgetown University during graduate school and

that he had been the District Court Judge’s “mentor,” among other things. Bond

was very surprised.

Later, in 2003, after this Court remanded the attorneys’ fees issue to the District

Court, Bond put this information in an affidavit, attached to a Motion to Recuse.

In Reply to this Motion to Recuse, the Court, for the first time, answered as to

Bond’s complaints regarding the Court’s conflict, while, concealing, avoiding, or

misleading as to the substantial allegations. It was only during preparation of these

underlying Rule 60 Motions during the Spring of 2007 that Bond saw, finally,

after reading the same thing over and over, the slip that the Court made in this

Reply, and information several lawyers had repeatedly missed. What was long

suspected was now the truth. In Judge Garbis’ own words:

along with his wife, had been law school classmate of the judge and her husband
and who was a partner of the judge's husband.” U.S. v. Jordan, C.A.5 (Tex.) 1995,
49 F.3d 152.

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 “When assigned this instant case in August of 2001, I
noted that Plaintiff’s criminal counsel in Cleveland had
been Mr. Messerman. This fact was of no moment to
me whatsoever.” (Emphasis added.)[Judge Garbis
Memorandum and Order, April 23, 2003.]

It is clear from this statement, as Bond’s copyright action was filed on August 29,

2001 and made no mention of Messerman, that the District Court was having

secret, clandestine conversations with either Gerald A. Messerman, Esq., or

someone on his behalf. Otherwise, how would the Court know this information?

The Court violated both 28 U.S.C. 455 (a) & (e) by not recusing themselves

immediately at the beginning of the case and/or by not at the beginning of the case

putting their extrajudicial knowledge out for all to know and to make objections to

as need be. Because this information was concealed, and because it still has not

been answered to, a reasonable person could only infer that a lack of impartiality

and bias have permeated this Case since its inception.

And it is right here that the Appellate review of this Case should end. While we do

not have the subject Judge having concealed conversations with reporters from the

New Yorker, the analysis is the same as done by the D.C. Circuit Court of Appeals

in United States v. Microsoft Corp., 253 F. 3d (D.C. Cir. 2001). In this case below,

-22-
the District Court was asked more than three times to recuse themselves or to

explain the missing Messerman information. The Court has refused to do so.9 One

can only infer bad behavior and partiality from this silence.

Clearly, here, we have absolute proof of some sort of extrajudicial knowledge

and contact outside of the court room. And if that isn’t enough, 28 U.S.C. 455 (a)

speaks to “appearance" as does the Supreme Court many times. “What matters is

not the reality of bias or prejudice but its appearance.” Liteky v. United States, 510

U.S. 540, 548 (1994). See also: Liljeberg v. Health Services Acquisition Corp.,

486 U.S. 847(1988), as well as the Tenth Circuit's decision in United States v.

Cooley, 1 F.3d 985 (10th Cir. 1993), and the Ninth Circuit's decision in Preston v.

United States, 923 F.2d 731 (9th Cir. 1991). And as we said above, the analysis in

United States v. Microsoft Corp., 253 F. 3d (D.C. Cir. 2001) should control the

analysis in this case.

B) The Case in 2003 – 2007

9
While these Motions may be testy to those unfamiliar with the facts,
politically appointed, public servants have a duty to uphold the integrity of their
institutions. The obviousness of the recusal issues presented by Bond further
enhances his credibility that nefarious motives were and are at work in this Case.
-23-
In 2003, once confronted with partial evidence of the District Court’s conflict, and

once Motions were filed for Recusal, the District Court continued to bash Bond,

and, knowing their hidden and concealed conflict, awarded the copyright case

Defendants more than $151,000.00 in attorneys’ fees. Clearly, evidence of bias.

Further, when Bond won a settlement from Gossbart in one of the State Tort

Actions he filed, this money was garnished by the Defendants and processed

through the District Court by the subject Judge, knowing full well that this money

was being “stolen” by the Defendants under the hidden guise of the Court’s lack of

impartiality. The Court continued to watch, as the Defendants harassed Bond and

his wife10 with numerous garnishments and bank account freezes, depositions, and

other harassments, all the while knowing that the Court was keeping hidden from

Bond and his Attorney information which would have warranted the Recusal of

the Court and the vacatur of the Judgment.

C) The Case in 2007

10
Team Blum knew that Mrs. Bond was stricken with lymphoma – her own
father continued to bash her family and her own financial health – hardly a man
concerned about his “family.”
-24-
Bond filed Renewed Motions for Recusal, Motions for Reconsideration, and a

Supplement, later converted by the Court to an Independent Motion because of

clerical error.11

Bond asked the Court to Recuse because of the non answer as to the Messerman

issues, the fact that the Court was a subject of the Rule 60 Actions, the fact that the

Court was a former law partner with an attorney in the case who was the

‘architect’ of the “Fraud Upon the Court,” the fact that the Court and the

Defendants were subjects of the U.S. Attorney investigation, that the Court was

now a Defendant in Bond’s FOIA Lawsuit, and, finally, that the Judge was ‘best

friends’ and had written books with the attorney who was representing the primary

fact witness in the underlying case, should the Court’s Orders be vacated. 12

11
There has been rampant clerical error in Bond’s District Court cases
because of his pro se status. Simply, he has not been copied orders or papers at
various times, to his determent. The Informal Appendix of Appellant, for example,
does not contain the Defendants’ filings because, as Bond was assembling his
Appendix and comparing it to the docket, he noted that Defendants had not copied
him paper numbers 258, 259, 260. While Bond was going to include the
Defendants’ filings in his Informal Appendix, he obviously did not have their
complete filings, nor did he know their content at the time the Appendix needed to
be at the printers. Therefore, he has suggested to Defendants that, should they
desire to have this Court have the convenience of their filings before them, they
make their own Informal Appendix.
12
Please see: IAA, Vol. 1, Tab #’s 1, 10, 11, 12, 17, 18, 19, 20, & 21.
-25-
The Court repeatedly violated both 28 U.S.C. 455 (a) & (e) by either not recusing,

not answering to recusal, or not revealing conflicts, such as the conflict with

attorney Paul Mark Sandler, Esq., which was independently discovered by Bond

by accident.13

In sum, the citing of the hundreds of pages of case law available at Westlaw on 28

U.S.C. 455 is unnecessary here. The facts are obvious. And they are multiple.

Further, the close call should go to the party asking for recusal. See: “If question

of whether judge's impartiality might reasonably be questioned so as to require his

disqualification is close one, balance tips in favor of recusal.” Nichols v. Alley,

C.A.10 (Okla.) 1995, 71 F.3d 347. “Judge should exercise his discretion in favor

of disqualification if he has any question about propriety of sitting in particular

case.” Hall v. Small Business Admin., C.A.5 (Miss.) 1983, 695 F.2d 175.

D) Venue & Special Assignment

The reasonable man theory is based upon the “reasonable” every man, not

attorneys playing mind games with the truth. No more evidence is needed in this

Case than the fact that the United States Attorney itself was going to seek a change

13
Please see: IAA, Vol. 1, Tab # 18, 20, & 21.
-26-
of venue in their prosecution of Bond’s criminal referral because of the public

officials’ and former public officials’ involvement with the Court. But, this Court

could also, as well, ask various ‘every men and women’ at the drug store, the car

wash, etc., about the facts of this Case and they would all say, universally, that

when one sues a U.S. District Court and has made criminal and ethical allegations

against one of its Judges, that getting a fair trial in that jurisdiction might be far

fetched. See: “A judge faced with a potential ground for disqualification ought to

consider how his participation in a given case looks to the average person on the

street; use of the word "might" in this section was intended to indicate that

disqualification should follow if reasonable man, were he to know all the

circumstances, would harbor, doubts about judge's impartiality.” Potashnick v.

Port City Const. Co., C.A.5 (Ala.) 1980, 609 F.2d 1101, rehearing denied 613 F.2d

314, certiorari denied 101 S.Ct. 78, 449 U.S. 820, 66 L.Ed.2d 22.

Here, the personalities, again, won out, not the important job of vetting the

integrity of the institution so that it may survive human foibles, have its integrity

checked, and prove itself to be worthy of public trust and confidence. Again, the

cases cited on 28 U.S.C. 455 all speak in one way or another to this very important

issue: the public’s confidence in the institution is far more important than those of

-27-
the feelings of a U.S. District Judge, rightly or wrongly accused.

Clearly, the facts below merited either a change of Venue or that a Visiting Judge

be Specially Assigned.14 This Court should send a message so that in the future,

when legitimate claims such as this are made, the Court errs on the side of caution

to protect the institution, rather than the man.

E) The Chief Judge

While Writs of Mandamus are abolished at the District Court level, this Court

should answer the very technical question of whether or not the Chief Judge of a

District Court has any “equitable” power over his Associate Judges on issues that

would be subject to a Writ of Mandamus at the Circuit Court level when those

issues are so obvious as to cry out for judicial intervention and efficiency, and to

14
Should this Court remand Bond’s claims, Venue and Special Assignment
are paramount issues and should be granted under the facts of this Case, but now
that the Court below has split Bond’s claims, Bond states to this Court that he has
no problem with the current Judge, who has Bond’s Rule 60 “Independent
Action”, former Chief Judge of the U.S. District Court of Maryland, the Hon. J.
Frederick Motz, hearing his combined actions, should this Court return this Case,
as his integrity and fairness Bond has learned are beyond reproach. Nevertheless,
as to those thoughts and opinions, one District Judge ruling upon the actions of his
fellow Judge creates problems which are best solved by Venue and Special
Assignment.
-28-
save the District Court not only from embarrassment, but to reinforce the public’s

confidence in the Court. It is Bond’s contention that because of the “equitable”

power of the Court that the Court was not impotent in this Case and could, and

should, have acted to protect the integrity of the Court as an institution.

II. DID THE DISTRICT COURT ERR IN NOT GRANTING

PLAINTIFF’S MOTIONS FOR RULE 60 RELIEF?

This Court has already ruled on the issues this Case presents: “Involvement of an

attorney, as an officer of the court, in a scheme to suborn perjury would

certainly be considered fraud on the court.” (Emphasis added.) Great Coastal

Express, Inc., v. International Brotherhood of Teamsters, 675 F. 2nd 1349 (4th

Circuit 1982).

In this Case, we have not only the involvement of one attorney, but several, and

the Judge in the “Fraud Upon the Court.” In this Case, we also have an

“Orchestrated Effort on behalf of the Defendants, Witnesses, Other Persons, and

Attorneys to Defraud the Court on a Matter of Public Import.” Clearly, as alleged

below in great detail a fraud was perpetrated upon the Court by the Defendants,

-29-
Witnesses, Other Persons, and Attorneys. The fraud was not simple, Rule 60(b)(3)

fraud which must be pled in one year, as Defendants have claimed in their post

judgments papers, but clearly the type of fraud which is “manifestly

unconscionable” and has no time limit.15

Team Blum makes no arguments below why these allegations by Bond do not

merit Rule 60 relief other than to rely upon res judicata and collateral estoppel of

the defiled Judgments in question and to cry that too much time has passed.16

This Court, the copyright laws of the United States, and Bond, himself, need to be

protected from the perpetrators of this “Fraud Upon the Court.” Bond is entitled to

every and all relief he requested below.

See: IAA, Vol. 1, Tab #’s 2, 3, 5, 13, & 14 in addition to the Recusal
15

Motions already cited above.

16
It is a typical tactic by Team Blum to assert that a supposed technicality
would absolve them of responsibility for their criminal behavior in continuing the
Federal and State litigations with defenses and victories gained via Fraud and then
to claim Bond is late to the altar when he finally has exhausted State remedies as
to their crimes and returns to the Federal arena, well within the three-year statute
of limitations in Maryland, with new allegations and new facts. The important
issue here is the perversion of the Justice System by Team Blum, not how long
Bond has had to fight to get an audience as to his violation. See: Hazel-Atlas Glass
Co. v. Hartford-Empire Co., 322 U.S. 238 (1944) and Great Coastal Express, Inc.,
v. International Brotherhood of Teamsters, 675 F. 2nd 1349 (4th Circuit 1982).
-30-
 III. DID THE DISTRICT COURT ERR IN NOT GRANTING
PLAINTIFF’S MOTIONS FOR A TRO, PERMANENT
INJUNCTION, AND DISCOVERY?

Clearly, Bond alleged new and additional facts which would warrant any impartial

fact finder to order the return and accounting of his property and to order new

discovery and/or post judgment discovery so as to get to the bottom of the

allegations which Bond raised below and which the facts support as having merit,

including the illegal use of Bond’s manuscripts by The Washington Post.17

Further, although Team Blum claims below that Bond did not follow Fed. R. Civ.

P. Rule 27(a) as far as “petitioning” the Court for Discovery, nothing could be

further from the truth. A careful reading will show that Bond, in his underlying

Motion for new Discovery, (Please see: IAA, Vol. 1, Tab 6), has thoroughly

described what he is seeking and why. In addition, it is not only Rule 27(a) which

is applicable to Bond’s Motions, but Rule 27(c).

17
See: IAA, Vol. 1, Tab #’s 4, 5, 6, & 15.
-31-
 IV. DID THE DISTRICT COURT ERR IN NOT REOPENING
THE CASE TO GRANT SANCTIONS AGAINST THE
DEFENDANTS?

Team Blum, in their post judgement arguments below, cites Outen v. Baltimore

County, Maryland, 177 F.R.D. 346 (4th Circuit 1998) rather than the controlling

case, Great Coastal Express, Inc., v. International Brotherhood of Teamsters, 675

F. 2nd 1349 (4th Circuit 1982). This Court should remember that in Outen and in

Great Coastal Express, this Court expressed dismay that Fed. R. Civ. P. Rule 60

(b)(3) limited them to a one year moratorium for fraud and expressed a desire that

they could do something about the facts with which they were presented. Team

Blum here, again, seems to imply that Bond is frivolous for complaining as to his

damages to property and person.

But, as is clear, this is a Fed. R. Civ. P. 60 (b) “Fraud Upon the Court” Attack

Upon the Judgment which has no time limit. This Court may reopen the

underlying Judgment. This Court may also order Sanctions imposed against the

offending parties or persons, some of whom may now be immune from their

greater crimes because of the statute of limitations or settlement releases.

-32-
Further, Bond would argue that Rule 11 safe harbor has been met as Team Blum

had adequate time and notice to correct the record below, were they so inclined, as

clearly the case was never opened for the time to toll. In addition, Bond asked for

Sanctions in categories outside of Rule 11 which would be up to the fact finder to

impose.

Bond urges this Court that, in this Case, Sanctions are appropriate and allowed.

V. DID THE DISTRICT COURT ERR IN NOT

DISQUALIFYING THE ATTORNEYS AT THE BEGINNING
OF THE RULE 60 MOTIONS?

Yes. Bond’s arguments are explained in his Conclusion to this Informal Brief.

VI. DID THE DISTRICT COURT ERR IN NOT REFERRING

THE ALLEGED CRIMINAL ACTS TO THE APPROPRIATE
CRIMINAL AND ETHICAL AUTHORITIES?

Yes. Again, Bond’s arguments are explained in his Conclusion to this Informal

Brief.

-33-
 REQUEST FOR ORAL ARGUMENT AND INFORMAL REPLY BRIEF

This Case was previously heard by this Court, albeit with crucial information

missing. While Bond views the issues presented here to be simple and easy to

resolve, no doubt Team Blum will seek to cloud these simple issues with their

filings to confuse the Court. Therefore, Bond requests that the Court order the

Clerk to provide a date for him to file an Informal Reply Brief. Further, because of

the long and tortured nature of this litigation, which has produced many, many

facts, and issues arising thereof, which may cause the Court some confusion as to

time lines, motivations of parties, etc., Bond requests that this Court grant Oral

Argument on an expedited basis should they be disposed to Rule in favor of Team

Blum.

RELIEF REQUESTED

Bond seeks the vacatur of the underlying Judgement and Orders in this Case,

including the award of attorneys fees to Team Blum, and the ordered return and

accounting of his manuscripts. Bond seeks to be awarded attorneys’ fees in the

case below and that this Court order Sanctions against Team Blum and other

persons. Bond seeks the recusal of the subject Judge and that this Case on remand

be either assigned to Judge J. Frederick Motz, a specially assigned visiting Judge,

-34-
or transferred to the District Court of the District of Columbia for Trial on the

merits, should Bond himself not be entitled to Summary Judgement and a directed

Verdict. Bond seeks the disqualification of the attorneys and an order by this

Court for these matters to be investigated at the District Court level, both

criminally and ethically.

In the alternative, Bond requests that this Court order stricken from the record any

reference to the findings below that Bond’s actions were “frivolous,” that his

manuscripts were not “stolen” and that anyone but Bond was in “rightful”

possession of his manuscripts, to strike the award of attorneys’ fees to Team Blum,

and to order new Discovery to be conducted in this matter.

Bond requests any and all other relief to which he would be entitled.

CONCLUSION

“It may well be that Plaintiff has claims as to which there

would be questions of facts requiring resolution.
However, those matters were not presented for decision
in the instant case, were not resolved in the instant case
and, apparently have been raised and resolved in other

-35-
 litigation conducted by Plaintiff.” (Emphasis added).
(Judge Marvin J. Garbis, Order 7/12/2007, Page 7).18

Obviously, these claims consisting of facts requiring resolution are questions

requiring Federal resolution. And it is only because of the concealed extrajudicial

conflicts and other conflicts the subject Judge has, and had, in this Case that

Bond’s issues are even before this Court. This Case, since its inception, has always

been about the parties and never about the law or the facts.19

And as Judge Garbis says above, if there are facts requiring resolution, obviously,

the attorneys involved who created those questionable facts, should not be

involved in their resolution – criminals should not be involved in fact finding.

Hence, it is obvious, that at some point, at minimum, that one Gerard P. Martin,

Esq., be disqualified as counsel in this Case.20

18
See: IAA, Vol. 1, Tab # 19.
19
Most of the Parties and persons implicated of wrong doing in the case
below are members of and/or associated with the Baltimore Irish/Jewish
Democratic Party fundraising machines who have controlled Maryland and
Baltimore City politics for over forty years, including Judicial appointments. This
“Pikesville Mafia” has used every ounce of its influence to defeat Bond at every
step of the way, including manipulating the Maryland Attorney General’s Office
and the Maryland State Police.
20
Martin disingenuously states in his Opposition to Bond’s Motion to Refer
Criminal Acts, paper # 260, that Bond’s claims are “utterly without basis” and that
-36-
As for the issues of criminal and ethical sanctions: while these Defendants,

Witnesses, Other Persons, and Attorneys may well have been good people at one

time, that has all been lost with their entry into crime, to win at all costs, and to

manipulate and game the legal system for their own profit. Good attorneys will

refuse to accept representation or to defend the indefensible when that

representation involves the manufacture of new facts or the obstruction into fact

finding. At Bar, the Attorneys had the knowledge that their clients committed a

theft of copyrighted property from the office of an attorney. They were caught red

handed. But, rather than advise their clients to get out of more trouble, they joined

in and piled on.21

The Attorneys’ situation in this Case is no different from that of the four Navy

SEALs who jumped to their deaths out of helicopters into the sea which was

swirling with sixteen foot waves during the invasion of Grenada in 1983. While

Bond has not “explained what acts he attributes to any attorney or any defendant
that would justify referral to the U.S. Attorney, etc. ...” But, Bond, in his Rule 60
Motions, has clearly alleged and stated factual proof by Martin’s own words that
he and Defendant Hodgson conspired to commit perjury, suborn perjury, and
obstruct justice, among many other crimes. (Please see: IAA, Vol. 1, Tab 3, Pages
30 - 35, 42 - 45.)

Please see: Maryland Rules, The Maryland Lawyer’s Rules of

21

Professional Conduct, Rule 3.1, 8.3, & 8.4.

-37-
each of those men were noble (Bond is by no means comparing the character of

those warriors to those who make up Team Blum, only the events of their story are

relevant here), they did not balance the reality of wearing 110lb packs while trying

to swim hundreds of yards in impossible conditions. Further, they did not question

their commanders who were issuing these orders for suicide. They did not properly

balance one of the fundamental tenets of warfare: aggression v. caution.

Here, assuming the Attorneys in this Case were ever good people, they did not

balance the realities of their conditions, including knowing full well that some of

their clients were criminals, associated with criminals, and/or had previously been

prosecuted by the U.S. Government for racketeering, with the facts they were

presented with. These Attorneys should have known better. They should have

known that this whole mess stank to high heaven. But they did not. In fact, they

piled on and used their leverage and connections to have clandestine meetings with

the police and the Maryland Attorney General’s Office in an effort to get Bond

prosecuted and incarcerated for ten years for an unrelated, victimless crime of

having handguns locked in a safe in his home all so they could win the collateral

custody case. They now can seek no mercy that their crimes here should not bear

-38-
the full wrath of the law. The Bible says: “He who lives by the sword, dies by the

sword.”

“... Plaintiff is free to take whatever legal action may be

appropriate in whatever forum may be available to him.”
(Judge Garbis, Order 7/12/2007, Page 10.)22

Team Blum and their accomplices have knowingly used their defiled victories

before the District and this Court to win all other collateral cases. A review by this

Court of their filings below will show that, even after accused by Bond, they have

continued to make a mockery of this Court by using those Judgments and Orders in

defense of these Rule 60 Actions. There is no other polite way to put it than this: is

this Court going to allow a bunch of lying criminals and their Attorneys to

defile this Court and get away with it?

“You know you have ‘right’ on your side.” Barbara S. Sale, Chief, Criminal

Division, United States Attorney, District of Maryland, November 16, 2004.

Appellant prays for “Shelter” from this honorable Court.

22
Please see: IAA, Vol. 1, Tab 19.
-39-
Respectfully submitted,

WILLIAM C. BOND
Pro Se
309 Suffolk Road
Baltimore, Maryland 21218
(410) 243-8152

-40-
 UNITED STATES COURT OF APPEALS

for the

FOURTH CIRCUIT

WILLIAM C. BOND, *

Plaintiff Pro Se
v. * 07-1720 Bond v. Blum

KENNETH BLUM, SR., et al. *

Defendants *

* * * * * * * * *

CERTIFICATE OF FILING AND SERVICE

I HEREBY CERTIFY that on the 24th day of August, 2007, the required
number of copies of Appellant’s Informal Brief and Appendix were mailed U.S.
Mail, postage prepaid, to the: Clerk, U.S. Court of Appeals, Fourth Circuit, U.S.
Courthouse Annex, 5th Floor, 1100 East Main Street, Richmond, Virginia 23219
and to: William F. Ryan, Jr., Esquire, Amy E. Askew, Esquire, Whiteford, Taylor
& Preston, LLP, Suite 1400, 7 St. Paul Street, Baltimore, Maryland 21202-1626,
attorneys for Appellees McDaniel, Bennett & Griffin; Gerard P. Martin, Esquire,
Thy C. Pham, Esquire, Rosenberg, Martin, Greenberg LLP, 25 South Charles
Street, Suite 2115, Baltimore, Maryland 21201-3322, attorneys for Appellees,
Dudley F. B. Hodgson, Kenneth Blum, Sr. and Kenneth Blum, Jr.; Andrew
Radding, Esquire, Michael R. Severino, Esquire, Adelberg, Rudow, Dorf &
Hendler, LLC, 7 St. Paul Street, Suite 600, Baltimore, Maryland 21202, attorneys
for Appellees, Adelberg, Rudow, Dorf & Hendler, LLC; and Appellee William H.
Slavin, 300 Three Island Boulevard, Apartment 810, Hollandale Beach, Florida
33009.
WILLIAM C. BOND
Pro Se
309 Suffolk Road
Baltimore, Maryland 21218
(410) 243-8152