Andy Martin: Mark Kirk's Secret Agent Man?

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By Bill Pascoe | January 7, 2010 

If I were a Birther, or a Bircher, or Mel Gibson playing Jerry Fletcher in "Conspiracy Theory", I'd be convinced that Andy Martin's campaign is being secretly funded by allies of GOP rival Mark Steven Kirk.
Kirk, of course, is the liberal Republican congressman who represents Illinois' 10th Congressional District -- Chicago's North Shore suburbs (which you've seen in the background if you ever watched "Ferris Bueller's Day Off" or "Risky Business" or the CBS summer replacement series "Swingtown") -- and is now running for the GOP nomination for the Senate seat once held by Barack Obama.

Martin, for those readers outside the listening range of Chicago radio stations WLS, WGN, and WBBM, would be described properly as a "gadfly," except that I actually know and like some gadflies, and I wouldn't want to insult them.

He is a perpetual candidate for office whose Wikipedia entry is so wildly amusing that three weeks ago, he filed a lawsuit against -- wait for it -- Wikipedia itself, claiming that it is "a tax-exempt protosocialist scam that seeks to harass Republicans, conservatives and Obama opponents."

So, with that as our background, why would a conspiracy theorist believe that Kirk's allies are secretly funding Martin's campaign?

Because last week, Martin aired radio ads declaring that a well known conservative donor in Illinois says there is a "solid rumor" that Kirk is gay. And yesterday, Martin upped the ante, swapping out that ad for a new radio ad, declaring that Kirk is a "de facto pedophile."
Even in the cesspool that is Chicago politics, this is strong stuff.

Nobody I know buys the content of the advertising. In fact, just about everybody I know -- myself included -- thinks it's some of the most repugnant stuff they've ever heard aired in a campaign.

These ads are so inflammatory that, surely, any reasonable person could see that they do nothing but damage whatever kind of a "campaign" Martin had put together for himself.

More importantly, in an odd turn, the ads actually help Kirk.

To understand how, we have to back up just a bit.

Consider:
The National Republican Senatorial Committee wants this seat badly. This is the seat, after all, that is currently held by Roland Burris. Given the national controversy over then-Gov. Rod Blagojevich's decision to appoint Burris, the NRSC, appropriately, almost feels entitled to the seat.
From the beginning, Kirk is the guy they wanted in the race. His liberal-to-moderate record -- he scored a 48 on the American Conservative Union rating in 2008, and a 40 in 2007 -- made him, in the eyes of Washington-based GOP strategists, just the kind of "centrist Republican" they thought would be needed to win a statewide race in Illinois.

For months, Kirk played coy. He would express interest, but refuse to commit -- clearly, he was worried about Democratic Attorney General Lisa Madigan jumping into the race on the other side of the aisle. Why give up a House seat he had held onto in two tough re-election campaigns in 2006 and 2008, just to lose to the 800-pound gorilla of Illinois politics?
So when Kirk voted for the cap-and-trade environmental bill -- he was one of only eight Republicans in the House to do so -- many of those same Washington-based Republican strategists took it as a sign he wouldn't be running for the Senate after all.

The NRSC, approaching desperation, began discussions with then-Illinois GOP chairman Andy McKenna (whose previous run at statewide office -- coincidentally, for the same Senate seat, in 2004 -- had ended in a disappointing fourth-place finish in the GOP primary).

Then Madigan announced she wouldn't be running for the Senate, and Kirk immediately declared a mulligan. He started calling allies, telling them he'd decided to get in, after all. But McKenna saw Kirk's vote for cap-and-trade as a massive liability (especially in a GOP primary), and made strong noises about challenging Kirk for the nod. Kirk made clear to the NRSC that the committee had to get McKenna out of the Senate primary, or he wouldn't get in. Eventually, McKenna backed off, and decided to run for the GOP nomination for governor instead.

So NRSC leaders ultimately got the candidate they wanted -- a Republican congressman from the North Shore suburbs, whose liberal voting record includes not just the vote for cap-and-trade, but strong support for abortion rights (Kirk earned a 100 percent rating from both Planned Parenthood and NARAL), an "F" rating from the NRA (and an "F-" from the Gun Owners of America!), and votes against the ban on "partial-birth" abortion and against defending traditional marriage.

Perhaps more importantly for an Illinois Republican primary, Kirk also voted to authorize funding to transfer enemy combatants from Guantanamo Bay.

The NRSC may have had influence over McKenna, but the committee had little influence over others in Illinois who were interested in the GOP nomination -- like Patrick Hughes and John Arrington and Kathleen Thomas and Don Lowery.

By all accounts, it's difficult to find much evidence of campaigns being mounted by Arrington, Thomas, and Lowery.

Hughes, on the other hand, is a different matter.
A Hinsdale developer, Hughes announced in August 2009 that he would challenge Kirk for the GOP nomination.

He launched his first TV ad this week, and his appearance before the Chicago Tribune editorial board shows a candidate who is thoughtful, reasonable, and conservative -- and one who knows how to define a contrast between himself and his opponent.
He began his campaign by putting his money where his mouth is, with a $250,000 contribution to kick-start things. The grass-roots enthusiasm for his candidacy appears to be growing -- on Tuesday, in Homer Glen (a southwest suburb of Chicago), 500 people showed up at a meet-and-greet hosted by the Will County Tea Party Alliance, and the campaign almost ran out of yard signs. As I write this on Thursday, he's got a crowd of 100 who've braved a Chicago snowstorm to attend a fundraising lunch in Lake Forest (a North Shore suburb in Kirk's back yard).

But he faces the same chicken-and-egg problem all underdog, underfinanced campaigns face when it comes to taking on the big dogs -- people who should be his natural allies say, "We'd love to be helpful, but you need to show us some metrics that show you can win." No one wants to be the first to plant a flag; even among many conservatives, there's a tendency to want to wrap oneself in the strength provided by numbers.
Kirk, of course, is acting like there's no primary, because it's to his benefit to sneak this one in under the radar. He's making few campaign appearances, skipping the kind of local joint candidate forums that are the bread and butter of primary campaigns. He's paid for no television ads, no radio ads, no direct mail, and only one walk piece. He's hoping that his superior name identification, combined with what will likely be low primary turnout for the Feb. 2 primary, can lead him to victory without having to drain any of his precious campaign resources -- resources he thinks he'll need for a bruising fall general election campaign.

So Kirk would be happy if the Illinois media didn't write a single article about the contest between now and Feb. 2; failing that, his next highest wish is to have nothing written about Hughes, the one conservative challenger who looks like he could actually mount a sustained challenge to Kirk's nomination.

Given that there's a donnybrook going on in the contest for the GOP nomination for governor -- a contest which features no fewer than six serious candidates, and which has provided much entertainment for the political class in Illinois -- Kirk isn't asking for much. He's just trying to keep his head down and keep everyone's attention focused on the governor's race instead of the Senate primary, and whatever you do, don't write about Hughes.

That's why Martin's outrageous ads help Kirk -- they suck up what little media oxygen is in the room for the Senate contest. Hughes can't break through in earned media if the story of the day is Andy Martin and his whacko ads.

It's almost enough to make you think ... nah, not even Machiavelli would have come up with this kind of scheme.

Of course, Machiavelli probably would've lost a race for Alderman.

Andy Martin's Dirty Tricks. DO NOT VOTE FOR HIM IN 2010

The dirty tricks are really being played by Andy Martin. Look at his record. Jail time, lies (lots of them), disconnect with reality, frivolous lawsuits, ANTI-Semitic statements and physical violence against others. Just look at these videos.

http://www.youtube.com/watch?v=BFnuhaU458Y

http://www.youtube.com/watch?v=AaxIoQljADw



Martin has been declared to have mental issues making him not worthy of being admitted to the Illinois bar association. he wasn't admitted but should be committed.

He is a danger to society and himself. It's a matter of time before he really hurts someone or possibly kills someone based on his mental state.

Another Frivolous Lawsuit by Andy Martin.

In an Illinois lawsuit submitted in September 2009, Martin details his accusations against Maryland residents and authorities.

His conspiracy theory of Obama Operatives runs deep into his mind with this one. Please keep in mind that this man is running for a senate seat in Illinois. The lawsuit below reads exactly as he submitted it to the courts.

IN THE CIRCUIT COURT
FOR THE SEVENTH JUDICIAL CIRCUIT OF ILLINOIS
SPRINGFIELD, ILLINOIS

IN CHANCERY
CASE NO. 09 CH 737

ANDY MARTIN,

Plaintiff,

vs.

WASHINGTON POST COMPANY,
DANIEL MORSE, SCOTT SHIRLEY,
D/B/A/ ADR PRODUCTIONS,
GOOGLE, INC.,
JOHN GILCHRIST,
A/K/A JOHN BORLAZA,
JIM BROSEMER,
MONTGOMERY COUNTY,
MARYLAND,
JOHN J. MCCARTHY,
JOHN DOE AGENT OF MARK and/or
KIRK BARACK HUSSEIN OBAMA
WILLIAM G. SIMMONS,
EUGENE WOLFE, CHERYL MCCALLY,

Defendants.

COMPLAINT

Introduction

The 1972 Watergate Conspiracy began as a “third-rate burglary,” and culminated in a national scandal exposed by the Washington Post. This lawsuit arises out of a mini-Watergate scandal, in which a small—time huckster and extortionist, Scott Shirley, has combined with Plaintiff’s political opposition to harass Plaintiff’s professional and political activity using Maryland judges as adjuncts to the criminal conspiracy. At this time, the full dimensions and all of the identities of the co-conspirators are unknown. In due course, they will be exposed. This time, rather than exposing the conspiracy, the Washington Post appears to be part of the political machinations to violate the law.
COUNT ONE

[OWNERSHIP CLAIM]

1. Jurisdiction and venue
a. This court has general common law jurisdiction of the controversy.
b. Substantially all of the operative activity of the defendants is targeted at and “purposefully directed” against the Plaintiff in Illinois. Therefore, this Court has personal jurisdiction.
2. The parties
a. Plaintiff Andy Martin (“Plaintiff”) is a candidate for United States Senator. He is a world-respected Internet publisher and columnist, see e.g. ContrarianCommentary.com. Martin is Illinois’ most durable and independent corruption fighter (see http://www.andymartin.com/) and has helped send corrupt politicians and judges to jail.
b. Defendant Washington Post Company and its employee Daniel Morse are involved in some fashion with defendant Scott Shirley, as well as possibly other Kirk/Obama-related defendants, in a civil conspiracy directed at Plaintiff in Illinois.
c. Defendant Scott Shirley, d/b/a ADR Productions, is involved in both a civil and criminal conspiracy to harass and obstruct Plaintiff’s professional and political activity, as set forth in this Complaint.
d. Google, Inc. is the owner of YouTube and has been broadcasting Shirley's bogus attack ad, using Plaintiff’s pirated intellectual property on the Internet.
e. John Gilchrist, a/k/a John Borlaza, is a person whose full role in the matters sub judice is still not clear.
f. Montgomery County, Maryland is a defendant based on the failure of the county to protect Plaintiff’s right to file a consumer complaint without fear of harassment from the corrupt governmental structure of the county.
g. John J. McCarthy is the State Attorney of Montgomery County, and has refused to investigate the violations of Plaintiff’s rights by Shirley and others.
h. John Doe agent of Mark Kirk, and/or Barack Hussein Obama, is a person or persons unknown whose identity will be revealed during the course of this lawsuit.
i. William G. Simmons, Eugene Wolfe and Cheryl McCally are “chumbolone” members of the district court in Montgomery County who have been aiding and abetting Shirley in his extortion and harassment scheme against the Plaintiff.
3. Factual allegations
a. The Washington Conference involving Barack Obama
A. Plaintiff organized an April 3-4, 2009 Washington, DC conference concerning Barack Obama and his missing birth certificate [see www.NationalConferenceonObama.blogspot.com].
B. At some point Plaintiff was contacted by defendant John Gilchrist/John Borlaza (hereinafter “Gilchrist/Borlaza”) who asked if Plaintiff had made arrangements to tape his conference.
C. Gilchrist/Borlaza offered to pay to tape Plaintiff’s conference. While Plaintiff does not remember all of the details of the contacts with Gilchrist/Borlaza, it was agreed between Plaintiff and Gilchrist/Borlaza that Gilchrist/Borlaza would find someone to tape Plaintiff's conference and assume the cost of said taping, but that the conference and the product of the conference belonged to Plaintiff.
D. At no time did Gilchrist/Borlaza claim to own either Plaintiff’s intellectual property (the conference) or the evidence of that property (the tapes).
E. Gilchrist/Borlaza apparently hired defendant Scott Shirley (“Shirley”) to tape the conference. Plaintiff met Shirley at the Capital Hilton in Washington, DC and Shirley could not have been more cordial and cooperative.
F. After the conference ended, and while final editing was being discussed, Shirley prepared a “trailer” or prevue from Plaintiff's copyrighted material. In fact, as set forth in Exhibit A, Plaintiff said the following to Shirley: “Could you please add the copyright sign and notice copyright by Andy Martin 2009 on the trailer...John and I agreed that I would hold the copyright rights to the material. The same notice should go on any and all of the segments we post on the net.” (Exhibit A).
G. Shirley replied “Andy, Here’s the link for the video with changes (Donate to…and © copyright…).(Exhibit A).
H. The ownership of the copyright for Plaintiff’s materials is not in dispute.
b. The Conference editing process and new work
A. Shirley’s “trailer,” which he is now misusing in violation of his contractual responsibilities, was an excellent piece of work.
B. Plaintiff spoke with Shirley on the phone about editing a Hawai’i film that he was producing in May, and Shirley unhesitatingly agreed. Plaintiff had no reason to suspect Shirley was a crook, crackpot or double agent for Kirk/Obama.
C. Gilchrist/Borlaza asked Plaintiff to edit the Conference tapes and Shirley sent Plaintiff the approximately two hours of tapes to edit. Plaintiff did so and returned his copies to Shirley.
D. On May 15th, Plaintiff e-mailed Shirley and said “I have two tapes from Honolulu…” (Exhibit B)
E. Shirley replied “You may send the tapes however you see fit…I will look for them. I hope your trip was a successful one. (Exhibit B, 2 pages).
F. On May 20, 2009 Plaintiff e-mailed Shirley(Exhibit C, 2 pages) “Hi Scott—Is it possible you can make a copy and send the [Hawai’i] originals back to me…Re: April, Washington, DC conference—do you have a rough date when you can finish editing?...I want to give you all the time you need to do a good creative job…”
G. Shirley replied (Exhibit C), “I will make copies as soon as my computer is freed up…The first project should be done next week if everything goes well. I’m sorry for the delay…I have no problem with the added work…With regards to the Hawai’i project...”
H. Shirley and Plaintiff had previously spoken and Plaintiff had agreed to bear any cost overruns.
I. In July, 2009, Shirley said the “first project” was nearly completed and would be ready “next week.”
J. Shirley never completed any project, never made any copies and never rendered any bill to Plaintiff.
K. Plaintiff became increasingly concerned, and eventually increasingly suspicious, as Shirley became unreachable, refusing to respond to phone calls or e-mails.
c. Scott Shirley begins acting bizarrely
A. At no time was Plaintiff ever in the State of Maryland, and the only communication Plaintiff had with Shirley related to his non-performance of a contract and Plaintiff’s desire to seek the return of his property.
B. When Shirley did not return phone calls or respond to e-mails concerning the missing tapes, Plaintiff eventually complained to Montgomery County Maryland (Exhibit D) and the Greater Washington Better Business Bureau (“BBB”)(Exhibit E).
C. Shirley responded to Plaintiff’s complaints with a bizarre and delusional letter, Exhibit F, and the filing of a bogus “peace bond” claim predicated on Plaintiff’s BBB/Montgomery County consumer complaints.
d. Maryland judges enter the picture
A. No reasonable person could listen to Shirley’s claims without realizing that he was seeking to create a controversy to escape his contractual obligations and to resell Plaintiff’s property for a higher price to corrupt representatives of Mark Kirk and/or Barack Hussein Obama.
B. Shirley’s own “complaint” to the defendants admitted he was responding to Plaintiff’s complaint to the BBB (Exhibit E).
C. In his detailed multiple responses to the BBB Shirley never made any claim that he had ever been threatened in any way by Plaintiff.
D. Shirley knew what he was doing when he went shopping for judges in the highly partisan Democratic Party-dominated Maryland judiciary.
E. The defendants then began demanding that Plaintiff suspend his campaign for the U. S. Senate, fly to Washington and attend a kangaroo count session involving accusations by someone whose claims were facially delusional, and appear before one of the corrupt defendants (McCally). McCally, Wolfe and Simmons have since played musical chairs with the controversy.
F. Shirley, through his new sponsors and behind-the-scene political influence from Democrats, was using Maryland’s Democratic judges to politically harass Plaintiff and to attempt to interrupt his Senate campaign with fraudulent proceedings in the Maryland courts.
e. The Washington Post enters the fray
A. On August 25, 2009 Plaintiff received a call from defendant Dan Morse (“Morse”), a Washington Post employee in Rockville, Maryland. While Plaintiff does not recollect Morse’s original call completely, he remembers Morse suggesting Morse had been in the courthouse and stumbled over Plaintiff’s case. Morse gave no indication he had interviewed Shirley, received documents from him or done any research involving Plaintiff.
B. Not knowing that Morse and Shirley had been conspiring by e-mail and otherwise (presumably in person), Plaintiff initially furnished Morse with approximately 90 pages of documents.
C. Morse then recorded a phone call with Plaintiff which ran for over an hour.
D. Rather than being interested in Shirley’s machinations, Morse was interested in defendant Brosemer, whom Morse claimed had told Morse that Plaintiff attacked him (Brosemer). Brosemer’s claim was utterly fictitious, and part of the aftermath of Brosemer’s firing by Scripps-Howard Broadcasting after he attacked Plaintiff at WPTV-TV 13 years ago.
E. Brosemer’s claims to Morse were false and defamatory.
F. After Plaintiff complained to Morse’s editors, Morse called Plaintiff a third time; Morse said he had initially received an e-mail from Shirley a week earlier, as well as some of the same documents that Plaintiff later faxed in good faith.
G. Throughout the lengthy taped conversation(s), Morse was obsessed with peripheral events in Plaintiff’s life going back almost 40, 35 and 25 years, none of which bore the remotest relationship to Shirley’s conspiratorial activity. There was no way Morse’s questions would have fitted in any “news hole” of the Washington Post allocated to the Maryland suburbs.
H. Either knowingly or unknowingly, wittingly or unwittingly, Morse was acting in concert and conspiracy with Shirley, and acting in furtherance of the Kirk/Obama scheme to politically harass Plaintiff’s campaign for the U. S. Senate.
I. Given the opportunity to deny or clarify or explain Morse’s conspiratorial, fraudulent and bizarre “research” spanning decades in Plaintiff’s life, the Washington Post has remained mute and through silence essentially admitted that Morse was acting as a political saboteur and not as a bona fide reporter for the Post.
f. The true purpose of Shirley’s conspiracy is revealed

A. Shortly after coconspirator William Simmons entered yet another bogus order in furtherance of the civil rights conspiracy, Shirley’s missing trailer surfaced on the Internet as an attack video against Plaintiff’s campaign for the U. S. Senate:
http://www.youtube.com/watch?v=BLq0rP4QXWE.
B. Shirley used Plaintiff’s property, which Shirley and his coconspirators had stolen from Plaintiff, to attack Plaintiff’s U. S. Senate candidacy.
C. Shirley’s farce in Montgomery County courts had been and continues to be a charade to use Maryland judges as part of Shirley’s political conspiracy to harass and attack plaintiff, initially with bogus legal proceedings and, when that approach failed, with attack ads which were based on the theft and misuse of Plaintiff’s intellectual property.
D. Shirley, who had initially appeared to be an honest businessman performing a helpful service for Plaintiff’s conference, has completed the transformation to crook and political smear artist.
E. Shirley refuses to return Plaintiff’s tapes while continuing to misuse them himself.
F. It is not yet clear with whom Shirley is acting in concert, but his associations will be revealed in due course. Most likely, Shirley has sold himself to agents of defendant Mark Kirk or Barack Hussein Obama, acting individually or in conjunction with Kirk who is Obama’s “favorite Republican.”
G. Gilchrist/Borlaza has disappeared from the scene and may himself have been an Obama operative.
4. Legal claim
a. Shirley is holding Plaintiff’s original tapes and refuses to return them to Plaintiff.
b. On information and belief, no one else claims any copyright or ownership of the tapes.
c. Despite the fact that Shirley makes no claim to ownership of Plaintiff’s tapes, and appears to be a crooked businessman, Shirley has been able to file his perjurious claims with Maryland authorities and enlist the notoriously compromised Maryland judiciary in his Democratic Party/Kirk/Obama dirty tricks campaign against Plaintiff.
d. Plaintiff seeks an order directing Shirley and anyone else with possession of any of Plaintiff’s tapes or copies thereof, which includes the third parties to whom Shirley has given the harassment material, to return the tapes to Plaintiff.
5. Demand for judgment
a. Plaintiff seeks money damages as the Court or a jury may impose, as follows:
A. Money damages from Shirley in the amount of $25,000;
B. Money damages from Brosemer in the amount of $25,000, as well as a finding that Brosemer’s claims were defamatory and without any basis in fact.
b. Plaintiff seeks any and all declaratory and equitable relief to which he may be entitled from all of the defendants, jointly and severally, known and currently unknown (“John Doe agent of Mark Kirk and/or Barack Hussein Obama”).
COUNT TWO
[§§ 1983-1985 CIVIL RIGHTS CONSPIRACY]
1-3. Plaintiff repeats and realleges ¶¶ 1-3 of Count One and further pleads:
4. Legal claim
a. Federal law protects the right of persons to seek public office, see e.g. 18 U.S.C. § 245 (b)(1)(A).
b. Shirley, who appears to have begun his relationship with Plaintiff acting as an honest local businessman, has morphed into a political crook who is working to corrupt the local judiciary in Maryland and Google, Inc. (YouTube), all as part of someone’s plans to disrupt Plaintiff’s campaign for the U. S. Senate. The dirty tricksters are most likely Kirk’s and/or Obama’s supporters.
c. The actions of the defendants constitute a classic civil rights conspiracy, using bogus legal proceedings and other activity to corrupt local Democratic Party officials in order to harass a federal candidate of the Republican Party, all “under color of” state law.
5. Demand for judgment
Plaintiff seeks any and all relief to which he may be entitled under Count One, not to exceed $70,000 in aggregate money damages.
COUNT THREE
[CONVERSION]
1-3. Plaintiff repeats and realleges ¶¶ 1-3 of Count One and further pleads:
4. Legal claim
a. Shirley has converted Plaintiff’s intellectual property and directly or indirectly through agents is using Plaintiff’s property to attack Plaintiff on the Internet:
http://www.youtube.com/watch?v=BLq0rP4QXWE.
b. Shirley’s conduct and that of his coconspirators constitutes the common law tort of conversion.
5. Demand for Judgment
Plaintiff seeks declaratory and injunctive relief pursuant to the Illinois common law of conversion, as well as the relief in Count One not to exceed $70,000 in aggregate money damages.
COUNT FOUR
[PRIMA FACIE TORT]
1-3. Plaintiff repeats and realleges ¶¶ 1-3 of Count One and further pleads:
4. Legal claim
a. Illinois courts have adopted the concept of prima facie tort, see Pendleton v. Time, Inc., 339 Ill.App. 188, 89 N.E.2d 435 (Ill.App. 1st Dist. 1949) as originally recognized in Advance Music v. American Tobacco, 183 Misc. 855, 51 N.Y.S. 692, aff’d 296 N.Y. 79, 70 N.E.2d 401 (N.Y.).
b. The defendants’ ongoing activity is a classic case of prima face tort, because their activity represents the quintessential type of political dirty tricks using judges and corrupt public officials that are universally condemned by American society.
5. Demand for Judgment
a. Plaintiff seeks the same relief as sought in Count One.
COUNT FIVE
[BREACH OF CONTRACT/THIRD PARTY BENEFICIARY]
1-3. Plaintiff repeats and realleges ¶¶ 1-3 of Count One and further pleads:
4. Legal claim
a. Throughout the controversy which Shirley has manufactured, Shirley has claimed he only had a “contract” with Gilchrist/Borlaza.
b. In point of fact, District of Columbia law follows traditional third-party beneficiary contract law, Western Union v. Massman Construction, 402 A.2d 1275, 1277 (Dc App. 1979).
c. Although Gilchrest/Borlaza was paying for the work, he did not claim any interest in either the intellectual property or the evidence of the intellectual property (the tapes) that was being created by the Plaintiff.
d. Shirley has constantly cooked up imaginary defenses having no basis in law to frustrate Plaintiff’s contractual ownership rights in the original tapes, all in violation of the three-party contract agreed to between the parties.
e. Plaintiff has a right as a beneficiary to seek possession of his tapes.
5. Demand for Judgment
a. Plaintiff seeks the same relief as sought in Count One.
DATED: August 27, 2009
Respectfully submitted,

ANDY MARTIN

Motions Filed In This Lawsuit