IN THE XXX DISTRICT COURT
IN AND FOR THE NORTHERN DISTRICT OF XXX
XXX)
Plaintiff, )
)
v. ) Case No.XXX
) (GTS/TWD)
STF SERVICES CORP.; BLOOMBERG L.P.; )
THE BUREAU OF NATIONAL AFFAIRS, INC. )
And XXX )
Defendants. )
NOTICE OF MOTION TO LIFT BAR ORDER
You are hereby notified that on the ____ day of September, XXX, XXX
will bring on for hearing his Motion to Lift Bar Order before the above court. It will be
based on the subsequent motion as well as any oral arguments that may be presented
before the Court.
Dated this ____ day of September ,XXX
Respectfully Submitted,
___________________________________
XXX,
Plaintiff in pro per
IN THE XXX DISTRICT COURT
IN AND FOR THE NORTHERN DISTRICT OFXXX
XXX )
Plaintiff, )
)
v. ) Case No. XXX) (GTS/TWD)
STF SERVICES CORP.; XXX.; )
THE BUREAU OF NATIONAL AFFAIRS, INC. )
And XXX )
Defendants. )
MOTION TO LIFT BAR ORDER
NOW COMES XXX, Plaintiff, and files this Motion to Lift Bar Order, and
for cause would show this Honorable Court as follows:
1. On January XXX, this Court issued a bar order in which Plaintiff was barred
from filing pro se any future motions or documents in this action without first
obtaining leave of the Court, pursuant to 28 U.S.C. § 1651(a) and the Court’s
inherent authority to control and manage its own docket.
2. As from the date the Order was issued to the date of Plaintiff filing this motion,
Plaintiff has fully complied with the Order. Plaintiff has not filed any motion pro
se.
3. After much thought and consideration, Plaintiff has realized the impact of his
actions and/or omissions in his failure to show cause, vexatious conduct and
filing of six “notices of motion” that improperly lacked either a supporting
memorandum of law or supporting affidavit.
4. Plaintiff is appearing as a self-representing litigant as he cannot be able to hire
an attorney licensed to practice law in the Northern District of New York. As a pro
se litigant, Plaintiff tries to present his case with his limited knowledge of the law
and procedure.
5. The Bar Order seems like a sanction for Plaintiff’s lack of an attorney. According
to the Order, Plaintiff may not file any motions without leave of this Court while
appearing in pro se. If Plaintiff was to hire an attorney, he would file motions
without leave of this Court and not be in violation of the Bar Order issued by the
Court.
6. There is no such similar Bar Order against Defendants who are represented by
counsel. Defendants can file motions without leave of this Court in order to obtain
relief from the court. The Bar Order denies Plaintiff the similar right to obtain relief
from the Court without first filing obtaining leave to file motions.
7. Moving forward, Plaintiff will ensure that motions and other pleadings filed before
this Court are filed on time and following the correct format according to the
rules.
REASONS WHEREFORE, PREMISES CONSIDERED, Plaintiff respectfully requests
this Honorable Court to GRANT this Motion and LIFT the Bar Order issued on January
XXX
Dated this ____ day of September, XXXX
Respectfully Submitted,
___________________________________
XXX.
Plaintiff in pro per
VERIFICATION
I, Jeffrey S. Jackson do hereby state that I have read the foregoing Motion to Lift Bar
Order and know the contents thereof. That the matters, facts and things stated therein
are true and correct to the best of my knowledge.
Dated this ____ day of September, XXX
Respectfully Submitted,
___________________________________
XXX,
Plaintiff in pro per
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