Subject:  Memorandum of Facts and Law
From:  Michael Williams 100705,1252
Date:  29-Aug-95 18:09

IN THE UNITED STATES COURT OF APPEALS FOR THE SEVENTH CIRCUIT EASTERN DIVISION

UNITED STATES OF AMERICA,       )
                                                )
                        Plaintiff.              )       CASE NO. 94 24 83
                                                )
                v.                              )       JUDGE LEINENWEBER
                                                ) MICHAEL WILLIAMS,                       )
                                                )
                        Defendant.              )

PETITION FOR MEMORANDUM OF FACTS AND LAW PRO SE APPELLANT

TO:     Mr. Thomas F. Strubbe                   Carol A. Davilo
        Clerk of the U.S. Court of Appeals              Assistant United States Attorney
        219 S. Dearborn, 20th Fl.                       219 S. Dearborn, 20th Fl.
        Chicago, IL   60604                             Chicago, IL   60604

        Juleann Hornyak                         SA Richard Loyd
        Clerk of the Supreme Court                      FBI - Room 905
        Supreme Court Building                  219 S. Dearborn
        Springfield, IL   62706                 Chicago, IL   60604

        William J. Stevens                              A.R.D.C.
        135 S. La Salle St.                             One Prudential Plaza
        Suite 1407                                      130 E. Randolph Drive
        Chicago, IL   60603                             Chicago, IL   60601-6219

        Boutros Boutros-Ghali                   J. Moller, Chief of Branch
        Secretary General                               Centre for Human Rights
        United Nations                          United Nations
        Room S-3800A                            Palais des Nations
        New York, NY   10014                    8 - 14 Avenue de la Paix
                                                        1211 Geneva 10

        Amnesty International                   United States Supreme Court
        Monbijoustrasse 26/Postfach                     1 First St., N.E.
        CH-3011 Bern                            Washington, D.C.
        Switzerland

        I, Michael Williams, declare that I am the Defendant-Appellant in the above-entitled proceeding. I am not an attorney, do not have the funds necessary to retain one, have not been appointed one despite my many persistent requests, and am thus being forced to prepare this motion myself, even though I am not qualified to do so.

1.      Defendant-Appellant is in receipt today of a document from the Court dated 8. August 1995 which was, as all documents sent to him from the Court, despite his continuous objections, sent by sea.

2.      Said document indicates that several of Defendant-Appellant's motions have been wrongfully denied as "frivolous", to wit:

        a.)     Motion to Order F.B.I. to Produce and Deliver Property Seized to the
                Court for Inspection, filed on May 19, 1995;

        b.)     Motion to Order F.B.I. to Release Freedom of Information File, filed
                May 10, 1995;

        c.)     Motion to Order Registered Air Mail or Express Mail Delivery of All
                Correspondence sent to Defendant, filed May 10, 1995;

        d.)     Motion for Third Party Minor Claim to Ownership of Unlawfully Seized
                Property, filed May 16, 1995;

        e.)     Motion to Order Copy of Government's Answer, filed July 14, 1995;

        f.)     Motion to Dismiss U.S.A.'s Motion to Authorize Sale of Coins and
                Disburse Proceeds and Motion for an Order to Return Defendant's
                Property, filed July 14, 1995;

        g.)     Motion to Order Subpoena of Records and for an Order Prohibiting
                U.S.A.'s Contact with Bearers of Records, filed July 14, 1995; and,

        h.)     Motion to Transfer Case to Rightful Jurisdiction, filed July 14, 1995.

3.      Although in a telephone conversation, Ann MacArthur, Senior Motion Clerk for

the United States Court of Appeals for the Seventh Circuit, stated to Defendant-Appellant: "I have personally read each and every word of each and every one of your motions", it was obvious from our conversation that she had absolutely no knowledge of any of the motions, leading Defendant to believe they were denied without even being read.

4.      Defendant-Appellant is certain there exists a stalwart, well-organised conspiracy, whose clear itent is to deprive him of his right to Due Process and to cover up the F.B.I.'s criminally illegal seizure of all of his assets and personal property, including

- 2 - highly-sensitive confidential political correspondence between U.S. Senator/Presidential candidate Gary Hart and Defendant-Appellant.

5.      Said conspiracy includes former U.S. President George Herbert Walker Bush, Assistant United States Attorney Carol A. Davilo, FBI Special Agent in Charge Richard Loyd, attorney William J. Stevens, attorney Robert G. Clarke, members known and

unknown of the United States Attorney's Office, the United States Department of Justice, The Federal Bureau of Investigation, the United States Bureau of Prisons, the Attorney Registration and Disciplinary Commission of the Supreme Court of Illinois, others as yet unknown, and may include members of the Judiciary.

6.      A conspiracy is actionable under 42 U.S.C. 1985 when there has been an "actual of denial of due process. (Civil Rights). - Jennings v. Nester (1954, Ca. 7 III.) 217, F 2d 153, CERT DEN 349 U.S. 958, 99 L Ed. 1281, 75 S. Ct. 888.

7.      Defendant-Appellant requests a Memorandum of Facts and Law for the following
motions which were denied by the United States Court of Appeals for the Seventh
Circuit,  denied on 8. August 1995, to wit:

        a.)     Motion to Order F.B.I. to Produce and Deliver Property Seized to the
                Court for Inspection, filed on May 19, 1995;

        b.)     Motion to Order F.B.I. to Release Freedom of Information File, filed
                May 10, 1995;

        c.)     Motion to Order Registered Air Mail or Express Mail Delivery of All
                Correspondence sent to Defendant, filed May 10, 1995;

        d.)     Motion for Third Party Minor Claim to Ownership of Unlawfully Seized
                Property, filed May 16, 1995;

        e.)     Motion to Order Copy of Government's Answer, filed July 14, 1995;

        f.)     Motion to Dismiss U.S.A.'s Motion to Authorize Sale of Coins and
                Disburse Proceeds and Motion for an Order to Return Defendant's
                Property, filed July 14, 1995;

 - 3 -
        g.)     Motion to Order Subpoena of Records and for an Order Prohibiting
                U.S.A.'s Contact with Bearers of Records, filed July 14, 1995; and,

        h.)     Motion to Transfer Case to Rightful Jurisdiction, filed July 14, 1995.

In conclusion, this Memorandum of Facts and Law is necessary so Defendant-Appellant may file a more complete Petition for Mandamus in the United States Supreme Court.

Further, this should suspend the running of the clock on the filing of Defendant-Appellant's appellate brief.


                                                Respectfully submitted,



        
                                                MICHAEL WILLIAMS, in Pro Se
                                                Postfach 20
                                                CH-3112 Allmendingen bei Bern
                                                Switzerland



- 4 - AFFIDAVIT OF MAILING

CANTON OF BERNE                 )
                                                ) COUNTRY OF SWITZERLAND  )

MICHAEL WILLIAMS swears that on the 30. August, 1995, he placed a copy of PETITION FOR MEMORANDUM OF FACTS AND LAW - PRO SE APPELLANT in envelopes addressed to the following named individuals and caused the envelopes to be deposited in the Swiss mail depository located at the PTT Post Office in Muensingen, Switzerland on said date at or before the hour of 5:00 p.m.

        Mr. Thomas F. Strubbe                   Carol A. Davilo
        Clerk of the U.S. Court of Appeals              Assstant United States Attorney
        219 S. Dearborn, 20th Fl.                       219 S. Dearborn, 20th Fl.
        Chicago, IL   60604                             Chicago, IL   60604

        Juleann Hornyak                         SA Richard Loyd
        Clerk of the Supreme Court                      FBI - Room 905
        Supreme Court Building                  219 S. Dearborn
        Springfield, IL   62706                 Chicago, IL   60604

        William J. Stevens                              A.R.D.C.
        135 S. La Salle St.                             One Prudential Plaza
        Suite 1407                                      130 E. Randolph Drive
        Chicago, IL   60603                             Chicago, IL   60601-6219

        Boutros Boutros-Ghali                   J. Moller, Chief of Branch
        Secretary General                               Centre for Human Rights ZeD+*_ United Nations                          United Nations
        Room S-3800A                            Palais de^Pd