Only touched on below are the extraordinary facts-documented by  court records in our care, of such fraud, fraud on the court, conducted by our own legal counselors-under color of law in  conspiracy with the below named bank that shocks the conscience and violates the decencies of civilized conduct:

Vincent and Sophie Germano, residents of Texas, at all times pertinent, as we had done many times during our business career since our marriage in 1948, we obtained an appraisal by the Oklahoma Appraisal Company of a parcel of land at Interstate 40, Oklahoma City, OK, next to Mc Donald’s to develop into a motel.  

June 25, 1981-We paid $112,762.00 by Cashiers Check-(Exhibit “1”)-No. 47956. The seller conveyed clear title to one acre of land, and took back a mortgage on the remaining parcel. Together with an additional $263,000.00 of our own money and Guaranty Bank's construction loan, we contracted construction of the first of a planned two section motel, consisting of fifty-four rooms, complete with a rental office, manager’s apartment, laundry and hot water system to service 43 additional rooms. Named American Inn, and opened for business December 16, 1981, the motel achieved an occupancy rate in excess of similar motels and was appraised for $1,500,000.00.

Having amicably negotiated settlement of several problems arising in its development, we had no idea that the refusal by (Siscorp) to honor its agreement to payoff Guaranty Bank’s construction loan and kept $30,000.00 fee, was a precursor of predatory lending, bias and denial of functions of state/federal governments subjected us throughout the following years.

FBI agents who came to our motel to investigate another of Siscorp’s  victims, expressed their sorrow and stated they were not authorized to investigate our complaint-(Exhibit " ")-office cards of four (4) FBI agents.

Guaranty Bank accommodated us far beyond it's one year loan agreement before calling for payment of its note-(Exhibit “" its letter regarding (AI’S) account and its agreement to fund the construction loan for American Inn’s forty three additional rooms.

March 29, 1983-for a consideration of $9000.00 and based on letters from several New York banks, First National Bank of Bethany, OK, now First Bethany Bank & Trust N. A., approved our application to fund a mortgage and pay-off Guaranty Bank-(Exhibit "")-the bank’s letter regarding our loan application and $375, 000.00 investment in AI'S first section, and rating the Germanos number one in credit, cooperation and ability. 

Peter G. Pierce (Sr.) was bank president, majority stockholder and chairman of its board of trustees. Several family members were involved in the bank’s ownership and operations. Peter G. Pierce III, (Pierce) a lawyer and son of Pierce (Sr.) closed the loan and represented the bank at all times thereafter as follows.

Pursuant to our good faith negotiations, writer, Vincent Germano, notified Pierce Senior (in his office on the bank’s second floor) that Tinker Investment & Mortgage Corporation approved our mortgage loan application and would issue its commitment (after Christmas) to pay-off his bank’s note/mortgage. Pierce stated not to make any more payments and to bring the commitment to him when issued.  

January 4, 1985-without notice and in violation of bank law, Peter Pierce III filed bank’s lawsuit foreclosing its note/mortgage , case CJ-85-0095. In his bank’s Petition, Pierce, alleges, in part: "default of its note and mortgage; there is no substantial controversy as to any material fact; American Inn has an equity of redemption; the foreclosure suit is in accord with the June 11, 1984 joint statement of the Comptroller of the Currency and Board of Governors of the Federal Reserve System."

January 28, 1985-Tinker Investment & Mortgage Corporation issued its written commitment with a March 31, 1985 closing deadline, which we promptly hand delivered to Pierce senior, who stated he would cease the foreclosure and tender the documents to the title company for closing by our legal counsel. A $19,500.00 consideration was paid to Tinker, a subsidiary of the Federal Credit Union of employees of U. S. Tinker Air Force Base.

However, the bank’s wielding of power to manipulate the legal and other systems of governments propelled us into a never ending search for ethical legal representation from 1985 to the present:

February 14, 1985-Lawyer Alan M. Reaves, filed a (One Page Answer) in which he failed to demand a trial by jury and assert an affirmative defense and move the court to order the bank (which had refused to tender the papers to close the loan to payoff its note and mortgage since issued January 28); that the June 11, 1984 joint statement of the Comptroller of the Currency and Board of Governors of the Federal Reserve System, clearly advises member banks against foreclosure “in cases in which the note is secured and in the process of collection,” as true in our case-(Exhibit "" )-Lawyer Reaves’ (1) Page Answer.

March 15, 1985- Pierce filed his bank’s Motion For Summary Judgment on its foreclosure, Statement Of Undisputed Facts, and Brief In Support Of Motion For Summary Judgment. Lawyer Reaves, having failed to move the court to order bank to tender its papers to the title company for closing the Tinker loan since January 28, (with (16) days left of Tinker’s March 31 closing deadline), lawyer Reaves failed to file an Answer.

March 21, 1985-letter response to Vincent Germano’s request by Ed Phelps, Tinker’s mortgage officer, extending its mortgage commitment to April 30, 1985, to permit financing alternatives-(Exhibit"")-letter.

April 4, 1985-On our demand lawyer Reaves obtained leave to file AI'S Counterclaim (out of time) in banks foreclosure, in which he claimed, in part: "$1,000,000.00 in actual damages; $2,000,000.00 in punitive damages for Plaintiff's fraudulent conduct; costs of this action; reasonable attorneys fees; interest at the rate of 15% per annum"-(Exhibit "")-AI Counterclaim).

 April 5, 1985-Lawyer Reaves asked Vincent Germano and our son Wayne, to wait in the courthouse hall, while he went into a courtroom. We later discovered that Reaves had "secretly" filed a Journal Entry of Judgment dismissing AI'S Counterclaim. The Journal Entry was signed by judge Blevins and filed in court records (without consent of client and affidavit of attorney pursuant to Oklahoma Statute)-(Exhibit " ")-Journal Entry of Judgment.

April 5, 1985-DAILY OKLAHOMAN article, "Order Blocks Motel Auction" paper officials refused our request to publish a correction of the false, misleading statements that covered up the truth outlined herein that prejudiced us in the legal system thereafter. (The article included a statement by Peter Pierce, "If he's got the money, why doesn't he go ahead and pay it"-(Exhibit " ")-Article.

April 5, 1985-Vincent Germano and our son Wayne complained of the bank's fraudulent legal actions to the U.S. Attorney (Bill Price). On assistant E. Thompson’s recommendation to hire Alan C. Durbin stating "he had given her a hard time in defense of a client and would defend your rights." We went to the large law firm of Andrews, Davis, Legg, Bixler, Milsten & Murrah. (The Federal Building in Oklahoma City is named after Judge Murrah).

In his law office, Alan C. Durbin assured us he didn't have a conflict of interests with the bank or other parties involved in our case, and accepted our case advising that he would move the court to vacate the (default) foreclosure judgment, and  close the Tinker loan and pay-off bank's note-(Exhibits " " “ “)-Thompson's office card and Durbin's Detail of Service, revealing their phone contact regarding our case and bank’s April 8, 1985-Answer to the AI Counterclaim.

April 8, 1985-Lawyer Durbin letter to Tinker's Ed Phelps, one of his numerous letters to parties involved in our efforts to close the Tinker loan and pay-off of the bank’s note-(Exhibit " ").

April 8, 1985-Pierce, (having acted with Reaves and Durbin in refusing to close the Tinker loan since January 28), filed Bank's Motion For Summary Judgment on the same counterclaim (that Reaves had secretly dismissed by Journal Entry of Judgment). Pierce, stated, in part: "the Commitment was issued January 28, 1985 and expired March 31, 1985"-(Exhibit " ").

April 8, 1985-Durbin letter to Tinker's mortgage officer, Ed Phelps-(Exhibit " ").

April 9, 1985-Three days after Durbin undertook our case, Vincent Germano and our son Wayne went to Alan Reaves' law office, picked up and signed a receipt for case files at which time Reaves handed us his Motion To Withdraw from our case, and asked us to give it to Durbin with case files.

It was later discovered that lawyers Reaves and Durbin conspired in altering dates of their Motion to Withdraw and Entry of Appearance in iur case as follows:

As shown by these (4) Exhibits, Reaves, dismissed April 5, 1985, gave his receipt for case files April 9; Alan Durbin undertook our case April 5 in his law office, and dated his employment letter April 8, 1985. Acting together, they POST-DATED Durbin’s Entry of Appearance in our case to April 30, 1985, and Reaves' Motion To Withdraw as Attorney Of Record, from April 5, to May 6; put a line through April, and Post-Dated the Motion's Certificate of Mailing to May 3, 1985. (This was to appear that Reaves was still counsel during the issuance of the (default) foreclosure judgment and time for its  appeal-(4 Exhibits "").

Durbin, recommended by the U.S. Attorney, also refused to correct his employment letter of April 8, 1985, in which he stated, in part: he was hired in the "proposed lending transaction with Tinker Investment & Mortgage Corporation for the end loan financing of a motel project (TO BE) located in Oklahoma City, OK; "in the event the subject loan does not close for reasons other than any omission by this firm, our fees and expenses will be due on billing and we will expect payment from the client."

Lawyer Durbin, was initially informed AI’S first section was completed, and doing business since December 1981, and that the Tinker commitment was obtained for $19,500.00 and was in full force and effect since January 28, 1985.

April 16, 1985-Durbin letter to Tinker’s Ed Phelps was unauthorized negotiation-(Exhibit " "). April 21, 1985-On our request by letter, Tinker extended its commitment to April 30, 1985, to permit sufficient time to select financing alternatives-(Exhibit " ").

April 23, 1985-Durbin letter to Tinker's Ed Phelps inquiring if we, (his clients) had paid the $19, 500.00) commitment fee- (Exhibit "").

April 23, 1985-Ed Phelps (Tinker mortgage officer) letter addressed to Alan Durbin, in part; We offered to extend the commitment based on our discussion with Vincent Germano relative to selling the property to a qualified buyer or bringing into the project an additional guarantor, in addition to return our fee if he was unable to restructure his project-(Exhibit " ")-Tinker letter.

April 30, 1985-With knowledge Pierce had refused to cooperate in closing the Tinker commitment from January 28, to March 31, deadline for its closing; Lawyer Durbin’s letter to bank's Pierce, in part: "We are steering to close with Tinker within the next ten days", "otherwise we will have to submit a request to the Court to hear our request"-(Exhibit "").

May 1, 1985-Bank, Pierce’s letter to Durbin, who, without discussion of its contents with us and authorization, signed it-(Exhibit " ").

May 3, 1985-At Durbin's request by phone, Vincent and Sophie Germano, with our six-year-old grandson, went to his law office (wherein he withheld from us Reaves’ secret filing of the Journal Entry of Judgment dismissing our counterclaim in bank’s foreclosure suit, and asked us to sign a Journal Entry Of Judgment-dismissing the SAME counterclaim in the bank’s Foreclosure case. 

We declined, however, anxious to resume our business, on Durbin's assurance he would keep it until he (closed Tinker's loan that week) and repay AI'S debt to the Bank, Vincent Germano, signed the J. E. of J. dated May 3, 1985. Durbin corruptly gave it to Pierce and continued refusing to close the Tinker loan. Judge Blevins also signed this J. E. of J.-(Exhibit " ").

April 5, 1985-Lawyer Durbin letter to Tinker’s Ed Phillips seeking us (without consideration) to deed American Inn to another client (Allan Garland) along with the Tinker loan-(Exhibit " ")-letter.

Bank (Pierce’s)  letters mailed to Durbin dated May 1, and May 10, 1985, (absent letterhead) stating in part: "Please let me know at your earliest convenience of the status of putting the Tinker deal together. If there is anything on this that can be done to expedite, please let me know"-(Exhibit " ")-Letters.

May 28, 1985-Our credit ruined, we tried to recoup some of our investment pursuant to Tinker’s restructured loan agreement requiring a second guarantor. His treachery still unknown, Durbin  drafted the (33 page) General Partnership Agreement. Executed by our son Wayne Germano and Juanita Anne Rorem who paid $105,000.00 into a bank escrow account for one-third interest in the AI. Durbin also violated that agreement and refused to close the restructured loan-(Exhibit " ")-General Partnership Agreement.

May 28, 1985-Durbin letter to Tinker mortgage officer Ed Phelps regarding the General Partnership Agreement-(Exhibits " ")-Durbin letter.

June 3, 1985-(Four months after its issuance) Tinker mailed its letter canceling its commitment to pay-off bank’s note/mortgage with a check for $19,200.00 of the $19,500.00 commitment fee. However, until seeing Pierce submit the letter at the June 7, Temporary Restraining Order hearing (below), we had no knowledge of the cancellation or received the letter in the mail until returning to the motel after the hearing.

 June 4, 1`985-AI’S lawsuit, case #CJ-85-5070: Our third  legal counsel,  Charles Rouse filed the suit, amended it June 6 & obtained Temporary Restraining Order, staying Sheriffs Sale of AI. Lawyer Rouse alleges, in part: "The Defendant herein perpetrated fraud upon the Plaintiff herein, knowing that the same would work irrevocable hardship on the Plaintiff herein and at the same time cause a windfall to the Defendant."

"That the Defendant has conspired with person or persons currently unknown to defraud the Plaintiff of its real property for a sum of less than one half the actual value of the said property." "The fraud of the Defendant entitles the Plaintiff to actual damages of $2,000.000.000.00, $1,000.000.000.00 punitive damages and recovery of exemplary damages as an example to others similarly situated in the sum of $150,000,000.00-(Exhibit "")- AI’S Petition and TRO.

Due to Rouse's failure to oppose Pierce's motion-as he had also advised was essential, assigned to judge Parr, the case was re-assigned to judge James B. Blevins (whose void judgments the suit sought to set aside under Oklahoma Statute and settled precedent).

June 7, 1985-TRO HEARING, on (ONE) of the Four counts of AI’S lawsuit: As shown on the Transcript of the hearing also in our care, the Pierce and co counsel Joel Carson filed in the case, copies of the Tinker letter cancelling its commitment with the check of $19,200.00 fee, (before we learned of the cancellation or received it in the mail on our return to the motel after the hearing)-(Exhibit"")-Tinker letter.

As shown by the transcript (in our care)Pierce and co council Joel Carson, posed trick questions to writer Vincent Germano (on the witness chair) to cover up-suppress the extraordinary fraud, fraud on the court outlined above. Vincent attempted to controvert such deception, but Judge Blevins stopped me stating "you are represented by counsel." Lawyer Durbin, still AI’S counsel of record, subpoenaed by the bank (as its witness!!) Judge Blevins asked him to take the witness chair, stating, "you need not swear an oath, you are an officer on the court." Durbin REMAINED SILENT, until Rouse (visibly intimidated by judge Blevins' obvious bias toward the bank and Durbin), failed to question him and excused Durbin wrongfully stated "he was not involved in the judgment."

Judge Blevins allowed Pierce and co counsel Joel Carson to testify as to what witnesses-summoned and seated in the courtroom, would say if called to the witness chair to testify, then, displaying his anger, judge Blevins stated it was a hearing on the merits, and wromgfully granted Pierce's Motion for Summary Judgment, on all FOUR counts, and ended the court stay.

Following cancellation of the Tinker loan, we released $105, 000.00 paid by Mrs. Rorem into a bank escrow account contingent on the Tinker loan closing by lawyer Alan Durbin-(Exhibit " " )-letter of Rorem attorney David Cheek.

June 10, 1985-Letter by Alan Durbin to us, in part, "We regret that we were unable to convince you that the litigation posture that you chose to pursue lacked a reasonable expectation of success." "It is unfortunate that the events of the past few days have not proved successful." Durbin further states, "you must remit to us the sum of $11,533.90, for fees and expenses within 39 days of your receipt of this letter"-(Ex. " ")-letter.

June 13, 1985-Lawyer Rouse filed the Petition In Error-Preliminary Statement and withdrew form our case. In part: "Trial court erred in prevented plaintiff from presenting evidence relevant to the temporary restraining order, and permitted defendant to present argument, cross examination, and authority on all aspects of the case"-(Exhibit " ")-Petition In Error.

June 14, 1985-Bank, Pierce Motion To Settle Amount Of Attorney’s Fees, Oklahoma County, OK, Dist. Court, case# CJ-89-5990-(Exhibit " ")-Motion.

August 16, 1985-Pierce’s letter to Tinker's mortgage officer Ed Phelps, in part: "As you probably know, American Inn, Inc. jumped into a reorganization proceeding under CH -II, bankruptcy Code"-(Exhibit " ").

June 19, 1985-Pierce law partner Joel Carson's letter to Charles Rouse -(Exhibit " ")-letter.

June 19, 1985-Pierce letter to lawyer Rouse with his motion and court order reassigning Judge James B. Blevins to preside over the (attorney fee hearing). On his motion Pierce states, in part: "the adverse publicity that the plaintiff generated," "the novelty of questions presented in this case, the skill required to completely defeat this action in THREE DAYS," "Mr. Carson's and Mr. Pierces experience in commercial litigation," "The quick reaction by Defendant's counsel, and prompt successful termination of this litigation should have served TO SET AN EAMPLE that FRIVOLOUS LITIGATION WILL NOT BE TOLERATED. Pierce seeks a court order for legal fees based on the attached "Defendant counsel's DETAILED TIME RECORDS for the period in question"-(Exhibit " ").

Tony Blazer, lay employee of the Oklahoma Bar Association, on receipt of Pierce’s TIME RECORDS filed with his Response to one of our many Grievances, informed Vincent Germano by phone that Pierce RE-WROTE, OMITTED INCRIMINATING EVIDENCE from his TIME RECORDS that he had filed in court records with this MOTION TO SETTLE THE AMOUNT OF ATTORNEY'S FEES.

We promptly informed the OKLAHOMA BAR of Mr. Blasier's revelation of Pierce's felony perjured Time Records filed as a part of his Response to our Grievance. The bar ignored such outright fraud and permitted Pierce to continue violating its rules of conduct outlined below, and denied a total of ten (10) Grievances .

December 10, 1985- Oklahoma Supreme Court, case #64,709: AI’S fourth attorney, Jerome Blumenthal, received a $2500.00 fee and filed the opening brief-absent claims arising in the above facts. The appeal was taken over by Pierce for his bank and continued his outrageous, indefensible criminal conduct to defeat AI’S appeal and CH II bankruptcy reorganization as follows-(Exhibit "")- Brief filed by lawyer Blumenthal.

June 26, 1985-AI’S CH II Bankruptcy Petition, case #Bk-85-2221-A, staying Sheriff Sale: Assigned to judge Berry, the case was reassigned to Chief judge Richard Bohanon-who was seated from (chose in action) Alan Durbin's large (Andrews, Davis law firm) which was paying him for stock sold-back to the law firm. Luther Bohanon (Sr.) was a senior judge in that same federal court district, a violation of 458, 28, U.S. Code. This conflict of interests fueled the Striking of our petitions in the federal and state courts, below-(Exhibit "")-AI Petition.

WITNESS AFFIDAVIT (of Pierce and lawyer Alan C. Durbin’s felony draud on the Court) by attorney Charles R. Rouse dated November 6, 1985, attesting: "I was attorney for the Debtor in possession of American Inn, Inc. and as such, attended the hearing conducted pursuant to 11, U.S.C., Sec. 2004. During an off the record recess from this proceeding, Peter G. Pierce III, Alan Durbin, Vincent Germano and I were talking informally among ourselves." "During the conversation Mr. Pierce looked at Vincent Germano and stated, "We could have had the Tinker loan closed in one week if you hadn't filed your lawsuit against the Bank." Mr. Durbin responded, "that’s right." (Lawyer Rouse had filed our lawsuit)-(Exhibit "") Affidavit by Lawyer Charles R. Rouse.

Upon Rouse’s refusal to have the court reporter record Pierce and Durbin’s gloating confession of their fraudulent prosecution of the bank’s foreclosure suit which caused AI’S bankruptcy, Vincent Germano left the hearing and went to the office of Court Administrator Steve Liveshee, who was out of his office. All other court officials were also out to lunch. On my return to the hearing, on lawyer Charles Rouse's assurance he would provide the above affidavit, Vincent Germano relented.

On hind sight, had I, Vincent Germano, waited for Mr. Levishe’s return to his office, or contacted a federal Marshal to register such virtual confession of felony fraud, corrupt conduct, fraud on the court, the bank, Pierce III and coconspirator lawyers’ my family and I would have sparred the continued cover up, suppression by each successor lawyer of the nine Oklahoma law firms who undertook our cause throughout the following years:

Judge Bohanon, based on applications and (Affidavits sworn under Solemn Oath), appointed Alan C. Durbin Chairman of the Unsecured Creditor’s Committee and Committee counsel; Michael Rolinaitis Trustee and counsel for himself; Mrs. Rolinaitis, bankrupt estate’s accountant; Peter G. Pierce III counsel for the Trustee to prosecute an adversary suit against us-(Exhibits " ")-Applications, Affidavits and court order).

Attorney David Dunlop (a prior member of Trustee Michael Rolinaitis’ law firm) submitted his affidavit attesting to Rolinaitis and his wife’s troubled loans with Piece’s bank; Rolinaitis also had a attorney-client duty to AI and us, arising from his agreement to prosecute an adversary action against the bank and lawyer co conspirators;

Peter G. Pierce III, an officer and stockholder of the bank, a defendant in AI'S lawsuit on appeal-(that was taken over by the Trustee Roinaitis-(Exhibit "")-Affidavit by Rolinaitis’s ex partner Lawyer David Dunlop.

July 23, 1985-Order by the Chief Justice, Supreme Court of Oklahoma, "directed that all parties show cause why all proceedings in this appellate matter (arising from the summary dismissal of our lawsuit, case 5070, above) should not be stayed immediately-(Exhibit "")-Order.

August 2, 1985-In the ongoing fraudulent bankruptcy proceeding, Pierce, corruptly acting as his bank (a defendant in the bankrupt estate’s lawsuit on appeal), and Trustee’s legal counsel, filed the five page, Appellees Response As To Why Proceedings Should Not Be Stayed. For the reasons discussed below, and based upon authorities cited, the Appellee respectively submits that there is no impediment to continuation of this proceeding, and should not be stayed-(Exhibit " ")-Appellees Response as follows:

"filed by Peter Pierce" while acting with Durbin and Trustee Rolinaitis in filing their Plan of CH 11 Reorganization stating, in part, their intent to DISMISS AI’S Appeal, and to DISREGARD it if GRANTED. The failure of lawyers of the four (4) law firms who undertook AI’S CH II bankruptcy and our personal objections, they withdrew their sham plan, but defeated the bankrupt estate’s appeal and reorganization as follows:

August 15, 1985-Pierce letter to Rouse and Reaves regarding the 2004 bankruptcy examination (knowing) Reaves was dismissed on April 5, 1985-(Exhibit "")-Pierce letter.

August 16, 1985-Pierce’s letter to Tinker's mortgage officer, Ed Phelps, in part: "As you probably know, American Inn, Inc. jumped into a reorganization proceeding, CH -II, bankruptcy Code"-(Exhibit " ").

September 19, 1985-Letter by Charles Rouse (second appearance in our cause) to Bank's Pierce, the only secured creditor, regarding missing Touch Ross (AI'S accountant) work papers taken from case files while in Pierce's possession in the bankruptcy case- (Exhibit " ").

October 4, 1985-Charles Rouse, Motion, Objection To Appointment Of Trustee, response (filed by Susan Manchester) to Pierce and Alan C. Durbin's joint-motion for Trustee McDonald to take over management of AI from us (then debtor in possession)-Exhibit " ")-Manchester’s Motion filed for trustee MacDonald, Transcript of the bankruptcy court hearing and Court Order.

(See Federal case below: Manchester’s  and Floyd Taylor’s fraudulent cover-up, of their appearance for trustee Mc Donald to deceive us into hiring them; how they filed our petition (absent prepetition/bankruptcy crimes, and withdrew alleging we changed their agreement to withdraw keeping our unearned $5,999.00 fee).

February 6, 1986-Durbin and Pierce, in full, control of AI'S bankruptcy proceeding, filed a Motion For Issuance Of Order To Show Cause & For tempt Order, against Vincent and Sophie Germano, and seeking an order to seize the $19,200.00 refunded by Tinker to us-(Exhibit ""). March 27, 1986-Notice that NO REPLY BIEF Will BE FILED by

Trustee Rolinaitis in AI’S appeal case #64,709-(Exhibit " ")-Notice.

May 2, 1986-Pierce letter (no letterhead) to Bankruptcy Trustee Rolinaitis (his bank’s troubled creditor) seeking to defeat AI’S Appeal of the district court ruling granting Bank summary judgment-(Exhibit " ")-letter.

May 4, 1986-Office Card of FBI special agent Michael Puskus who took our complaint and supporting (court instruments) of pre-petition and bankruptcy, fraud, corruption. The head agent of the Oklahoma City FBI office, didn't respond-(Exhibit "")-Office Card of FBI Special agent Michael Puskus.

May 8, 1986-Waiver Of Oral Argument, signed by Trustee Rolinaitis and Pierce-(Exhibit "")-Waiver of Oral Argument.

Adversary suit against Vincent and Sophie Germano, Case #86-423-A, by Appellee bank's Pierce, Trustee Rolinaitis and Durbin alleging unauthorized payments as debtor in possession-(Exhibit "")-Adversary suit.

August 4, 1986-On our complaint of the failure to prosecute the ongoing bankruptcy fraud, lawyer David Pepper (one of four law firms whose lawyers appeared in our motel’s bankruptcy, failed to cease the ongoing bankruptcy fraud, corruption, then abandoned us, and withdrew from our case and (required us to sign a hold harmless) agreement before refunding our fee-(Exhibit “ “)-Hold harmless agreement.

We filed pro se, Defendant 's Motion In Opposition To Plaintiff's Motion To Strike and supporting Affidavit. To no avail, Oklahoma City Municipal Counselor Howard Haralson filed a motion, 9/17/86, objecting to our pro se motion to remove Pierce, Trustee Rolinaitis and Durbin from positions in fraudulent control of AI’S bankruptcy proceeding. (Pierce had been a member of the Oklahoma City Counsel, and Pierce Sr. was well connected in politics)-(Exhibit "").

September 17, 1986-Pierce letter addressed to us and mailed to our home in Kingwood, TX, seeking to collect on the fraudulently begotten Default bankruptcy judgments) and threatening to have "professional Collection Attorneys in Houston TX who literally will pursue the debts the rest of your lives"-(Exhibit "")-Pierce letter.

These are the default judgments levied against us in the facts outlined above, which R.W. Abbott drafted for judge Richard Bohanon and mailed to our home in Texas. Bohanon allowed Abbott to keep $3700.00 of the $5000.00 fee paid him on his agreement "to do a CRAM DOWN against the bank and coconspirators in bankruptcy court. Abbott is one of the lawyers of the four law firms who undertook AI'S bankruptcy case and acted in the ongoing fraudulent bankruptcy and adversary proceedings. As is also shown in the federal case below, Taylor and Manchester removed the void judgments from case files delivered to their Oklahoma City law office to cover up lawyer Abbot’s bankruptcy fraud and corrupt conduct in drafting the Default judgments (against his ex clients. (The facts in which the judgments were awarded are also documented by the court records in our possession).

Lawyer Rouse (who gave his affidavit attesting to the bank, Reaves’ Durbin’s foreclosure fraud in the bankruptcy case) filed our Response Brief in Opposition to Motion To Remove Trustee, To Remove Attorney For Trustee And To Reinstate Debtor In Possession. Rouse filed with this motion were; Affidavit of proposed attorneys, Trustee's Motion to Employ Professional Person For a Limited Purpose, Debtor's Brief, and Objection by AI, Inc, and allowance of Claim and Confirmation of Plan-(Exhibit "")-Motion.

November19, 1986-Lawyer Rouse letter to Affiant withdrawing from the case to be called as a witness (regarding Pierce and Durbin’s admission of their fraudulent prosecution of the bank foreclosure attested to on his affidavit). Lawyer Rouse was never called to testify by his successor lawyers who covered up/suppressed the affidavit-(Exhibits "")-letter and affidavit.

September 19, 1986-Now without counsel, we filed pro se, Combined Response to Pierce's Response to the above Motion (by attorney Rouse) to Remove Trustee Rolinaitis and Pierce-acting as his counsel in a severe conflict of interests, objecting to such fraud, including, comparing us to Tax Protesters-(Exhibit "").

January 5, 1987-Reply by Chief Judge Richard Bohanon denying our motion demanding Rights Sua Sponte. As show herein, Bohanon took reassignment despite his severe conflict of interests and allowed lawyers of four (4) (of a total of nine (9) law firms who appeared in our cause) to conspire in open court to defeat AI’S Appeal & reorganization, now advised that we "retain a competent attorney"-(Exhibit "")-letter by Chief Judge Richard Bohanon.

Upon filing our motion (pro se), Trustee Michael Rolinaitis resigned (6 days before the hearing) and was appointed "estate administrator."

January 8, 1987-Pierce's (4 page) letter submitted in the Settlement Conference before Federal Magistrate Pat Irwin, on January 14, speaks to his bank’s wielding of political power to manipulate the legal system to perfect the virtual theft of our American Inn-(Exhibit "")-Pierce letter. 

January 9, 1987-Orders by Judge Bohanon Converting AI’S CH II, to CH 7, And The Appointment of L. Win Holbrook Interim Trustee And Approving Standing Bond for the American Inn, Inc. estate, case #86-2221-A-(Exhibit " ").Court Orders.

Vincent and Wayne Germano lodged a complaint with Holbrook of violation of AI’S bankruptcy and appeal supported by affidavits by lawyers Charles R. Rouse and David Dunlop. Holbrook moved the Oklahoma Court of Appeals for Rehearing of AI’S Appeal (below):

January 12, 1987-Court Of Appeals For The State of Oklahoma, Div. No. 3, L. Win Holbrook, Entry Of Appearance, as attorney for Trustee L. Win Holbrook, of American Inn, Inc.-(Exhibit " "). January 12, 1987-Order by the Court Of Appeals For The State of Oklahoma, Div. No. 3, granting Trustee Holbrook until February 2, 1987 in which to Petition for Rehearing (AI’S Appeal, case # 64,709) and Brief in support thereof-(Exhibit " ")-Court Order.

Interim Trustee Holbrook, however, joined the bank’s ongoing conspiracy and abandoned the bankrupt estate (American Inn") Appeal. Informed of Pierce’s and Alan Durbin’s prepetition fraud that caused AI’S bankruptcy as attested to by attorney Charles R. Rouse on his witness Affidavit dated November 6, 1985, the lawyers of four Oklahoma law firms who appeared in AI’S bankruptcy proceeding acted with the conspirators in covering up the criminally fraudulent bankruptcy and adversary proceeding.

January 12, 1987-Bankruptcy Court Order For Meeting Of Creditor etc. As shown on the Order (bottom left) W. Rogers Abbott, who appeared in AI'S bankruptcy case and joined bank, Pierce, Durbin and trustee Rolinaitis in covering up the ongoing fraudulent proceeding, withdrew from the case and moved the court to keep unearned $3700.00 of $5000.00 paid on his agreement to do a "cram down" against the bank and coconspirators.

January 23, 1987-Judge Bohanon granted Rouse's motion to withdraw-leaving US SEATED ALONE AT THE TABLE with interim Trustee Holbrook, Durbin, Pierce and others, seated at the other table. Microphone in hand, Pierce verbally supported his previously submitted motion for default summary judgment over the P.A. System.

Judge Bohanon granted his bank Default Judgment, converting the case to CH-7. Pierce, thus, perfected bank's criminally fraudulent foreclosure-(Exhibit "")-Mandate. Abbott, as AI'S ex-attorney, DRAFTED (for Chief judge Richard Bohanon), the fraudulently begotten default judgments against Vincent and Sophie Germano and mailed them to our home in Texas. Though the original judgments were removed from case files by lawyers Susan Manchester and Floyed Taylor, this Exhibit consists of the Court Order.

February 24, 1987-Pierce took possession of our American Inn for his Bank at Sheriff Sale for a fraction of his bank’s mortgage, and as lawyer Charles Rouse, stated in his pleadings to the court in the 5990 case (above) the bank made a "windfall." On information and belief, Pierce parlayed its ill gotten windfall by claiming a loss on the Bank's IRS Income Tax Returns.

February 29, 1989-We mailed a complaint, with a three page summary of the above outlined bankruptcy fraud to Assistant U. S. Trustee Michael Freemen, U.S. Bankruptcy Court, 201 Dean A. McGee, Okla. City, OK, 73102, Freeman didn’t bother to respond.

On our complaint of the bankruptcy fraud, corruption: John Green, assistant U.S. Attorney, OK City office, an African American, started writing our complaint, but on hearing judge Richard Bohanon's name, stopped writing and stated "I will not embarrass Luther Bohanon” (father of bankruptcy judge Richard Bohanon, a senior judge in that same federal district, because “he integrated the schools in Oklahoma." A violation of Sec. 458 FRCP) that fueled the STRIKING of our Petitions in the state and federal courts in Oklahoma City and Houston Texas as shown below.

We personally lodged a complaint of the bankruptcy fraud committed in bankruptcy court in Oklahoma, with Assistant U.S. Trustee, Nancy Holley of the Houston, Texas, bankruptcy court. She gave us her card and ignored our pleas for help. Shortly thereafter, her boss (Trustee Head), resigned amid charges of his wrongdoing.

NEWS RELEASE by Congressman Jack Brooks: Due to complaints of ours and other victims of such conflict of interests, cronyism, bankruptcy fraud, corruption suffered by us, Congressman Brooks moved General Accounting Office to investigate the Justice Department’s U.S. Bankruptcy Program. No response was received, however, Judge Bohanon was removed as Chief judge, but is still a judge in that bankruptcy court-(Exhibit ""-News Release). 16

U.S. District Court, case CIV-87-525-T: Vincent Germano and son Wayne, drove (8 hours) to the law office of Miskovsky, Sullivan, Taylor & Manchester, Oklahoma City, OK. Informed of the above facts, they stated they didn't have a conflict of interests with parties involved in our cause, and that they would include in our petition a referral to the (17-Page Paper) that Pierce had presented at the April 3, 1987 Banking Law Institute, Oklahoma City University, titled, Bank's, Lawyers And Liability Revisited-(Exhibit "").

Based on their written agreement to "prosecute the parties who caused the financial collapse of the American Inn--through appeal," our son Wayne and I handed them a $5000.00 check and the "original default bankruptcy judgments. In his paper, Pierce stated in part as follows: "the traditional "Plaintiffs Bar" does not know very much about financial regulation but, they are certainly experts in common law and tort theories. And most of them can pronounce, if not expound upon, RICO." There is a decided inclination on the banker's part to act now and worry about ramifications later.” “Keep a clean file, assume that everything in a credit or customer file will be read to a jury. A good paper trail can prevent a debtor from getting to a jury. Communicate if the bank thought the borrower was a sufficiently astute businessman to justify credit initially, does it have reason to consider him inept today?” "Likely not"-(Exhibit "")-Pierce’s seventeen page paper.

The case was assigned to Chief Judge Ralph Thompson: Lawyers Taylor and Manchester, filed our Petition omitting mention of the Paper and claims arising from facts touched on above. We later learned that Taylor and Manchester also lied to deceive us into hiring them; unbeknown to us, Susan Manchester appeared for Trustee McDonald (to replace us as debtor in possession in AI'S bankruptcy case).

Taylor and Manchester, removed from case files the original Judgments levied against us by “default”, received in an envelope of the law firm of R.W. Rogers Abbott, 414 Park Harvey Center. Okla. City, OK, 73102. Abbott is one of the lawyers of four law firms who appeared in AI'S bankruptcy (above) and covered up, suppressed the bank’s and coconspirator lawyers prepetition and ongoing  bankruptcy fraud. Abbott drafted the default judgments for Chief Bankruptcy Judge Bohanon, after he granted his motion to withdraw from our case and keep $3700 of $5000.00 paid on his agreement to prosecute what Abbot stated was a "Cram Down" against the Bank and conspiring attorneys.

April 7, 1987-We received an Affidavit and cover letter by U.S. Mail from the Oklahoma City, OK, law office, by Susan Manchester, advising us to sign the enclosed Affidavit. Her appearance for trustee Mc Donald to take over management of the AI still unknown to us, after her refusal to add all of our claims from the affidavit only touched-on herein, by phone, we refused to sign the affidavit-(Exhibit “ “ )-Affidvit and the transcript of their appearance at trustee McDonald’s bankruptcy court hearing.

Chief Federal Judge Thompson granted Taylor and Manchester's motion to withdraw from our case, alleging that we insisted on changing their employment agreement to keep $5000.00 paid on their (written agreement to "prosecute the parties who caused the financial collapse of American Inn--through appeal"-(Exhibit " ").

Chief judge Thompson, stating "certain claims are viable and appropriate," reassigned the case to Judge Lynn Phillips (whose wife) was associated with Alan Durbin's chose in action Andrews, Davis, law firm.

May 27, 1987-Pierce filed Defendant's Brief in Support Of Motions For Entry Of Judgment And Imposition Of Sanctions against the Germanos, citing facts and legal precedent having no record support-(Exhibit "")-Brief and Motion.

June 5, 1987-We wrote to Bill Price, the then U.S. Attorney, in Oklahoma City, who had recommended Alan Durbin, inquiring about our previously filed criminal complaint against bank's Peter G. Pierce III. No response was received-(Exhibit "").

June 31, 1987: Motion, Response of Counsel by trial lawyer Richard Denney and letter by Dallas attorney L.S. Kaplan, who, in his Dallas law office, recommended Denny to Vincent Germano and son Wayne. Mr. Denny discussed filing a federal Civil Rico action, filed an entry of appearance, then withdrew because of a possible conflict of interests-(Exhibit ""-Lawyer Denney Motion and the Kaplan letter).

With the pending deadline for filing our Amended Petition, we Wayne, drove (8 hours) to meet lawyer Craig Dodd (of Enid Oklahoma) at Sullivan’s restaurant in Oklahoma City. Upon confirmation of his phone agreement and to mail his written agreement to amend our Petition with all our claims-through appeal, we paid him $5000.00. Dodd, however, didn't mail his written agreement and compounded Manchester and Taylor’s felony fraud, fraud on the court.

Lawyer Craig Dodd filed an Amended Petition-omitting claims arising in the extraordinary facts only touched upon herein. Dodd's associate David Vorwald, expressed amazement over evidence learned in deposing lawyer Alan C. Durbin, but refused to provide the transcript of the deposition. In a fit of remorse, Vorwald stated the reason for omitting our claims from our Amended Petition and refusal to provide a copy of the transcript, could be found by obtaining the name of the high official whose daughter was married to one of the parties involved in our case.

Due to the high profile persons involved, one Oklahoma City investigator, returned our fee, and the other firm accepted, then abandoned our case. Having uncovered certain of the conflict of interests on our own initiative that caused the lawyers of the nine (9) Oklahoma law firms who undertook our cause throughout the years and violated our right to due process, we have yet to uncover the names of the parties alluded to by lawyer David Vorwald.

July 21, 1987-Judge Layn Phillips' Order denying our pro se motion to disqualify him because we did not question his impartiality. Thus, despite the fact that his wife was associated with a main, chose in action conspirator law firm, our efforts to defend our right to an impartial judge and constitutional due process, came to naught once again-(Exhibit "")-Court Order.

July 27, 1987-Our Reply Brief (filed by our son Wayne) In in opposition Pierce’s Motion To Dismiss And Motion For Summary Judgment, with two pages of case law and facts having no relationship to the extraordinary fraud, corruption, briefly outlined herein-(Exhibit " ").

Based on lawyer Craig Dodd’s In Camera Affidavit, alleging wrongdoing by us (clients) Judge Phillips STRUCK our lawsuit and granted Dodd's motion to withdraw and to keep our un-earned $5000.00 fee-(Exhibit ""-Pierce Reply Brief).

Late one evening Craig Dodd phoned writer Vincent Germano and stated "if he had pleaded the truth of our case in the Amended Complaint, he would have had to appeal all cases thereafter." Dodd further stated his son was disabled and couldn’t afford to appeal all cases.  I expressed my sorrow for his son’s disability and stated the court records in our possession documenting violations systemic violations of due process were grounds to thwart any politically induced punishment for defending his clients.

Notified by phone by Mr. French, Clerk, Federal District Court, of a hearing, we drove (eight hours) to Oklahoma City only to see a dark Courtroom. Chief Judge Thompson's secretary, on hearing our inquiry, exclaimed "my god you were prejudiced," but Judge Thompson, told her he wasn't allowed to speak with us ex-parte. We drove another eight hours back to our apartment in Kingwood, Texas.

September 1, 1987-Bankruptcy Trustee L.W. Holbrook, following  his and trustee Michael Rolinaitis defeat of AI’S CH II bankruptcy in the extraordinary facts briefly outlined herein above, trustee Holbrook filed another false sworn affidavit in support of Pierce's motion for summary judgment on which Judge Phillips, Struck our lawsuit in the CIV-87-525 Case-(Exhibit "")-Trustee Affidavit.

November 20, 1987-Pierce, by Subpoena of the U.S. District Court, Southern District of Texas, Houston Division, served on our family, deposed our daughters Deborah Speaks, Pamela and John Kutchback and son Wayne Germano, at the law office of Eikenburgh & Styles, 1100 First National Bank Building, Houston, Texas-(Exhibit "").

January 7, 1988-We filed the Affidavit by Dr. David Nickeson in Support Of a Motion For Continuance," Case #CIV-87-525-P. Attesting to Vincent Germano’s physical condition following percutaneous transluminal coronary angioplasty, performed at the V.A. hospital, Houston, Texas-(Exhibit "").

January 19, 1988-U.S. Tenth Circuit Court of Appeals, case #88-1244, USDC case#: CIV-87-525: Vincent Germano and son Wayne,  pro se, appealed the striking of our lawsuit and filed a series of compelling motions and briefs opposing Pierce's pleadings designed to cover up his, our counsels' and bankruptcy Trustee's fraud touched on herein. During a phone inquiry, the court clerk stated to Vincent Germano, "what's the matter, don't you like the justice you received"?-(Exhibit "" )-Case Docket.

Tenth Circuit Court of Appeals, Order affirming the district court order; denied en banc rehearing and motion to stay issuance of mandate pending application to U.S. Supreme Court-(Exhibit "")-Court Orders.

February 20, 1989-We submitted a four-page complaint to Assistant U.S. Trustee of that district, Michael Freeman regarding bankruptcy fraud outlined herein, no response was received-(Exhibit “ “).

January 28, 1988-Pierce filed his Affidavit In Support Of Attorney Fees-(Exhibit "").

March 8, 1989-Response by Philip M. Zeidner, Executive Office Of U. S. Trustees, U. S. Department Of Justice, to our complaint of bankruptcy fraud. He expressed his outrage over the phone and moved C. P. Wood (Kansas Trustee) to investigate our complaint. Though judge Bohanon was removed as Chief judge, he is still judge in that federal bankruptcy court, Ms. Wood allowed the bankruptcy fraud to continue to defeat our motel reorganization and appeal from  bank & our counselors’ prepetition felony fraud, fraud on the court--(Exhibit "").

March 9, 1989-Summoned to appear at an asset hearing (by Pierce) in Federal Court in Oklahoma City, we drove eight hours to the hearing presided over by Magistrate Robin Cauthron. Pierce questioned me,Vincent Germano and lied to goad me into objecting: He stated in part: "This is in 1987 after you were kicked out of management of the American Inn." "Mr. Germano, after the U.S. Bankruptcy Court, Western District of Oklahoma removed you as manager"-(Exhibit “ “)-Transcript of the hearing.

Though the Transcript of the hearing shows I answered "yes" to one statement, the court record proves both statements were false and done to provoke me into objecting and calling Pierce a liar. Magistrate Cauthron stated (LYING) wasn’t relevant to the hearing, and by Order of June 29, 1989 she certified a finding of Contempt of Court to federal Judge Layn Phillips. (Magistrate Cauthron had granted Pierce's motion for legal fees in the CIV-87-626-P case, stating "Incurred as a result of (Germano’s) bad faith institution and pursuit of this lawsuit). Coauthor was appointed Judge in that federal court district!

June 28, 1990-Page 33 of transcript of Contempt Hearing, attorney J. W. Coyle received a $700 fee to present the document which shows we had sold the Motel to (Faust) based upon an irrevocable letter of Credit, only to have his lender refuse to honor it. Coyle (remained seated, and failed to present the document in my defense at the hearing before judge Layn Phillips. Judge Phillips whose wife was associated with bank main coconspirator Alan Durbin law firm and  (recommended by the U.S. Attorney) ignored my offer of the document (before me on the witness stand).

Judge Phillips called a federal marshal into the courtroom and sentenced me to five (5) days in the Oklahoma County Jail (to punish me for defending our rights). Instructed to take me to the Oklahoma County Jail, the federal marshal, now retired, stated he wasn’t going to shackle me and to sit in the front seat with him for the trip to the jail. I thanked the Marshal for his kindness.  Judge Phillips released me the next day-(Exhibits "")-page 33 of transcript, Jail receipt and letter by the shorthand reporter.

May 23, 1989-I filed a Common Law Affidavit in Real Property Records of Oklahoma County, OK, Clerk, file # 000446557. It declared in part, Sheriffs Deed of the American Inn, is fraudulent: Fraud lies in the fact that said instrument is being used in a continuing criminal episode and in an endless chain scheme of fictitious sales and is a forgery. Said instrument is perjures, constituting fraud, and fraudulent use of process being invalid from its inception as a direct trespass without due process of law and a deprivation of all rights. The affidavit cites the Supreme Court ruling in Rich vs. Braxton, 158 U.S. 375, 376, 1985, specifically forbidding Judges from invoking equity jurisdiction to remove common law liens or similar "clouds of title." Our legal counselors, failed to cite this ruling and the facts stated, in part above.

June 28, 1989-Petition, First National Bank of Bethany, case # CJ-85-5990: Filed by Peter G. Pierce III to expunge the Affidavits also named Oklahoma County as defendant. The case was assigned to Judge Owens. Pierce Amended the Petition August 37, 1989.

Robert Mitchell, Assistant Oklahoma County Attorney, who was shown the supporting court records by me, Vincent Germano, filed an Answer, July 7, 1869, stating in part. "Plaintiff petition fails to state a claim which relief may be granted as to the defendant.” “Plaintiff requests an order from this court which would prevent him from carrying out statutory duties of his office in the manner prescribed by law, and injunctive relief sought against this defendant is not authorized or appropriate under the facts of the case."

July 25, 1989-Following denial of our cause by several Oklahoma law firms, we filed an Entry of Appearance pro se. Lawyer Charles Rouse induced us to hire him (a third time) based upon his personal knowledge of the facts, his affidavit and letter of May 25, 1989, in which he states, in part: "I have received your chronology and note that on its face, you appear to have an excellent 1983 action against numerous parties that have actively conspired against you; As you can imagine, several of the defendants, including (bankruptcy) Judge Bohanon, Alan Durbin, Peter Pierce and the Rolinaitis' (trustee) are looking at disbarment in the event that we prevail.

“As you know, Peter Pierce has a nasty habit of launching a paperwork blizzard when one is not required. I do not believe that each of the above listed Defendants would leave no stone unturned in their attempts to win this suit because of the disastrous professional and financial ramifications should you win."-(Exhibit "")-Rouse letter mailed to our home in Texas. As in each prior action, pursuant to Pierces motion, the case was reassigned to his favorite judges; in this case judge James B. Blevins, whose void judgments this suit sought to set aside under OK Statute, shown to have violated our constitutionally protected right to a trial by jury and due process in each prior judicial hearings.

August 18, 1989-Letter by attorney Charles Rouse addressed to our home in Texas, stating, in part: "Enclosed please find our Very Rough First Draft of the Answer and Cross Petition that we have furnished for review in your case." "Prior to finalizing this matter, it will be necessary to document the violation of E.C.O.A. and review a copy of the Cross Petition in CJ-85-0095, and the retaliatory suit that I filed in CJ-95-5070 Case"-(Exhibit "")-lawyer Lawyer Charles Rouse letter and witness affidavit.

…"The reason for this is that res judicata on anything filed in the counterclaim which the judge gave judgment to the bank on our petition (CJ-85-5070) to vacate earlier upon which the judge gave judgment on, --all sustained as per fraudulent Appeal (case # 64,709) prior to finishing this matter." "Additionally, we are intending to bring a cause of action for Damages, mental Duress, Loss of Credit Standing etc. on your behalf." "This has not been added to the rough draft, BUT WILL BE ADDED IN THE FUTURE" 23

Lawyer CHARLES R. ROUSE, however, FILED THE SAME "VERY ROUGH FIRST DRAFT" as our Answer and Cross Petition-(Exhibit "").

September 1, 1989-Reply To (our) Counterclaim, by Pierce for his bank, stated, in part: "claims are barred by statutes of limitations, and the doctrines of issue preclusion and claims preclusion-(Exhibit "")-bank reply.

September 1, 1989-U.S-Bankruptcy Court Trustee L.Win Holbrook once-again filed his Affidavit extending his bankruptcy fraud into this state court action case # CJ-89-5990-(Exhibit "")-Trustee Holbrook’s false sworn affidavit.

September 26, 1989-Our cover letter submitted with our Affidavit, mailed to Robert Macy, Oklahoma County District Attorney, requesting a Grand Jury investigation into our complaint involving violations of our civil rights and criminal laws perpetrated under color of law in the state-federal courts, above. The OK County District Attorney didn't respond-(Exhibit "").

January 8, 1990-Our letter to attorney Rouse requesting him to perform discovery and other services-he advised were vital to our case. As in his prior appearances, he failed to conduct discovery beginning in Plaintiff Bank's foreclosure suit-(Exhibit "")-letter.

January 12, 1989-Our letter in response to attorney Rouse's letter containing Pierce's Requests For Interrogatories Admissions And Documents THREE (3) DAYS before they were due in Pierce’s Oklahoma City office, knowing we couldn’t complete them in time-(Exhibit ""-).

January 22, 1990-AS IN EACH PRIOR ACTION, Pierce filed his bank’s Motion For Summary Judgment And Notice Of Hearing-(Exhibit "")-bank motion.

January 27, 1990-Our son Wayne FedExed this letter to attorney Rouse with our Discovery drafts and Admissions and request that Rouse demand a trial by jury and that answers to Pierce's discovery requests will be delivered to you by Monday February 5, 1990-(Exhibit "")-letter

January 30, 1990-Our Grievance filed with the Oklahoma Bar, asking Dan Murdock not to discipline Charles Rouse, but to have him cease neglecting duties and legal actions which he advised were critical to our legal defense and cross petition-(Exhibit "")-OK state bar denied ten compelling grievances.

January 30, 1990-Our letter to Rudolph Hargrave, Chief Justice, Oklahoma Supreme Court, outlining case history of violations of due process with a copy of our grievance to the Okla. Bar Association, requesting him to order Rouse to perform legal services. The justice didn’t respond to our pleas for help-(Exhibit "")-letter.

February 7, 1990-Lawyer Rouse followibf his failure to move the court for judge Blevins’ recusal, as he had advised was vital, we filed an application for his recusal-(Exhibit "")-application.

February 8, 1990-Order and Judgment, U.S. 10th Circuit Court of Appeals affirming the District Court Ruling Striking our lawsuit; “two orders” denying en banc rehearing and stay issuance of the mandate until the U.S. Supreme Court rules of our motion. The Orders cite facts and legal precedent having no record support of case history of violations of constitutionally protected due process and trial by jury touched on herein-(Exhibit "")-Court Orders.

March 14, 1990-Motion To Withdraw by attorney Charles Rouse, asserting, in part; that we refused to cooperate in discovery required by statute. That we have filed pleadings in this matter having no merit; Vincent Germano’s overwhelming fixation with this matter appears to be psychogenetic in nature obstructing his rational analysis of the situations faced in the course of this litigation"-(Exhibit "")-Motion.

With the probable granting of Plaintiff Bank's Motion For Summary Judgment, I, Vincent Germano underwent a psychiatric examination by Dr. Jose Carranza and mailed the finding to Judge Blevins asking that he deny Rouse's motion, as a replacement attorney was not available to us in Oklahoma-(Exhibit "")-Finding by Dr. Jose Carranza.

March 25, 1990-Our letter to attorney Rouse (Certified Mail-Return Receipt Requested), in part: That he move the court to vacate its Order granting Defendant's Motion For Imposition Of Sanctions, by DEFAULT following his failure to attend the hearing-(Exhibit "")-Letter to Rouse.

April 2, 1990-Plaintiff' Bank Pierce's motion, Concurrence With (Rouse's) Application To Withdraw As attorney Of Record-(Exhibit "")-Motion.

April 9, 1990-Letter by lawyer Rouse to us, in part: Upon ORAL MOTION the court vacated sanctions, then re-imposed sanctions after learning that you refused to Verify the Answers, and admonishes us for "claiming injuries that don't exist." Rouse withheld from the court that we requested him to replace Verifications that he had mailed to us because they were "illegible copies" and would have been rejected by Pierce-(Exhibit "")-Letter. 

May 3, 1990-Our letter sent by Certified Mail to Robert L. Mitchell, Assistant D. A. Oklahoma City, OK, complaining, in part, of bankruptcy Trustee Holbrook's false sworn Affidavit submitted in support of Pierce’s motion for summary judgment. No response-(Exhibit "")-Letter.

 June 10, 1990-Our one page cover letter to the Clerk of the U.S. Supreme Court, with three supporting instruments attached thereto-(Exhibit "").

July 17, 1990-Affidavit Of Judgment, and Journal Entry Of Judgment on bank's lawsuit, case #CJ-89-5990, dismissing our Crosspetition, and PERMANENTLY ENJOINED AND RESTRAINED us from filing legal action against the Bank, its parent, Devonshire Investment Company, and American Inn Motel Of Oklahoma City, Inc. (our motel) and VERY ROUGH FIRST DRASFT OF OUR CROSS PETION which named only the bank-(Exhibits " "). July 18, 1990.

Pierce mailed to our home in Texas, letters addressed to us and Robert Mitchell, Assistant D.A., Oklahoma County, OK, with the Appellee 's Journal Entry of Judgment, by judge Blevins filed July 17,1990-(Exhibit "").

August 9, 1990-Agreement by Jerome Blumenthal to prosecute our appeal, in part: "I will prepare the petition in error and file same. I will prepare and file a brief to all issues and facts of this case regardless of implications to parties in high office." Like his predecessors, he omitted the fraud, corrupt ion by his predecessors briefly outlined above-(Exhibit "")-Blumenthal Agreement.

September 25, 1990-Order, Oklahoma Supreme Court, denied our (pro se) Writ of Mandamus to disqualify Judge Blevins, which states "adequate remedy by appeal". The Order was signed by Chief justice (Hargrave) who failed to respond to our letter and copy of our bar grievance dated January 30, above, asking to prevent Rouse from abandoning our cause-(Exhibit "")-Court Order.

May 21, 1991-We filed pro se, Motion and Brief To Sanction Peter G. Pierce III, in the Oklahoma Supreme Court. Blumenthal didn't controvert the facts and case law asserted by Pierce, having no relationship to his and our legal counselors litany of fraud, corruption shown in part herein-(Exhibit "")-Letter and Motion.

U.S. Supreme Court: following our legal counselors’ systematic refusal to move the court to disqualify Judge Blevins and demand a trial by jury since January 4, 1985, our son Wayne drafted our Corrected Combined Motion To Disqualify And Sanction Peter G. Pierce III And Strike Brief In Opposition To Petition For Writ Of Certiorari. It was filed stamped May 1 and June 10, 1991.

July 4, 1991-U.S. SUPREME COURT: Our Brief In Support Of Plaintiff's Combined Motion To Reconsider And Vacate The Related Orders etc. and the Order by Judge Phillips of July 21, 1987. The "Constitutional Court" denied a total of FIVE pleas for appellate relief from violations of constitutionally protected due process in each and every case at the hands of the lawyers of the nine (9) Oklahoma law firms who undertook our cause since 1985.

January 18, 1993-Oklahoma Supreme Court-This is one of the pleadings filed by us pro se: Appellants’ Amended Petition For Writ of Certiorari. The justices also ignored the ten page petition of a compelling overview of the extraordinary history of violations of every element of Constitutionally protected Due Process-through which judges seized our motel for the bank and ended a successful family business-(Exhibit "").

October 18, 1994-Attorney Charles Rouse stated in his letter to us, "Thank you for a copy of your disillusional diatribe. As you are aware, it contains numerous slanderous and false statements. Only your poverty prevents me from seeking remedy. I hope you get the help you need"-(Exhibit "")-Lawyer Charles Rouse letter.

October 15, 1999-U.S. District Court, Houston, TX: Our lawsuit filed pro se against First National Bank of Bethany, OK, Now First Bethany Bank & Trust, N.A., case #H-98-CV-2688, demanding a trial by jury. It also named its officers, directors and privies, jointly, individually and severally. The suit was supported by our (15 page) Affidavit listing the cases in Oklahoma state and federal courts of the Western District of Oklahoma. The suit listed the cases (all limited to sham judicial proceedings) and their disposition by summary judgment-(Exhibit "")-Petition and General Docket). 

Docketed a Civil Rights case by the filing court clerk, the case was  assigned to Judge John D. Rainey. The Houston, TX, law firm filed bank’s Answer, absent demand for a trial by jury. Judge Rainey, informed of the omittion of the Adversary suit from the rendition of cases listed on the Affidavit filed with bank’s Answer actually proves  our suit stems from history of judicial foreclosure and summary dismissal of our efforts to adjudicate our claims in the courts in Oklahoma state. And as also shown in the above bankruptcy case, the Affidavit was omitted by Peter  Pierce III, to cover up that he prosecuted the Adversary case (# 86-04-23) his felony conspiracy with our prior legal counselors and trustee in full felony control of the bankruptcy proceeding. Together, the lawyers prosecuted the suit to move the court to award Peter Pierce’s bank two judgments (by default) against us to convert our motel’s CH II to CH 7. Thus, the Affidavit is falsely sworn to deceive; commit fraud on the court as he (Pierce) had done in each of the prior cases in Oklahoma State-(Exhibit "")-false sworn Affidavit by Peter G. Pierce III.

September 29, 1999-Judge Rainey issued a Memorandum and Order granting Pierce’s Motion For Summary Judgment - striking our Civil Rights suit. The Order consists of a (7 page ruling and legal precedent) having-no record support of violations of due process and trial by jury litany of Pierce’s and our legal counselors’ fraud, corrupt conduct, fraud on the courts in each prior legal actions-(Exhibit “ “)-Memoranda and Order.

December 27, 1999-We appealed the ruling in the U.S. Fifth Circuit Court of Appeals, case # 99-20969-(Exhibit "")-Appellant Brief and General Docket).

November 16, 1999-Clerk letter notifying us, in part, the appeal was docketed, and included a caption for the appeal and asked that we use it on any briefs you file with this court. We notified the Clerk that the caption was not correct, that our prior legal counselors and the judges were named bank's co-conspirators-not defendants as stated, the Clerk failed to correct the caption-(Exhibit "").

We filed numerous pleadings in this Appeal, however, our concern for its defeat arose with Deputy Clerk Janne Winne's directives by phone and U.S. Mail that deceived us into canceling our timely filed motions for en-banc rehearing of court rulings denying our motion to supplement the record, in defense of the false facts repeated slander of our integrity and probable defeat of our appeal.

Thus, the Deputy Clerk deprived us the right of reconsideration by the full court of such wrongdoing and slanderous pleadings pursuant to court rules governing en bank rehearing-(Exhibit "")-Docket.

July 13, 2000-Appellee Bank's Louisiana counsel filed bank's Original Brief, replete with false history, facts and three pages of Authorities having no record support, and crossed the line of common decency: The lawyers slandered and accused us of abuse of process and waste of tax resources.

The bank’s counsel further stated, in part: "Blinded by Ignorance and Obsession, the Germanos filed suit in the Southern District of Texas in July 1999, asserting the same claims based upon some FAUX conspiracy." "The Germanos have abused the civil court system for nearly a generation. They have plagued First Bethany, forcing it to defend claims wholly lacking in merit. Unable to respond in damages or monetary sanctions, living on exempt income with relatives in Houston's luxurious Kingwood addition,”“the Germanos approach the courts with impudence and contempt."

"First Bethany respectfully submit that the District Court order dismissing the Germanos' case (and in the alternative entering summary judgment should be affirmed with sanctions against the appellants).” The order is legally correct and furthers the policy that frivolous Complaints ought not vex either those called to defend or an overtaxed judiciary, or the third party in all Litigation, the Taxpayers whose money the Germanos have repeatedly squandered."

November 10, 1999-Letter by Meredith Ann Pierce notifying us to direct 29 correspondence to her at the Jones, Walker law firm in Baton Rouge, Louisiana. Ms. Pierce, an Oklahoma resident is the grand-daughter of Peter Pierce Sr., Appellee bank's President, majority stockholder and board chairman-(Exhibit "")-letter by lawyer Meredith A. Pierce.

We motioned the court complaining about attorneys, E.S. Wilson's slanderous language and Meredith A. Pierce's conflict of interests. Appellee 's Louisiana counsel responded stating that Wilson and Ms. Pierce were dismissed and replaced-(Exhibits"")-both motions to substitute counsel.

 February 9, 2000-We petitioned the Senate Judiciary Committee, with supporting exhibits stating our concern for the likely defeat of our appeal and asked the committee, having oversight powers of such legal system corruption, to bring finality to a gross miscarriage of justice and civil rights violations that have devastated our lives since 1985-(Exhibit ""-Petition).

August 1, 2000-We filed a comb-bound Appellant's Motion To Supplement The Record consisting of (15) pages of text defining the (42) key court records included therein. How the lawyers of nine (9) law firms conspired with bank's insider-lawyer to move the courts to evade a trial by jury and due process by awarding bank (summary judgments) to take possession of our AI and dismiss our counterclaims-(Exhibit "")-Appellant's Motion To Supplement Record.

August 31, 2000-Appellee bank’s (3 page) Motion, response to our Reply to Appellee's Original Brief asking the court to strike our Response, stating in part: "The Germanos are persistent in their attempt to supplement the record with offensive allegations of professional misconduct, unethical, and illegal behavior of the Appellee and its officers, directors and lawyers. Appellant' s response to Appellee's Motion To Strike is insulting to the Court and ignores the significance of the Appellate Rules of Appellate procedure ("FRAP") and federal precedent."

"Furthermore, the Germanos seek to remand this case to the district court for a trial by jury on the merits, and have been litigating this issue and harassing the Appellee for over fifteen years. The District Court properly granted Appellees motion for summary judgment. The Germano appeal is frivolous and a continuous waste of time and resources. The Court should not allow pro se litigants to ignore the rules that our federal system has in place for its judicial process"-(Exhibit "")-Appellee (3) page motion.

September 7, 2000-Our motion "Complaint Regarding Appellee Counselor's Disregard For The ABA'S Model Rules Of Professional Conduct," in part: Appellee's Louisiana counsel, rather than submit evidence to disprove our claims, persists in slandering our integrity and alleging our pleadings are insulting to this Court. Appellants ask the Court to protect us from further abuse and require Appellee's Louisiana counsel to withdraw from representing Appellee and to grant our motion to supplement the record and for what other relief this court deems justifiable under the extraordinary facts of our case.” The Motion is also not listed on the Docket-(Exhibit "").

September 13, 2000: Court issued its Order denying Appellant's motion to supplement the record, and granted Appellee’s motion to Strike our Motion to Supplement the record-(Exhibits "")-Court Order.

September 22, 2000-We timely filed Appellants Motion For En banc Reconsideration Of The Court Order Denying our Motion To Supplement The Record, docketed August 1, 2000 (above). Due to concern for the likely defeat of our appeal, due to a court clerk’s misleading phone and written directives, February 9, 2001, we petitioned Senator Leahy, Chairman, of the Senate Judiciary Committee, to invoke congressional oversight power to defend the constitutionally protected right trial by jury and due process.

The court, however, ruled to uphold the lower court order Striking of our lawsuit docketed a civil rights case. Though, no written response was received from the Senate Judiciary Committee to our petition, a court clerk (by phone) informed us that that our appeal was reopened. The case was dismissed a second time shortly thereafter.

As only touched on above and documented by the court records in our possession, the simple set of facts of our legal defense were turned into a nightmare of a never ending search for ethical representation by a succession of attorneys named/pictured herein, who acted with the bank’s Pierce in moving the courts for judicial foreclosure (by Default) and summary dismissal of our efforts to  exercise constitutionally protected (trial by jury) and due process, through such violations of trust, fraud, corruption, that shocks the conscience and violates the decencies of civilized conduct.

Thus, all constitutional functions and statutory duties of government have been closed to us since summoned as defendants in the bank’s criminally fraudulent lawsuit in foreclosure January 4, 1985:

Compelling, documented petitions of having suffered violations of due process in the courts, and denial of grievances and complaints by the Oklahoma Bar, law enforcement and regulatory systems of state/federal government.. Petitions for congressional oversight of such legal system felony fraud, corruption were denied by Congressional Representatives during four administrations of both major-political-parties. Several representatives (officers of the court of the judicial branch themselves) denied our petitions citing Constitutional Separation Of Powers Doctrine!!

Vincent Germano