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					 Case 11-42834        Doc 220     Filed 12/30/11 Entered 12/31/11 00:12:11           Desc Main
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                        Go UNITED STATES BANKRUPTCY COURT
                           FOR THE DISTRICT OF MINNESOTA


In Re:                                                      Chapter 11

Yehud-Monosson USA, Inc.
                                                            Case File No.: 11-42834 (NCD)
                       Debtor,


                             RESPONSE OF REBEKAH M. NETT
                               TO ORDER TO SHOW CAUSE


         Attorney Rebekah M. Nett hereby responds to the Order to Show Cause against her as

follows:

                                  FACTUAL BACKGROUND

         The facts are that on November 17, 2011 I reported for a hearing in the matter of Yehud-

Monosson USA, Inc. at 1:20 – 1:25 p.m. Upon speaking to a clerk in the courtroom, I learned

that the hearing noticed for 1:30 p.m. had already taken place. Subsequently, Judge Dreher’s law

clerk came out to talk with me, and told me that there had been confusion as to why nobody was

present on behalf of Debtor but that the judge had not wanted to proceed without Debtor present.

Nobody raised the concern that the matter had been noticed for 1:30 p.m. and not 1:00 p.m. The

judge asked if we could have a hearing at 4:00 p.m. that same day. Unfortunately, I had prior

commitments I was unable to change, and I asked if we could have the hearing the next morning.

Apparently that did not work with the court’s schedule. Judge Dreher’s law clerk returned to

chambers to see what could be worked out. On his return, he advised me that he had contacted

the scheduling clerk and learned that Trustee Nauni Manty had made the scheduling mistake in

that she had scheduled the matter for 1:00 p.m. on the court’s calendar, but she had noticed the

matter for 1:30 p.m. in the Notice of Hearing, which is all Debtor had to rely on. Further, he


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indicated she had already scheduled another hearing for December 6, 2011. He suggested that

we leave the matter scheduled for that date since we couldn’t have a hearing at 4:00 p.m. the

same day or first thing the next morning.

        The following day, November 18, 2011 Judge Dreher issued an Order in response to the

November 17, 2011 hearing at which nobody for Debtor was present. In that Order, the Court

indicated that the U.S. Trustee Colin Kreuziger had also been present at the 1:00 p.m. hearing on

November 17th. This immediately raised a stir as previously I had understood that the matter was

simply a typographical mistake on the part of Ms. Manty’s office. However, the U.S. Trustee

would also have been served with the same Notice of Hearing that Debtor received through ECF

filing. Therefore, how did he know to show up for a hearing at 1:00 p.m. instead of 1:30 p.m.?

Furthermore, it was apparent from paragraph 2 of the Order that the trustee’s counsel had

presented argument in support of her motion for contempt at the November 17th hearing. The

Court’s Order in response permitted the Trustee to make a record at the continued hearing that

meets the test for a finding of contempt. Review of the audio transcript of that hearing confirmed

this.

        Debtor’s principal officer believes that the meaning of paragraph 2 is that the trustee will

be permitted to make a record that Naomi Isaacson had notice of the Court’s October 7, 2011

Order for Turnover in this case and by that record alone, it would be confirmed that she was in

contempt of the Turnover Order and subject to immediate arrest from the courtroom. The Debtor

and Ms. Isaacson believed this wholeheartedly and still does in fact. Debtor believes that the

outcome of this case has been essentially predetermined all along and that the Court and trustees

are all bound and determined to simply harm and destroy the Debtor because of who its

shareholder is. (It’s shareholder is Dr. R.C. Samanta Roy Institute of Science and Technology,



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Inc. – a non-profit organization (“SIST”). The president of that organization is Dr. Avraham

Cohen, a person outside the mainstream who has been attacked by Jesuit controlled mainstream

media for three and one-half decades.

       In the local area he resided in for many years in Wisconsin, numerous individuals and

organizations connected with him have been targeted with rumors, negative publicity, and

unfavorable municipal or court decisions under “color of law” – in other words, the outcome of

the authority figure’s decision is justified by a seemingly non-biased reason; however, in

comparison to other similar situations and by sheer repetition, it is apparent that the authority

figures, whether City officials or local judges, go out of their way to find a “non-biased” reason

to rule against these people’s favor. In fact, this is common knowledge in the community of

Shawano, Wisconsin but most average people don’t want to speak out for fear of also being

targeted. This discrimination became most heated subsequent to Lorna Marquardt’s election as

Mayor of Shawano in April 2002. Debtor believes that Lorna Marquardt has made it her

prerogative to put SIST out of operation entirely. Furthermore, Debtor believes that Lorna

Marquardt is associated with the Free Masons, another secret society that also ultimately assists

the Jesuit Order.

       The result of this scenario has been that Debtor’s principals (the same principals as those

of its parent company) absolutely know that all decisions against them in every situation are due

to organized discrimination and prejudice. Debtor’s parent company and numerous subsidiaries

filed a joint Chapter 11 bankruptcy proceeding in Delaware in March 2009. After six-months, the

cases were ALL dismissed for failure to make enough progress towards reorganization and

alleged misconduct, inter alia. Thereafter, when individual entities tried to re-file they were ALL

immediately and repeatedly targeted by the U.S. Trustee’s office as “bad faith” and repeat filers



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and subjected to motions to dismiss before they could even get their cases off the ground. It

would take reams of paper and months of writing to set forth all the details of the discrimination

experienced by Debtor’s principals in this one response. Debtor’s principal officers have

therefore formed a strong belief through all of this that just as Dr. Cohen has been subject to

repeated accusations and negative media for three and a half decades, so to they are being

targeted through the legal system because of who they are rather than on the merits of their cases.

Through this experience, Debtor has learned that our legal system is no longer founded simply

on principles of liberty and justice for all under the Constitution of the United States Republic.

       In particular they strongly believe that this Debtor’s case, which was converted from a

Chapter 11 to a Chapter 7, was converted illegally and contrary to bankruptcy code 11 U.S.C.

§303(a) (Debtor’s parent company is a non-profit company) only for the purpose to harm Debtor.

The fact that the appellate courts (8th Circuit Bankruptcy Appellate Panel for Yehud-Monosson’s

case and 3rd Circuit for this Debtor’s parent company’s case) have affirmed the MN Bankruptcy

Court’s decision to convert the case of this Debtor and the Delaware Bankruptcy Court’s

decision to dismiss sua sponte the consolidated bankruptcies of this Debtor’s parent company

and numerous subsidiaries simply proves to Debtor Yehud-Monosson’s principals that the

conspiracy extends to the appellate courts also.

       In light of all the foregoing and subsequent to Ms. Isaacson’s having obtained legal

advice from separate counsel, we determined it was appropriate and necessary to bring a motion

to vacate the November 18th Order. This was not a frivolous motion by any means.

       Debtor and Ms. Isaacson believe that all statements made in the November 25, 2011

motion were in fact supported by fact. Further, Debtor believes such statements were not made




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for the purpose to harass the court or any other parties, and they were not made for any other

improper purpose. A clarification of each of the statements raised by the Court follows:

   A. “Chapter 7 Trustee Nauni Manty had actually scheduled the hearing with Nancy Dreher,
      the Catholic judge, for 1:00 p.m. but sent notice to the Debtor that the hearing was set for
      1:30 p.m.”

       Trustee Manty filed her Motion for Contempt along with Notice of Hearing on November

2, 2011. Both the court filing confirmation notice and Trustee Manty’s Notice of Hearing stated

that the hearing time was November 17, 2011 at 1:30 p.m. (See Docket No. 187) This is the only

Notice of Hearing filed regarding this matter prior to November 17th, and this notice was served

on all interested parties in the case, including the U.S. Trustee via electronic filing. On

November 17th, counsel for the Debtor was advised by the judge’s clerk that Trustee Manty had

in fact scheduled the hearing with the Court for 1:00 p.m.

   B. “Debtor seriously questions Chapter 7 Trustee Nauni Manty’s motive in informing
      Debtor of the wrong time for the hearing. Was it to the make the job of the black-robed
      bigot that much easier? So, rather than forcing the Court to hear the case on its merits,
      the matter can just go by default? Debtor is suspicious of the Chapter 7 Trustee Nauni
      Manty’s motive given her track record of lies, deceit, treachery, and connivery,
      particularly, since the Chapter 7 Trustee Nauni Manty, the U.S. Trustee Colin Kreuziger,
      and Nancy Dreher, the Catholic judge, have been communicating with each other about
      this Debtor on an ex parte basis.”


       Debtor was noticed that a hearing was to take place at 1:30 p.m. on November 17, 2011.

Debtor’s representative showed up to discover that unbeknownst to Debtor a hearing had

occurred at 1:00 p.m. already. Debtor was never notified of that hearing; yet the hearing

proceeded, and Trustee Manty’s counsel presented arguments to the Court in support of her

motion. Although the hearing was ultimately continued, and Trustee filed a Notice of Continued

Hearing, the Court still also issued an Order in which the Court addressed matters the Trustee

had presented to the Court on November 17th at the hearing that Debtor was given no notice for.



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All such communication was carried out in the absence of Debtor and without Debtor’s having

received any prior notice. Therefore, all such communication was in fact ex parte.

   C. “ U.S. Trustee Colin Kreuziger, Chapter 7 Trustee Nauni Manty, and Nancy Dreher, the
      Catholic judge, are of the same race and religion5 and their track record demonstrates
      their conspiracy and deceitful practices to hurt the Debtor. Even though all documents
      have been produced, Jesuitess Nauni Manty keeps repeating the same lie that records are
      missing.”


       See Section below herein titled Historical Facts supporting Controversial Statements.

This section includes only a fraction of the complete details and history existing regarding this

matter and the infiltration of our justice system. Debtor is arguing that it is a targeted entity, and

the Court and Trustee are working for this infiltrated system to bring about the Debtor’s harm

rather than justice. Despite the use of the word Catholic, it does not actually suggest or refer to

religious affiliation. In fact, historically, there have been notable non-Catholic people who have

done more to further the cause of the infiltrators than any person of Catholic faith has. See any

number of the references cited in the Historical Facts section for further information and details

concerning these matters. The list of references is far from inclusive of all references on this

topic, as this response would at least take several months to prepare if I was to address them all.

   D. “Across the country the court systems and particularly the Bankruptcy Court in
      Minnesota, are composed of a bunch of ignoramus, bigoted Catholic beasts that carry the
      sword of the church. Judge Dennis O’Brien is a Jesuit, Judge Nancy Dreher is a Catholic
      Knight Witch Hunter, U.S. Trustee Colin Kreuziger is a priest’s boy, and the infamous
      Chapter 7 Trustee Nauni Manty is a Jesuitess.”


       See Section below herein titled Historical Facts supporting Controversial Statements.

This section includes only a fraction of the complete details and history existing regarding this

matter and the infiltration of our justice system. Debtor is arguing that it is a targeted entity, and

the Court and Trustee are working for this infiltrated system to bring about the Debtor’s harm



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rather than justice. Despite the use of the word Catholic, it does not actually suggest or refer to

religious affiliation. In fact, historically, there have been notable non-Catholic people who have

done more to further the cause of the infiltrators than any person of Catholic faith has. See any

number of the references cited in the Historical Facts section for further information and details

concerning these matters. Particularly, I note that the reference to Colin Kreuziger as “priest’s

boy” mirrors the description by Priest Phelan in 1912 when he is quoted as saying, “Why is it the

pope has such tremendous power? Why the pope is the ruler of the world. All the emperors, all

the kings, all the princes, all the presidents of the world are as these ALTAR BOYS of mine.” —

Priest Phelan, Western Watchman, June 27, 1912, emphasis supplied.

   E. “Debtor and its representatives have never experienced any justice at the hands of these
      inquisitors. Since Debtor has been vocal is exposing their dirty deeds, these dirty
      Catholics have conspired together to hurt Debtor.”


       See Section below herein titled Historical Facts supporting Controversial Statements.

This section includes only a fraction of the complete details and history existing regarding this

matter and the infiltration of our justice system. Debtor is arguing that it is a targeted entity, and

the Court and Trustee are working for this infiltrated system to bring about the Debtor’s harm

rather than justice. Despite the use of the word Catholic, it does not actually suggest or refer to

religious affiliation. In fact, historically, there have been notable non-Catholic people who have

done more to further the cause of the infiltrators than any person of Catholic faith has. See any

number of the references cited in the Historical Facts section for further information and details

concerning these matters. The list of references is far from inclusive of all references on this

topic, as this response would at least take several months to prepare if I was to address them all.

   F. “Both the Chapter 7 Trustee Nauni Manty and the U.S. Trustee Colin Kreuziger
      appeared at 1:00 p.m. and both the Chapter 7 Trustee Nauni Manty and the U.S. Trustee
      Colin Kreuziger ‘pretended’ to not know why Debtor’s counsel was not present for the


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       hearing. Therefore, Nancy Dreher, the Catholic judge, proceeded with the hearing in
       Debtor’s absence and allowed the Chapter 7 Trustee Nauni Manty to argue her case as
       to why Debtor is in violation of the Court’s Order for Turnover dated October 7,
       2011.[...] When Debtor’s counsel arrived for hearing at 1:20 p.m., no other parties to the
       case were present, and the Court’s clerk informed Debtor’s counsel that the hearing had
       been held at 1:00 p.m. The Chapter 7 Trustee Nauni Manty and the U.S. Trustee Colin
       Kreuziger had already come and gone. The Court’s clerk confirmed that the notice that
       was sent to Debtor indicated that the hearing was set for 1:30 p.m. but informed Debtor’s
       counsel that the matter had been continued to December 6, 2011.”


       U.S. Trustee Colin Kreuziger received the same Notice of Hearing that Debtor received.

       Yet, he somehow knew to be present for a hearing at 1:00 p.m. while Debtor knew

       nothing about the matter. Given that all parties, including Trustee Manty received an

       electronic copy of the filed Notice of Hearing, how could it be that there was confusion

       about why Debtor was not present. All other statements in this paragraph are simple facts.

   G. “Shockingly, on November 18, 2011, however, Nancy Dreher, the Catholic judge, issued
      an Order that effectively already finds that Debtor is in violation of the October 7th
      Turnover Order. Such Order states Chapter 7 Trustee Nauni Manty is permitted to make
      a record at such hearing that meets the test for a finding of contempt. The November 18th
      Order further states that the Debtor representative is required to be present at the
      hearing. Given what these dirty Catholics are capable of and particularly since there is
      no law to protect the minority, Debtor is concerned about what their secret plans are for
      the December 6, 2011 hearing. Catholic deeds throughout the history have been bloody
      and murderous.”


       Paragraph 2 of the November 18th Order indicates from its very content that the trustee’s

counsel had presented argument in support of her motion for contempt at the November 17th

hearing. The Court’s Order in response permitted the Trustee to make a record at the continued

hearing that meets the test for a finding of contempt. Review of the audio transcript of that

hearing confirmed this.

   H. “For Nancy Dreher, the Catholic judge, to issue such an Order when she knew that the
      Debtor was not present due to being intentionally misled by Chapter 7 Trustee Nauni
      Manty is unfathomable. One can only conclude that Nancy Dreher, the Catholic judge, is
      part of the conspiracy to deprive Debtor of its due process rights since she went ahead


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        and issued an Order when she clearly knew the reason Debtor’s counsel was not present
        at the hearing.”


        See Section below herein titled Historical Facts supporting Controversial Statements.

This section includes only a fraction of the complete details and history existing regarding this

matter and the infiltration of our justice system. Debtor is arguing that it is a targeted entity, and

the Court and Trustee are working for this infiltrated system to bring about the Debtor’s harm

rather than justice. Despite the use of the word Catholic, it does not actually suggest or refer to

religious affiliation. In fact, historically, there have been notable non-Catholic people who have

done more to further the cause of the infiltrators than any person of Catholic faith has. See any

number of the references cited in the Historical Facts section for further information and details

concerning these matters. The list of references is far from inclusive of all references on this

topic, as this response would at least take several months to prepare if I was to address them all.

   I.    “Under normal circumstances, a Court would wait ten minutes in case some unfortunate
        mishap had befallen counsel to give her an opportunity to appear. What was the reason
        for the haste to hold this hearing? What secret discussions occurred during their secret
        meeting? Debtor has filed numerous pleadings which outline in detail its response to the
        Chapter 7’s Trustee Nauni Manty’s motion which clearly document that Debtor has
        produced all the records in its possession. Debtor has a right to be heard on that issue.
        The entry of the order is illegal and in violation of Debtor’s due process rights. In the
        interests of justice, this Order must be vacated.”


        See Section below herein titled Historical Facts supporting Controversial Statements.

This section includes only a fraction of the complete details and history existing regarding this

matter and the infiltration of our justice system. Debtor is arguing that it is a targeted entity, and

the Court and Trustee are working for this infiltrated system to bring about the Debtor’s harm

rather than justice. Despite the use of the word Catholic, it does not actually suggest or refer to

religious affiliation. In fact, historically, there have been notable non-Catholic people who have



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done more to further the cause of the infiltrators than any person of Catholic faith has. See any

number of the references cited in the Historical Facts section for further information and details

concerning these matters. The list of references is far from inclusive of all references on this

topic, as this response would at least take several months to prepare if I was to address them all.


   J. “Given the track record of injustice in this case, it seems that Debtor will never see
      justice until the matter is addressed in an international court in Beijing, China.”

       Obviously, from the history and this Debtor’s experiences, Debtor believes it will never

receive any fair treatment in this system. The reference to China is made as Debtor believes

China to be a system that has not been infiltrated by Jesuits thus far. However, upon learning that

Jesuits have been working in Beijing, China since 1601, Debtor now questions if fair treatment

would be possible there either.



       HISTORICAL FACTS SUPPORTING CONTROVERSIAL STATEMENTS

       To be clear, references made to “Catholic” do not refer to the Catholic religion per se or

to being a person who considers him or herself to be of the Catholic religious faith and lives

sincerely according to his or her religious creed. Rather, these remarks refer to a very real and

ominous geo-political element connected to the Catholic Church. This element is the Roman cult

and their military arm – the Jesuit Order, which has been in existence since 1534. See www.one-

evil.org for endless information and historical details concerning both the Roman cult and the

Jesuits as well as their activities and exploits all over the world throughout history. Their endless

activities touch every aspect of our society and have heavily influenced political events and laws

throughout our history.




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        The Jesuit Order was principally founded by Ignatius of Loyola, who preached an

extreme military based devotion to Catholicism during the Spanish Inquisition. Francis Borja

was the principle financier and architect in the formalization of the Jesuits into the first dedicated

military order of monks of the Catholic Church. He was also responsible for securing the Papal

Bull Regimini militantis (September 27, 1540) from Borja family friend Alessandro Farnese

Pope Paul III which first gave the Jesuits official status as an order. Borja strengthened the

already substantial powers of the Jesuit Superior General to be greater than any other Order in

the history of the Catholic Church. While technically monks, the Constitution of the Order was

unique in that it exempted priests from the cloisted rule (i.e. living in monasteries). Instead,

Jesuit monks were to live "in the world". Only the Dominican Priests who were the chief

torturers of the Inquisition and the Catholic Church at the time had anything like such freedoms.

However, the Jesuit Constitution from the very beginning went even further in that it permitted

and even encouraged the priests not to wear the habit (traditional monk dress) so that they would

"blend in" to the world.

        Borja secured a Papal Bull from Pope Paul III in 1545 permitting the Jesuits to preach,

hear confession, dispense the sacraments and say mass without having to refer to a bishop-

effectively placing them outside the control of the regional clergy. In addition, Borja amended

the Constitution of the Jesuit Military Order even further when he bestowed powers to the office

of the Superior General of the Jesuits second only to the Pope. By its own constitution from 1565

(and which remains in force even today), the Superior General can “absolve” priests and new

recruits of all their sins, even the sin of heresy and schism, the falsification of apostolic writings.

Further, the Superior Generals from the time of Borja onwards had the "official" power by Papal

Bull and its by-laws to reverse sentences of excommunication, suspension or interdict and even



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“absolve” Jesuit priests guilty of murder and bigamy. Tthe most stunning victories of Superior

General Borja was in the year he died, when he secured under Pope Gregory XIII in 1572 the

rights of the Jesuits to deal in commerce and banking - a right that had not been granted to any

religious order of the Catholic Church since the Knights Templars four hundred years earlier.

In fact, it is these laws under the Constitution of the Jesuit Order that gave rise to the

uncontrolled power, deceit, greed, and bloody acts undertaken by an unholy, political movement

with an insatiable appetite to control – all under the guise of religion.

       While from its very beginning, the Military Order of Jesuits were architected to be able to

undertake all kinds of dangerous missions from assassination, propaganda, forgery and theft,

their primary mission was and remains today the complete defeat of all forces in opposition to

the authority of the Roman Catholic Pope - specifically the Protestant movement. Of all the

consequences of the Reformation, the most dangerous to the Catholic Church was (and still is)

education. It is why the Jesuits were forced to adopt a counter position in education at such an

early stage. Using their unheralded powers, the Jesuits established a counter education movement

to the Protestants, using their priceless access to the secret Vatican archives, the Jesuits dedicated

themselves to manipulating every major stream of science and philosophy against the Protestant

intellectuals, including subverting their secret societies, such as the Free Masons. The

recruitment and promotion of Education had a secondary benefit for the Jesuits in that it ensured

higher calibre recruits and made their services more attractive across the Catholic world. The

Jesuits quickly became known as the Order dedicated to education excellence in Catholic

countries, a perverse notion considering their original purpose for existence and structure was

military.




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       For the next 200 years the Jesuits repeatedly demonstrated themselves to be a militant

group that did not provide any benefit for the Catholic countries and Catholic people. Notable

among their early economic achievements was the purchase of the port of Nagasaki from a local

Japanese warlord in 1580. The Jesuits promoted heavily the growth of their wholly owned port

of Nagasaki, to one of the most profitable trading ports in the world. Jesuit ownership of the port

of Nagasaki gave the Society a concrete monopoly in taxation over all imported goods coming

into Japan. The Jesuits under Peter Claver S.J. were also instrumental in the development of

the slave trade from Africa to South America to be used in the gold mines. Up to half a

million slaves were shipped into the chains of slavery and suffering under the watch of Peter

Claver S. J. Later, to perpetrate their great deceit, the Jesuits transformed Claver from one

history's worst slave masters to a patron saint of slaves.

       Both Spain and Portugal in particular were angry at the increasing wealth and influence

of the Jesuits encroaching on their profits from the slaves and monopolization of trade. In

response to Portugal’s attempts to limit their trade monopoly, the Jesuits used their exclusive

powers to conduct banking and commerce and formed an alliance with the Dutch in order to

create the Dutch East India Company, which represented one of the most profitable companies of

history thanks to its control of spices, slaves, drugs and plantations. The Jesuits only lost control

in 1773 at the official disbandment of the Order.

       By 1769 political pressure against the Jesuits had grown so strong that Pope Clement XIII

prepared to disband them. In demonstration of his “righteousness”, Jesuit General Lorenzo Ricci

had the pope murdered the night before he was to sign a papal bull disbanding the Jesuit Order.

His successor, Pope Clement IV was himself Jesuit educated and therefore more strategic in his

response to the Jesuit problem. He signed an Order disbanding the Jesuits in July 1773 and



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simultaneously had their churches and properties raided. The Jesuits were taken by surprise, and

Jesuit General Lorenzo Ricci was imprisoned on August 17, 1773. However, even from prison

he managed to have Pope Clement IV assassinated on September 22, 1774. Although the Jesuits

were disbanded by the pope the disbandment order was only valid in countries the promulgated

the order. Russia chose not to promulgate the order, and Jesuits continued to flourish there.

       By 1785 the Jesuits began to plan their revenge against the Catholic Church, pope, and

Catholic countries that had expelled them. Their chance to carry out their revenge shortly

presented itself. In 1785 King of France Louis XVI was bent on reform for the benefit of

France’s poorest citizens. He called an assembly of notables at which he presented his intent to

institute a tax for the first time on the noble family’s of France and the Catholic church in order

to improve the lot of France’s poorest class. Catholic Bishops were outraged and called in the

Jesuits to assist in subverting King Louis XVI’s plan.

       Using their well honed and evil skills, the Jesuits quickly exploited the King's plan to by-

pass the thoroughly corrupt Parliament and began printing false propaganda pamphlets against

the King stating the King was actually working against the common people, because by law one

third (The Third Estate) of French Parliament were elected from the common people. Again

exploiting the reform minded King's desire to see change work, the Jesuits promoted open riots

and a counter movement, falsely claiming it was really the people who wanted change, not the

King. To end the chaos, in 1791, King Louis XVI promulgated a new Constitution in which

France would function as a constitutional monarchy - providing real political freedom and

democracy for the first time for any mainland European nation. Such a principle was completely

contrary to Roman Catholic ideals; therefore, in response, Pope Pius VI (1775-1799) ordered

Holy Roman Emperor Leopold II of Austria to attack his brother in law. Thereafter, the Jesuits



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had their open invitation to commence the French Revolution and by 1792, the Jesuit controlled

Jacobites had captured the King and for the following two years during the Jesuit "reign of

terror" over 40,000 people were executed, mostly without even a trial in one of history’s

bloodiest revolutions.

       Thereafter, Jesuit agent Marquis La Fayette was tasked by the Jesuits to take the vast gold

reserves of France to the United States of America. In New York, the stolen French gold was

placed in the care of the Bank of New York (founded 1784) and the newly formed Bank of the

Manhattan Company (now JP Morgan Chase Bank).

       Back in France, Jesuit agent Antoine Christophe Saliceti had carefully groomed the

career of fellow Corsican Napoleon Bonaparte for several years. In 1795, whilst serving in Paris,

Napoleon succeeded in crushing a rebellion of royalists and counter-revolutionaries and was

promoted by the new regime leader Paul François Jean Nicolas, vicomte de Barras (Paul Barras).

Napoleon was given command of the French Army of Italy in March 1796 and ordered to invade

Italy, specifically to capture the Pope in Rome. At the same time, the Jesuits through Switzerland

formed the private banks Darier Hentsch & Cie and Lombard Odier Darier Hentsch as custodians

for all gold, treasure and contracts seized during the pre-planned campaign against the Vatican

and Roman Catholic Church they were supposedly subject to. Their plans were foiled for a short

time when Pope Pius VI arranged his own peace treaty with Napoleon as Tolentino on February

19, 1797. It took the Jesuits arranging the murder of French brigadier-general Mathurin-Léonard

Duphot in Rome, to get Napoleon to finally complete the task of arresting the Pope and

imprisoning him. Subsequently, the Jesuit agents of Superior General Gabriel Lenkiewicz S.J.

reviewed all the treasury notes of the Vatican as to the various locations of Vatican gold and




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treasure, sending it to Switzerland and Darier Hentsch & Cie Bank. In turn, the bank continued

for a time to fund Napoleon for his continued campaigns of conquest.

       Meanwhile, Pope Pius VI died in August 1799 as a French prisoner, and Cardinal Count

Barnaba Chiaramonti was eventually elected as Pope Pius VII on March 14, 1800. Initially, the

new pope was on acceptable terms with Napoleon, however, by 1808, he was a prisoner of

France, not by Jesuit intrigue but by Napoleon now making his own orders. After the disastrous

Russian campaign had sufficiently weakened the power of Napoleon, Jesuit leader Tadeusz

Brzozowski met with Pope Pius VII at his prison in Jan/Feb 1814 and secured an agreement with

Pope Pius VII to fully restore the Jesuit Order and grant it new lands and rights in Asia upon the

agreement: (1) That the Jesuits would arrange for the safe release of the Pope upon the arrest of

Napoleon (which occurred in April 1814); (2) That the Jesuits would not undertake anymore

actions against any more Popes and restate their pledge of loyalty; (3) That the Pope get back

control of the Papal territories and (4) That some of the funds of the Catholic church controlled

by the Vatican would be returned. Subsequently, the Society was restored to the world by the

Papal letter "Solicitudine Omnium Ecclesiarum" on August 14, 1814.

       Encouraged by their conquests and success at subverting governments to the point of

collapse, since that date, the bloodthirsty and militant Jesuit terrorists have turned their attention

to the United States of America in order to subvert the “unholy” and “heretical” ideals and

practices of the new republic, which was premised on liberty and justice for all and freedom of

religion. Their hidden but most important purpose is to subvert these ideals in order to subdue

the country back into conformance with the edict of Pope Boniface VIII who issued a Papal Bull

Unum Sanctum in 1302 stating: “We declare, say, define, and pronounce that is absolutely

necessary for the salvation of every human creature to be subject to the Roman pontiff.”



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       The preamble to a recent book titled “The Secret Terrorists” states as follows: “The

United States is in more danger today than she has ever been. A secret terrorist

organization has been working within to destroy America, its Constitution, and everything

for which she stands. This book gives all the details, and shows how far this terrorist

organization has been able to progress in the destruction of America.”

       Numerous prominent Americans have known of and spoken out against the Jesuit plot to

subvert the constitutional freedoms of this country for the past 200 years. Yet, the various

individuals here and there who dared to speak the truth of what they saw were helpless to stop

the deceitful, organized, and cancerous infiltration from continuing to occur to the point that

every major system and organization within this country has been successfully infiltrated by

Jesuits. Their words were downplayed by the media at every turn and ultimately dismissed as

unimportant.

       Following are a great number of quotes concerning the organized takeover of this country

by the Jesuit Order. These quotes are by no means exhaustive; it is simply not feasible to include

all of this secret history in a memorandum. Rather, this memorandum merely addresses a

sampling of the total history to demonstrate the facts upon which Debtor’s controversial

statements are based. Any interested reader can review additional information for themselves in

the cited works.

       Subsequent to the political reconciliation between Jesuits and the Vatican, European

sovereigns and the Vatican convened a general council in Vienna, Austria in 1814. This council

has come to be known as the Congress of Vienna. The Congress continued its proceedings for

one year, ending in 1815.

       “The Congress of Vienna was a black conspiracy against Popular Governments at
       which the ‘high contracting parties’ announced at its close that they had formed a


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          ‘holy alliance.’ This was a cloak under which they masked to deceive the people.
          The particular business of the Congress of Verona, it developed, was the
          RATIFICATION of Article Six of the Congress of Vienna, which was in short, a
          promise to prevent or destroy Popular Governments wherever found, and to
          reestablish monarchy where it had been set aside.
                  The ‘high contracting parties’ of this compact, which were Russia,
          Prussia, [Germany], Austria, and Pope Pius VII, king of the Papal States, entered
          into a secret treaty to do so.” — Burke McCarty, The Suppressed Truth About the
          Assassination of Abraham Lincoln, Arya Varta Publishing, 1924, p. 7.

          According to McCarty, the Congress of Vienna formed the Holy Alliance, whose primary

goal was the destruction of all popular governments. Popular governments are those, such as the

United States of America, where the government allows its subjects to enjoy certain inalienable

rights.

          Senator Robert L. Owen placed in the Congressional Record of April 25, 1916 the

following statement, which shows clearly he thought the primary target of the “Holy Alliance”

was the United States.

          “The Holy Alliance having destroyed popular government in Spain, and in Italy,
          had well-laid plans also to destroy popular government in the American Colonies
          which had revolted from Spain and Portugal in Central and South America under
          the influence of the successful example of the United States. It was because of
          this conspiracy against the American Republics by the European monarchies that
          the great English statesman, Canning, called the attention of our government to
          it.” — Ibid. pp. 9, 10. (emphasis added).

Senator Owen understood from the Congress of Vienna that the united monarchies of Europe

would seek to destroy the great American republic and its blood-bought freedoms.

          Senator Owen was not the only prominent citizen of his time to speak out. In 1894, R.W.

Thompson, American Secretary of the Navy, wrote,

          “The sovereigns of the ‘Holy Alliance’ had massed large armies, and soon entered
          into a pledge to devote them to the suppression of all uprisings of the people in
          favor of free government; and he [Pope Pius VII] desired to devote the Jesuits,
          supported by his pontifical power, to the accomplishment of that end. He knew
          how faithfully they would apply themselves to that work, and hence he counseled
          them, in his decree of restoration, to strictly observe the ‘useful advices and


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        salutary counsels’ whereby Loyola had made absolution the cornerstone of the
        society.” — R.W. Thompson, The Footprints of the Jesuits, Hunt and Eaton,
        1894, p. 251.

        The famous inventor of the Morse Code, Samuel B. Morse, also wrote of this sinister plot

against the United States.

        “The author undertakes to show that a conspiracy against the liberties of this
        Republic is now in full action, under the direction of the wily Prince Metternich
        of Austria, who knowing the impossibility of obliterating this troublesome
        example of a great and free nation by force of arms, is attempting to accomplish
        his object through the agency of an army of Jesuits. The array of facts and
        arguments going to prove the existence of such a conspiracy, will astonish any
        man who opens the book with the same incredulity as we did.” — Samuel B.
        Morse, Foreign Conspiracy Against the Liberties of the United States, Crocker
        and Brewster, 1835, Preface.

The array of books written that detail the sinister plots of the Congress of Vienna and the Jesuits

against the American Republic are numerous. That this conspiracy has raged since 1815 is a fact

of history.

        According to the author of The Secret Terrorists, most people know very little about the

Jesuits. The reason for this is that they are a very secretive society.

        “They are Jesuits. This society of men, after exerting their tyranny for upwards of
        two hundred years, at length became so formidable to the world, threatening the
        entire subversion of all social order, that even the Pope, whose devoted subjects
        they are, and must be, by the vow of their society, was compelled to dissolve
        them. [Pope Clement suppressed the Jesuit Order in 1773.] They had not been
        suppressed, however, for fifty years, before the waning influence of Popery and
        Despotism required their useful labors, to resist the light of Democratic liberty,
        and the Pope [Pius VII] simultaneously with the formation of the Holy Alliance,
        [1815] revived the order of the Jesuits in all their power…
                And do Americans need to be told what Jesuits are?… they are a secret
        society, a sort of Masonic order, with super added features of revolting
        odiousness, and a thousand times more dangerous. They are not merely priests, or
        of one religious creed; they are merchants, and lawyers, and editors, and men of
        any profession, having no outward badge by which to be recognized; they are
        about in all your society. They can assume any character, that of angels of light,
        or ministers of darkness, to accomplish their one great end… They are all
        educated men, prepared and sworn to start at any moment, and in any direction,
        and for any service, commanded by the general of their order, bound to no family,


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       community, or country, by the ordinary ties which bind men; and sold for life to
       the cause of the Roman Pontiff.” — J. Wayne Laurens, The Crisis in America: or
       the Enemies of America Unmasked, G. D. Miller, 1855, pp. 265-267.

       Even more telling, “[T]he Vatican condemned the Declaration of Independence as

wickedness and called the Constitution of the United States a Satanic Document.” — Avro

Manhattan, The Dollar and the Vatican, Ozark Book Publishers, 1988, p. 26.

Following is part of the Jesuit Oath:

       “I do further promise and declare, that I will have no opinion or will of my own,
       or any mental reservation whatever, even as a corpse or cadaver, but will
       unhesitatingly obey each and every command that I may receive from my
       superiors in the Militia of the Pope… I furthermore promise and declare that I
       will, when opportunity presents, make and wage relentless war, secretly or
       openly, against all heretics, Protestants and Liberals, as I am directed to do, to
       extirpate and exterminate them from the face of the whole earth; and that I will
       spare neither age, sex or condition; and that I will hang, burn, waste, boil, flay,
       strangle and bury alive these infamous heretics, rip up the stomachs and the
       wombs of their women and crush their infants heads against the walls, in order to
       annihilate forever their execrable race. That when the same cannot be done
       openly, I will secretly use the poisoned cup, the strangulating cord, the steel of the
       poniard or the leaden bullet, regardless of the honor, rank, dignity, or authority of
       the person or persons, whatever may be their condition in life, either public or
       private, as I at any time may be directed so to do by any agent of the Pope or
       Superior of the Brotherhood of the Holy Faith, of the Society of Jesus.” — Edwin
       A. Sherman, The Engineer Corps of Hell; or Rome’s Sapper’s and Miners, Private
       Subscription, 1883, pp. 118-124.

       In a letter from John Adams to then President Thomas Jefferson about the Jesuits we

read, “[S]hall we not have regular swarms of them here, in as many disguises as only a king of

the gypsies can assume, dressed as painters, publishers, writers and schoolmasters? If ever there

was a body of men who merited eternal damnation on earth and in hell it is this Society of

Loyola’s [the Jesuits]. — George Reimer, The New Jesuits, Little, Brown, and Co., 1971, p. 14.

       After becoming disenchanted with Jesuit authority, Napoleon Bonaparte made this

statement:




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       “The Jesuits are a military organization, not a religious order. Their chief is a
       general of an army, not the mere father abbot of a monastery. And the aim of this
       organization is: POWER. Power in its most despotic exercise. Absolute power,
       universal power, power to control the world by the volition of a single man.
       Jesuitism is the most absolute of despotisms; and at the same time the greatest and
       most enormous of abuses…. The general of the Jesuits insists on being master,
       sovereign, over the sovereign. Wherever the Jesuits are admitted they will be
       masters, cost what it may. Their society is by nature dictatorial, and therefore it is
       the irreconcilable enemy of all constituted authority. Every act, every crime,
       however atrocious, is a meritorious work, if committed for the interest of the
       Society of Jesuits, or by the order of the general.” — General Montholon,
       Memorial of the Captivity of Napoleon at St. Helena, pp. 62, 174.

Another telling description follows:

        “There was no disguise they could not assume, and therefore, there was no place
       into which they could not penetrate. They could enter unheard the closet of the
       Monarch, or the Cabinet of the Statesman. They could sit unseen in convocation
       or General Assembly, and mingle unsuspected in the deliberations and debates.
       There was no tongue they could not speak, and no creed they could not profess,
       and thus there was no people among whom they might not sojourn, and no church
       whose membership they might not enter and whose functions they might not
       discharge. They could execrate the Pope with the Lutheran, and swear the Solemn
       League with the Covenantor.” — J. A. Wylie, The History of Protestantism, Vol.
       II, p. 412. (quoted in Sydney Hunter, Is Alberto for Real?, Chick Publications,
       page 13.)

The author of The Secret Terrorists states,

       “[I]n the light of these statements, several questions arise. Since the Jesuits began
       a direct assault on America in 1815 and nothing stands in their way, then are the
       policies carried out today in America under the control of this despot of Rome?
       Have the assassinations of certain presidents, like Abraham Lincoln, William
       McKinley, James Garfield, and William Henry Harrison, been Jesuit inspired?
       Have the atrocities, like Waco, Oklahoma City, and the destruction of the Twin
       Towers in New York City been planned behind the walls of the Vatican? What
       about our precious Constitution and the Bill of Rights that have come under such
       unrelenting attack in the past few decades? Is this the ultimate prize of the Jesuits
       to annihilate our precious freedoms that were purchased at so great a cost?” –
       Pacific Institute, The Secret Terrorists, Chapter 1.

       As if the Congress of Vienna was not clear enough as to the objectives of the European

monarchs and the Jesuit Order, there were two more Congresses that were convened. The first of

these was held at Verona in 1822. The other meeting was held in Chieri, Italy in 1825. These


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three meetings, at Vienna, Verona, and Chieri, were held with as much secrecy as possible.

However, one man attended the first two meetings that would not be silenced. British foreign

minister George Canning contacted the U.S. government to warn them that the monarchs of

Europe were planning to destroy the free institutions of America.

       “It was because of this conspiracy against the American Republics by the
       European monarchies that the great English statesman Canning, called the
       attention of our government to it, and our statesmen then, including Thomas
       Jefferson, who was still living at that time, took an active part to bring about the
       declaration by President Monroe in his next annual message to the Congress of
       the United States that the United States would regard it as an act of hostility to the
       government of the United States and an unfriendly act, if this coalition, or if any
       power of Europe ever undertook to establish upon the American continent any
       control of any American republic, or to acquire any territorial rights.
       This is the so-called Monroe Doctrine. The threat under the secret treaty of
       Verona to suppress popular government in the American republics is the basis of
       the Monroe Doctrine. This secret treaty sets forth clearly the conflict between
       monarchial government and popular government, and the government of the few
       as against the government of the many.” — Burke McCarty, The Suppressed
       Truth About the Assassination of Abraham Lincoln, page 10.
       According to the author of The Secret Terrorists,

       “[T]he Monroe Doctrine was America’s response to the Jesuit’s Congress of
       Vienna and Verona. America would consider it an act of war if any European
       nation sought colonial expansion in the western hemisphere. The Jesuits have
       been able secretly to attack and infiltrate America to accomplish exactly what the
       Monroe Doctrine was stated to protect against. They have been able to get away
       with it because it was done with the utmost secrecy and under the facade of being
       a church.” – Pacific Institute, The Secret Terrorists, Chapter 1.

In a letter to President Monroe, Thomas Jefferson made the following observations:

       “The question presented by the letters you have sent to me, is the most
       momentous which has ever been offered to my contemplation since that of
       Independence. That made us a nation, this sets our compass and points the course
       which we are to steer through the ocean of time opening on us. And never could
       we embark on it under circumstances more auspicious. Our first and fundamental
       maxim should be, never to entangle ourselves in the broils of Europe. Our second,
       never to suffer Europe to intermeddle with cis-Atlantic affairs. America, North
       and South, has a set of interests distinct from those of Europe, and peculiarly her
       own. She should therefore have a system of her own, separate and apart from that
       of Europe. While the last is laboring to become the domicile of despotism, our
       endeavor should surely be, to make our hemisphere that of freedom… [We must


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          be] declaring our protest against the atrocious violations of the rights of nations,
          by the interference of any one in the internal affairs of another, so flagitiously
          begun by Bonaparte, and now continued by the equally lawless Alliance, calling
          itself Holy… We will oppose, with all of our means, the forcible interposition of
          any other power… The question now proposed involves consequences so lasting,
          and effects so decisive of our future destinies, as to rekindle all the interest I have
          heretofore felt on such occasions, and to induce me to the hazard of opinions,
          which will prove only my wish to contribute still my mite towards anything which
          may be useful to our country.” — Archives, Mount Holyoke College.

          Jefferson saw this as a great crisis in America’s young history because the wily and

sinister Jesuits had been ordered to target America’s destruction.

          The Monroe Doctrine challenged any advance on America by Europe. However,

according to the author of The Secret Terrorists,

          “Monroe did not really understand that the crafty Jesuits would not initially use
          the force of arms to gain their objectives. They would use cunning, craftiness, and
          utmost secrecy. They would appeal to men’s basest points. They would plant their
          agents in positions of wealth and power and then use their influence to gain their
          great prize — the subversion and destruction of every Protestant principle as
          outlined in the Constitution of the United States.” – Pacific Institute, The Secret
          Terrorists, Chapter 1.

          These people were traitors and a serious threat to the continued existence of the United

States.

          “A nation can survive its fools, and even the ambitious. But it cannot survive
          treason from within. An enemy at the gates is less formidable, for he is known
          and carries his banners openly against the city. But the traitor moves among those
          within the gates freely, his sly whispers rustling through all the alleys, heard in the
          very halls of government itself. For the traitor appears no traitor; he speaks in the
          accents familiar to his victims, and he wears their face and their garments, and he
          appeals to the baseness that lies deep in the hearts of all men. He rots the soul of a
          nation; he works secretly and unknown in the night to undermine the pillars of a
          city; he infects the body politic so that it can no longer resist.” — Marcus Cicero,
          speaking to Caesar, Crassus, Pompey and the Roman Senate.

          One of those agents was Vice-President to Andrew Jackson, John C. Calhoun who was

the originator and serious proponent of the idea of State’s Rights and secession from the Union.


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Calhoun used the tariff to create friction between the North and the South for the purpose of

dividing and destroying the union. This ultimately lead to Civil War. Many spoke out against his

underhanded methods. Daniel Webster said:

       “Sir, the world will scarcely believe that this whole controversy, and all the
       desperate means which its support requires, has no other foundation than a
       difference of opinion between a majority of the people of South Carolina on the
       one side, and a vast majority of the people of the United States on the other. The
       world will not credit the fact. We who hear and see it can ourselves hardly yet
       believe it.” — John Smith Dye, The Adder’s Den, p. 25.

An ex-Catholic priest, Charles Chiniquy wrote towards the end of the 19th Century,

       “Rome saw at once that the very existence of the United States was a formidable
       menace to her own life. From the very beginning she perfidiously sowed the
       germs of division and hatred between the two great sections of this country and
       succeeded in dividing South from North on the burning question of slavery. That
       division was her golden opportunity to crush one by the other, and reign over the
       bloody ruins of both, a favored, long-standing policy.” — Charles Chiniquy, Fifty
       Years in the Church of Rome, Chick Publications, p. 291, emphasis supplied.

       As stated by the author of The Secret Terrorists, “[C]alhoun was not a loyal

citizen of the United States. He worked to advance the pope’s agenda. He seemed to be

an American, but, was really a Jesuit in the pope’s army in the effort to destroy

America.” – Pacific Institute, The Secret Terrorists, Chapter 2.

Another Roman Catholic Priest Phelan makes this statement.

       “Why, if the government of the United States were at war with the Church, we
       would say tomorrow, ‘To Hell with the government of the United States;’ and if
       the church and all the governments of the world were at war, we would say: ‘To
       Hell with all the governments of the world.’ Why is it the pope has such
       tremendous power? Why the pope is the ruler of the world. All the emperors, all
       the kings, all the princes, all the presidents of the world are as these ALTAR
       BOYS of mine.” — Priest Phelan, Western Watchman, June 27, 1912, emphasis
       supplied.

       Jesuits will go to any means to accomplish their goals. Sinking the Titanic in order to rid

themselves of any powerful opposition to their plans for a Central Bank – the Federal Reserve



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Bank was one such incredible feat. Edward Smith was the captain of the Titanic. He had been

traveling the North Atlantic waters for twenty-six years and was the world’s most experienced

master of the North Atlantic routes. He had worked for Jesuit, J.P. Morgan, for many years. –

Pacific Institute, The Secret Terrorists, Chapter 5.

       According to Pacific Institute, Edward Smith was a ‘Jesuit tempore co-adjator.’ This

means that he was not a priest, but he was a Jesuit of the short robe. Jesuits are not necessarily

priests. Those who are not priests serve the order through their profession. Anyone could be a

Jesuit, and their identity would not be known. Edward Smith served the Jesuit Order in his

profession as a sea captain. – Pacific Institute, The Secret Terrorists, Chapter 5.

       Many interesting points about the Titanic are discussed in a videotape made by National

Geographic in 1986. The videotape is entitled The Secrets of the Titanic. When the Titanic

departed from Southern England on April 10, 1912, Francis Browne, the Jesuit master of Edward

Smith, boarded the Titanic. This man was the most powerful Jesuit in all of Ireland and answered

directly to the general of the Jesuit Order in Rome. The videotape declares:

       “A vacationing priest, Father Francis Browne, caught these poignant snapshots of
       his fellow passengers, most of them on a voyage to eternity. The next day Titanic
       made her last stop off the coast of Queenstown, Ireland. Here tenders brought out
       the last passengers; mostly Irish immigrants headed for new homes in America.
       And here, the lucky Father Browne disembarked.... Father Browne caught Captain
       Smith peering down from Titanic’s bridge, poised on the brink of destiny.” —
       The Secrets of the Titanic, National Geographic, video tape, 1986.

       “Here is Jesuit treachery at its finest. The Provincial [Father Francis Browne]
       boards Titanic, photographs the victims, most assuredly briefs the Captain
       concerning his oath as a Jesuit, and the following morning bids him farewell.” —
       Eric J. Phelps, Vatican Assassins, Halycon Unified Services, p. 427.

       Browne went over with Edward Smith one last time exactly what he was supposed to do

in the North Atlantic waters. The Jesuit General told Francis Browne what was to happen;

Browne then tells Smith and the rest is history. Edward Smith believed that the Jesuit General


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       “. . . is the god of the [Jesuit] society, and nothing but his electric touch can
       galvanize their dead corpses into life and action. Until he speaks, they are like
       serpents coiled up in their wintry graves, lifeless and inactive; but the moment he
       gives the word of command, each member springs instantaneously to his feet,
       leaving unfinished whatsoever may have engaged him, ready to assail
       whomsoever he may require to be assailed, and to strike wheresoever he shall
       direct a blow to be stricken.” — R.W. Thompson, The Footprints of the Jesuits,
       Hunt and Eaton, pp. 72, 73.

       “There is no record in history of an association whose organization has stood for
       three hundred years unchanged and unaltered by all the assaults of men and time,
       and which has exercised such an immense influence over the destinies of
       mankind… ‘The ends justify the means,’ is his favorite maxim; and as his only
       end, as we have shewn, is the order, at its bidding the Jesuit is ready to commit
       any crime whatsoever.” — G. B. Nicolini, The History of the Jesuits, Henry G.
       Bohn, pp. 495, 496, emphasis added.

       “Popes and their Jesuitical agents have been and are the instigators of wars, and
       while the world is having real pain, Rome is having champagne.” — Jeremiah J.
       Crowley (a former Catholic priest), Romanism: A Menace to the Nation, Menace
       Publishing, p. 144.

       “The Pope was just as much in the Second World War as was Hitler and Catholic
       Mussolini and therefore just as guilty of the murder of six million Jews. In fact,
       Popes have been in or instigated most, if not all, the European wars down through
       the centuries.” — F. Paul Peterson, Peter’s Tomb Recently Discovered in
       Jerusalem, p. 63. (Quoted in: Is Alberto for Real, Sidney Hunter, Chick
       Publications, page 41).

       “One may say quite specifically that in 1914, the Roman Church started the series
       of hellish wars. It was then that the tribute of blood which she has always taken
       from the peoples began to swell into a veritable torrent.” — Edmond Paris, The
       Vatican Against Europe, The Wickliffe Press, p. 48.

       Similarly, Adolf Hitler was guilty of all kinds of atrocities during the Second World War.

Was he really responsible for these atrocities, or was he simply carrying out orders? Consider

who was pulling the strings in Hitler’s Germany.

       “In Germany, the Papal Nuncio in Berlin, Mgr. Pacelli and Franz von Papen,
       privy Chamberlain to the Pope, advocated a ‘union with Rome’ and concentrated
       on the overthrow of the Weimar Republic. The German Catholics were hostile to
       Nazism, but were informed that the Pope himself was ‘favourably disposed
       towards Hitler.’ Consequently the Catholic Zentrum, axis of all parliamentary
       majorities, voted full rights to Hitler on January 30, 1933.


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              This operation was promptly followed, as in Italy, by the concluding of a
       Concordat which was most advantageous to the Roman church. The German
       Episcopate swore allegiance to the Fuhrer and Catholic Youth organizations
       combined with those of the Nazis.” — Edmond Paris, The Vatican Against
       Europe, The Wickliffe Press, page 15.

       “The Vatican helped Hitler to gain power and then helped him consolidate his
       grip on Germany. This was done in party by ‘advising’ the Catholic Party of
       Germany to vote for Nazi candidates.
               The Catholic vote gave Hitler the majority he needed to legally form a
       government in 1933. Further to this, the Vatican ordered Catholic members of the
       Reichstag Parliament to support legislation giving Hitler the power to rule by
       decree. This measure gave Hitler the dictatorial power he needed to destroy the
       German Communists.
               The whole Vatican-Hitler bargain had been conducted in secret before
       Hitler became Chancellor of Germany in January 1933. In June of the same year,
       Hitler and the Vatican signed a Concordat, under terms of which the church swore
       allegiance to the Nazi regime....
               Soon afterward, Catholic Franz von Papen, the second in command to
       Hitler, put the essence of the Hitler-Vatican alliance very succinctly in these
       words: “The Third Reich,” he said, “is the first power which not only recognizes,
       but puts into practice, the high principles of the Papacy.” — Avro Manhattan, The
       Vatican Moscow Washington Alliance, Ozark Books, (quoted in Sydney Hunter,
       Is Alberto for Real, Chick Publications, pp. 42, 43)

       Author of The Secret Terrorists writes in Chapter 7, [W]ho supported Hitler in war

ravaged Germany? Remember, Germany had been reduced to rags by World War One and the

heinous Treaty of Versailles.

       “Immense sums belonging to our national-bank depositors have been given to
       Germany on no collateral security whatever... Billions upon billions of our money
       has been pumped into Germany by the Federal Reserve Board and the Federal
       Reserve Banks... On April 27, 1932, the Federal Reserve outfit sent $750,000,
       belonging to American bank depositors, in gold to Germany. A week later,
       another $300,000 in gold was shipped to Germany in the same way. About the
       middle of May $12,000,000 in gold was shipped to Germany by the Federal
       Reserve banks. Almost every week there is a shipment of gold to Germany.” —
       H.S. Kenan, The Federal Reserve Bank, The Noontide Press, 1966, p. 158.

       Predating the creation of the Jesuit Order, another military order of the Roman Catholic

Church existed; it was known as the Knights of the Sedes Sacrorum (SS). They were bestowed

by the legal orders of the Roman Pontiff on behalf of the Mother Church to wage constant Holy


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Inquisition against all heretics, including assassinations, torture and counter-intelligence, to

protect the name of the Holy Roman Catholic Church and directly represent the interests of the

Holy See as its primary order of Holy Knights-- the SS (Sedes Sacrorum or Holy See). As a

spiritual order of the Roman Catholic Church, the SS --were bestowed with the

extraordinary Roman Catholic grace of being forgiven for all their mortal sins (therefore can go

to Heaven) that "unfortunately" must be done in order to observe its temporal orders. In other

words, the troops of the Grand Inquisitor Tomás de Torquemada were the first religious military

order to be granted "immunity" from Hell by the Pope on account of its acts of torture, terror and

evil.

        By the beginning of the 20th Century, there were less than a few hundred SS soldiers still

assigned to the Holy Inquisition. However, upon the appointment of Fr Heinrich Himmler S.J. in

1929 to the NSDAP in Germany, a new Nazi SS (Knights of the Sedes Sacrorum) Army of

several hundred thousand was created by 1939 to wage the single greatest Inquisition ever

undertaken by the Roman Cult-- with over 18 million innocent people burned alive in ovens in

Russia and Poland. (See www.one-evil.org for immense greater facts concerning this matter.)

As set forth in chapter 6 of The Secret Terrorists,

        “[T]he Federal Reserve Bank was a creation of the Jesuits. They use it to finance
        their insane puppets like Adolf Hitler. Kenan states that the Federal Reserve
        financed Hitler and the Nazis. If the Federal Reserve Bank is controlled and run
        by Americans, how could it finance a deadly enemy like Hitler, who stood for
        everything that the Constitution condemns? In light of Kenan’s statement, the
        Federal Reserve Bank is not American; it is our enemy, financing our enemies.
        Thus it makes sense that the Jesuit controlled bank would fund a Jesuit controlled
        puppet like Adolph Hitler.” – Pacific Institute, The Secret Terrorists, Chapter 7.

        “It wasn’t just the three axis powers of Europe, with their Catholic puppets, that
        did Rome’s bidding during World War Two. Franklin Roosevelt, President of the
        United States, also carried out Rome’s wishes.
               [Cardinal] Spellman was offered an unprecedented opportunity by
        Roosevelt that would necessitate leaving his archdiocese for months on end.…


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       The astounding proposal Roosevelt put forth was that Spellman act as a
       clandestine agent for him in the four corners of the world. It would be the
       archbishop’s job to contact chiefs of state in the Middle East, Europe, Asia, and
       Africa. He would carry messages for the President ... and act as Roosevelt’s eyes
       and ears.… The President offered him an opportunity to wield more power than
       any other American religious figure had ever had. Spellman would move as an
       equal among the greatest figures on the world political stage... But few people
       were certain about what the archbishop did during his far-flung travels. His
       clandestine work raised questions at home about the role of a religious figure
       involved deeply in governmental affairs.” — John Cooney, The American Pope,
       Times Books, pp. 124, 125.

       Spellman’s first allegiance was to Pope Pius XII, and yet, he was used by Franklin

Roosevelt as his own personal agent.

       “Roosevelt and Eisenhower approved of the forced repatriation of some six
       million [Orthodox Christian] people back to Russia, many of whom were tortured
       or killed after they reached their destination. Two Russians who have written
       about this abominable decision by these American leaders are Nikolai Tolstoy and
       Alexander Solzhenitsyn. The Americans called this repatriation ‘Operation
       Keelhaul,’ after the naval form of torture where the prisoner is hauled under the
       keel of a ship by a rope tied to the prisoner’s body to be severely cut by the
       barnacles on the bottom of the ship.
                These six million individuals were not only soldiers who had fought on the
       side of the Germans against the Russians, but they were women and children as
       well....
                Even though it was Churchill and Roosevelt who made the incredible
       decision to send millions of anti-Communist Russians back to certain death, it
       was General Dwight Eisenhower who enforced ‘Operation Keelhaul,’ with no
       apparent pangs of conscience.” — Ralph Epperson, The Unseen Hand, Publius
       Press, p. 301.
       Author of The Secret Terrorists writes,

       “[W]hile the Orthodox Christians of Russia were being exterminated by the
       papacy, there was a similar massacre going on in Yugoslavia. Some of the many
       books that have been written about this atrocity of World War Two include
       Convert... or Die! by Edmond Paris, The Vatican’s Holocaust by Avro Manhattan,
       and Ravening Wolves by Monica Farrell. These books all discuss the murder of
       around one million Orthodox Christians during World War Two by the Catholic
       Ustashi. On the cover of Farrell’s book, we read,
                ‘This is the record of torture and murder committed in Europe in 1941-
       1943 by an army of Catholic Actionists known as the Ustashi, led by monks and
       priests, and even participated in by nuns. The victims suffered and died in the
       cause of liberty and freedom of conscience. The least we can do is to read the
       record of their sufferings and keep in mind that it happened, not in the dark ages,


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       but in our own ENLIGHTENED generation. Ustashi is another name for Catholic
       Action.’ — Monica Farrell, Ravening Wolves, Protestant Publications, cover.

       “The mass expulsion or forced conversion of the Orthodox Christians to Roman
       Catholicism was on the agenda. All measures, aiming at the elimination of
       Serbdom in Croatia were carried out under the slogan enunciated by one of the
       Croatian ministers: “We shall massacre the first third of the Serbs, expel the
       second third from the country and force the final third to accept the Catholic faith,
       whereby they will be absorbed by the Catholic element.” — Lazo M. Kostich,
       Holocaust in the Independent State of Croatia, Liberty, p. 18.

       Avro Manhattan was a British journalist who worked for many years for the British

Broadcasting Company. In his book, Vietnam: Why Did We Go?, he tells us,

       “The political and military origin of the war of Vietnam has been described with
       millions of written and spoken words. Yet, nothing has been said about one of the
       most significant forces which contributed to its promotion, namely, the role
       played by religion, which in this case, means the part played by the Catholic
       Church, and by her diplomatic counterpart, the Vatican. Their active participation
       is not mere speculation. It is an historical fact as concrete as the presence of the
       U.S., or the massive guerilla resistance of Asian communism. The activities of the
       last two have been scrutinized by thousands of books, but the former has never
       been assessed, not even in a summarized form. The Catholic Church must be
       considered as a main promoter in the origin, escalation and prosecution of the
       Vietnamese conflict. From the very beginning this religious motivation helped set
       in motion the avalanche that was to cause endless agonies in the Asiatic and
       American continents.
               The price paid was immense: thousands of billions of dollars; the mass
       dislocation of entire populations; political anarchy; military devastation on an
       unprecedented scale; the disgrace upon the civilized world; the loss of thousands
       upon thousands of young Asian and American lives. Last but not least, the
       wounding, mutilation, and death of hundreds of thousands of men, women, and
       children. The tragedy of Vietnam will go down in history as one of the most
       pernicious deeds of the contemporary alliance between politics and organized
       religion.
               Factors of a political, ideological, economic, and military nature played no
       mean role in the unfolding of the war, but the religion of the Catholic Church was
       one of its main instigators. From the beginning her role has been minimized when
       not obliterated altogether. Concrete facts however, cannot be wiped away so
       easily, and it is these which we shall now scrutinize, even if briefly.” — Avro
       Manhattan, Vietnam: Why Did We Go?, Chick Publications, 1984, p. 13,
       emphasis added.

The publisher’s foreword to this book, page 3, states:



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       “Avro Manhattan, world authority on Vatican politics, has blown the cover on the
       real reason our boys suffered and died in Vietnam. He traces their death to the
       Vatican’s passionate desire to make Asia Roman Catholic. Vatican agents hatched
       and plotted the Vietnam War. American soldiers were serving the Vatican in their
       desperate struggle to survive the jungles, the hell of warfare, pain, death and
       destruction. It was all engineered by…her Jesuits.” — Ibid. p. 3, emphasis added.

       To be clear, unsuspecting people, especially Catholics, may take exception to the facts

stated in the previous quotes, but facts must be stated as they are and as they happened. These

facts are not about the faithful church members who know nothing about things like this. It is

speaking of the rulers of the Vatican and their Order of the Jesuits.

       According to Avro Manhattan, the war in Vietnam was fought because the Vatican

wanted to create a power base in Southeast Asia from which to take over all of Southeast Asia

and then all of Asia. The following quotes are from this same book.

       “Ho Chi Minh began before World War Two to maneuver for a communist
       Vietnam. He received help from the U.S. against the Japanese but used that aid to
       consolidate his hold on the highlands of Tonkin. In August, 1945 he marched into
       Hanoi and set up the provisional government of the Democratic Republic of
       Vietnam. A master strategist, he cooperated in the transplanting of nearly a
       million Catholic North Vietnamese into the South…After the election of Pope
       John the 23rd in 1958 and the turn of the Vatican from the Cold War toward
       cooperation with Marxism, Ho Chi Minh made a secret deal with Pope John
       which eventually led to full control of the country by the North. — Vietnam: Why
       Did We Go?, Chick Publications, 1984, p. 177.
                President Ngo Dinh Diem of South Vietnam was a practicing Catholic
       who ruled South Vietnam with an iron fist. He was a genuine believer in the evil
       of Communism and the uniqueness of the Catholic Church. He had originally
       been planted in the presidency by Cardinal Spellman and Pope Pius the 12th. He
       transformed the presidency into a virtual Catholic dictatorship, ruthlessly crushing
       his religious and political opponents. Many Buddhist monks committed suicide by
       fire, burning themselves alive in protest against his religious persecutions. His
       discriminatory persecution of non-Catholics, particularly Buddhists, caused the
       disruption of the government and mass desertions in the army. This eventually led
       to U.S. military intervention in South Vietnam.
                In this terrorization he was aided by his two Catholic brothers, the Chief of
       the Secret Police and the Archbishop of Hue.” — Vietnam: Why Did We Go?,
       Chick Publications, 1984, p. 56, (emphasis added).




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       Cardinal Francis Spellman, the archbishop of New York, was the key man that brought

America into the conflict.

       “He was active in persuading the U.S. to select Diem and support him as president
       of South Vietnam. He was made Vicar General of the U.S. Armed Forces and
       called the GIs the ‘Soldiers of Christ’ [meaning soldiers for the Catholic Church]
       in his frequent visits to the Vietnam war front.” — Vietnam: Why Did We Go?,
       Chick Publications, 1984, p. 71.

Author of The Secret Terrorists writes in Chapter 8,

       “[T]he Vatican played both sides against each other in this Vietnamese Civil War.
       They controlled Diem in the South while advising and making secret deals with
       Ho Chi Minh in the North. Thus, however the war turned out, the Vatican would
       triumph and have control in Vietnam. President Kennedy’s attempt to halt the
       bloodbath incurred the undying wrath of the instigators of the war — the Jesuits
       of the papacy.” – Pacific Institute, The Secret Terrorists, Chapter 8.

       President John F. Kennedy began to de-escalate America’s involvement in Vietnam

shortly before his death. The day after his brutal murder, the following occurred:

       “At 8:30 a.m., Saturday, the 23rd of November, 1963, the limousine carrying CIA
       director John McCone pulled into the White House grounds…. He was also there
       to transact one piece of business prior to becoming involved in all the details
       entailed in a presidential transition — the signing of National Security
       Memorandum 278, a classified document which immediately reversed John
       Kennedy’s decision to de-escalate the war in Vietnam. The effect of
       Memorandum 278 would give the Central Intelligence Agency carte blanche to
       proceed with a full-scale war in the Far East…. In effect, as of November 23,
       1963, the Far East would replace Cuba as the thorn in America’s side. It would
       also create a whole new source of narcotics for the Mafia’s worldwide markets.”
       — Robert Morrow, First Hand Knowledge, Shapolsky Publishers, p. 249.

       As stated in The Secret Terrorists, “[T]he day after Kennedy was killed, the decision to

stop America’s involvement in Vietnam was reversed and the Vatican’s program continued.” –

Pacific Institute, The Secret Terrorists, Chapter 8.

       For a little insight, following is an excerpt from the secret instructions of the Jesuit Order,

written by their founder, Ignatius Loyola.




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       “Finally, let all with such artfulness gain the ascendance over princes, noblemen
       and the magistrates of every place that they may be ready at our beck and call,
       even to sacrifice their nearest relatives and most intimate friends when we say it is
       for our interest and our advantage.” — W. C. Brownlee, Secret Instructions of the
       Jesuits, American and Foreign Christian Union, p. 47.

Avro Manhattan tells us:

       “Cardinal Francis Spellman, of New York , was the military vicar of the
       American Armed Forces in Vietnam. He was also the unofficial link between the
       pope and John Foster Dulles, the U.S. Secretary of State and therefore the
       Secretary’s brother, Alan, who was the head of the CIA.” — Avro Manhattan,
       Murder in the Vatican, Ozark Books, pp. 35, 36.

       “The Catholic Church in the USA, financially can stand up to all the giant trusts
       of America. Politically, she looms ever larger in the White House, in the Senate
       and in the Congress. She is a force in the Pentagon, a secret agent in the FBI and
       the most subtly intangible prime mover of the S.S. wheel within a wheel; the
       Central Intelligence Agency.” — Avro Manhattan, Murder in the Vatican, Ozark
       Books, p. 271.

       Jean Hill was also a witness to the Kennedy murder. In her book, entitled JFK: The Last

Dissenting Witness, she states that during a conversation her friend, J.B., who was one of the

policeman in the motorcade that was with Kennedy, told her,

       “Well, while Kennedy was busy shaking hands with all the well wishers at the
       airport, Johnson’s Secret Service people came over to the motorcycle cops and
       gave us a bunch of instructions. The darnedest thing was they told us the parade
       route through Dealy Plaza was being changed.” “Changed? How,” Jean Hill asks.
       “It was originally supposed to go straight down Main Street.” J.B. said, “but they
       said for us to disregard that. Instead we were told to make the little jog on
       Houston and cut over to Elm.” Jean felt her mouth drop open. “If you’d stayed on
       Main Street, Kennedy might’ve been completely out of range of whoever was
       shooting at him. My ‘shooter’ behind the wooden fence definitely wouldn’t have
       had much chance to hit him from there.” J.B. stared at her with a straight face.
       “Maybe that’s why they changed the route,” he said bluntly. “But that’s not all.
       They also ordered us into the craziest escort formation I’ve ever seen. Ordinarily,
       you bracket the car with four motorcycles, one on each fender. But this time they
       told the four of us assigned to the president’s car there’d be no forward escorts.
       We were to stay well to the back and not let ourselves get ahead of the car’s rear
       wheels under any circumstances. I’d never heard of a formation like that much
       less ridden in one, but they said they wanted to let the crowds have an
       ‘unrestricted view’ of the president. Well, I guess somebody got an unrestricted



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       view of him all right.” — Jean Hill, JFK: The Last Dissenting Witness, Pelican
       Publishing, p. 113.

       Referring to the Council of Foreign Relations and the groups who created the council,

Rear Admiral Chester Ward, a member of the CFR for 16 years, stated: “The most powerful

clique in these elitist groups have one objective in common — they want to bring about the

surrender of the sovereignty of the national independence of the United States.” — Barry

Goldwater, With No Apologies, William Morrow and Company, page 278.

       Similarly, John Swinton, Chief of Staff for the New York Times, who is considered to be

the dean of his profession, made a most bold confession. In 1953, at a New York Press Club, he

declared,

       “There is no such thing, at this date of the world’s history, in America, as an
       independent press. You know it, and I know it. There is not one of you who dares
       to write your honest opinions, and if you did, you know beforehand that it would
       never appear in print. I am paid weekly for keeping my honest opinion out of the
       paper I am connected with. Others of you are paid similar salaries for similar
       things, and any of you who would be so foolish as to write honest opinions would
       be out on the streets looking for another job. If I allowed my honest opinions to
       appear in one issue of my newspaper, before twenty-four hours my occupation
       would be gone. The business of the journalists is to destroy the truth; to lie
       outright; to pervert; to vilify; to fawn at the feet of mammon, and to sell his
       country and his race for his daily bread. You know it, and I know it and what folly
       is this toasting an independent press? We are the tools and vassals of rich men
       behind the scenes. We are the jumping jacks, they pull the strings and we dance.
       Our talents, our possibilities and our lives are all the property of other men. We
       are intellectual prostitutes.” — Multiple contributors, A U.S. Police Action:
       Operation Vampire Killer, The American Citizens and Laumen Association, pp.
       18-19, (emphasis supplied).

       Other telling quotes are as follows: “In 1960, John Kennedy went from Washington to

Texas to assure Protestant preachers that he would not obey the pope. In 2001, George Bush

came from Texas up to Washington to assure a group of Catholic bishops that he would obey the

pope.” — Washington Times, April 16, 2001.




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       “The pope is the ruler of the world. All the emperors, all the kings, all the princes, all the

presidents of the world are as these altar boys of mine.” — Priest D. S. Phelan, Western

Watchman, June 27, 1912

Former priest Charles Chiniquy stated in his autobiography,

       “Long before I was ordained a priest, I knew that my church was the most
       implacable enemy of this republic. My professors… had been unanimous in
       telling me that the principles and laws of the Church of Rome were absolutely
       antagonistic to the principles which are the foundations stones of the Constitution
       of the United States of America.” — Charles Chiniquy, Fifty Years in the Church
       of Rome, Chick Publications, p. 283.

       In Chapter 11, author of The Secret Terrorists writes, “This is alarming information. The

highest echelons in the United States Government, the highest echelons in business and finance,

and the highest echelons in the schools, colleges, and media, are all claiming to be Americans.

They are all claiming to be working for the betterment of America. They are all claiming to be

working for the preservation of the Constitution. In fact, they are under the control of the Jesuits,

the most implacable enemies of this Republic. With a patriotic and religious facade, they are

secretly leading America to ruin.” – Pacific Institute, The Secret Terrorists, Chapter 11

       Also telling are the words of Dr. Koryagina, the economic advisor to Vladimir Putin,

leader of Russia, who was interviewed by a speaker for American Freedom News in July 2001.

In the interview, she discussed secret societies, criminal and religious organizations that are

controlling the world. She also declared that there is a shadow government seeking to bring

down the United States and bring in world government. She warned in Moscow, in July of 2001,




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that the United States would be attacked. She said that when the American people wake up to

what is happening to them, and who did it, they will be in a state of shock.

        “Everybody knows about organized crime and the Mafia. Also people have
        known for a long time about secret societies and so forth. During my research, I
        started to notice that those structures can be put together and can be joined. And I
        realized that right now, we have a criminal monster, a hybrid of organized crime,
        Mafia and secret societies that have merged together.” (aired December 6, 2001),
        – Pacific Institute, The Secret Terrorists, Chapter 11 (A full online copy of this
        book is available for review at www.pacinst.com/terrorists/preamble.html.

        As set forth herein, Debtor’s comments regarding our court system and targeting of

Debtor for harm are unfortunately statements founded in truth.

                                      LEGAL ARGUMENT

   I.      THE TRIAL COURT ABUSED ITS DISCRETION BY ORDERING
           SANCTIONS SUA SPONTE WHERE COUNSEL’S INQUIRY WAS
           REASONABLE UNDER THE CIRCUMSTANCES AND THE AMOUNT IS
           OVERLY EXCESSIVE AND NOT LIMITED TO AN AMOUNT THAT FITS
           THE CONDUCT AT ISSUE FOR THE PURPOSES OF DETERRENCE.

        Under Federal Rule of Civil Procedure 11, every pleading, motion, or paper of a party

represented by an attorney must be signed by the attorney of record. That signature constitutes a

certificate by the signer, that the signer has read the pleading, motion, or paper; that to the best of

the signer's knowledge, information, and belief formed after reasonable inquiry it is well

grounded in fact and is warranted by existing law or a good faith argument for the extension,

modification, or reversal of existing law, and that it is not interposed for any improper purpose,

such as to harass or to cause unnecessary delay or needless increase in the cost of litigation. Fed.

R. Civ. Proc. 11(b); Clark v. United Parcel Service, Inc., 460 F.3d 1004, 1008 (8th Cir. 2006)

Kapco Manufacturing Co. v. C & O Enterprises, Inc., 886 F.2d 1485, 1491 (7th Cir. 1989). Rule

11 additionally provides that, if an attorney presents pleadings to a court for “any improper

purpose, such as to harass or to cause unnecessary delay or needless increase in the cost of


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litigation,” monetary sanctions may be imposed. Fed. R. Civ. Proc. 11(b)(1) & (c); Cooter &

Gell v. Hartmarx Corp., 496 U.S. 384, 405, 110 S.Ct. 2447, 110 L.Ed.2d 359 (1990)

       The standard under Rule 11 is whether the attorney's conduct, "viewed objectively,

manifests either intentional or reckless disregard of the attorney's duties to the court." Clark v.

United Parcel Service, Inc., 460 F.3d at 1009; Perkins v. Spivey, 911 F.2d 22, 36 (8th Cir.1990).

       If awarded, a sanction must be "limited to what is sufficient to deter repetition of such

conduct or comparable conduct by others similarly situated." Fed.R.Civ.P. 11(c)(2); Clark v.

United Parcel Service, Inc., 460 F.3d at 1011. Specifically, Rule 11(c)(2) states that “[a] sanction

imposed for violation of this rule shall be limited to what is sufficient to deter repetition of such

conduct or comparable conduct by others similarly situated. Subject to the limitations in sub-

paragraphs (A) and (B), the sanction may consist of, or include, directives of a nonmonetary

nature, an order to pay a penalty into court . . .” Fed. R. Bankr. Proc. 9011(c)(2), emphasis

added; Kirk Capital Corp. v. Bailey, 16 F.3d 1485, 1488 (8th Cir. 1994).

          Appellate courts in this circuit have strongly suggested that trial courts limit their

sanctions to what “constitutes the least severe sanction that will adequately deter the undesirable

conduct,” Kirk Capital Corp. v. Bailey, 16 F.3d at 1490; Pope v. Federal Express 974 F.2d 982,

984 (8th Cir.1992).

          In the event an award of sanctions is warranted, it should be the least severe amount

that is adequate to serve the purposes of deterrence. Clark v. United Parcel Service, Inc., 460

F.3d at 1009; Perkins v. Spivey, 911 F.2d 22, 36 (8th Cir.1990); see also Divane v. Krull Electric

Co., 200 F.3d 1020, 1030 (7th Cir., 1999). Absent extraordinary circumstances not shown here,

sua sponte sanctions are generally limited to smaller amounts. In Vollmer I, the 7th Circuit

particularly stated that $500-$1,000 was an appropriate amount for sanctions imposed sua sponte



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as was done in this case. Vollmer v. Publishers Clearing House (Vollmer I), 248 F.3d at 709-712.

Similarly, in Burda v. M. Ecker Co., the 7th Circuit Court of Appeals found that although the

district court was well within its discretion in imposing sanctions on the attorney, the imposition

of a $2,500 sanction was excessive and therefore reduced the sua sponte sanction from $2,500 to

$1,000. Burda v. M. Ecker Co., 2 F.3d 769, 776 (7th Cir. 1993) See also, In re Bagdade, 334

F.3d 568, 571-72 (7th Cir.2003) (imposing a $1,000 sua sponte sanction).

       In this case the sanctions are inappropriate because the statements made in the Motion to

Vacate were not interposed for any improper purpose, such as to harass or to cause unnecessary

delay or needless increase in the cost of litigation. Fed. R. Civ. Proc. 11(b) and 11(c); Clark v.

United Parcel Service, Inc., 460 F.3d at 1008; Kapco Manufacturing Co, 886 F.2d at 1491. Upon

information and belief, Debtor believes every statement contained in the pleading is true and

accurate. Moreover, given the uniqueness, of this Debtor’s case, the likelihood of repetition of

the contentious statements the Court has deemed offensive, unsupported by fact, and/or harassing

is not a concern to be reckoned with.

                   RESPONSE TO VARIOUS SUGGESTED SANCTIONS

Payment within ten days of issuance of any sanction order of a $1,000 monetary sanction for
each, separate, and factually unsupported statement:

       First of all, as set forth above herein, each of the above listed statements is not factually

unsupported. Further, a sanction, when taken together with both its monetary and non-monetary

aspects, must be “limited to what is sufficient to deter repetition of such conduct or comparable

conduct by others similarly situated." Fed.R.Civ.P. 11(c)(2); Clark v. United Parcel Service, Inc.,

460 F.3d at 1011. A monetary sanction that alone totals $10,000 is not limited to an amount

sufficient to deter repetition. Quite frankly, this case has been a most difficult one, and I

anticipate that the situation that arose in this case will never repeat itself whether any sanction is


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imposed or not. Therefore, an excessive monetary sanction is unnecessary as well as

unwarranted. Moreover, if this Court were to insist on such an excessive sanction than inquiry

best be made as to the undersigned ability to pay such a sanction and provisions must be made to

allow payment of such a severe sanction over an extended amount of time.

Possible removal, if deemed appropriate by the Chief Judge of the United States District Court
for the District of Minnesota, from the roster of attorneys admitted to practic before the United
States District Court and this court under Loc. R. Bankr. P. (D. Minn.) 9010-3(a).
        As stated previously, a sanction, when taken together with both its monetary and non-

monetary aspects, must be “limited to what is sufficient to deter repetition of such conduct or

comparable conduct by others similarly situated." Fed.R.Civ.P. 11(c)(2); Clark v. United Parcel

Service, Inc., 460 F.3d at 1011. A non-monetary sanction that ultimately restricts counsel’s

ability to continue a livelihood that is uneventful and non-confrontational 99% of the time is not

limited to an amount sufficient to deter repetition. Quite frankly, this case has been a most

difficult one, and I anticipate that the situation that arose in this case will never repeat itself

whether any sanction is imposed or not. Therefore, an excessive monetary or fundamentally

penalizing sanction is unnecessary as well as unwarranted.




Dated this 30th day of December, 2011.               WESTVIEW LAW CENTER, PLC

                                                        /e/ Rebekah M. Nett
                                                     Rebekah M. Nett, 0299571
                                                     1303 South Frontage Road, Suite 1
                                                     Hastings, MN 55033


                                           Verification

       I, Rebekah M. Nett, declare under penalty of perjury that the foregoing is true and correct
according to the best of my knowledge, information and belief.


                                                39
 Case 11-42834    Doc 220    Filed 12/30/11 Entered 12/31/11 00:12:11      Desc Main
                             Document      Page 40 of 42


Executed on: December 30, 2011               Signed: __/e/ Rebekah M. Nett________
                                                     Rebekah M. Nett, 0299571
                                                     1303 South Frontage Road, Suite 1
                                                     Hastings, MN 55033




                                        40
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                                 Document      Page 41 of 42


                        UNITED STATES BANKRUPTCY COURT
                         FOR THE DISTRICT OF MINNESOTA


In Re:                                                      Chapter 11

Yehud-Monosson USA, Inc.
                                                           Case File No.:    11-42834 (NCD)
                      Debtor,


                         UNSWORN CERTIFICATE OF SERVICE

        I, Rebekah M. Nett, do hereby certify that on the 30th day of December, 2011, a true and
correct copy of the Response of Rebekah M. Nett to Order to Show Cause were filed with the
United States Bankruptcy Court on December 30, 2011, thereby generating electronic service
upon the parties indicated below.

CM/ECF:

Jeff C Braegelmann on behalf of Defendant American Bank of St. Paul
jbraegelmann@gislason.com

John E Brandt on behalf of Interested Party William Egan
jbrandt@murnane.com

Roylene A Champeaux on behalf of Interested Party UNITED STATES OF AMERICA IRS
Roylene.Champeaux@usdoj.gov, karen.malikowski@usdoj.gov;
usamn.ecfbankruptcy@usdoj.gov; darcie.boschee@usdoj.gov

Michael S. Dove on behalf of Interested Party American Bank of St. Paul
mdove@gislason.com, KGleisner@gislason.com;JBurgau@gislason.com

Michelle K. Dove on behalf of Trustee Nauni Manty
michelle@mantylaw.com, carisa@mantylaw.com

David Jon Hoiland on behalf of Interested Party Lubrication Technologies, Inc.
Hoilandesq@aol.com, vmailer@e-lawfirm.com

Michael J Iannacone on behalf of Creditor VERMILLION STATE BANK
mji@iannacone.com, miannacone@ecf.epiqsystems.com; knt@iannacone.com;
trustee@iannacone.com

                                                1
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                                Document      Page 42 of 42




Colin Kreuziger on behalf of U.S. Trustee US Trustee
Colin.Kreuziger@usdoj.gov

Nauni Jo Manty
ecf@mantylaw.com, mn12@ecfcbis.com

Manty & Associates PA on behalf of Trustee Nauni Manty
ecf@mantylaw.com

Tyler K Olson on behalf of Interested Party Tiger Peg Capital Corp.
tolson@oppenheimer.com

Randall L. Seaver
rlseaver@fullerseaverramette.com, rseaver@ecf.epiqsystems.com

US Trustee
ustpregion12.mn.ecf@usdoj.gov



Dated this 30th day of December, 2011.             WESTVIEW LAW CENTER, PLC

                                                     /e/ Rebekah M. Nett
                                                   Rebekah M. Nett, 0299571
                                                   1303 South Frontage Road, Suite 1
                                                   Hastings, MN 55033
                                                   Attorney for Debtor




                                               2

				
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