September 24, 2003
Bevill M. Dean, Clerk
Richmond Circuit Court
John Marshall Courts Building
400 North Ninth Street
Richmond, VA 23219
RE: Commonwealth
of Virginia, ex rel., The Concerned Citizen of Petersburg v. The Honorable Leroy R. Hassell, Sr., Chief Justice of the Supreme Court of Virginia
Dear Mr. Dean:
Enclosed
please find a Motion to Quash Demurrer, Plea to the Jurisdiction of the Court
and Motion to Dismiss Petition for Writ of Quo Warranto in the above-styled
matter, which I would appreciate your filing with the Court.
If
you have any questions, please do not hesitate to call me.
September 8, 2003
CERTIFIED MAIL
Honorable James F. D'Alton, Jr.
Petersburg Circuit Court
7 Courthouse Avenue
Petersburg, VA 23803
RE: Attached
Courtesy Copy of Petition for Writ of Quo Warranto
Dear Judge D'Alton:
Please
find enclosed a courtesy copy of my Petition for Writ of Quo Warranto. As you can see from the pleadings and
exhibits, you would likely be a witness in this matter; I thought Your Honor
should be aware of this as you consider recusing yourself in the matter of the
Petition of the Concerned Citizens of Petersburg.
Very truly yours,
September 8, 2003
Honorable Leroy R. Hassell, Sr.
Supreme Court of Virginia
100 North Ninth Street
Richmond, VA 23218-1315
RE: Attached
Courtesy Copy of Petition for Writ of Quo Warranto
Dear Chief Justice Hassell:
Enclosed
please find a courtesy copy of a Petition for Writ of Quo Warranto, which I am
filing with the Circuit Court of Richmond.
Very truly yours,