Noted for 1:30 pm Wednesday, November 30, 2005
STATE OF
) No.
petitioner, )
) MOTION TO MODIFY
v. )
COMMISSIONER’S ORDER
)
Roger William Knight. )
)
respondent. )
____________________________________)
Comes
now, ROGER W. KNIGHT, the respondent, and moves for a modification of the
commissioner’s order entered on
1. RELIEF REQUESTED
Plaintiff respectfully requests a modification of the Order entered on November 10, 2005 eliminating the requirement to seek or maintain employment and bring proof of such employment efforts on the grounds that such an order is declared null and void by the Antipeonage Act, 42 U.S.C. §1994.
2.
STATEMENT OF FACTS
A
true and correct copy of the
Order entered on
3.
STATEMENT OF ISSUES
Should the Order entered on November 10, 2005 be modified to eliminate the requirement to seek or maintain employment and bring proof of such employment efforts on the grounds that such an order is declared null and void by the Antipeonage Act, 42 U.S.C. §1994?
4. EVIDENCE RELIED UPON
Pleadings filed herein.
5.
LEGAL AUTHORITY AND ARGUMENT
The Antipeonage Act of 1867, 42 U.S.C. §1994. It reads:
The holding of any person to service or labor under the system
known as peonage is abolished and forever prohibited in any Territory or State
of the United States; and all acts, laws, resolutions, orders, regulations, or
usages of any Territory or State, which have heretofore established,
maintained, or enforced, or by virtue of which any attempt shall hereafter be made
to establish, maintain, or enforce, directly or indirectly, the voluntary or
involuntary service or labor of any persons as peons, in liquidation of any
debt or obligation, or otherwise, are declared null and void.
Congress is authorized to pass this provision by Section 2 of the Thirteenth Amendment.
6.
CONCLUSION
For the reasons stated herein, this Motion for Revision of Commissioner’s Order should be granted and the Order entered on November 10, 2005 should be modified to eliminate the requirement to seek or maintain employment and bring proof of such employment efforts on the grounds that such an order is declared null and void by the Antipeonge Act, 42 U.S.C. §1994.
7.
PROPOSED ORDER
A copy of the proposed Order will be supplied.
Respectfully submitted,
____________________________________
Roger W. Knight, pro se
If the back button does not take you there, click Home to go to the Index page of this Antipeonage Act Website, click Enemies for the main Enemies page, click Letters for the Letters page, and click Allies for the Allies page. Click 04-2-10673-7 SEA to get to the main page for the Writs Act case. Or you can use the Antipeonage Act Site Map.