Carlos A. Alonso Cano, et al. v. 245 C & C, LLC, et al.
AdministrativeLaw SocialSecurity Securities Immigration
Whether the Court of Appeals erred in imposing sanctions without demonstrating frivolous claims and in denying motions to investigate alleged fraud in judicial proceedings
QUESTIONS PRESENTED 1. Whether the CA, erred and violated the Canon 3B (6) of the Code of Conduct of U.S. Judges for not ordering the DC, to investigate the fraud upon the court, that we denounced was committed by Defendants’ attorney Leslie W. Langbein, together with Defendants’ Court Reporter Mr. Elias Martinez, by redacting the transcripts of our depositions and by withholding until today, the Zoon recordings of those depositions that are needed to be compared with the “forged” transcripts that they provided and filed in the DC and in the CA. . 2.— Whether the CA, erred by “conclusory” saying that we filed frivolous motions without demonstrating it, based on what says the 11th Cir. R. 27-4. 3. Whether the CA erred by granting Defendants’ motion for sanctions against us, even when the Defendants neither contradict nor defeat each one of our arguments and evidences, demonstrating that the Defendants and their lawyer, mislead the DC, misrepresented the facts, withheld relevant evidence and committed discovery abuses all of which have affected the outcome of this case. 4. — Whether the CA erred by imposing us to pay Lawyer’s fees to Defendants, using the two cases of Procup v. Strickland, 792 F.2d 1069, 1073-74 (11th Cir. 1986) and Theriault v. Silber, 579 F.2d 302, 303 (5th Cir. 1978), to support its order (Doc. 81, 5/31/24), when these two cases were not decided in the context of the Fair Housing Act. it 5. — Whether, on the contrary, the CA erred by imposing sanctions on us, without demonstrating that the claims we included in our motions are “frivolous, unreasonable, or without foundation,” pursuant the standard established by this court in Christiansburg Garment Co. v. EEOC, 434 U.S. 412, 421 (1978). 6. Whether, the CA erred by imposing us to pay lawyer’s fees as sanction, if recently the U.S. Magistrate Judge LAUREN F. LOUIS of the DC, recommended to deny Defendants’ request for lawyer’s fees. See case No. 19-cv-21826-JAL, (DE 822, 8/30/24), and 7. — Whether this court or the CA, sua sponte, should “severely” sanction Defendants and/or Ms. Leslie W. Langbein, by ordering them to pay up to $500,000.00 or serve up to five years in prison, pursuant to 18 U.S.C. § 152(4) for filing a “FALSE CLAIM FOR ATTORNEY'S FEES” in Carlos’ bankruptcy case (No. 21-19589-LMI) in the Southern District of Florida, because said attorney’s fees that were claimed there, had not been granted at that time either by the order (DE 555, 8/12/22), nor by the orders (DE 678 & 679, 7/20/23), which demonstrates that the Defendants were not entitled to lawyer's fees which “is supported” by the recent “Report and Recommendation of the Magistrate Judge Lauren Lois.” See (DE 822, 8/30/24), (emphasis added).