R | APPELLANT’S RESPONSE TO APPELLEE'S RULE 38 MOTION

UNITED STATES COURT OF APPEALS
ELEVENTH CIRCUIT
ELIAS MAKERE, FSA, MAAA Appellant/Plaintiff vs. ALLSTATE INSURANCE COMPANY, Appellee/Defendant	) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )	CASE NUMBER 24-11336-JJ Case No (LT): 3:20-cv-00905-MMH-LLL US District Court, Florida, Middle District

APPELLANT’S RESPONSE IN OPPOSITION TO
APPELLEE’S RULE 38 MOTION

Appellant, ELIAS MAKERE, on this 31st day of December 2024, respectfully asks this Court to deny ‘Appellee’s Rule 38 Motion’ (hereinafter “That Motion”) {#32}. A motion ballooned up on demonstrable falsehoods; lies; hypocrisy^1/; and illogical premises.

Key Points:

• Points: Appellee’s guilt; evidentiary support; relevance; • Grounds: US Constitution (1^st, 7^th, 14^th Amendments)

Table of Contents:
Table of Contents:
Context	3^rd Page
Material Facts	3^rd Page
Response	6^th Page
Certificates	22^nd Page
Exhibits	26^th Page
Attachments	33^rd Page

----

ascending from below [on state-sponsored hot-air], Defendant has blown more smoke onto a higher-court proceeding.^1/

yet, as defendant’s falsehoods [further] descend upon this court, it/they will only further the judiciary’s descent.

so, may this court reject Defendant's latest perjury-clad motion before Defendant floats/moves any further.

----

Background:	Facts prove Appellee’s guilt
Problem:	Appellee seeks further obstruction of Appellant’s rights
Request:	Court denies Appellee’s latest perversions1/

Rule 38 | Fed. R. App. P. | Frivolous Appeal – Damages...

“If a court of appeals determines that an appeal is frivolous, it may, after a separately filed motion or notice from the court and reasonable opportunity to respond, award just damages and single or double costs to the appellee.”

1^st Amendment | US Constitution | Access to the Courts

“[the people have the right] to petition the Government for a redress of grievances.”

7^th Amendment | US Constitution | Trial-by-Jury

“In Suits at common law, where the value in controversy shall exceed twenty dollars, the right of trial by jury shall be preserved, and no fact tried by a jury, shall be otherwise reexamined in any Court of the United States, than according to the rules of the common law.”

14^th Amendment | US Constitution | Equal Protections, Due Process

“No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.”

Abbreviations

[A###]	Page ### from Appellant’s Appendix on Appeal
[AB##]	Page ## from Appellee’s Answer Brief
[M###]	Paragraph ### from ‘That Motion’
FCHR	Florida Commission on Human Relations
FS	Florida Statute
LT	Lower Tribunal
USFLMD	US District Court, Florida, Middle District

MATERIAL FACTS

1. Government records prove that That Motion is wrong about material facts.

2. The most significant of which, perhaps, is the number of actions that Appellant has initiated against Appellee:

APPELLEE’S CLAIM	REALITY
21	2

a. On Page 3 of That Motion, Appellee claimed that Appellant has filed 21 causes of action against Appellee.

b. Appellee’s claim, of course, is false.

c. Appellant has filed 2; as follows:

#	FCHR Case Number	Filing Date	Caption
1	2017-01432	6/30/2017	Makere v Allstate
2	2019-19238	4/10/2019	Makere v Allstate

Moreover, these are the only two cases which Appellee attacks [in its Answer Brief].

i. Appellee does so by calling Appellant’s First Charge the “2017 Charge” [AB04]-[AB07].

ii. Appellee [also] does so by calling Appellant’s Second Charge the “2019 Charge” [AB07]-[AB09].

d. This falsehood/fact was fundamental to That Motion. Thus, it renders the entire motion moot; leaving Appellee nothing to stand on (Rule 27-4 11th Cir. R.).

3. Notwithstanding, That Motion is still wrong about another material fact: the State of Florida does [indeed] conspire to obstruct charges of employment discrimination. In fact, the State of Florida – via its longstanding FCHR Executive Director - has admitted this [itself] (highlights added):

“On 07/03/20, [FCHR Commissioner Jay Pichard] specifically asked [FCHR Director Michelle Wilson] for “flexibility” to “save businesses.” By this [the FCHR Commissioner] meant dismissing employment discrimination charges at intake, without investigation, issuing a “no cause” finding so charging parties could not go to court.”

a. In That Motion, Appellee claimed the opposite, however. Thereby stating that the State of Florida’s [alleged/well-pled] obstructions were a “far-fetched” government conspiracy (highlights added):

“[Appellant’s] Third Amended complaint because the administrative proceedings were unfair, which is based on a far-fetched government conspiracy.”

“a claim of post-termination retaliation based on Section 1981, Title VII, or the FCRA as such claims are premised on far-fetched conspiracies without evidentiary support.”

b. Appellee, notably, made this “far-fetched” statement twelve (12) times (ie, often/religiously).

c. Appellee’s claim, of course, is false. The FCHR (whose obstructions Appellee has benefited from) admitted to the FCHR’s unlawful conspiracies (¶3a supra).

[Exhibit A] [Exhibit B]

d. Moreover, Appellee knew that its claim was false. Appellee discovered the claim’s falsehood prior to filing That Motion – as Appellant shared the pertinent public records [with Appellee]. [Attachment A]

4. Thus, Appellee was lying. In other words, That Motion is frivolous (Baker v Alderman, 158 F.3d 516 (11th Cir. 1998)).

Segue

5. Nevertheless – and although these two material facts are enough to end this discussion (please see Catrett v. Johns-Manville, 756 F.2d 181 (DC Cir. 1985)) – a longer response will show how Appellee is [indeed] guilty of the underlying discrimination. Thereby serving as the [metaphorical] flight data recorder for the hot-air balloon which Appellee floated That Motion on.

RESPONSE

6. Despite not attacking the merits of Appellant’s case, That Motion did begin by tiptoeing onto the undisputed facts. Thus, a mild dive into the undisputed facts (and procedural history) will accomplish three things. It will reveal that:

a. That Motion is debunked by the record;

b. Appellee is guilty of the underlying action (ie, discrimination); and

c. The FCHR has [indeed] obstructed Appellee’s case in order to cover for Appellee.

I. Statement of Undisputed Fact

7. On November 18, 2013, Appellant began working for Appellee. [A0027]

8. Appellee admitted Appellant into Appellee’s Actuarial Career Program (“ACP”) alongside many of his newfound co-workers. The ACP’s goal was to develop its members into FSAs (Fellows of the Society of Actuaries). [A0027]

9. At the time of hiring, Appellant had already passed six (6) actuarial exams, and had a little over one year of experience. This meant that he would have to pass four (4) more exams to attain the desired credential. [A0027]

10. Throughout Appellant’s 3-year tenure, Appellee subjected him to a hostile work environment. With harassment that included – but was not limited to:

a. Unwanted date requests from his direct manager [A0028]-[A0029];

b. Racist dolls [A0033]; racist characterizations [A0033]-[A0034]; and

c. Cursing at Appellant for buying a condolence card. [A0025]

11. Appellee also conditioned Appellant’s employment on racial inferiority. Highlights included – but were not limited to:

a. Paying Appellant a lower ASA salary than it paid other similarly-situated employees [A0033];

b. Proclaiming that Appellant’s newly acquired actuarial credentials (ASA) “devalue[d] the profession” [A0028].

12. Recognizing Appellee’s animus, Appellant begged management to let him work from home [A0035]; doing so on a routine basis. A request that Appellee always denied.

a. A work privilege, however, that Appellee granted to everyone else in its actuarial department. Everyone else, of course, was of a different demographic. [A0035]-[A0036]

13. Yet every time Appellant tried to avoid the hostilities, Appellee targeted him for more.

a. In Fall 2015, an IT manager phoned Appellant, told Appellant a series of lies, then explained how he would get Appellant fired. That same IT manager carried out the plan. [A0036]-[A0037]

i. That same IT manager, importantly, had been charged with employment discrimination before. [A0037],[A0084]

b. Also, in Fall 2015, Appellant’s direct manager relayed a message from a different IT manager. A different IT manager who wanted Appellant fired. Appellant’s direct manager also relayed that the ‘different IT manager’ never gave a reason for the adverse desires. [A0037]

14. Given these facts & circumstances, Appellant filed an internal discrimination complaint. The primary subject of the complaint (¶13a) acknowledged that it was based on “racism”.

15. Thereafter, Appellee worsened the work environment for Appellant. With acts that included – but were not limited to:

a. job replacement [A0038];

b. denied raises [A0038];

c. sabotaged work [A0038]; and

d. Appellee forcing Appellant to pay [$1,025] for an actuarial exam fee - while never forcing its other employees to do the same. [A0039]

16. Appellee met Appellant’s additional internal complaints with indignation. Telling Appellant to “figure out if this [was] the place for [him] to work”. [A0038]

17. Soon thereafter – on Friday, August 12, 2016 – Appellee told Appellant that it was terminating his employment; effective immediately. [A0039]

a. Notably, Appellant’s direct manager made the decision just hours after Appellant declined her last date request (doing so on 8/10/16).

18. Appellee’s reason for firing Appellant was that Appellant had failed an actuarial exam. It gave no other reason. [A0041]

19. Yet, Appellee had many other employees who also failed actuarial exams. Some who failed multiple exams; all who failed easier exams. Discriminatorily, though, Appellee never fired any of them. [A0041]

20. Plus, immediately after firing Appellant, Appellee replaced him with two employees who had never even passed one exam. The disparity in qualifications is/was drastic (0 exams passed vs 8 exams passed). [A0041]

21. Right after termination, Appellant passed the exam-in-question, and continued to avoid Appellee (and its employees). [A0042]

a. From 8/12/16 until now: Appellant has never done any work for Appellee; never tried; and never inquired. [A0042]

22. He did, however, attempt to seek justice & repair from the harassment/discrimination/retaliation that Appellee subjected him to. As well as punishment for the unlawful conduct Appellee has subjected – and will subject – others to (see ¶13ai).

II. External Discrimination Complaint #1 (Makere v Allstate)

23. On June 30, 2017, Appellant filed an employment discrimination complaint with the FCHR (“First Charge”). Pursuant to §760.11(1) FS, he alleged that Appellee had violated his rights on the bases of race and sex. [A0094]

24. On September 8, 2017, Appellee denied both allegations. Specifically, because he had failed an actuarial exam (highlights added):

“[Appellant] was terminated solely because he failed his [FSA] exam.”

It bears repeating: Appellee explicitly acknowledged that Appellant’s First Charge contained “allegations of discrimination based upon race and sex discrimination” (emphasis added). [A0096]

25. On December 15, 2017, the FCHR concluded its investigation. Notably affirming that race and sex were the bases of Appellant’s First Charge. [A0105]

26. On January 19, 2018, Appellant filed his Petition for Relief with the FCHR. Just as in his original charge, he listed only race and sex as the protected characteristics for his complaint. Thus, pursuant to §760.11(7) FS and §120.569 FS, the FCHR transmitted it to DOAH.

27. During the pendency of that administrative action, Appellee amplified its retaliation [against Appellant]. Thereby enlisting its employees (and others) to dissuade Appellant from continuing with his lawsuit. It did so in a variety of ways:

a. via death threats [A0051];

b. via smear campaigns [A0046]-[A0050]; and

c. via lethal attacks [A0052].

28. The evidence (which pointed to Appellee’s guilt), however, was too strong. So, Appellant continued. Reason: Appellee’s unlawful conduct presented a textbook case of employment discrimination.

29. A textbook case which, unfortunately, ran counter to widespread anti-black-male propaganda (as foretold by the Ku Klux Klan – and its progenies). Faced with these probative facts, several state officials went on the attack.

30. So – after a series of procedural irregularities (authority breaches, deposition sit-ins, recusals, etc.) – a man named Edward Gary Early became the administrative hearing officer over the case (circa November 13, 2018). [A0054]

31. That man – in his quest to cover for Appellee – further violated Appellant’s constitutional rights. He did so by (a) hiding evidence; and (b) committing perjury. [A0196]-[A0225]

32. Due to these attacks, Appellant sought subsequent relief. First: against Appellee (¶34-37, infra); and second: against the state hearing officer (¶42-44 infra).

III. External Discrimination Complaint #2 (Makere v Allstate)

33. With the attacks abounding (¶27 supra), Appellant sought to amend his First Charge. Thwarted by state officials, though, he had to file anew.

34. Thus, on April 10, 2019 – and due to Appellee’s continued retaliation – Appellant sent the FCHR his second discrimination complaint (“Second Charge”). [A0091]-[A0092]

35. This Second Charge – which was dual-filed with the EEOC – included Appellee’s post-termination retaliation (¶27, supra).

36. Those state officials, though, used the color of law to unleash more state-sponsored treachery [on Appellant]. Treachery that included – but was not limited to:

a. ALJ Edward Gary Early committing perjury;

i. He did so by [falsely] claiming that Appellant’s First Charge did not include a sex discrimination basis. [A0196]-[A0225]

b. ALJ Edward Gary Early hiding evidence;

i. He did so by removing a crucial transcript page (which proved Appellee’s prima facie guilt – in clear & convincing fashion). [A0196]-[A0225]

c. FCHR Staff Attorney Stanley George Gorsica ratifying perjury;

d. FCHR-SA Gorsica filing a null & void determination;

e. FCHR-SA Gorsica mailing that null & void determination to an erroneous person; [A0112]-[A0130] and

f. FCHR-SA Gorsica refusing to relinquish jurisdiction.

i. Thereby forcing Appellant to seek a Writ of Prohibition (among other things).

37. Nevertheless, October 7, 2019 marked the deadline for the FCHR’s determination, but the state agency failed to produce one (at least not on time). [A0112]-[A0130]

a. Instead, the FCHR issued a [null & void] phantom notice (on October 18, 2019). [A0112]-[A0130]. A null & void phantom notice that was [also] untimely, of course.

IV. Background | Judicial History

38. Despite the inequities, Appellant filed this lawsuit in federal court. Doing so on August 12, 2020. Doing so, importantly, under both federal (42 USC §1981) and state law (§760 FS).

a. Unfortunately, Appellant’s initial complaint did not include his Title VII charges [A0019]. Later – and once the inequities began diminishing – he attached them (circa March 9, 2021). [A0112]-[A0130]

b. Importantly, the Title VII counts and the state counts were hydrated by Appellant’s Second Charge (¶34-37, supra).

39. On February 8, 2021, the LT entered its partial order of dismissal (“Improvident Order”) [A0131]. Therein, the lower court dismissed Appellant’s state counts (ie, §760 FS), because of administrative timeliness (highlights added):

“In sum, the record establishes that the FCHR rendered timely “No Cause” determinations on [Appellant’s state] charges... As such, [Appellant] is administratively barred under section 760.11(7) of the Florida Statutes from pursuing his [state] claims here. The Court will [dismiss] Counts I-III of the Complaint and dismiss the [state] claims in their entirety.”

40. The next day (ie, February 9, 2021), Appellant asked the LT to take judicial notice of Appellant’s [officially] time-stamped charge of discrimination (¶33 supra).

41. Plus, two weeks later, Appellant filed his objections [A0169] (and appealed). He also amended his complaint. An amendment that Appellee met with another motion to dismiss.

a. Appellee’s subsequent motion featured a crucial lie.

b. A crucial lie, importantly, that was the same one promulgated by Mr. Early (¶30, 36; infra).

c. A crucial lie that Appellant met with:

i. a motion for sanctions [A0184]; and

ii. a motion in limine [A0196].

42. Then, on October 13, 2021, the LT ordered Appellant to amend his complaint once more. Therein, the LT instructed Appellant to include all of his claims (highlights added):

“[Appellant] therefore should include all claims and factual allegations he wishes for the Court to consider in his Third Amended Complaint.”

Appellant obliged [A0020], and added a charge for Appellee’s fraud-on-the-court (¶41a supra).

43. On November 4, 2021, Appellant filed his fully amended complaint (“The Complaint”). It included – but was not limited to – counts under: (a) the FCRA; and (b) Title VII. Appellant, importantly, invoked both statutes to redress all of Appellee’s misconduct (ie, from 2013 onward). [A0020]

44. On October 13, 2022 the lower court overruled Appellant’s objections (¶36); thereby crystallizing the falsehood [on administrative timeliness] (¶39 supra, compare ¶46 infra).

45. Months later – on June 21, 2023 – the LT dismissed several counts from The Complaint (“Premeditated Order”). Thereby keeping Appellant’s Title VII counts – for the limited purpose of examining timeliness (highlights added):

“Nevertheless, in light of the foregoing and given the particular circumstances of this case, the Court finds it appropriate to bifurcate the proceedings. The Court will allow the parties to proceed with limited discovery only as relevant to the statute of limitations, exhaustion, and collateral estoppel issues, and will set a deadline for the filing of a dispositive motion, if appropriate, on those issues. All other discovery in this action will remain stayed pending further order of the Court.”

46. Nine months later – on March 26, 2024 – the LT granted Appellant’s [2/9/21] motion for judicial notice [of the correct filing date] (¶36 supra) (highlights added):

“These filings all concern Makere’s ongoing contention that he filed the 2019 FCHR Charge on April 10, 2019, and not on April 26, 2019, as the Court stated in the [Improvident Order].”

“In support, Makere submits an email he sent to the FCHR on that date requesting an investigation into his “employment discrimination complaint against Allstate Insurance Company.” See Motion for Judicial Notice at 3, Ex. A. Makere contends that he included with that email an EEOC Charge Form and a “Complaint Attachment.” See id. at 3. He submits a copy of the “Complaint Attachment,” which bears an FCHR time stamp of April 10, 2019. Id., Ex. B, part 1 at 1.”

“In light of the foregoing, the Court will grant Makere’s Request for Judicial Notice and Motion for Clarification to the extent he asks the Court to consider his evidence of an April 10, 2019 filing date.”

47. However, within that same [3/26/24] order, the LT also incorporated the Improvident Order (in its entirety). The Improvident Order, confoundingly, was entirely based on the wrong filing date (highlights added):

“In the [Improvident Order], the [LT] set forth at length the factual allegations giving rise to this lawsuit as well as the convoluted procedural history of this case and the prior administrative proceedings. See [Improvident Order] at 5-14; 2023 Order at 3-14. The Court provides a brief overview below but will otherwise presume the reader’s familiarity with those Orders and adopt their defined terms.”

48. Plus, within that same [3/26/24] order, the LT also entered summary judgment in favor of Appellee (“Final Order”); doing so on the basis of administrative timeliness. A decision which claimed that the [correct] filing date no longer mattered (contrast with ¶39-40, ¶45-46 supra) (highlights added):

“[Appellant] failed to timely exhaust his administrative remedies and the Title VII claims remaining in this case are not actionable.

⁸ [Appellant]’s 2019 Charge also included acts of post-termination retaliation. However, as noted above, the Court previously dismissed [Appellant]’s Title VII claims premised on those acts. See 2023 Order at 19-28, 31 n.15. Thus, the [LT] need not determine whether [Appellant]’s 2019 Charge was timely filed as to those discrete acts.

⁹ As discussed in the 2021 Order, [Appellant] previously filed a charge with the FCHR in 2017. See 2021 Order at 8. ... As such, the Court does not consider the 2017 FCHR Charge in this analysis.”

V. Procedural Summary

49. Put simply, the Lower Tribunal [improvidently] ruled that Appellant’s [state + federal] counts were untimely (¶39). Then, it ruled that the [materially] correct filing date no longer mattered (¶48).

a. It must be noted that the LT consumed 3+ years to [even] acknowledge the correct filing date (¶46).

b. Moreover, it must be noted that this cause-of-action involves a textbook case of discrimination (¶28).

50. Many procedural hiccups and state-engineered hurdles arose along the way.

a. Yet, the core facts [of the case] have remained in Appellant’s favor (¶7-32, supra). And they have remained as untarnished (and clear to see) as ever.

VI. Legal Application

51. As such, this Court is well-positioned to deny That Motion.

a. For one, That Motion was based on two material falsehoods (¶1-5 supra);

b. Secondly, Appellee is guilty of the underlying legal action;

c. Third, Appellant is entitled to damages; and

d. Fourth, That Motion has failed to [even] allege – let alone prove – that Appellant’s appeal has involved sanctionable conduct.

52. As this Court has held, sanctionable conduct involves dishonesty (Massengale v Ray, 267 F.3d 1298 (11th Cir. 2001)).

53. Plus, sanctions are designed to preserve the sanctity of the judiciary – while preventing delay (Donaldson v. Clark, 819 F.2d 1551, 1557 (11th Cir. 1987)).

54. In the instant action, Appellant has not engaged in any dishonesty. Nor has he engaged in any delay.

a. In fact, That Motion does not [even] allege any dishonesty [from Appellant] (nor use the word).

b. Nor does That Motion allege any delay [from Appellant] (nor use the word).

55. As the record shows, however, it has been Appellee (ie, Defendant Allstate Insurance Company) who has [hypocritically] engaged in dishonesty.

56. Plus – as the record shows – it has been Appellee who has [hypocritically] engaged in delay.

REQUEST FOR A FULL & FAIR HEARING

Moreover, Appellant requests that the parties be afforded a prompt, full and fair hearing on That Motion. Whereby: (i) Appellee can explain why it used [known] material falsehoods when Appellee drafted That Motion; and (ii) Appellant can address any ad hoc (and/or ad hominem and/or immaterial) attacks that any case participant floats forth.

CONCLUSION

WHEREFORE, Appellant respectfully asks this Court to deny Appellee’s Rule 38 Motion for Sanctions; because it was based on falsehoods; lies; false premises; and hypocrisy.

Dated this 31st day of December 2024.

Respectfully submitted,

/s/ Elias Makere
Elias Makere, FSA, MAAA
Plaintiff
PO Box 324
Hobart, IN 46342
P: 904.294.0026
E: Justice.Actuarial@gmail.com
W: TextBookDiscrimination.com
Get Booked Up on Justice!

Endnotes:

^1/ public records show that Appellee (ie, Allstate Insurance Company) has been sanctioned many times – by many tribunals. These sanctions come from cases which include – but are not limited to:

1. Allstate v. Scroghan, 851 N.E.2d 317

2. Allstate v. Sunbeam, 53 F.3d 804

3. Allstate v. Fougere, 22-1258 (1st Circuit Court of Appeals – US)

Link to Underlying Complaint (HTML, PDF, Video)

HTML	TextBookDiscrimination.com/Allstate/Complaint-Full
PDF	TextBookDiscrimination.com/Files/USFLMD/20000905_AAC_20211104_230439.pdf
VIDEO	https://youtu.be/e3mgBPHesXg

Electronic Copy: (text-searchable)

TextBookDiscrimination.com/Files/CA11/24011336_GMOT_20241231_164511.pdf
TextBookDiscrimination.com/Allstate/ResponseRule38

CERTIFICATE OF COMPLIANCE

1. Type-Volume

☒	This document complies with the word limit of Rule 27(d)(2)(A) Fed. R. App. P., because - excluding the parts of the document exempted by Rule 32(f) - this document contains 3,491 words.

or

☐	This brief complies with the line limit prescribed by Rule 32(a)(7)(B)(i) Fed. R. App. P., because – excluding the parts of the document exempted by Rule 32(f) – this document contains [NNNN] lines of monospaced text.

2. Typeface and Type-Style

☒	This document uses Courier New (12-Pt) Font; thereby complying with the typeface requirements of Rule 32(a)(5)(B) Fed. R. App. P.. This document also satisfies the type-style requirements of Rule 32(a)(6).

12/31/2024	/s/ Elias Makere
Date	Elias Makere, FSA, MAAA

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 31^st day of December 2024, I electronically filed the foregoing with the Clerk of Courts by using PACER; which will send a notice of electronic filing to the [attached] service list.

/s/ Elias Makere

SERVICE LIST

Kimberly J. Doud, Esquire (0523771)
Lauren C. Robertson, Esquire (1024845)

E: kdoud@littler.com
E: lcrobertson@littler.com
P: 407.393.2900
F: 407.393.2929

Littler Mendleson, PC
111 North Orange Avenue, Suite 1750
Orlando, FL 32801-2366

(defendant’s trial lawyers)

CIP

United States Court of Appeals
Eleventh Circuit

24-11336-JJ
Makere v Allstate

{unchanged}

UNITED STATES COURT OF APPEALS
ELEVENTH CIRCUIT

Makere v Allstate, 24-11336-J

CERTIFICATE OF INTERESTED PERSONS
AND CORPORATE DISCLOSURE STATEMENT

Lower Tribunal:
Lambert, Laura	Magistrate
Howard, Marcia	District Judge

Parties:
Allstate Insurance Company (NYSE: ALL)	Appellee
Makere, Elias (FSA, MAAA)	Appellant

Appellant is not a subsidiary/affiliate of a publicly owned corporation. Pursuant to Rule 26.1-2 11th Cir. R., Appellant does not know of any other entities that have interest in this case. Appellant hereby certifies that this CIP is complete.

EXHIBITS

ATTACHMENTS

Congratulations! You're now Booked Up on the Plaintiff's/Appellant's Response to Defendant's Rule 38 Motion that a Floridian filed in this textbook case of employment discrimination (against Allstate Insurance Company).

Reading it might help you recover from the damages that lawbreaking organizations/judges/lawyers/agencies have inflicted upon you [and/or the public] (see this example of a Florida judge who outright committed perjury).

Also, please beware that the FCHR (ie, the state agency incriminated in this lawsuit) has corrupted itself. Thereby doing so in the following ways (among others):

FCHR Bribery

FCHR Corruption

FCHR Obstruction

FCHR Self-Discrimination

Nevertheless – and as always – please get the justice you deserve.

Sincerely,

www.TextBookDiscrimination.com

	Download
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	A Judge's Perjury
	A Judge's Perjury
	Audio: Drop the Steal
	Breakdown: Drop the Steal
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R | APPELLANT’S RESPONSE TO APPELLEE'S RULE 38 MOTION

APPELLANT’S RESPONSE IN OPPOSITION TO
APPELLEE’S RULE 38 MOTION

MATERIAL FACTS

Segue

RESPONSE

I. Statement of Undisputed Fact

II. External Discrimination Complaint #1 (Makere v Allstate)

III. External Discrimination Complaint #2 (Makere v Allstate)

IV. Background | Judicial History

V. Procedural Summary

VI. Legal Application

REQUEST FOR A FULL & FAIR HEARING

CONCLUSION

Endnotes:

Link to Underlying Complaint (HTML, PDF, Video)

CERTIFICATE OF COMPLIANCE

1. Type-Volume

or

2. Typeface and Type-Style

CERTIFICATE OF SERVICE

SERVICE LIST

CIP

United States Court of Appeals
Eleventh Circuit

24-11336-JJ
Makere v Allstate

{unchanged}

UNITED STATES COURT OF APPEALS
ELEVENTH CIRCUIT

Makere v Allstate, 24-11336-J

CERTIFICATE OF INTERESTED PERSONS
AND CORPORATE DISCLOSURE STATEMENT

EXHIBITS

ATTACHMENTS

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R | APPELLANT’S RESPONSE TO APPELLEE'S RULE 38 MOTION

APPELLANT’S RESPONSE IN OPPOSITION TOAPPELLEE’S RULE 38 MOTION

MATERIAL FACTS

Segue

RESPONSE

I. Statement of Undisputed Fact

II. External Discrimination Complaint #1 (Makere v Allstate)

III. External Discrimination Complaint #2 (Makere v Allstate)

IV. Background | Judicial History

V. Procedural Summary

VI. Legal Application

REQUEST FOR A FULL & FAIR HEARING

CONCLUSION

Endnotes:

Link to Underlying Complaint (HTML, PDF, Video)

CERTIFICATE OF COMPLIANCE

1. Type-Volume

or

2. Typeface and Type-Style

CERTIFICATE OF SERVICE

SERVICE LIST

CIP United States Court of Appeals Eleventh Circuit 24-11336-JJ Makere v Allstate {unchanged}

UNITED STATES COURT OF APPEALSELEVENTH CIRCUIT Makere v Allstate, 24-11336-J

CERTIFICATE OF INTERESTED PERSONSAND CORPORATE DISCLOSURE STATEMENT

EXHIBITS

ATTACHMENTS

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APPELLANT’S RESPONSE IN OPPOSITION TO
APPELLEE’S RULE 38 MOTION

CIP

United States Court of Appeals
Eleventh Circuit

24-11336-JJ
Makere v Allstate

{unchanged}

UNITED STATES COURT OF APPEALS
ELEVENTH CIRCUIT

Makere v Allstate, 24-11336-J

CERTIFICATE OF INTERESTED PERSONS
AND CORPORATE DISCLOSURE STATEMENT

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