February 11, 2020, at 1420 hrs. in lieu of filing a Reply Brief:

            GOOD AFTERNOON. I REQUEST PERMISSION FOR MY COURT REPORTER (IT WAS GRANTED).

            MAY IT PLEASE THE COURT. 

            I AM ISIDORO RODRIGUEZ.  I ARGUE TO SEEK REVERSAL, AND FOR THE ISSUANCE OF A WRIT OF MANDAMUS TO THE VIRGINIA STATE BAR DISCIPLINARY BOARD ENJOINING THEIR SITTING AS A KANGAROO COURT BASED ON THE ISSUANCE OF A VOID AB INITIO ORDER.  THE VOID ORDER WAS ISSUED AS THE LINCHPIN OF A PROHIBITED STATUTORY BUSINESS CONSPIRACY BY WASHINGTON D.C. LOBBYIST/ATTORNEY ERIC HOLDER ET AL.   TO DAMAGE MY BUSINESS, PROPERTY RIGHTS, REPUTATION, PROFESSION AND RIGHT TO EMPLOYMENT BY REVOKING MY LAW LICENSE IN RETALIATION FOR LITIGATING TO ENFORCE MY STATUTORY PROPERTY RIGHT IN A CHOATE ATTORNEYS LIEN AND RIGHTS OF A FATHER TO PROTECT MY U.S. CITIZEN SON FROM BEING TAKEN FROM A “ZONE OF WAR” IN FY 2000 IN THE REPUBLIC OF COLOMBIA.  THIS IN VIOLATION OF MY RIGHT TO DUE PROCESS UNDER THE U.S. CONSTITUTION, AND THE LIMITATIONS AND PROHIBITIONS UNDER ART. VI §§ 1, 5 & 7 VA CONST., AS WELL AS VA CODE § 54.1-3935 (1950 TO 2017). (SEE Complaint against the Offices of the United States Attorney for the E.D. of Virginia and District of Columbia, as well as the Federal Bureau of Investigation for Refusing to Investigate/Charge Eric Holder et al. for a Business Conspiracy in violation of Va. Code § 18.2-499, 500, by acts of Malfeasance During the Obama Administration in Violations of Art. VI of the VA Const., VA Code, and the Void Ab Initio Order Doctrine.

            THUS, THE BENCHMARK FOR THE WRIT ARE THE CONTROLLING PRECEDENTS OF THIS COURT FROM 1835 TO 2007 MANDATING THAT PURSUANT TO ART. VI VA CONST. THE JUDICIAL POWER TO REVOKE A VIRGINIA LAW LICENSE WITH STATEWIDE EFFECT CAN ONLY BE BY STATUTE THAT WAS ENACTED BY THE GENERAL ASSEMBLY.  THUS, NO COURT CAN ISSUE COURT RULES IT POWER TO DISBAR AN ATTORNEY WITH STATEWIDE EFFECT INCONSISTENT WITH RIGHT UNDER VA CODE.  SEE EX PARTE FISHER, 6 LEIGH (33 VA.) 619 (1835) 624-25 (1835), LEGAL CLUB OF LYNCHBURG V. A.H. LIGHT, 137 VA. 249 AT 250, 119 S.E. 55 (1923), AND IN RE: JOHATHAN A. MOSELEY, SUP CT. VA NO 061237 (2007).  THUS, THE WRIT OF MANDAMUS IS BASED ON THE VOID AB INITIO ORDER DOCTRINE UNDER VIRGINIA CONST., VA CODE, AND CASE LAW,[1]   AS MARBURY V. MADISON, 1 CRUNCH 137, 140 (1803), STATES,

“[C]OURTS ARE CONSTITUTED BY CONSTITUTIONAL AUTHORITY AND THEY CANNOT ACT BEYOND THE POWER DELEGATED TO THEM. IF THEY ACT BEYOND THAT AUTHORITY, AND CERTAINLY IN CONTRAVENTION OF IT, THEIR JUDGMENTS AND ORDERS ARE REGARDED AS NULLITIES. THEY ARE NOT JUST VOIDABLE, BUT SIMPLY VOID, AND THIS EVEN PRIOR TO REVERSAL.”

            ALL OF THE ABOVE COMMAND THAT WHEN AN ENTITY CREATED BY COURT RULES SUCH AS THE VIRGINIA STATE BAR DISCIPLINARY BOARD HAS NEITHER CONSTITUTIONAL AUTHORITY, NOR STATUTORY AUTHORITY, NOR INHERENT LEGAL POWER, NOR JURISDICTION TO RENDER ANY ORDER.  THUS THE 2006 ORDER VOID AB INITIO IS A COMPLETE NULLITY FROM THE DATE OF ITS ISSUANCE AND MAY BE IMPEACHED DIRECTLY OR COLLATERALLY AT ANY TIME, OR IN ANY MANNER.  THIS PARTICULARLY BASED ON THE SYSTEMIC DENIAL OF ACCESS TO AN IMPARTIAL COURT AND COMMON LAW JURY TRIAL TO PRESENT THE EVIDENCE OF MALFEASANCE.

            THEREFORE, THE WRIT SEEKS,

• TO ENFORCE THE PROHIBITIONS AND MANDATES OF SEPARATION OF POWER UNDER I § 5 VA CONST.;[2]
• THE WRIT SEEKS TO ENFORCE THE RESTRICTION UNDER ART. VI §§ 1[3], 5[4] & 7[5] VA CONST. WHEREIN THE CITIZENS GAVE ONLY TO THE GENERAL ASSEMBLY THE POWER TO IMPART JUDICIAL AUTHORITY AND TO APPOINT JUDGES.
• THE WRIT SEEKS TO ENFORCE VA CODE § 54.1-3915[6] & § 54.1-3935 (1950-2009),[7] ENACTED BY THE GENERAL ASSEMBLY CONSISTENT WITH THE VA CONST. RESTRICTIONS TO ESTABLISH A STATEWIDE DECENTRALIZE ATTORNEY DISCIPLINARY SYSTEM IN EACH IN COUNTY CIRCUIT COURT OF VIRGINIA, IN TANDEM WITH THE BOARD OF BAR EXAMINERS POWER UNDER VA CODE § 54.1-3934.[8]
• THE WRIT SEEKS TO ENFORCE PROHIBITIONS OF 1 § 9 AND ART. XII § 1 OF THE VA CONST.,[9] TO ENJOIN THE EX POST FACTO AMENDMENT OF VA CODE § 54.1-3935 TO ADOPT RETROACTIVELY IN 2017 THE 1998 COURT RULES THAT BESTOWED JUDICIAL AUTHORITY ON THE VIRGINIA STATE BAR DISCIPLINARY BOARD AND APPOINTED THEM AS JUDGES.
• THE WRIT SEEKS IN THE INTEREST OF JUSTICE, COMPENSATION UNDER VA CODE §§ 18.2-499 & 500[10] FOR A RETALIATORY BUSINESS CONSPIRACY TO REVOKE MY LAW LICENSE FOR LITIGATING TO ENFORCE MY STATUTORY PROPERTY RIGHTS IN A CHOATE VA CODE ATTORNEYS LIEN ON A CLIENT’S CONTRACT CLAIM TO TREASURE TROVE VALUED AT $18 BILLION DOLLARS AND LITIGATING TO ENFORCE MY RIGHTS AS A FATHER UNDER JOINT CUSTODY AGREEMENT/VA CODE TO PROTECT MY U.S. CITIZEN SON FROM BEING TAKEN OUT OF THE UNITED STATES AGAINST HIS WILL IN 2000 TO A “WAR ZONE” IN THE REPUBLIC OF COLOMBIA.  THE VIRGINIA STATE BAR DISCIPLINARY BOARD ISSUED THE 2006 VOID AB INITIO ORDER TO DAMAGE MY BUSINESS, REPUTATION, PROFESSION, EMPLOYMENT, AND STATUTORY RIGHT TO 2006 FEDERAL UNEMPLOYMENT COMPENSATION.

            THE GOVERNMENT SURREALLY NEITHER DENIES NOR CHALLENGES THE ABOVE EVIDENCE OF THEIR WILLFUL CONSTITUTIONAL AND STATUTORY VIOLATIONS AND THEIR PARTICIPATION IN THE BUSINESS CONSPIRACY BY WASHINGTON D.C. LOBBYIST/ATTORNEY ERIC HOLDER ET AL.

            RATHER THE GOVERNMENT IN THE MANDAMUS ACTION BELOW OPPOSES THE ISSUANCE OF THE WRIT BASED ONLY ON THE DELEGATION OF COURT RULEMAKING AUTHORITY UNDER VA CODE § 54.1-3909, AND ARGUING LACK OF STANDING DESPITE THE CLEAR VIOLATION OF THE VOID AB INITIO ORDER DOCTRINE, VA CONST AND VA CODE.

            THIS IN AND OF ITSELF IS A CONFIRMATION OF THE WILLFUL CHARACTER OF THE VIOLATION OF THE VA CONST. AND VA CODE, AS WELL AS THE DENIAL OF DUE PROCESS UNDER THE U.S. CONSTITUTION BY VIOLATION OF THE DECENTRALIZED SYSTEM ESTABLISHED UNDER THE 1950 VA CODE BY COURT RULES THAT UNLAWFULLY BESTOWED JUDICIAL AUTHORITY AND THE APPOINTING OF ITS MEMBERS AS JUDGES TO DISCIPLINE ATTORNEYS.

            FINALLY, THE WRIT IS SOUGHT BASED ON THE RECORD OF A SYSTEMIC DENIAL OF ACCESS TO AN IMPARTIAL COURT AND COMMON LAW TRIAL BY JURY TO ENFORCE THE LIMITATIONS AND PROHIBITIONS UNDER VA CONST. AND VA CODE.  THE LITIGATION RECORD FROM 2004 TO THE PRESENT PROVIDES EVIDENCE OF THIS DENIAL OF DUE PROCESS, INCLUDING :

            FIRST, U.S. DIST. CT. HON JUDGE GIBNEY (EDVA) FAILURE TO RECUSE HIMSELF BASED ON THE FACT THAT HIS WIFE IS A MEMBER OF THE VIRGINIA STATE BAR DISCIPLINARY BOARD, AND ISSUING IN 2013 A SUMMARY ORDER GRANTING IMPUNITY, PRIOR RESTRAINING, AND ISSUING A NATIONWIDE INJUNCTION DEPRIVING ME OF ACCESS TO ANY FEDERAL COURT SO FOR THE VIOLATIONS OF VA CONST AND VA CODE AND BUSINESS CONSPIRACY.

            SECOND, IN RESPONSE TO PETITIONS FOR REDRESS BY THE GENERAL ASSEMBLY (HTTP://T.CO/SLV7PZ3ZD5), FROM 2017 TO 2019:  (A) THERE WAS ENACTED AN EX POST FACTO AMENDMENT TO VA CODE § 54.1-3934 TO ADOPT RETROACTIVELY THE 1998 COURT RULES; AND, (B) THERE WAS ENACTED VA CODE § 8.01-223.2 AS SPECIAL LEGISLATION IN VIOLATION OF ART. IV § 14, ¶3(18), TO GRANT IMMUNITY TO THE VIRGINIA STATE BAR DISCIPLINARY BOARD FROM ACCOUNTABILITY FOR THE BUSINESS CONSPIRACY (SEE ALSO 2019 HB 2111).

Isidoro Rodriguez

Rodriguez and Rodriguez

World Trade Center Barranquilla

Cale 76 No. 54-11, Suite 313

Barranquilla, Colombia S.A.

(571)477-5350

      [1] SEE, COLLINS V. SHEPHERD, 274 VA. 390, 402 (2007); SINGH V. MOONEY, 261 VA. 48, 51‑52(2001); BARNES V. AM. FERTILIZER CO., 144 VA. 692, 705 (1925); ROOK V. ROOK, 233 VA. 92, 95 (1987).

    [2] ARTICLE I § 5 VA CONST. “THAT THE LEGISLATIVE, EXECUTIVE, AND JUDICIAL DEPARTMENTS OF THE COMMONWEALTH SHOULD BE SEPARATE AND DISTINCT; AND THAT THE MEMBERS THEREOF MAY BE RESTRAINED FROM OPPRESSION, . . ..”

                         ART. VI § 1 VA CONST., STATES IN RELEVANT PART THAT JUDICIAL POWER SHALL BE VESTED, IN “COURTS OF ORIGINAL OR APPELLATE JURISDICTION SUBORDINATE TO THE SUPREME COURT AS THE GENERAL ASSEMBLY MAY FROM TIME TO TIME ESTABLISH.”

      [4] ART. VI § 5 VA CONST., STATES THAT ALTHOUGH THE SUPREME COURT SHALL HAVE THE AUTHORITY TO MAKE RULES, “SUCH RULES SHALL NOT BE IN CONFLICT WITH THE GENERAL LAW” ENACTED BY THE GENERAL ASSEMBLY.

                [5] ART. VI § 7 VA CONST., STATES IN RELEVANT PART THAT JUSTICES OF, “ALL OTHER COURTS OF RECORD SHALL BE CHOSEN BY . . .  THE GENERAL ASSEMBLY. . ..

[6] VA. Code § 54.1‑3915. Restrictions as to rules and regulations. ‑‑‑Notwithstanding the foregoing provisions of this article, the Supreme Court shall not promulgate rules or regulations prescribing a code of ethics governing the professional conduct of attorneys which are inconsistent with any statute; nor shall it promulgate any rule or regulation or method of procedure which eliminates the jurisdiction of the courts to deal with the discipline of attorneys. In no case, shall an attorney who demands to be tried by a court of competent jurisdiction for the violation of any rule or regulation adopted under this article be tried in any other manner.

[7] VA Code § 54.1‑3935 (1950-2007). Procedure for revocation of license.

1. If the Supreme Court, the Court of Appeals, or any circuit court of this Commonwealth observes, or if a complaint, verified by affidavit is made by any person to such court, that any attorney has. . . violated the Virginia Code of Professional Responsibility, the court may assign the matter to the Virginia State Bar for investigation. Upon receipt of the report of the Virginia State Bar, the court may issue a rule against such attorney to show cause why his license to practice law shall not be revoked. If the complaint, verified by affidavit, is made by a district committee of the Virginia State Bar, the court shall issue a rule against the attorney to show cause why his license to practice law shall not be revoked.
2. If the rule is issued by the Supreme Court . . . the rule shall be returnable to the Circuit Court of the City of Richmond. At the time, the rule is issued by the Supreme Court, the Chief Justice shall designate three circuit court judges to hear and decide the case. . .. In proceedings under this section, the court shall adopt the Rules and Procedures described in Part Six, Section IV, Paragraph 13 of the Rules of Court.

    [8] VA Code § 54.1-3934. Revocation of license by Board.  The Board of Bar Examiners may, for good cause, revoke any license issued by it at any time before there has been a qualification under it in any of the courts of this Commonwealth.  Code 1950, § 54-72; 1988, c. 765.

    [9] ARTICLE XII § 1 VA CONST. AMENDMENT, STATES, THAT ANY AMENDMENT TO THIS CONSTITUTION ARE TO BE REFERRED TO THE GENERAL ASSEMBLY, THEN IT SHALL BE THE DUTY OF THE GENERAL ASSEMBLY TO SUBMIT SUCH PROPOSED AMENDMENT OR AMENDMENTS TO THE CITIZENS FOR APPROVAL.

    [10] VA Code § 18.2-499. Combinations to injure others in their reputation, trade, business or profession; rights of employees.         A. Any two or more persons who combine, associate, agree, mutually undertake or concert together for the purpose of (i) willfully and maliciously injuring another in his reputation, trade, business or profession by any means whatever or (ii) willfully and maliciously compelling another to do or perform any act against his will, or preventing or hindering another from doing or performing any lawful act, shall be jointly and severally guilty of a Class 1 misdemeanor. Such punishment shall be in addition to any civil relief recoverable under § 18.2-500. 

Any person who attempts to procure the participation, cooperation, agreement or other assistance of any one or more persons to enter into any combination, association, agreement, mutual understanding or concert prohibited in subsection A of this section shall be guilty of a violation of this section and subject to the same penalties set out in subsection A.

            VA Code § 18.2-500. Same; civil relief; damages and counsel fees; injunctions. — (a) Any person who shall be injured in his reputation, trade, business or profession by reason of a violation of § 18.2-499, may sue therefor and recover three-fold the damages by him sustained, and the costs of suit, including a reasonable fee to plaintiff’s counsel; and without limiting the generality of the term, “damages” shall include loss of profits. . ..