What the Record Establishes

  • A verified filing of the State told the reviewing court that a disciplinary referral was among the justifications for restricting the appellant’s ability to file.
  • The same filing states, under verification, that appointed counsel confirmed willingness to seek a stay.
  • Illinois Supreme Court Rules 775 and 766 address the privileged and confidential character of communications to the disciplinary commission.

What They Have Not Produced

  • Whether a stay has been sought by anyone on the appellant’s behalf since August 5.
  • What record supports the characterization of a disciplinary referral as harassment.
  • Whether the reviewing court has ever been asked to examine the filing restriction on its own terms.

Two sentences in the State’s August 5 objection are doing more work than the other fifty-four pages combined, and both were verified under penalty.

Paragraph 14 is the one his lawyer has to answer

It states that appointed counsel “has explicitly confirmed their willingness to seek the relief they may ethically pursue: a stay on the circuit court’s June 17, 2026 order.” Set beside the July 31 order — which denied the appellant’s motions “without prejudice to any motion filed by his counsel, including a motion to stay” — the picture is exact. The court named the motion. The court addressed the naming to counsel. The State then told the court, under verification, that counsel was willing to bring it. Those three facts belong to a lawyer, not to a client, which is why the August 13 letter to appointed counsel is built out of them and asks for a written response by a stated hour on a stated date.

Paragraph 13 is the one that should trouble anyone reading it

It tells a reviewing court that the order restricting the appellant’s ability to file is “further justified by defendant’s harassing Notice of Disciplinary Referral.” Illinois Supreme Court Rule 775 addresses the privileged character of communications to the Attorney Registration and Disciplinary Commission; Rule 766 addresses the confidentiality of the Commission’s file. A litigant who complains to the disciplinary body is using a channel the Supreme Court of Illinois built for exactly that purpose.

What this archive does and does not say about it

It does not say the assertion was made in bad faith. It does not say the State violated a rule. It publishes the paragraph, publishes the rules it sits next to, and notes the obvious structural problem: if using the disciplinary channel is itself a reason to restrict a litigant’s access to the court, then the channel has a cost the rules do not mention.

The restraint that has never been examined

The July 31 order imposed two restrictions — file nothing further, communicate with appellee’s counsel by no means. The August 7 order reviewed the appointment of counsel at length and never mentioned either one. The August 13 motion makes that observation in a single paragraph and asks the court to look at the restraints on their own terms. It is a request for review, not a claim of error.

The compliance nobody had to prove

Every letter in the August 13 round is copied only to permitted addresses. The letter to appointed counsel says so in its own recipient block and again in its body, and expressly excludes appellee’s counsel and the State’s Attorney from service. That compliance is itself one of the arguments: a litigant who is being described as harassing has, on the face of his own paper, obeyed the communication restriction to the letter while asking a court to examine it.

Who was served, on what date, through which channel, with what proof.