UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

______________________________

JOHNNIE DENHAM

Plaintiff, HON. STEPHEN J. MURPHY

U.S. District Court Judge

-vsHON. R. STEVEN WHALEN

ALBERT LORD, U.S. Magistrate Judge

PAUL D. BORJA,

BOLHOUSE, VANDER HULST, RISKO, Case No. 2:09-CV-12740

 BAAR & LEFERE, and

WARREN C. EVANS

Defendants.

______________________________/

SECOND SUPPLEMENTAL BRIEF IN SUPPORT OF MOTIONS BY DEFENDANT BOLHOUSE 

LAW AND MOTION BY DEFENDANT LORD TO DISMISS PLAINTIFF’S COMPLAINT

Defendants Lord and Bolhouse Law have previously filed Motions to Dismiss Plaintiff’s 

Complaint. Since the filing of the Motion to Dismiss, as well as these Defendants’ supplemental 

brief, additional actions have taken place which establish Plaintiff’s continued abuse of both the 

state and federal court systems. In Defendant Bolhouse Law’s Motion to Dismiss, Bolhouse 

Law offered a timeline of events, numbered 1-17, of events that had taken place with respect to

this matter. On December 31, 2009, these Defendants offered a supplemental pleading 

outlining additional events, numbered 18–27. These Defendants further supplement the 

timeline of events as follows:

28. December 30, 2009 - Denham again files for Chapter 13 Bankruptcy, Case # 09-

79573-tjt.

1

29. December 30, 2009 – Denham files yet another Adversary Proceeding, Case 

Number 2:09-ap-0738.

30. January 10, 2010 – The Bankruptcy Court issues a Show Cause Order requiring 

Denham to appear and show cause as to why his sixth bankruptcy petition

 1 This bankruptcy filing was Debtor’s sixth bankruptcy petition since 2002. Of the previous five petitions, 

only one resulted in a discharge. 

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2ii

should not be dismissed and why Denham should not be barred from filing 

another bankruptcy case for 180 days.

31. January 28, 2010 – the hearing on the Show Case Order was held. Denham 

appeared. The Court entered an Order dismissing the bankruptcy case and 

barred Denham from filing another bankruptcy petition, without counsel, for 180 

days.

32. January 28, 2010 – Adversary Case # 2:09-ap-0738 is dismissed.

Defendants Lord and Bolhouse Law request that the Court dismiss Plaintiff’s Complaint 

with prejudice, and award sanctions against Denham for his continued abuse of the legal 

system.

Respectfully submitted,

Dated: February 8, 2010 Bolhouse, Vander Hulst, Risko, Baar & Lefere, P.C.

By: /s/ Joel W. Baar

 Joel W. Baar (P56796)

3996 Chicago Drive SW

Grandville State Bank Building

Grandville MI 49418

Phone: (616) 531-7711

Attorneys for Bolhouse Law & Albert Lord

joelb@bolhouselaw.com

PROOF OF SERVICE

On the date below, the undersigned, employed in the offices of Bolhouse, Vander Hulst, 

Risko, Baar & Lefere, P.C., sent by first-class mail a copy of:

• SECOND SUPPLEMENTAL BRIEF IN SUPPORT OF MOTION BY DEFENDANT 

BOLHOUSE LAW and DEFENDANT LORD TO DISMISS PLAINTIFF’S COMPLAINT

2:09-cv-12740-SJM-RSW Doc # 17 Filed 02/08/10 Pg 2 of 3 Pg ID 186
3ii

to:

Johnnie Denham

35816 Concord Dr.

Romulus, MI 48174

The foregoing pleading was electronically filed and notice sent to attorneys of record. I 

declare that the statements above are true to the best of my information, knowledge and belief.

Date: February 8, 2010 /s/ Joel W. Baar

Joel W. Baar

3996 Chicago Drive SW

Grandville State Bank Building

Grandville MI 49418

Phone: (616) 531-7711

Attorneys for Defendants Bolhouse Law and 

Albert Lord

joelb@bolhouselaw.com

2:09-cv-12740-SJM-RSW Doc # 17 Filed 02/08/10 Pg 3 of 3 Pg ID 187