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UNITED STATES COURT OF APPEALS

for the

FOURTH CIRCUIT

In re: William C. Bond No.: 17-1955

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MOTION TO SUPPLEMENT THE MOTION TO ALLOW RICHARD A.

POSNER, ESQUIRE, TO APPEAR AS ADVISORY COUNSEL ON
BEHALF OF PETITIONER WILLIAM C. BOND & REQUEST THAT THE
SUPPLEMENTED MOTION BE IMMEDIATELY EXPEDITED AND
RULED UPON

Comes now petitioner pro se, William C. Bond, and states:

1. Petitioner filed his MOTION TO ALLOW RICHARD A. POSNER, ESQUIRE,

TO APPEAR AS ADVISORY COUNSEL ON BEHALF OF PETITIONER

WILLIAM C. BOND on October 17, 2017. 1

1
Please see: Docket entry number 6.
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2. Petitioner has now waited more than a full month to obtain permission from this

court to be represented in this proceeding by one of the countrys most

distinguished federal judges, now retired Judge Richard A. Posner from the U.S.

7th Circuit Court of Appeals.

3. Mr. Posner is a member in good standing of the Bar of the State of New York

and has agreed to represent petitioner herein.

4. This court has offered no explanation whatsoever over an almost 5-week period

why the permission has been silently withheld.

5. This courts failure to facilitate or permit (with any necessary conditions set

forth) petitioners representation by distinguished and willing counsel compounds

for no apparent reason the underlying denials of due process that are the gravamen

of petitioners Second Amended Complaint.

6. Surely it is not the complexity of the motion for advisory counsel representation

that has caused the more than 30-day delay.

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7. If the court concludes that additional conditions should be imposed, it is easy

enough to state them.

8. If there are reasons for denying the advisory counsel relief that the court

concludes cannot be resolved by attaching conditions, then petitioner asks that the

court order that Mr. Posner may be admitted to the Bar of the Fourth Circuit for the

purpose of representing petitioner as counsel herein without the advisory label. 2

9. To be very clear petitioner and Mr. Posner still agree that petitioner should be

allowed to remain pro se with Mr. Posners advisory counsel assistance. In short,

petitioner believes he has the due process right to win this case on his own efforts,

perfected by Mr. Posners assistance.

10. But, if the court will not allow their review of petitioners case to proceed with

advisory counsel, the court must allow Mr. Posner to now enter this case as

petitioners full counsel of record. 3

2
Please see: Exhibit no.:1, the Second Affidavit of Richard A. Posner.
3
Should the court take this course, it is only right and just that the court
order Mr. Posners future costs in this case to be offset and subsidized per Local
Rule 46(d), if not other Local Rules.
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11. Should the court fail to promptly act on this supplemented motion it is

depriving this petitioner of the opportunity and right to be represented by

distinguished and willing counsel.

12. In acting on the motion, the court should either expressly order or authorize the

representation or clearly identify the path to representation that it would permit.

13. Petitioner asks that the court act expeditiously on this supplemented motion in

fairness to both him and Mr. Posner.

14. Finally, petitioner asks that other than an order requiring that respondents

answer the petition for writ of mandamus, the court take no action in this

proceeding until 30 days after it has resolved the issue of petitioners

representation as raised in this supplemented motion.

WHEREFORE, for the aforementioned reasons, petitioner prays that the court

grant the requested relief expeditiously. 4

4
Petitioner contacted opposing counsel under Local Rule 27(a) about the
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Respectfully submitted,

/s/
_________________________
WILLIAM C. BOND
Pro Se
P.O. Box 4823
Baltimore, Maryland 21211
(443) 970-2887
proselitigator@aol.com

CERTIFICATE OF FILING AND SERVICE

I HEREBY CERTIFY that on the 20th day of November 2017, copies of

Petitioners MOTION TO SUPPLEMENT THE MOTION TO ALLOW
RICHARD A. POSNER, ESQUIRE, TO APPEAR AS ADVISORY
COUNSEL ON BEHALF OF PETITIONER WILLIAM C. BOND &
REQUEST THAT THE SUPPLEMENTED MOTION BE IMMEDIATELY
EXPEDITED AND RULED UPON were served by Email to: ALLEN F.
LOUCKS, AUSA, U.S. Attorneys Office, District of Maryland, 36 S. Charles
Street, 4th Floor, Baltimore, Maryland 21201, allen.loucks@usdoj.gov; and to:
MATTHEW P. PHELPS, AUSA, U.S. Attorneys Office, District of Maryland,
36 S. Charles Street, 4th Floor, Baltimore, Maryland 21201,
matthew.phelps@usdoj.gov; and by Email to: MARK ZANCHELLI, Chief
Deputy Clerk, U.S. Court of Appeals for the Fourth Circuit, 1100 East Main Street,
Suite 501, Richmond, Virginia 23219, 4cca-filing@ca4.uscourts.gov.

/s/
_________________________
WILLIAM C. BOND

motions comprising this filing and was informed that the government does not
consent and will determine how to respond once the motions have been filed.
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