Letter to Commercial National Bank
Vice President Will Jackson proving bank Director and Attorney, William Peatross, influence and representation on behalf of his client/borrower Kent Dupree in obtaining loan.

Title 18, Section 215

Ledger Sheets
Proving fees received for representation of Dupree in obtaining loan.

Caddo Abstract Invoices
Proving Director  Peatross worked for Dupree (Borrower) in obtaining loan "for a fee".

Title 18, Sections 1001, 215, 1016

Cook 2
Proving Cook, Yancey, King and Galloway-represented Dupree, borrower and the Partnership in obtaining the loan.

Conflict of Interest

Loan Commitment Letter to Ken Dupree
(unaccepted) – Stating the Terms and Conditions for the first loan in the amount of $746,000.00 loan matured 270 days later (May, 1985).

General Condition of Construction Loan
All condition and agreement were unlawfully altered and modified.

Commercial Loan Application
Loan application showing payment schedule and missing master note.

Letter to Ken Dupree
Showing repayment schedule payment for loan number 1; also cc to Bill Peatross Dupree's representative and Bank Director, who received a lucrative contract for his services.

Title 18, Sections 1983, 1986

Illegal Promissory Note (June 20, 1986)
Proving second loan in which no record exists and no money received by Audubon Meadow Partnership.

Title 18, Sections 1621, 1001, 1005

Construction Loan Agreement
Invalid. Not sign by bank.

Denial of USC42 Title 1981, 1983, 1985

Denial of Right to Attorney

Denial of Due Process of Service

LARS 9.605 Actions for legal malpractice

Proof of Case and Violation of Law
Robert L. Lucien Sr. entered into a partnership with one Kent Dupree of Shreveport Louisiana to obtain a loan for manufactured housing

July 26, 1999


First American and Deposit Guaranty National Banks  were involved in a conspiracy which sacrificed a black businessman and his black female Attorney to protect and shield a highly influential white Attorney and bank Director (William Peatross) whose brother is the Second Circuit Courts of Appeal Judge (Charles B. Peatross), who represented his brother against Robert Lucien and Audubon Meadow Partnership in this case. The same Court that has sat on every appeal by Lucien. Also, sitting on this case is Judge Stewart, (the brother of Judge Carl Stewart) who rendered the illegal Judgment 1990.

Attorney William C. Peatross, the bank Director of Commercial National Bank of Shreveport Louisiana in 1983-1985 represented a white businessman, Mr. Kent Dupree II, who conspired with their Director, Vice President and Attorneys in obtaining a loan from his bank, receiving something of value i.e., contracts, fees and counseling in an Attorney/Client relationship using a black businessman, Robert Lucien of New Orleans in which numerous State, Federal, banking and ethical laws were violated, including using illegal confected, improperly notarized contracts, notes and mortgages unlawfully executed by bank officials, Director and Attorneys Cook, Yancey and Galloway, who sued their own admitted friend and Client (Kent Dupree II), as well as their created Partnership which is a serious violation of Professional Code of Ethics and the Public's Trust.

These same Banking Officials, Director, Attorneys and their Client Dupree II, executed a second Promissory Note, June 1986 using documents [Foot note- It is a gross miscarriage of justice for anyone black or white to be judged by his adversaries and blood relatives.] from the 1984 loan, years after the original loan commitment letter expired November 1984. And was used to make an unlawful Loan of $746,000.00 to their Client Dupree of which the proceeds were unlawfully shared for their part in influencing the approval of this loan. The June 1986 Promissory Note was for a second unauthorized Loan of $713,000.00 of which was never received by the Partnership. All Court Judgments, documents and Bank letters purporting to be  a loan to the Partnership which was never shown or proven to have any connection to a construction project involving Audubon Meadow.

Lucien was denied Due Process and Equal Protection of the Law after his Attorney (Emile Turner Jr.) of Turner, Young, Hebbler and Babin failed to advance these defenses or represent him in his Partnership interest, Trial Transcript 332-510 February 22, 1990, page 3, # 26 evidencing Attorney Babin and Turner represented the partnership for the explicit purpose to enable it to get an illegal Judgment against the unrepresented Partnership.

This is contrary to Mr. Turner's sworn Affidavit that he only represented Lucien. The Partnership never had process of service after Dupree's bankruptcy. But CNB (Commercial National Bank) through its Attorney Mr. Johnson continued and failed to recognize Lucien as its legal representative, as he was sole owner and manager after Dupree's bankruptcy as stated in the Partnership Agreement Article III, which was drawn up by Attorneys Cook, Yancey, King and Galloway law firm.

Lucien's black female attorney (JoAnn Gines), who was intimidated, harassed, terrorized and hospitalized with a physical and nervous breakdown after attempts of disbarrment as punishment for her lawful efforts in seeking justice in this bias, racist and discriminating bank and court system in this City.

All Judgments, facts and evidence were untrue and misrepresented. Lucien and the Partnership were unrepresented, "No Service of Process"(RS 13:4231) states proper notice must be given. (See Court Transcript 1990) They also denied his request for an Attorney (see attached). This Bank has been involved in the denial of black and minorities' Civil and Constitutional Rights for over 40 years which include supplying privileged and confidential information to the Sovereignty Commission of the State of Mississippi, which was set-up by the State Legislature specifically, to deny blacks their Civil and Constitutional Rights. In all actions, supeona for documents and records have been denied and/or destroyed. No Notes, checks or records of the original loan were available and absolutely, there were no contracts or loan documents executed between the Bank and Borrower. (See Bank Attorney's brief denying Lucien's Cause and Right of Action, as well as Appeal Courts –stating that No Rights exists for anyone not a party to the Contract) (Attorney Johnson's Brief  1988). Equal Protection of the Law was denied Lucien as it was absolutely, established that the Bank was not a party to the Contract.

There is evidence of scores of other illegal loans. The million dollar land development securing the bank loan and financed by the Bank was sold for taxes during litigation, 1996-1997 without any notification to Lucien whatsoever, and/or any attempt to protect the Bank and its Guarantor's interest as required by Law.

The defendants in the Texaco case were accused of making derogatory , racist, prejudice comments and threatening to destroy evidence of which cost great humiliation and embarrassment. However, they were exonerated and found not guilty of any civil, criminal or Constitutional law violations.

Here we have absolute, positive, undeniable proof of all these violations through documents, depositions and misstated Judgments by conspiracy, perjury, collusion, intimidation, misrepresentation and falsification of Federal, State and Court records all in an attempt to obstruct justice for the protection of  the banking officials and attorneys.

This corruption is so absolute that the violators are more powerful than the President of the United States, who is not above the law. These people have actually impeded a Federal, State and Bar Association investigation by starvation, intimidation, fear, coercion and extortion to force the victims to sign a release and withdraw their complaints against the Judge (Judge Scott Crichton) and themselves. They had a Judge in open court render a Judgment ordering the victims to give up their Civil and Constitutional Rights to equal protection of the law; which is a blanten violation of the 14th Amendment to the Constitution of the United States. As stated by U.S. District Court Judge Susan Webber, no matter how aggravating a lawsuit, it is simply, not acceptable to use false testimony to get out of it. No matter which lofty government office a defendant might hold, he has to be held accountable for his misconduct under the same laws as that apply to anyone else to preserve the integrity of the Judicial System.


Mr. Robert L. Lucien Sr. was a minority businessman, developer, civic and community leader in the New Orleans, Louisiana area for over 30 years. He has 25-30 years experience as a minority contractor/developer, Tile Contractor, Low-moderate Housing developer, entrepreneur in the development, establishment and the proprietor of three Hotels in the community, Real Estate/Landlord of numerous properties, NAACP member, Constituent and confidante of the Legislative District 93, where he works diligently giving of his time, expertise and assistance to the office of the Honorable State Representative Avery C. Alexander. A friend to other minority developers and Contractors in the community where he at one time had the financial ability to support various Construction Contracts to assist various projects.As a Civic leader he serves as a member and Chairman of the New Orleans Redevelopment Authority for the City of New Orleans for the past fifteen years. Vice President of a Non-profit organization assisting with housing and supportive services to homeless and displaced individuals of the community. Member of Mayor Marc Morial 100 Member Association. Past Board Member of the YMCA (Dryades Street), Reserve Civil and Criminal Sheriff and a member of the New Orleans Chamber of Commerce. His expertise, determination and perseverance allowed him to become comfortable and prosperous with his business entourage to gross an income of 1 million plus dollars a year business and a $100, 000.00 a year personal income.To his dismize his achievements and success was quickly destroyed in 1987, leaving him bankrupted, dishearten with very little confidence in his fellow man. In addition to little confidence in the legal systems.

*His story begins with a contact made to him by a White friend whose son needed assistance with a land development in the Shreveport Louisiana area."


Mr. William Dupree an Insurance Executive in New Orleans Louisiana had a son in the Shreveport Louisiana Area who needed financial backing for a construction land development loan. On the initial contact Mr. Lucien was informed that Mr. Dupree's son only needed him as a (guarantor) for interim financing of this loan due to the fact  Mr. Dupree had been working on this particular project for the last several years but did not have the financial backing and expertise for this particular project. He was also informed that the project in turn would acquire Permanent Financing thus limiting and extinguishing his obligation once the Permanent Financing was in place as evidence by the Loan Contract. He was also informed that the Bank had specific requirements in which the loan had to be made by; At the time the specific was not elaborated on but it was emphasized that the basis and particulars were addressed and approved by the Bank Director Bill Peatross (See Dupree Deposition). He was later informed that the Bank required that as guarantor that a Partnership Agreement had to be instituted and that the Bank would addressed and draw up the particulars for the agreement. (See exhibit Dupree Deposition, MC Michael Statement, William Dykes, Commercial National Bank Attorney).


The purpose of this project was to acquire and develop land in which manufactured homes would be placed on and sold.The original development began with 43 acres, 12 of which was developed.The value of $11,000.00 was the amount per lot.


Commercial National Bank of Shreveport Louisiana in 1984 extended a Land Development Loan to a friend and Client( William Kent Dupree) of their Bank Director William Peatross and Bank Attorney William Dykes.  Unknowingly to the sought after Black Guarantor Mr. Robert Lucien of New Orleans Louisiana, this land development construction loan was in the making several years prior to him being approached to become the guarantor of this project. Unfortunately, much of the legal aspects of this construction land development had been planned a year prior to Mr. Lucien being sought after in that all of the legal work was done by (Attorney William Peatross) in regards to appraisals, land acquisition and control and other construction and development perpetration was taken care of prior to Mr. Lucien participation (Please see exhibit, it would be wise to keep in mind that the latter will be denied by Attorney Peatross and Commercial National Bank Officials and Attorneys in forth coming exhibits to cover up the conspiracy of this illegal loan). It has been exleplified through documentation that the way was smooth for Mr. Dupree for this development with only one problem, Mr. Dupree did not have the financial as well as the construction expertise for the development. It is believed that this loan was also a minority set aside, in which a minority developer was needed to further set the stage for this Client/friend of the Bank Director and Attorneys to achieve this goal. Ironically, these same Bank Officers, Director and Attorneys would sue their Client and friend Dupree, Audubon Meadow and Lucien using the very same documents and evidence that they were paid to create for the partnership against them, when it is also the Bank's Attorneys Cook, Yancey, King and Galloway.


The amount of the Note was for $713,000.00. The original Note was signed in 1984 in the said amount of $746,000 for a construction loan development in the Shreveport Louisiana area. Later it was discovered that the Bank somehow lost the original notes and with the uncontested help of Mr. Dupree signed another note two years later without the consent and approval of Mr. Lucien in the amount of $713,000.000 due 6 months contrary to the approved and signed Permanent Contract to be paid at the completion of the Development of which the Bank refused to obtain or require at closing, Breach of it's own requirement.


It was discovered several years later after the loan had defaulted that the signature of the loan was not properly signed by a Banking official of Commercial National Bank but by the secretary of the known Caddo Abstract Company, who was not a banking officer and /or employee. Sadly, to say that this signature was unauthorized and illegally notarized as a Banking Officer and/or representative of the Bank by Mr. William Peatross which is a violation of LA Law Statue-35: 1-17;  LSA CC Art. 1835-1840.


A company 50% owned by Mr. William Peatross whose secretary was allowed to sign on the behalf of the bank.

Mr. Lucien participation was promised as guarantor (only); then he would be relieved when Permanent financing was available which was a condition stipulated in the Loan Contract. This would insure him that he would be freed from all financial obligations of this loan. This was a deliberate and broken agreement. At  the closing Mr. Dupree was informed that the Bank changed its mind referencing the Permanent Financing. (See exhibit- Dupree Deposition). In addition to the latter, there were also other agreements that were broken and not adhered to as promised.


1.) The Agreement referencing the payment of $11, 000.00 per lot to be paid as a condition to satisfy repayment of the loan; contrary to another agreement of this loan transaction in which

 2.) The total sum of $746, 000.00 dollars to be paid off in 270 days after the closing of the loan.  What's so confusing is the fact, neither of the above agreements were held to as promised as well as the controversy as to which agreement is actually the authentic Contract Agreement in which the terms of the loan was to be adhered to and the Bank now fraudulently uses the Court to cover-up.  Unfortunately, the development was not successful in that it was later discovered that

Mr. Dupree, the Partner, was more interested in selling the acquired property to Caucasian families. Unknowingly, to Mr. Lucien who was a businessman in the New Orleans area and not active as well as unaware of the stragedy and premeditation of Dupree and his friends. So when the development failed and it was time to repay the loan, with little and no production and success with the project, it folded. The Bank however was aware of the initial plan in the beginning. So, after suing Dupree, Lucien and the Partnership, the white partner, who incidentally was allowed to file bankruptcy to protect himself they traciously sued the black partner not as a borrower but as a guarantor for the failed construction deal. (see exhibit). Encountering numerous violations of Civil and Constitutional rights violations the black guarantor Lucien also had illegal seizures of property and banks accounts. (see exhibit)

Mr. Lucien initially contacted someone who he thought to have been a friend of his for the past 30 some years, Mr. Emile Turner.  Mr. Turner is a prominent white Attorney from the New Orleans Louisiana area. Mr. Lucien honestly believed  after  Mr. Turner was hired as his legal Counsel he would be working in his best interest,  finding a resolution that would certainly make clarification of this construction deal thus giving a  relief from the injustice committed against him. The unbelievable horror of the entire story rest on the proof that this entire loan transaction was based upon illegal documents forged and illegal confected documents. The sad part of this story is the obvious concerted effort through conspiracy, perjury, extortion, coercion and denial of due process in the legal system by some Banking Officials, Judges and the Appeal Courts (where certain relatives of some of the Judges setting on the Appeal Court has deliberately obstruct justice by denying Mr. Lucien his day in Court as well as conspiring to disbarred the one Black female Attorney who has tried tireless to vindicate her Client and other Clients in an unrelated case to Mr. Lucien held at blackmail, intimidation, extortion, conspiratorial cover-up efforts to obstruct justice and due process of Law. Due to the latter it has been very difficult and impossible to have this case heard on the Merits as well as an effort to have the victim fair day in Court. All Mr. Lucien seeks and pleads for is to be judged on the Truth, legal evidence and facts.

How does one obtain justice when the Administrators are the perpetrators that are denying one's equal protection of the Law.  Due to the above we need an investigation into this transaction by the FBI and all other applicable agencies to investigate this absolute and complete denial of justice.


              BEFORE ME, the undersigned authority, a Notary Public, duly commissioned and qualified within and for the Parish and State aforesaid, personally came and appeared: PETER SCOTT MICHELL who, afler being first duly sworn, did depose and state that:

I. That Robert Lucien brought an agreement of partnership for Audubon Meadow Partnership to my office in order that his signature could be notarized by a Louisiana. notary.

2. That I did not prepare the document and I did. not advise Robert Lucien in any manner concerning this document, nor did I discuss this document with William Dykes, Esquire or any other attorney at any time.


SWORN TO AND SUBSCRIBED Before me this 22nd day of Jan. 1996

Donna N. Crawford




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