ILiWNAL IN THE SUPREME COURT OF OHIO DENA G. LAIYIBERT, Appellant, On Appeal from the Summit County Court of Appeals, V. Ninth Appellate District STATE OF OHIO, Court of Appeals Case No. 13846 Appellees. MOTION TO FILE DELAYED APPEAL Dena Gaye Lambert respectfully moves the Court pursuant to Ohio Supreme Court Rule II, Section 2(A)(4)(a) for leave to file a Delayed Appeal and a Notice of Appeal. This cases involves a felony and more than 45 days has passed since the Court of Appeals decision was filed in this case. A memorandum in support is attached. 11 0 SEP 2 a tb1? Respectfully submitted, CLERK OF COURT SUPREME CGUR7 OF OHIO Dena G. Lambert, in Pro Se #021684 - Lincoln Ohio Reformatory for Women 1479 Collins Avenue Marysville, Ohio 43040 n r Fff U DEFENDANT-APPELLANT SEt 2 i? CLERK OF CQURT SUPREME OCUo d 01 CR'C MEMORANDUM IN SUPPORT On April 26, 1989 the Court of Appeals filed its decision in my case. I have attached a copy of the Court of Appeals opinion to this motion. I was unable to file a Notice of Appeal to this Court, and a Memorandum in Support of Jurisdiction within 45 days of the Court of Appeal decision in my case for the following reasons: This case arises from my attempt to escape from the violent captivity of James Sprake, who for approximately 6 months in 1988, traveled across the United States, and Central & South America forcing me to commit criminal acts of: property and identity theft against businesses and individuals, pornography, prostitution, drug-trafficking & manufacturing, shop-lifting, fraud, and other criminal acts, under threats and acts of physical violence, and coercion, while subjecting me to emotional trauma, mental torture, sexual abuse, and physical bondage. I have an extended history, since early childhood, of being a victim of violent human-trafficking and domestic violence, and I have been either hospitalized or left-for-dead on several occasions. In 1978, at 14 years old,I ran away from an abusive home in Bellevue, Nebraska, only to eventually be forced into a well-organized, juvenile prostitution ring in California. This prostitution ring involved grown men who traveled with juvenile females, who were forced to attend "Gentlemen" parties at various locations across the United States. Upon being transported into the State of Ohio, in 1979, I was spotted by a hotel manager's wife, who suspected something was wrong with a young teenager with several grown men. Once I was taken into one of the several hotel rooms rented by my captors, a Sheriffs Deputy arrived and took me from the hotel room, handcuffed me, and sent me to a juvenile facility for holding until I told them who my dad was, so he could come and get me. None of the other juvenile were rescued because I was the only female one spotted by the hotel manager's wife, and non of the grown men who ran this illegal, juvenile prostitution ring were arrested. In 1983 in yet another incident of forced prostitution, at age 19, 1 was prostituted out at Casino's and truck stops by a man named Larry Delozier, whom the F.B.I. knew was a known drug-trafficker, 3hile being prostituted in a truck stop in Catoosa, "bookie", arms-dealer, bigamist, and pimp. V Oklahoma, I was stalked, abducted, sodomized, tortured, and Ie$ for dead by a serial killer who targeted me as his thirteenth prostitute victim and the only one who lived. He was never caught to my As a result Tailsa, Oklahorna, St. Francis Hospital Medical record (1983). knowledge. See Exhibit A, of this extreme torture, I suffered severe physical trauma, and facial lacerations, in addition to, (P.T.S.D.) which impaired my ability to function. See undiab osed Post Traumatic Stress Disorder Description of Post Traumatic Stress Disorder. ExhibitA(1), In December of 1987, as a result of homelessness in Tucson, Arizona, I meet James Sprake of Scottsdale, Arizona, whom I believed was a legitimate business man who sold insurance for department store owners. Over the course of several weeks of personal grooming and etiquette training by James Sprake, unfortunately I learned he was not an honest business man; rather, a well-connected, criminal mastermind who was unwilling to let me simply walk away. On approximately the 11"' day of June, 1988, James Sprake brought me to the city of Akron, Summit County Ohio, and registered at the State Road Inn. Once located in a hotel room, I was not allowed to make any contact with any individuals and not even the strangers James Sprake would Police occasionally bring to the hotel rooms for various criminal dealings. See Exhibit B, Akron Report of hotel employee. Upon arriving at the hotel, James Sprake had in his possession: a large quantity of cocaine in which he would process into crack: including marijuana, which he would consume over the next three days. Due to the paranoid tendencies of James Sprake, he would force me to remain awake during the entire time of his drug-binges. It was during these drug-binges that James Sprake would physically and sexually abuse me. And once the drugs were gone, James Sprake would make contact with local individuals to schedule more drug pick-ups after a night-out on the town where he would solicit strange females for group orgies which always resulted in the physical, escalation of violence against me. This was the regular routine of James Sprake. On the I4`h day of June, 1988, I was left alone in the hotel room and received a telephone call ordering from the hotel room by James Sprake who had left the hotel earlier. He was at a striper-club where he was attending a party. From pure exhaustion I had laid down in an attempt to sleep, but I knew the consequences of disobeying James Sprake so I got dressed. A cab arrived for me and I was driven to a striper club where James Sprake paid the cab fee and ordered me to make my choice. This choice was in picking which female striper James Sprake would bring back to the hotel. Since I complained the striper's were all ugly, James Sprake called for another cab and re-located to the "Touch of Class", and he told me I'd make a choice there. As the evening progressed and James Sprake became intoxicated, the verbal abuse and aggressive man-handling by James Sprake toward me increased, so I suggested he go somewhere else so he could shoot some pool while I tried to relax. I made this sugaestionfor the purpose of attempting another escape from James Sprake because there might be safer strangers to turn to for help at a regular bar, rather than seeking customer help from a striper-club. Also, on several previous occasions I attempted to escape from James Sprake only to be found by him through his multiple contacts with the criminal underground. James Sprake asked about the location of a pool table and was informed one was across the street at the "Temple Tavern", on North Hill in the city of Akron, Summit County, Ohio. As we entered the "Temple Tavern", I became very afraid because the tavern was crowded with motorcycle gang- members, wearing colors. As James Sprake started interacting with biker chicks at the pool table, I began looking for a safe individual to help me escape from James Sprake., After several conversations to request help from the tavern staff to no avail, I eventually approached a stranger, Mr. Harry Robinson, and asked him to help me get away from a dangerous man who brought me to the tavern. Mr. Robinson agreed to assist me, but only after he purchased me a drink. Mr. Robinson bought some drinks, but I purposefully spilled the drink for me because James Sprake kept purchasing me double- shots of Jack Daniels Whiskey, and I was already severely intoxicated. Mr. Harry Robinson agreed to take me to my hotel, so we left the tavern together. Once outside the tavern, I began crying and told Mr. Robinson that I wasn't from Ohio and had nobody to call for help and that I was in a very bad situation. I stated that all I needed was for him to drive me to the hotel room so I could get my belongings, then drop me off at a truck-stop or something and I would pay him in traveler's checks which James Sprake had left at the hotel. Mr. Robinson agreed and helped me into his car where I think I passed-out in the passenger seat because I don't recall the drive. Upon shaking me awake and escorting me up a few stairs, I resisted and expressed my awareness that the hotel I was staying in had no stairs. Mr. Robinson reassured me that I could use his telephone to call the hotel, so I continued to allow Mr. Robinson to assist me inside of his apartment. While inside Mr. Robinson's apartment, he seated me on his couch and put the telephone and telephone book on the coffee table in front of me. I attempted to locate the hotel I was staying at but was unable to remember the name of the hotel due to intoxication. When I went to grab for my purse, it was not on the coffee table where I had laid it. I felt panicked and a strong need to leave so I tried to find the exit door, but there were several doors in this room, and I was very disoriented.