AZZARELLI

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

JOY LUCRETIA CLARK, :

Plaintiff, :

:

v. : CIVIL ACTION NO. 25-7122

:

CAROLINE AZZARELLI, et al., :

Defendants. :

MEMORANDUM

MARSTON, J. June 15, 2026

Pro se Plaintiff Joy Lucretia Clark initiated this civil action in December 2025 against

The Advocacy Alliance (“the Alliance”) and one of its employees, Caroline Azzarelli, raising

federal and state claims. (Doc. No. 2.) She also moved for leave to proceed in forma pauperis,

which was initially denied without prejudice for lack of sufficient financial information. (Doc.

Nos. 1, 6.) After Clark filed a new motion to proceed in forma pauperis (Doc. Nos. 7, 8), the

Court granted her leave to proceed in forma pauperis and dismissed the Complaint for failure to

state a claim pursuant to 28 U.S.C. § 1915(e)(2)(B)(ii), and for lack of subject matter

jurisdiction, with leave to amend. Clark v. Azzarelli, No. 25-7122, 2026 WL 1045066, at *8

(E.D. Pa. Apr. 17, 2026). Clark has now filed an Amended Complaint, which is ripe for

screening pursuant to § 1915.1 (Doc. No. 15.) For the following reasons, the Court will dismiss

the Amended Complaint and will not provide further leave to amend.

1 The same day she filed her Amended Complaint, Clark separately filed a “Supplemental Notice

of Ongoing Conduct and Additional Evidence,” complaining of Defendants’ failure to acknowledge

documentation she claims to have submitted to them the day before. As the Court advised her previously,

“Clark cannot proceed in this fashion because the Federal Rules of Civil Procedure do not contemplate

piecemeal pleadings or the amalgamation of pleadings, even in the context of a pro se litigant. See Bryant

v. Raddad, No. 21cv1116, 2021 WL 2577061, at *2 (E.D. Pa. June 22, 2021) (“Allowing a plaintiff to file

partial amendments or fragmented supplements to the operative pleading, ‘presents an undue risk of

piecemeal litigation that precludes orderly resolution of cognizable claims.’”) (quoting Uribe v. Taylor,

I. FACTUAL ALLEGATIONS AND PROCEDURAL HISTORY2

According to the Amended Complaint, the Alliance administers special needs trusts “and

related matters affecting the Plaintiff,” and Azzarelli is an employee and agent of the Alliance

who was “directly involved in communications and decisions affecting the Plaintiff.” (Doc. No.

15-1 at 1.) Clark believes that the Alliance receives federal funding. (Doc. No. 15 at 2.) She

also alleges that “[b]eginning in or about 2024, Defendants caused to be submitted an IRS Form

SS-4 using Plaintiff’s Social Security Number without Plaintiff’s knowledge or authorization.”

(Doc. No. 15-1 at 1.) When she later became aware her Social Security Number had been used,

she contacted the Defendants requesting “documentation, and correction.” (Doc. No. 15 at 2.)

Defendants did not provide an adequate explanation or take corrective action. (Id.) She claims

the action “exposed [her] to identity theft risk, financial harm, and potential tax liability.” (Id.)

Clark states that she is being treated for ongoing psychiatric conditions and optic disk

edema, which affect her ability to work, concentrate, manage daily tasks, and deal with stress.

(Id.) She has been unable to maintain a job because of her medical conditions and has been

seeking Social Security Disability benefits since 2024. (Id.) She states that she has required

emergency care, and that her treating physician has “taken [her] out of work . . . due to the

severity of her conditions.” (Id.) Clark alleges that Defendants “were aware of [Clark’s]

medical conditions” and the effect that stress and instability had on her health. (Id.) Clark avers

that from 2024 on, Defendants generally failed to timely respond to communications, process

No. 10cv2615, 2011 WL 1670233, at *1 (E.D. Cal. May 2, 2011)).” Clark, 2026 WL 1045066, at *1 n.1.

Nevertheless, the Court need not apply this rule as nothing in Clark’s supplemental filing would alter the

Court’s analysis regarding Clark’s Amended Complaint.

2 The factual allegations set forth in this Memorandum are taken from Clark’s Amended

Complaint and attachment (Doc. Nos. 15, 15-1). The Court deems the entire submission to constitute the

Amended Complaint and adopts the pagination supplied by the CM/ECF docketing system.

requests, and provide clear answers to her inquiries, and that her health conditions got worse

during that period. (Id.)

Clark initially filed this action asserting violations of her and her son’s rights under the

United States Constitution through 42 U.S.C. § 1983, along with discrimination and retaliation

claims under the Americans with Disabilities Act (the “ADA”), and Section 504 of the

Rehabilitation Act (the “RA”). Clark, 2026 WL 1045066, at *1. She also raised what the Court

construed as an invasion of privacy claim under state law. Id. at *8. Because she improperly

brought the lawsuit on her son’s behalf, all claims asserted for her son were dismissed for lack of

standing. Id. at *4. The Court dismissed the civil rights claims under § 1983 because Clark

failed to plausibly allege that the Alliance or Azzarelli are state actors. See id. Her ADA and

RA claims were dismissed because they were deficient in multiple respects, including that she

failed to plausibly allege that she is a “qualified individual with a disability,” that she was

subjected to discrimination “on the basis of disability,” or that she was retaliated against due to

protected activity. Id. at *7–*8 & n.7. The Court dismissed her state law claims for lack of

subject matter jurisdiction because she did not allege complete diversity of the parties. Id. at *8.

In her Amended Complaint, Clark reasserts claims for discrimination and retaliation

under the RA and an invasion of privacy claim under state law. She includes an additional claim

for negligence under Pennsylvania law. (Doc. No. 15 at 4.) She requests money damages.3 (Id.

at 5.)

3 Clark seeks declaratory relief on her claims. Declaratory relief is unavailable to adjudicate past

conduct, so Clark’s request for this relief is improper. See Corliss v. O’Brien, 200 F. App’x 80, 84 (3d

Cir. 2006) (“Declaratory judgment is inappropriate solely to adjudicate past conduct” and is also not

“meant simply to proclaim that one party is liable to another.”); see also Andela v. Admin. Office of U.S.

Courts, 569 F. App’x 80, 83 (3d Cir. 2014) (“Declaratory judgments are meant to define the legal rights

and obligations of the parties in the anticipation of some future conduct.”). A declaratory judgment is

also not “meant simply to proclaim that one party is liable to another.” Corliss, 200 F. App’x at 84; see

also Taggart v. Saltz, No. 20-3574, 2021 WL 1191628, at *2 (3d Cir. Mar. 30, 2021) (“A declaratory

II. STANDARD OF REVIEW

As Clark is proceeding in forma pauperis, 28 U.S.C. § 1915(e)(2)(B)(ii) requires the

Court to dismiss the Amended Complaint if it fails to state a claim. Whether a complaint fails to

state a claim under § 1915(e)(2)(B)(ii) is governed by the same standard applicable to motions to

dismiss under Federal Rule of Civil Procedure 12(b)(6). See Harris v. Wetzel, 822 F. App’x 128,

130 (3d Cir. 2020); see also Tourscher v. McCullough, 184 F.3d 236, 240 (3d Cir. 1999). A

complaint states a claim if it contains “sufficient factual matter, accepted as true, to state a claim

to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quotations

omitted). At this early stage of the litigation, the Court will accept the facts alleged in Clark’s

Amended Complaint as true, draw all reasonable inferences in her favor, and ask only whether

the Amended Complaint contains facts sufficient to state a plausible claim. See Shorter v.

United States, 12 F.4th 366, 374 (3d Cir. 2021), abrogation on other grounds recognized by

Fisher v. Hollingsworth, 115 F.4th 197 (3d Cir. 2024). But conclusory allegations do not

suffice. Iqbal, 556 U.S. at 678; see also Martinez v. UPMC Susquehanna, 986 F.3d 261, 266 (3d

Cir. 2021) (“A plaintiff cannot survive dismissal just by alleging the conclusion to an ultimate

legal issue.”). And the Court construes the allegations of a pro se complaint liberally. See Vogt

v. Wetzel, 8 F.4th 182, 185 (3d Cir. 2021) (citing Mala v. Crown Bay Marina, Inc., 704 F.3d 239,

244–45 (3d Cir. 2013)).

In addition, the Court must dismiss the action “[i]f the court determines at any time that it

lacks subject-matter jurisdiction.” Fed. R. Civ. P. 12(h)(3); Grp. Against Smog and Pollution,

Inc. v. Shenango, Inc., 810 F.3d 116, 122 n.6 (3d Cir. 2016) (explaining that “an objection to

subject matter jurisdiction may be raised at any time [and] a court may raise jurisdictional issues

judgment is available to define the legal rights of the parties, not to adjudicate past conduct where there is

no threat of continuing harm.”). The Court will therefore dismiss Clark’s request for declaratory relief.

sua sponte”). A plaintiff commencing an action in federal court bears the burden of establishing

federal jurisdiction. See Lincoln Benefit Life Co. v. AEI Life, LLC, 800 F.3d 99, 105 (3d Cir.

2015) (“The burden of establishing federal jurisdiction rests with the party asserting its

existence.” (citing DaimlerChrysler Corp. v. Cuno, 547 U.S. 332, 342 n.3 (2006))).

III. DISCUSSION

A. Claims Under the RA

Clark asserts disability discrimination and retaliation under § 504 of the RA by the

Defendants. (Doc. No. 15 at 4); 29 U.S.C. § 794. “To state a claim under § 504, a plaintiff must

demonstrate that: (1) she is a qualified individual with a disability; (2) she was denied the

benefits of a program or activity of a public entity which receives federal funds; and (3) she was

discriminated against based on her disability.” Bittenbender v. Fam. Servs. Ass’n of Bucks Cnty.,

No. 25-5920, 2026 WL 561128, at *8 (E.D. Pa. Feb. 26, 2026) (quoting Giterman v. Pocono

Med. Ctr., 361 F. Supp. 3d 392, 409 (M.D. Pa. 2019)). Where a plaintiff, like Clark, seeks

compensatory damages, she “must also [allege] intentional discrimination under a deliberate

indifference standard.” Furgess v. Pa. Dep’t of Corr., 933 F.3d 285, 289 (3d Cir. 2019)

(footnote omitted).

First, the claims asserted under the RA are improper to the extent that Clark alleges them

in her Amended Complaint against Azzarelli. Evans v. President of Thomas Jefferson Univ.

Hosp., No. 22-1371, 2022 WL 2916685, at *4 (E.D. Pa. July 25, 2022) (“The proper Defendant

under an RA claim is the entity receiving federal assistance.” (citing A.W. v. Jersey City Pub.

Sch., 486 F.3d 791, 804 (3d Cir. 2007) (explaining that “suits may be brought pursuant to

Section 504 against recipients of federal financial assistance, but not against individuals”))). The

RA claims alleged against Azzarelli will be dismissed.

Second, Clark once again fails to allege plausible facts supporting her assertion that she

was subject to discrimination because of her disability. In the prior Memorandum dismissing

Clark’s claims, the Court concluded that the RA claim was deficient (in addition to other ways)

because Clark did not provide any facts that supported her “sweeping statements that she was

subjected to discrimination.” Clark, 2026 WL 1045066 at *8. As explained in the

Memorandum, a plaintiff must provide facts that “independently permit the court to infer more

than the mere possibility of misconduct.” Id. (citation and internal quotation marks omitted).

But Clark failed to allege any plausible facts in her Complaint that the Alliance denied her the

benefits of a program or activity on the basis of her disability. Id. The Court further instructed

that Clark’s amendment of the RA claim would require her to, “in good faith, allege additional

facts . . . about how her rights as an alleged disabled person were violated.” Id.

Despite that guidance, Clark has not added additional allegations or perceptively changed

her approach in the Amended Complaint. Clark merely claims that the Defendants “were aware

of Plaintiff’s medical conditions.” (Doc. No. 15 at 3.) She does not provide any facts beyond

that conclusory statement that plausibly demonstrate that awareness; this lack of support is

insufficient to state a claim. See Bou v. New Jersey, No. 11-6356, 2012 WL 1600444, at *3

(D.N.J. May 7, 2012) (dismissing RA claim where plaintiff failed to plead sufficient facts

demonstrating that police were aware of plaintiff’s mental illness when they used force). And

even if she had provided such facts, nothing in the Amended Complaint suggests that the

Alliance discriminated against Clark or that it did so based on her disability. Clark states that

Defendants engaged in “arbitrary, inconsistent, and non-responsive conduct,” that “created

instability and uncertainty” for her. (Doc. No. 15 at 3.) According to Clark, the Defendants’

offending conduct consisted of failing “to provide timely, clear, or consistent responses” and

ignoring communications. (Doc. No. 15-3.) These vague characterizations of Defendants’

responses to her inquiries or demands do not plausibly allege the denial of a program or activity

necessary to state a discrimination claim. See John v. Pennsylvania Dep’t of Hum. Servs., No.

24-0781, 2024 WL 3204474, at *5 (E.D. Pa. June 26, 2024) (rejecting RA claim where amended

complaint did not describe services, benefits, or programs from which the plaintiff was allegedly

excluded). Nor do any facts in the Amended Complaint come close to suggesting that the

Alliance discriminated against her on account of a disability. Evans, 2022 WL 2916685, at *5 &

n.8 (noting “parallel definitions of disability” under the ADA and RA and rejecting RA claim in

part because plaintiff made only conclusory allegations he was subject to discrimination because

of his disability); cf. Randolph v. Turgeon, No. 21-316, 2022 WL 22209559, at *7 (M.D. Pa.

May 5, 2022) (recommending dismissal of the ADA claim because “having a disability

concurrently with an adverse event is not enough to state a plausible ADA claim”), adopted by,

2022 WL 22001377 (M.D. Pa. June 9, 2022). And insofar as Clark seeks monetary damages, her

Amended Complaint also falls far short of alleging intentional discrimination under a deliberate

indifference standard.4 Evans, 2022 WL 2916685, at *4. So, the discrimination claims will be

dismissed.

Third, Clark has again failed to state a plausible retaliation claim under the RA.5 To state

a retaliation claim under the RA, a plaintiff must allege “(1) she engaged in protected activity;

4 Deliberate indifference is alleged where “(1) the defendant had knowledge that a federally

protected right is substantially likely to be violated, and (2) the [defendant] failed to act despite that

knowledge.” Evans, 2022 WL 2916685, at *4 (internal quotation marks omitted)). Clark makes no

plausible allegations of this kind in her Amended Complaint.

5 Clark cites only to the RA as the federal basis for her action. She does not appear to allege a

First Amendment retaliation claim under 42 U.S.C. § 1983. Such a claim would fail in any event

because, as the Court explained in its prior Memorandum, neither the Alliance or Azzarelli is a state actor

for the purposes of § 1983. Clark, 2026 WL 1045066, at *4 (“The color of state law element is a

threshold issue; there is no liability under § 1983 for those not acting under color of law.” (quoting

(2) she suffered a materially adverse action; and (3) there is a causal connection between the

adverse action and the protected activity.”6 Kendall v. Postmaster Gen. of U.S., 543 F. App'x

141, 144 (3d Cir. 2013) (citing Fogleman v. Mercy Hospital, Inc., 283 F.3d 561, 567 (3d Cir.

2002)). Clark alleged in her original Complaint that she “asserted legal and disability-related

rights.” (Doc. No. 2 at 3.) As the Court explained in the prior Memorandum, this bald statement

devoid of facts failed to convey “how and when she asserted her rights, and what, exactly,

Defendants did to retaliate against her in response.” Clark, 2026 WL 1045066, at *8 n.7. Yet, in

the Amended Complaint, Clark again relies only on a statement that she engaged in protected

activity by “asserting her legal rights.” (Doc. No. 15 at 3.) For the same reasons as before, this

statement is insufficient to plausibly allege protected activity. Further, objecting to the use of her

Social Security Number and requesting remedial action does not constitute “protected activity”

under the RA since the RA prohibits public entities receiving federal funds from denying

benefits of a program or activity based on disability-based discrimination. See Bittenbender,

2026 WL 561128, at *8. Misuse of a social security number is not an act or practice made

unlawful under the RA.

Moreover, even if she asserted some RA protected right in a manner recognized as

“protected,” Clark has not plausibly alleged causation. Clark needed to allege either “(1) an

Groman v. Township of Manalapan, 47 F .3d 628, 638 (3d Cir. 1995))); see also Massey v. Crady, No.

17-241, 2018 WL 4328002, at *6 (W.D. Pa. Aug. 8, 2018) (“Private citizens . . . are not state actors, and

therefore . . . any § 1983 claims against [them] should be dismissed.”).

6 The RA incorporates by reference the substantive standards of the ADA. Kendall v. Postmaster

Gen. of U.S., 543 F. App’x 141, 144 (3d Cir. 2013) (citing § 504 of the RA, 29 U.S.C. § 794(d), and the

ADA, 42 U.S.C. §§ 12201–04, 12210). Section 503(a) of the ADA prohibits retaliation, providing that:

“No person shall discriminate against any individual because such individual has opposed any act or

practice made unlawful by this chapter or because such individual made a charge, testified, assisted, or

participated in any manner in an investigation, proceeding, or hearing under this chapter.” 42 U.S.C. §

12203(a).

unusually suggestive temporal proximity between the protected activity and the allegedly

retaliatory action, or (2) a pattern of antagonism coupled with timing to establish a causal link.”

M.S. ex rel. Shihadeh v. Marple Newtown Sch. Dist., 82 F. Supp. 3d 625, 636 (E.D. Pa.), aff’d in

part, vacated in part, remanded sub nom. M.S. v. Marple Newtown Sch. Dist., 635 F. App’x 69

(3d Cir. 2015) (quoting Lauren W. ex rel. Jean W. v. DeFlaminis, 480 F.3d 259, 267 (3d Cir.

2007). Under “Retaliation,” in her factual allegations, Clark merely claims that Defendants

ignored her communications, failed to respond to her requests, and “continued inconsistent

conduct.” (Doc. No. 15 at 3.) She provides no temporal proximity between her alleged protected

actions and the conduct, nor does she allege a pattern coupled with timing. For all of these

reasons, the Court will dismiss the claims brought under the RA for failure to state a claim.

B. State Law Claims

Clark also alleges Invasion of Privacy and Negligence claims under state law related to

the alleged misuse of her social security number. (Id. at 4.) Because the Court has dismissed

Clark’s federal claims, the Court will not exercise supplemental jurisdiction under 28 U.S.C. §

1367(c) over any remaining state law claims. Accordingly, the only independent basis for

jurisdiction over any such claims is 28 U.S.C. § 1332(a), which grants a district court jurisdiction

over a case in which “the matter in controversy exceeds the sum or value of $75,000, exclusive

of interest and costs, and is between . . . citizens of different States.” Section 1332(a) requires

“complete diversity between all plaintiffs and all defendants,’ even though only minimal

diversity is constitutionally required. This means that, unless there is some other basis for

jurisdiction, ‘no plaintiff [may] be a citizen of the same state as any defendant.” Lincoln Benefit

Life Co., 800 F. 3d at 104 (quoting Lincoln Prop. Co., 546 U.S. at 89, and Zambelli Fireworks

Mfg. Co. v. Wood, 592 F.3d 412, 419 (3d Cir. 2010) (internal footnotes omitted)). An individual

is a citizen of the state where he is domiciled, meaning the state where he is physically present

and intends to remain. See Washington v. Hovensa LLC, 652 F.3d 340, 344 (3d Cir. 2011). It is

the plaintiff’s burden to establish diversity of citizenship, see Gibbs v. Buck, 307 U.S. 66, 72

(1939); Quaker State Dyeing & Finishing Co., Inc. v. ITT Terryphone Corp., 461 F.2d 1140,

1143 (3d Cir. 1972) (stating that, in diversity cases, the plaintiff must demonstrate complete

diversity between the parties and that the amount in controversy requirement has been met);

Jackson v. Rosen, No. 20-2842, 2020 WL 3498131, at *8 (E.D. Pa. June 26, 2020).

As the Court noted in its prior Memorandum when it considered Clark’s invasion of

privacy claim under state law, diversity jurisdiction requires a plaintiff to satisfactorily plead

complete diversity of the parties. Clark, 2026 WL 1045066, at *8. In her Amended Complaint,

however, Clark does not allege diversity citizenship of the parties. She states that she resides in

Philadelphia, Pennsylvania, but she does not provide any citizenship information in the Amended

Complaint about the Defendants. (Doc. No. 15 at 2.) Clark’s own allegations in the original

Complaint provided that the Alliance is a Pennsylvania-based entity, which would destroy

diversity jurisdiction. (Doc. No. 2 at 2.) So, Clark has not met her burden of alleging complete

diversity to establish the Court’s jurisdiction over any state law claim she intends to pursue, and

her state law claims will be dismissed.

IV. CONCLUSION

For the foregoing reasons, Clark’s claims alleged under the RA will be dismissed with

prejudice for failure to state a claim. See 28 U.S.C. § 1915(e)(2)(B)(ii). The state law claims

will be dismissed without prejudice for lack of subject matter jurisdiction. No further leave to

amend will be given because amendment would be futile.7 See Jones v. Unknown D.O.C. Bus

Driver & Transp. Crew, 944 F.3d 478, 483 (3d Cir. 2019) (amendment by pro se litigant would

be futile when litigant “already had two chances to tell his story”). An appropriate order

dismissing this case will be entered separately. See Fed. R. Civ. P. 58(a).

7 Clark has filed eleven civil actions in this Court since October 2024 and has moved to proceed

in forma pauperis in all of them. Between October 2024 and February 2025, Clark filed seven civil

actions. Clark never stated a plausible legal basis for any claim; rather, all of her cases were dismissed as

frivolous, because she failed to state a claim upon which relief may be granted, or because subject matter

jurisdiction was lacking. See Clark v. Navy Fed. Credit Union, No. 24-5446 (E.D. Pa.), Doc. No. 15

(May 27, 2025 Order dismissing case with prejudice for failure to state Fair Credit Reporting Act, Truth

in Lending Act, or state law claims); Clark v. Experian, No. 25-792 (E.D. Pa.), Doc. No. 7 (July 8, 2025

Order dismissing and closing case for failure to state claims under the Fair Credit Reporting Act and state

law); Clark v. Orphans Court Phila., No. 25-838 (E.D. Pa.), Doc. No. 8 (April 25, 2025 Order dismissing

case with prejudice on immunity grounds); Clark v. TD Bank, No. 25-881 (E.D. Pa.), Doc. No. 8 (May

27, 2025 Order dismissing case with prejudice for failure to state claims under the Gramm Leach Bliley

Act, the Massachusetts Data Breach Notification Law, and the New York Shield Law); Clark v. Dep’t of

Educ., No. 25-883 (E.D. Pa.), Doc. No. 7 (July 21, 2025 Order dismissing claims alleging violations of

the Higher Education Act, Federal Trade Commission Act, the Civil Rights Act , and state consumer

laws); Clark v. PNC Bank, No. 25-cv-885 (E.D. Pa.), Doc. No. 7 (June 17, 2025 Order dismissing

complaint alleging violations of the Fair Housing Act, Consumer Financial Protection Act, the Equal

Credit Opportunity Act with prejudice as frivolous and failing to state a plausible claim); Clark v. SoFi,

No. 25-909 (E.D. Pa.), Doc. No. 6 (June 4, 2025 Order dismissing case with prejudice for failure to state

claims under the National Currency Act of 1863, the Federal Deposit Insurance Act, the Truth in Lending

Act, or the Equal Credit Opportunity Act). Given the volume of cases she filed between October 2024

and February 2025 and that Clark never alleged a viable legal basis for the wide variety of claims she

sought to bring, the Court strongly cautioned her in its June 17, 2025 memorandum in Clark v. PNC Bank

that “the continued abuse of the judicial process and of in forma pauperis status may result in the denial

of an application to proceed in forma pauperis in the future. See Douris v. Middletown Township, 293 F.

App’x 130, 132 (3d Cir. 2008) (per curiam) (affirming district court’s denial of in forma pauperis motion

where litigant ‘repeatedly and unsuccessfully filed lawsuits’ claiming civil rights violations, which

‘required the expenditure of significant judicial resources’).” 2025 WL 1698702, at *1 n.2 (E.D. Pa. June

17, 2025).

Following the warning, Clark filed this matter on December 15, 2025, and proceeded to file three

more civil actions within the first week of January 2026. See Clark v. Davita, Inc., Civ. No. 26-23 (E.D.

Pa.); Clark v. Phila. Dep’t of Hum. Servs., Civ. No. 26-102 (E.D. Pa.), and Clark v. Phila. Parking Auth.,

Civ. No. 26-104 (E.D. Pa.). The latter two matters were dismissed for failure to prosecute and failure to

state a claim pursuant to 28 U.S.C. § 1915(e)(2)(B)(ii), respectively. Due to Clark’s demonstrated history

of filing multiple meritless cases at the same time of varying subject matter, claims, and defendants, and

her return a mere five months after her last case closed (and after she was warned of possible

consequences of abusing the judicial process), the Court issued a stern warning in its prior Memorandum

that the Court would take actions restricting Clark’s meritless filings should she continue to abuse the

judicial process and the in forma pauperis privilege, including in her amended complaints in this case and

in Clark v. Phila. Parking Auth., No. 26-104, and in the statutory screening of Clark v. Davita, Inc., No

26-23. The recent pleadings have not diverged from her well-established pattern. Accordingly, the Court

will take action to limit her ability to file meritless actions in the future. See Clark v. DaVita, Inc., No.

26-23 (Doc. No. 9 (Order to Show Cause)); see also Butler v. Dep’t of Justice, 492 F.3d 440, 445 (D.C.

Cir. 2007) (explaining that a litigant’s right of access to courts “must be counterbalanced by the

traditional right of courts to manage their dockets and limit abusive filings.” (citations and internal

quotation marks omitted)).