Petition for Rehearing — Alvin Sheldon Kanofsky, Petitioner v. Commissioner of Internal Revenue
Supreme Court briefMay 18, 2018
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IN THE
SUPREME COURT OF THE UNITED STATES
ALVIN S. KANOFSKY PETITIONER
VS.
COMMISSIONER OF THE IRS RESPONDENT
-
JEFF SESSIONS
ATTORNEY GENERAL OF THE UNITED STATES
-
NOEL FRANCISCO
-
SOLICITOR GENERAL OF THE UNITED STATES
ROOM 5614, DEPT. OF JUSTICE
950 PENNSYLVANIA AVE, WASHINGTON, D.C.
PETITION FOR REHEARING
OF PETITION FOR WRIT OF CERTIORARI
THE UNITED STATES 4TH CIRCUIT COURT OF APPEALS ENTERED IN
RICHMOND, VA. CASE NO. 17-1246
DR. ALVIN S. KANOFSKY. 229 E. CHURCH STREET BETHLEHEM, PA 18018
610-867-8064
QUESTIONS PRESENTED TO THE COURT
Is IT UNLAWFUL TO RETALIATE AGAINST WHISTLEBLOWING?
Government statutes state that it is unlawful to retaliate against whistleblowers. The laws state that retaliation will result in penalties against the
individuals or entities retaliating.
The Petitioner has acted as a whistle-blower for many years in these
proceedings, and is currently actively pursuing compensation from the
government for this activity. The petitioner also worked as a government
employee for many years, and the law clearly states that such retaliation by
the government against an employee is severely punishable.
The petitioner worked as a government contractor for some 25 years in
his role as a researcher at government laboratories such as Brookhaven
National Lab, Fermilab west of Chicago, Argonne National Lab, and also
finally the Superconducting Supercollider Laboratory to be build South of
Dallas Texas. As well, he worked as a contractor for for the Naval Air
Development Center in Warminster, as an investigator on radiation effects
on optical fibers and other components. Thus, he claims retaliation by his
former employer, the US government for his whistle blowing activities
,
IS IT UNLAWFUL TO IGNORE AFFIRMATIVE DEFENSES OF FRAUD
AND CORRUPTION? DOES THIS VIOLATE THE FIRST AMENDMENT
FREEDOM OF SPEECH?
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As stated above, the petitioner has frequently claimed fraud and corruption
as an affirmative defense. By not recognizing this defense the government is aiding
and abetting fraud and corruption, and is therefore complicit in these activities and
subject to the statutes against fraud and corruption such as RICO, acting under
color of law, etc.
Petitioner has presented numerous exhibits demonstrating the fraud and corruption
practiced against the petitioner. As well, he has presented many exhibits of Fraud
and Corruption in the societal environment within which he does business.
The government and the Courts have continued to ignore and block this
evidence, to the point of calling it frivolous and irrelevant and have threatened the
petitioner with sanctions of a fine up to $25,000 if he persists and more levies and
garnishments. This indicates that they condone and support the fraudulent and
corrupt activities.
As well, the courts and government have blocked any testimony by witnesses
the petitioner has proposed, where the petitioner can present evidence and
testimony of fraud and corruption, and of his own business activities.
IS IT UNLAWFUL TO IGNORE EVIDENCE OF BUSINESS ACTIVITY?
DOES THIS VIOLATE THE FIFTH AMENDMENT, DUE PROCESS?
The laws clearly state that obstructing justice, aiding and abetting unlawful
activity, acting under cover of law, RICOH, are all unlawful activities and
subject to severe penalties.
The petitioner has presented numerous exhibits of his own business activity
continual, ongoing, and with a purpose of showing a profit. The Court and
government again have chosen to ignore these exhibits and testimony, and have
thus in fact obstructed justice, aided and abetted unlawful activity, acted under
cover of law, and in conspiracy with others in unlawful activity.
-
WAS KANOFSKY TARGETED BECAUSE OF HIS CLAIMS OF FRAUD
AND CORRUPTION? AGAIN, A VIOLATION OF FREEDOM OF SPEECH
A FIRST AMENDMENT VIOLATION
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By threatening Sanctions for Claiming Fraud and Corruption, the Court was
targeting Kanofsky. In fact, it appears that this new ruling of the court to be able to
impose sanctions for frivolous and irrelevant statements may have been a direct
result of the Kanofsky Cases in the Court. Affirmative defenses are seemingly
allowed by the court, but seemingly not in Kanofsky's case. Was Kanofsky's
Freedom of Speech violated?
INVOLVEMENT WITH NSA SURVEILLANCE CASES. KLAYMAN, ACLU
GOVERNMENT RETALIATION SEARCH AND SEIZURE WITHOUT
WARRANT PROBABLE CAUSE FOURTH AMENDMENT.
-
-
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Since all of the Kanofsky Cases have been handled in the Federal Third
Circuit Court of Appeals by the Department of Justice, and that Kanofsky was
continually critical of the United States and indeed served in a whistleblower
status as did Edward Snowden in revealing the government surveillance
program, it is reasonable to assume that Kanofsky was in fact subjected to the
surveillance that the national security agencies maintained on other high profile
people who were critical of government activity.
Thus, it it is highly probable that his phone communications, internet
communications, etc. were monitored without his knowledge and under the
government program revealed by Snowden. This violates his fourth amendment
rights of the constitution against illegal search and seizure without a warrant.
As well, it is worth noting that Kanofsky has worked as a consultant to the
U.S. Supreme Court Chief Justices' father when he was head of Bethlehem
Steel. Chief Justice Roberts oversees the FISA court, making appointments and
monitoring its operation. The FISA court, of course, oversees the operation of the
NSA Surveillance. The Petitioner has repeatedly requested that Justice Roberts
recuse himself from considering his Previous Petitions, but to no avail.
6. DID GOVERNMENT RETALIATE BECAUSE OF KANOFSKY'S
INVOLVEMENT WITH THE PHILADELPHIA L&I SCANDAL, AND
DEATHS DUE TO BUILDING COLLAPSE? FURTHER EXAMPLE OF
FRAUD AND CORRUPTION.
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Kanofsky recently won a case against the Licenses and Inspections Bureau of
the City of Philadelphia, again citing Fraud and Corruption. The ruling of the lower
district court was overturned by the State Commonwealth Court on Appeal and
Remanded back to the lower Courts for a Further Reduction in the amounts
charged against Kanofsky
In addition, Kanofsky is asking compensation for seizures of valuable articles
from the family home and for pain and suffering. As well, while the case was being
litigated there was the devastating Kensington Warehouse Fire killing two firemen,
and the tragic collapse of the wall in downtown Philadelphia at the Salvation Army
Store resulting in six deaths and numerous injuries, both supposedly which
resulted in numerous injuries to people trapped beneath the wall debris. Both of
these cases were supposedly monitored and supervised by the Philadelphia Licenses
and Inspections Bureau.
The Kanofsky case was remanded back to the lower, court for a further billing
Reduction, but the other claims were denied, and are now again being appealed
upward to the State Supreme Court.
Many of the claims of Kanofsky in this case apply to the tragic incidents and
Kanofsky will remain active in supporting the claims of these victims and their
families in the Salvation Army and Kensington Fire Tragedies, as related to
malfeasance of the Philadelphia Licenses and Inspections division.
DID GOVERNMENT RETALIATE BECAUSE OF PETITIONER'S
INVOLVEMENT WITH GROUPS DENIED NON-PROFIT APPROVAL
SUCH AS THE CONSERVATIVE GROUPS AND THE JEWISH GROUPS?
FIRST AMENDMENT PROTECTS ALSO FREEDOM OF ASSOCIATION
AS INTERPRETED BY THE SUPREME COURT.
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As is well known, Kanofsky is active in Jewish affairs, and as well his
involvement with Israel. Is he being targeted in the same way as the conservative
groups and Israel supporter groups were targeted in applying for non-profit status.
Government continues to retaliate against Kanofsky for Claiming Freedom of
Speech, Whistle blowing, for due Process, etc. By piling more penalties and fines
and refusing to recognize his legal business activities.
DID GOVERNMENT DENY PETITIONER THE RIGHT TO A FAIR TRIAL,
AS REQUIRED BY THE SIXTH AMENDMENT I.E. THE RIGHT TO
HAVE WITNESSES, AND PRESENT EVIDENCE?
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Justice Department Response:
"The Tax Court acted well within its discretion in excluding exhibits offered by
taxpayer that were not relevant to his federal income tax liability for 2006 and
2007."
"Court acted properly by not allowing timer to schedule witnesses."
Statement of the standard or scope of review from pg. 28, of brief of Justice
Department to Appeals Court.
"The taxpayer also seeks to challenge the Tax Court's Rulings at trial excluding
some of his exhibits as irrelevant to the issue of taxpayers federal income tax
liability for 2006 and 2007. (Br. 2.6) The tax Court's decision to exclude evidence is'
reviewed for abuse of discretion to exclude evidence is reviewed for abuse of
discretion. See e,g, Polack v. Commissioner, 366 F. 3rd 608 612 (8th Cir. 2004);
Drobny v. Commissioner, 113 F. 3rd 670 684 n. 23 (7th Vit 1997); Little.
Commissioner, 106 F. 3d 1445, 1449 (9th Cir. 1997)
"The tax court acted well within its discretion in excluding certain trial
exhibits offered by taxpayer. At the beginning of the trail taxpayer submitted a
commingled pile of papers that the court referred to as a stack of documents and
taxpayer admitted that I realize that they could be considered irrelevant. (Doe. 12
at 78)
The court stated that it is I'm sustaining an objection not entirely for relevance but
because the documents are inappropriately collectively marked after urging
taxpayer to pull any documents that you think show deductible expenses, get them
marked, and I will give you a chance to prove them." In response, taxpayer offered
receipts for real estate taxes paid on the property that he described as my mountain
house. He also offered receipts and other records that he asserted he'd paid of real
estate taxes, repairs, and mortgage interest on the building next to Lehigh
University. The court did not admit any of these exhibits into evidence agreeing
with the Commissioner that they were irrelevant to taxpayers federal income tax
liability.
The Tax Court's evidentiary rulings were proper. The Tax Court is required
to conduct its proceedings in compliance with the rules of evidence applicable in
federal district courts, including the Federal Rules of Evidence. See IRC See 7463
Tax Cr. R 143 (a). Rule 401 of the Federal Rules of Evidence provides that evidence
is relevant if (a) the fact is of consequence in determining the the action "All of the
excluded exhibits fail the second part of the test because the taxpayer never
demonstrated that he had ongoing business activities that would permit him to
claim these expenses as a business deductions. As the court noted, these exhibits
were irrelevant and thereby inadmissible because taxpayer had not presented that
the properties in question were used for legitimate puniness purpose that would
have affect (taxpayer's )individual income tax liability. (Doc. 12 at 56) As a result,
the taxpayers expenses were of no consequence in determining the outcome of the
case, and the Tax Court Properly exercised its discretion in excluding these
exhibits."
DID GOVERNMENT VIOLATE EIGHTH AMENDMENT? I.E.
GOVERNMENT CANNOT REQUIRE EXCESSIVE BAIL OR FINES OR
CRUEL AND UNUSUAL PUNISHMENT.
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In determining the Petitioner's tax
liability, by actual direct action of the Secretary of the Treasury,the government
continues to apply the maximum penalties, fines, levies, and garnishment.
SHOULD PETITIONER BE GRANTED A CHANGE OF VENUE ON THIS
CASE?
As stated repeatedly, the Petitioner pursues his business activities in
theThird Circuit Court of Appeals, where fraud and corruption are all
pervasive, the Judges of the Third Circuit Court of Appeals are subjected to
the pressures brought to bear on them to not rule against their friends and
associates, and thus where numerous conflicts of interest exist.
RECENT EVENTS SINCE THE ORIGINAL SUBMISSION
In the interim period between when the first submission of the Petition
was made back in October 23, 2017 and now the following substantive events
have occurred in regard to petitioner's business activities. Most of this is in
regard to his real estate holdings, and how that affects his property values,
business expenses, and taxes.
The Conviction of the Allentown Mayor, Mr. Ed Pawlowski, on 47 Counts
of Fraud and Corruption in Federal Court, out of 54 original counts. This
was prosecuted by the U.S. Attorney General Louis Lappen of the
Philadelphia Office. This is as well a condemnation of the same
organizations that the Petitioner Kanofsky deals with in developing his
properties in the Lehigh Valley.
The Petitioner has had to deal with numerous fraudulent and corrupt
activities by the local entities supposedly representing the interests of the
local governments in the course of the current five year period of intensive
litigation. Many of the corrupt and fraudulent activities were amply in
evidence during the extensive trial in the Allentown Courthouse, and the
U.S. Attorney and his staff need no reiteration from this litigant as to what
they are. As well, they are clearly stated in his numerous court filings.
Petitioner Kanofsky has been a co-defendant with the United States
Government, represented by the local U.S. Attorney, Louis Lappen, in
Philadelphia in these proceedings, by virtue of the IRS liens filed by
the U.S. Government ,and it is required that Attorney Lappen, with
the United States of America as co-defendant, be served through U.S.
Attorney Lappen all the legal papers by the Petitioner.
The completion of the enormous office complex and Parking
Garage 200 feet from the Petitioner's building and lot. The office building will
house various offices of Lehigh University and Saint Luke's Hospital. The
developer is Atty. Dennis Benner.
Initially, Atty. Benner's Realtor, Ms. Lucy Lennon, had approached
the Petitioner with an offer to buy the building for $325 K, which the
Petitioner turned down. They then shifted to a more aggressive approach,
working with the city to pile up numerous violations on the Petitioner,
followed by formal court cases and litigation. The work and expenses that the
Petitioner had put into the building were presented to the Tax Court, and are
the subject of this Supreme Court Appeal, with the Tax Court Judge totally
ruling out any of the massive expenses in repairing the building the years
considered by the Tax Court 2007-2011.
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The City conveniently lost all records of the City when the Petitioner
finally obtained again the right to store objects in his building, and they fired
the Inspector who oversaw earlier work and repairs, Mr. Michael Palos.
There is numerous interim Litigation on numerous legal cases of the
Petitioner's Properties (the Lot and Building).This is presently in
progress in the Pa.State Commonwealth Court and State Supreme Court
with some of the cases now being prepared for the U.S. Supreme Court.
This litigation, with subsequent add-ons could proceed for several years.
Hopefully, the Conservator Ruling by the City of Betlehem and the
County Court will eventually be totally overturned by the Courts as totally
illegal and improper with proper compensation awarded to the Petitioner.
Other new developments are now in progress in the neighborhood.
These include the purchase of the Sands Casino Property down the Street
from the Petitioner's properties being purchased for $1.3 B dollars from
owner Sheldon Adelson by an Indian Tribe from Florida. Again, this should
further enhance the value of the Petitioner's properties.
The purchase requires the approval of the State Casino
Gambling Commission, which oversees the Gambling in the State of
Pennsylvania. This is an Alabama Indian Tribe, The Poarch Band of
Creek Indians, with company name Wind Creek Hospitality they
own the Wa She Shu Casino in Gardnerville, Nev. owned by the
Washoe Tribe.
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New Developments in regard to the City management and entities
involved in the development on the South Side of Bethlehem. The large
office complex and parking Garage Project Headed by Attorney Dennis
Benner has been completed in regard to construction and now is being
occupied by staff of Lehigh University and St. Luke's Hospital. This
should further enhance the value of the Petitioner's Properties by at least
a fourfold factor according to Real Estate Lawyers and Appraisers that
the Petitioner has consulted. Thus the appraised property values must be
greatly increased up to and above about $1M.
This amount is far more than what has been approved for than in the
Conservator proceedings.
Continuing Ongoing Litigation in regard to this other real estate
properties in Philadelphia and the Poconos. The house property in the
Poconos is again coming up for a Sheriff Sale, but this property as well is
part of the assets of the Petitioner and the United States of America has a
controlling interest in it which prevents it from being sold.
As well, the house in Philadelphia was sold despite the U.S.
Government having a controlling interest in that as well, and the court
case is coming up the end of the month before a Judge in Philadelphia as
to the resolution of the case.
There have been recent changes in Government, Local (Redistricting),
Nationally, and Worldwide. The congressional district boundaries in the
State of Pennsylvania have been changed to supposedly reduce the
Gerrymandering which supposedly favored the Republican Party. The
new election is the 15th of May.
Conclusion
In conclusion, the Petitioner respectfully requests that this court rule
in his favor and award compensation for loss of income and pain and suffering over
the many years that the City and State and it's various collaborators have
fraudulently and corruptly acted to prevent the Petitioner from pursuing his
business interests and activities.
Sincerely Yours,
V
V
Dr. Alvin S. Kanofky
May i%, 2018
APPENDIX -RECONSIDERATION FILING
RECONSIDERATION OF COURT ORDER DENYING PETITION FOR
ALLOWANCE OF APPEAL OF APRIL 16, 2018
The Petitioner was not responsible for the damage to the building such as the
cracked front window, stucco damage, etc. This was due to the city piling and
shoving snow against his building with a huge front loader after the record
32 inch snowfall of January 22, 2016 The impacts were also responsible for
the roof collapse. This was evident from the total destruction of the adjacent
concrete and steel sewer cover with the remains found on the Petitioner's lot
and against his building's wall. Exhibit A
.
This resulted in numerous citation violations for which Kanofsky was fined
a total of $30K and a sentence of 5 days in prison. Exhibit B
The city has been determined to seize the building of the Petitioner over the
many years he has owned it, with the most recent attempt being the
Conservator proceedings. In the hearing before Judge Beltrami the $30 K in
fines were incorporated into the costs billed against Kanofsky in the
Conservator settlement of funds obtained from the sale of the Petitioner's
building. Exhibit C
,
There was an attempt by the City to silence any opposition with bail and
conditions of Bail. There was a Statement by Judge Zito to the Prosecuting
City Solicitor Matthew lJeschler that :"My impression is he's become a burr
in your saddle so to speak" Zito said to Deschler. "I had to think that the city
of Bethlehem just wants bail to make a statement to be punitive." Exhibit D
The Petitioner discovered a Beltrami Case several years earlier that became
nationally known as one of the top Travesty of Justice cases in the country.
This was a case of a thirteen year old boy who was sentenced by Judge
Beltrami to two years incarceration and restitution of $625 K for setting fire
to a house. The only witness to the case was the woman who owned the
house. Despite the boy's insistence that he was innocent, acting on
the promise of the arresting officer that he could be home for Christmas if he
pleaded guilty, Judge Beltrami imposed the sentence.
It was only several years later that the Judge's stenographer Jane Walker
noticed the same woman who had accused the boy was there for a similar case with
another house. She suspected the woman had wrongfully accused the boy.
Judge Beltrami recused himself. The woman was indeed the guilty one in the
earlier case. The boy was totally exonerated and won $175K for damages in his
wrongful conviction. Exhibit E
There are numerous conflicts of interest with Judge Beltrami. For example,
Sharon Fields (head of Lehigh University Parking Authority) is the ex wife of
Beltrami's High School classmate, John Conahan, who works at the main
Bethlehem Post Office. Prosecuting Attorney, Mathew Deschler Assistant
Solicitor of Bethlehem, was Judge Beltrami's former law clerk. Exhibit F
,
,
Petitioner had a hearing before Judge Zito and with numerous violations
daily given by Bethlehem Chief Inspector Craig Hynes who has now retired,
thus complicating getting testimony. Exhibit G
Chief Inspector Hynes had no records of earlier repairs and work on building
which resulted in the City allowing occupancy by Kanofsky back in 2008.
It was remarkable in that these records were entirely missing from his files. Exhibit
H
The Conservator case was already in process when the trial before Judge
Zito was held, since the calls for proposals had already gone out in September,
2016, with the Conservator papers issued in October. Exhibit I
The city acted to block and delay the broken front window case, finally held
before Judge Murray. The city delayed any appearance on the resurrected
case before a Judge for several months, as can be seen from the Docket on the
case.In any event the court's all agree that Petitioner should be allowed to file
a civil lawsuit on the case as a response. Exhibit J
The Zito Commonweath Case was handed over to the Bethlehem City lawyer,
Matthew Deschler, rather than, as usual, being tried by the State District
Attorney of Northampton County, John Morganelli. Morganelli Is now
running for the United States House of Representatives, with the motto
"District Attorney with a heart." Exhibit K
There was repeated False testimony by all of the city witnesses, including
Redevelopment Director, Tony Hanna, Police Officer Hackett, Chief City
Code Director, Craig Hynes, and Development Director Alicia Karner.
There are numerous examples of Fraud and Corruption in the City of
Bethlehem and the Lehigh Valley. Recently, the Allentown Mayor, Ed Pawlowski,
was convicted of 47 counts of Fraud and Corruption in a case prosecuted by the
Philadelphia office of the FBI, headed by Director Louis Lappen. Attorney Lappen is
also representing the United States of America, with the Petitioners' Conservator
Proceedings.
Some entities involved with Pawlowski are the Chamber of Commerce, the
Economic Development Corporation, Community Development Corporation,
etc.,where these entities represent and serve for the City of Bethlehem, Easton,
and Allentown. Exhibit L
The case before Judge Murray dealt exclusively with the window crack, but
has a major bearing on the Zito Case since the crack and stucco violations
issued were due to the damage by the city's front loader removing snow from
the city street and lot after the record breaking 32 inch snowfall of January
22, 2016, and shoving and piling it against the building wall.
Subsequent removal of the stucco wall, as revealed in later pictures
demonstrate that it served merely a cosmetic function and provided no support or
protection for the underlying wall, as seemingly claimed by the violation notices.
Exhibit M
As well, the files on an earlier building inspection and clean out where
allowance of storage of were allowed, as evidenced by the notification from
the city, were claimed by Chief inspector, Mr.Craig Hynes to be totally nonexistent, as for example the agreement that Kanofsky could store his
personal items in the building.
The Petitioner has just learned that Mr. Craig Hynes, the chief City
Inspector who issued all the citations retired from his city position the beginning
of March 2018. Conveniently, he joins the prior inspector for the City, Mike Palos,
with no longer working for the city, thus making it more difficult for the Petitioner
to have them as witnesses in court proceedings. Exhibit N
13. Judge BROBSON, of Commonwealth Court, has repeatedly ruled against
Kanofsky, even ruling adversely on an earlier case in the Seizure of Petitioner's
building in Philadelphia. His claim in the Commonwealth Court Opinion that the
recent version of KanOfsky can not be accepted by the court, has no basis in reality
and evidence , as shown by the letter from the city, recent discussions with Mr.
John Rohal, the Director of Re-development at the time, and numerous pictures and
court documents of the of the building clean out, bills charged, court litigation, etc.
etc. for the work done on the building roof and walls in 2007,
2008, and allowances by the City, Building inspector Mr. Michael Palos, and
Magistrate Nancy Matos for occupancy by Kanofsky at the time. Exhibit 0
14. The courts have begun to rule in favor of the Petitioner as the become
familiar with the case, with numerous another travesties of Justice.
The Petitioner begs this court to continue in reversing earlier erroneous
decisions based on corrupt and conspiring actions, and provide just compensation
for pain and suffering inflicted on the Petitioner.
Respectfully Submitted,
2018
Alvin S.Kanofsky
".
V
EXHIBIT A
BUILDING DAMAGE FROM FRONT LOADER
EXHIBIT B
ZITO ORDER FROM CITATIONS
EXHIBIT C
CONSERVATOR PROCEEDINGS
EXHIBIT D
CITY ATTEMPT TO SHUT DOWN
PETITIONER'S OPPOSITION
EXHIBIT E
JUDGE BELTRAMI TRAVESTY OF JUSTICE CASE AS GIVEN IN UNIVERSITY
OF MICHIGAN INNOCENCE
PROJECT
• EXHIBIT F
CONFLICTS OF INTEREST
EXHIBIT G
VIOLATIONS ISSUED BY INSPECTOR CRAIG
HYNES
EXHIBIT H
REQUEST FOR PROPOSALS
EXHIBIT I
VIOLATIONS ON CRACKED WINDOW GLASS
EXHIBIT J
BROKEN WINDOW CASE
SHOWING DELAY.
EXHIBIT K
JUDGE MURRAY DECISION AND DOCKET
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JUDGE ZITO COMMONWEALTH CASE DOCKET SHOWING TRANSFER
OF CASE FROM D.A. JOHN MORGANELLI TO CITY ATTORNEY
DESCHLER
EXHIBIT L
FALSE TESTIMONY PAWLOWSKI
ALLENTOWN CASE
-
EXHIBIT M
JUDGE MURRAY CASE BROKEN WINDOW
-
1 *4IHJ zi
CERTIFICATE OF OCCUPANCY
ALLOWANCE
EXHIBIT 0
IN JUDGE BROBSON RULING, IT WAS CLAIMED VIOLATIONS WERE
MAINLY FOR A BROKEN WINDOW AND STUCCO DAMAGE BOTH OF
WHICH PETITIONER CLAIMS WERE CAUSED BY CITY AND NOT A LEAKING
ROOF AND LACK OF A CERTIFICATE OF OCCUPANCY.
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STATEMENT ON REHEARING SUBMISSION.
CASE 17-1271
This is to state that this Petition for a Rehearing on
my Petition for a Writ of Certiorari is submitted in
good faith to not extend the Period of Rejection
but on the basis of new events and material that
has occurred in the interim Period since the original
submission and the present time and is of essential
relevance to the case.
The Petitioner requests that the Court
reconsider the case 17-1271 in view of this additional
relevant information.
Respectfully Submitted,
Dr.
May 18, 2018
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