Motion to Proceed In Forma Pauperis — Perry Turner, Petitioner v. City of Los Angeles, California, et al.

No

IN THE

SUPREME COURT OF THE UNITED STATES

?ERY 7VJ4-4.

PETITIONER.

-

(Your Name)

VS.

Cu)' OF LM A h6ZEs

RESPONDENT(S)

MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS

The petitioner asks leave to' file the attached petition for a writ of certiorari

without prepayment of costs and to proceed in forma pauperis.

Please check the appropriate boxes:

Petitioner has previously been granted leave to proceed in forma pauperis in

the following court(s):

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LI Petitioner has not previously been granted leave to proceed in forma

pauperis in any other court.

Petitioner's affidavit or declaration in support of this motion is attached hereto.

LI Petitioner's affidavit or declaration is not attached because the court below

appointed counsel in the current proceeding, and:

LI The appointment was made under the following provision of law:

LII a copy of the order of appointment is

AFFIDAVIT OR. DECLARATION

IN SUPPORT OF MOTION FOR LEAVE TO PROCEED IN FORMA PAUPEF1S

, am the petitioner in the above-entitled case. In support of

Perry 7i/,116'r

nsbiè to pAy

that bc.se of tiert) I

rig, I

my m0ldiun t p?oceed in fO

the costs of this case or to give security therefor; and I believe I am entitled to redress.

1. For both you and your spouse estimate the average amount of money received from each of

the following sources during the past 12 months. Adjust any amount that was received

weekly, biweekly, quarterly, semiannually, or annually to show the monthly rate. Use gross

amounts, that is, amounts before any deductions for taxes or otherwise.

Income'ource

'u/t1' I11!4#i5 Ma1 ,y44.h/'.

Average monthi§ amount during

the past 12 months

Amount expected

next month

You

Spouse

You

Employment

$ 0.00

$ O oa

Self-employment

$32,

Income from real property

(such as rental income)

$_P,

s,V%.4

$/if/A

$4VA

Interest and dividends

$_a, '6

$_AØ9

$ 01 C140

$4/I

$o,oti

Spouse

$/OD.00

$ 41,24

$_ ,O

$

Alimony

$N/A

$'i/A

$ A//4

Child Support

$N/4

$N/A

Retirement (such as social

security, pensions,

annuities, insurance)

$YOO,2

$4'A

$n/A

$4'29

$_d24

$ N/A

$910, 1Z

$N/A

Disability (such as social

ecutity, inurence payments)

$N/4

$i4

$

$4/A

Unemployment payments

$k24

$A,9A

$,'t/4

$_________

Public-assistance

(such as welfare)

$A'A

$,ii

Other (specify): /VeIs

$22,/9

$',4

s2-r0 oc

$4/A

$IS113(

$40

$_ z6 let 8

s/

Gifts

V11r_0-4

P'td iid

icJ,e"

Total monthly income:

$__________

List your employment history for the past two years, most recent first. (Gross monthly pay

is before taxes or other deductions.)

Address

Employer

ni/A

Gross monthly pay

Dates of

$ 'lid'

__

List your spouse's employment history for the past two years, most recent employer first.

(Gross monthly pay is before taxes or other deductions.)

Employer

Address

N/A

A11,4

Gross monthly pay

Dates of

Em:

yment

How much cash do you and your spouse have? s20.62 (MD 5p /%!!)

Mow, state any money you or your spouse have in bank accounts or in any other financial

institution.

Type of account (e.

.,

checki g or savings) Amount you have Amo nt your spouse has

4ck;n4 (ire cJcrs'r; i%4) $ 2.3LS7

$44

$ N/A

.4

$ 441

sAt/A

_

List the assets, and their values, which you own or your spouse owns. Do not list clothing

and ordinary household furnishings.

Home

Value Ago PCO w6kef

EMotor Vehicle #1

/.€1' ~JI Z4^0(

Year, mtke & mOdel &Vit

11 7-m s.

Value 1; ipI4'x/e

dye4i?i&

! Other assets

'^ tZ Afty_cnir

Description/C~

Value 1,/cD

eri

D Other real estate

Value___________

l97 5f5tt

iciotor Vehicle #2

Year, make & mOdel Cider2Iij3mj.

Value S#O1OJ 1/rivibk fra44.

,'

Isfr VJ ,p,tr7'

Y4'4' 7%° c'4e- ,p

eI 41 &'ork,_1//P Jap7 _tl cisci II'

s'tw-;'er 'ced .i AJIc

r

6. State every person, business, or organization owing you or your spouse money, and the

amount owed.

Person awing, you or

your spousernçney

Amount owed to your spouse

Amount owed to you

2.4! l/ø

-1;"ii

,4lo 1qg

I#i(A)

$41/A

'A

$25,vc'

s'it/A

p'Lq

$iv/A

omW

State the persons who rely on you or, your spouse for support. For minor children; list initials

instead of names (e.g.'U.S." instead of "John Smith").

Name

Age

Relationship

/1f'ne

Estimate the average monthly expenses of you and your family. Show separately the amounts

paid by your spouse. Adjust any payments that are made weekly, biweekly, quarterly, or

annually to show the monthly rate.

Your spouse

You

Rent or home-mortgage payment

(include lot rented for mobile home)

Are real estate taxes included? U Yes VNo

Is property insurance included? U Yes t'*o

/1DttJt?

Utilities (electricity, heating fuel,

water, sewer, and telephone)

$6

/41

$/i/,/4

Home maintenance (repairs and upkeep)

/ti.'sf; ,4orne ,3q jso ds,qes7W/ vffra'fr-ad

Food

$ 0, Va

Clothing

$_.5'z?

Laundry and dry-cleaning

$ gyp

Medical and dental expenses

,4kI;4, ,-/t/e14s/ D Vi

5

sN/A$____________

5A

.44

You

Your spouse

Transportation (not including motor vehicle payments)

$9. 38

$4//

Recreation, entertainment, newspapers, magazines, etc.

$_0.00

144

Insurance (not deducted from wages or included in mortgage payments)

Homeowner's or renter's

$ /30 _Pz

SA(4

Life

$__________

AIR

$A%

010

AIM

$ IM,44

$ ,v4

Health /l4Vf4rr v'

01

Motor Vehicle

Other:

WIN

$____________

$,4

Taxes. (not deducted from wages or included in mortgage payments)

(specify): Pc,pe/ty 7x)Yi4M

$1A'/ i

sNA

Installment payments

Motor Vehicle

$_1.32. 4

Credit card(s)

$_2 / 0-0,57

Department stOre(s)

$_'VA4

Other: _____________________

5 ,1/1

Alimony, maintenance, and support paid to others

$______________

$_____________

$/V/ft

Regular expenses for operation of business, profession,

or farm (attach detailed statement) 4ñ'WM47'

Other (specify): Li 494i

Total monthly expenses:

ie'rv7re

$_,'.o8

$__________

Allif

$_________

$

Do you expect any major changes to your monthly income or expenses or in your assets or

liabilities during the next 12 months?

LII Yes 0'To

If yes, describe on an attached sheet.

Have you paid or will you be paying an attorney any money for services in connection

o

with this case, including the completion of this form? fl Yes

-

-

If yes, how much?

If yes, state the attorney's name, address, and telephone number:

Have you paid—or will you be paying—anyone other than an attorney (such as a paralegal or

a typist) any money for services in connection with this case, including the completion of this•

form?

El Yes

V'

No

If yes, how much?

If yes, state the person's name, address, and telephone number:

Provide any other information that will help explain why you cannot pay the costs of this case.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on:

M*rL L,

MOTION DECLARATION ATTACHMENT:

This is an attachment to my foregoing Declaration.

13. ONGOING BUSINESS COSTS:

I design, maintain, and host websites, and manage and fix server security; since mid

1996. I do seasonal artwork on commercial plate glass (an example is interleaved as the

next page) in November and December each year; starting autumn, 1999. I do GIS

mapping, starting 2008. Essential costs of those and of ancillary requests for direct

deposits from RMS are detailed here.

FOR

/YEAR

/MO.

web +mail servers

$132.00

$11.00

ssl+tls

$109.00

$9.08

dedicated addresses

$48.00

$4.00

domain renewals

$383.10

$31.93

printer ink/toner

$32.00

$2.67

fuel/motel

$240.00

$20.00

art supplies

$25.00

$2.08

GIS MAPPING

fuel

$540.00

$45.00

Reverse mortgage direct deposit

facsimiles

$72.00

$6.00

ACTIVITY

WEBSITES

SEASONAL ART

requests [facsimiles fix dates' of

receipt of what I send to RMS]

14. PROPERTY TAX:

Property tax figures going back 12 months take in April half of prior property tax year.

Current property tax itself is $1,482.72; due in two halves of 741.36 (by December 10,

Copyright C 2015 by P. Turner

tXh"/K/T 45t

then April 10). However, current property tax is increased by $3,522.81 to $5,005.53;

due in two halves, $2,502.77 and $2,502.76 (by December 10, then April 10). The City

imposed a $100.00 fine while I could not afford to have mere lawns mowed (while

unkempt yards within a nautical mile of my property increased to 15%), then kept

increasing it with penalties, and finally made it a lien as part of property tax, with no

notice whatsoever to me or anyone else that it would be made part of property tax, which

first appeared in the autumn, 2017 property tax bill. With the claim against LADWP for

$1,960.78 for vehicle damage still unpaid, and with RMS monthly direct deposits

consistently delayed (to near allowed 14 days) or after November also more than allowed

14 days (thus, late), I paid $1,902.77 timely December 10, 2018, then $660.00

(including 10% penalty on $600.00) December 30, 2018. I was also out $300.00 in

expected Nov.—Dec., 2017 income, without funds to support it. The next property tax

payment due is $2,502.76 by April 10, 2018. Thus, Apr+Dec in 2017 was 'not

$121.50/mo. but was $273.28/mo..

CREDIT CARD PAYMENTS:

Credit card payments allow outlay buffering. With my budgeting upset by current

property tax and by the stated monies that have not been disbursed to me (by LADWP)

or have been substantially delayed (by RMS), the difference between my monthly gross

income and my monthly gross outlay has required and still requires that buffering in

order to cope with it as best I can. That difference between the monthly averages

camouflages sudden impact of the property tax surprise in autumn, 2017 (supra, 14).

PROPERTY MAINTENANCE:

Property maintenance consists primarily of gardeners' periodic lawn and leaf

maintenance. The substantial (Ca. $25,000) damage done to the house during home

invasion that gave rise to this litigation is still unrepaired, including, inter alios, replacing

copper piping stolen (in effective entirety) from below the joists and other plumbing

stolen, repairing portions of electrical wiring stolen or mangled below the joists, and

repairing other severe damage throughout the house interior and exterior. RMS has not

disbursed funds for the repairs, and I am still in no position to fund the repairs

otherwise.

17. CIRCUMSTANCES AT LARGE:

The violently forcible home invasion burglary, ransacking, and vandalism effectively

destroyed both my home and virtual fortress (turned into a house) and my life in autumn

of 2013 and afterward. Rather than retired at now 72 years old I am necessarily

semi—retired in a "flat" economy, with more severely limited funds than grownups are

presumably supposed to have to deal with. I am still significantly distracted by the

aftermath from my work as well as from the necessities involved in litigation. The costs

of preparing, duplicating, and mailing a pro forma "booklet" petition are simply- beyond

my reach, notwithstanding that I have the skills to typeset and reproduce one.

true and correct.

I declare under penalty

Date: March 13, 2018.