Petition for Writ of Certiorari — Ronald Douglas, Petitioner v. Eric S. Schmitt, Attorney General of Missouri, et al.
Supreme Court briefAug 25, 2020
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20-6667
IN THE SUPREME COURT OF THE UNITED STATES
No: 19-3700
RONALD DOUGLAS, Petitioner
V.
MO. STATE ATTORNEY GENERAL JOSH HAWLEY & SAID
OFFICE’S OTHER OFFICIALS; CHARLES RETTIG IRS
COMMISSIONER & EMPLS. OF THE IRS; KENNETH ZELLERS
ACTING DIR OF THE MISSOURI DEPARTMENT OF REVENUE
EMPLOYEES OF THE MO. DEPARTMENT OF REVENUE &
THE TREASURER AS CUSTODIAN OF THE SEC. INJURY
FUND; U.S. ATTORNEY GENERAL WILLIAM BARR &
EMPLOYEES OF THE ATTORNEY GENERAL’S OFFICE; THE
TAX COURT; RICK STEVENS, PRESIDENT OF CHRISTIAN
3
HOSPITAL & EMPLOYEES OF CHRISTIAN HOSPITAL
NORTHWEST; AT&T; DR. SETH TILZER; THE BANKRUPTCY COURT
OF THE EASTERN DISTRICT OF MISSOURI: GOVERNOR
MIKE PARSON AND EMPLOYEES OF THE STATE OF MO.;
JUDGE MAURA B. McSHANE; JAY ASHCROFT MO. SEC. OF
COMMERCE & SECRETARY OF STATE; U.S. SECRETARY OF
COMMERCE WILBUR ROSS. THE DEP. OF COMMERCE’S
EMPLOYEES, EMPLOYEES OF NATIONAL TELECOM. &
INFORMATION ADMINISTRATION & THE DIRECTOR OF
THE OFFICE OF TELECOMMUNICATIONS; U.S. SECRETARY
OF THE INTERIOR DAVID BERNHARDT & EMPLOYEES OF
DEPARTMENT OF INTERIOR; THE CITY OF MOLINE ACRES’
ATTORNEY, ITS EMPLOYEES & ITS INSURER; JENNIFER
TIDBALL DIR. OF THE DEPT. OF SOCIAL SERVICES &EMPLS.
OF THE DEPARTMENT OF SOCIAL SERVICES; BETSY DEVOS
OFFICE OF THE CLERK
SUPREME COURT. U.S.
U.S. SECRETARY OF EDUCATION & EMPLS. OF THE DEPT.
OF EDUCATION; CHRIS SLINKARD DIRECTOR OF THE MO.
DIVISION OF EMPLOYMENT SECURITY & EMPLOYEES OF
THE MO. DEPARTMENT OF EMPLOYMENT SECURITY;
COMMISSIONER AJIT PAI, EMPLOYEES OF FEDERAL
COMMUNICATIONS COMMISSION & BRENDAN CARR;
ANNA HU I MISSOURI DIRECTOR OF LABOR & INDUSTRIAL
RELATIONS & EMPLOYEES OF THE LOBOR & INDUSTRIAL
RELATIONS COMMISSION; MARK STRINGER, DIRECTOR OF
THE DEPARTMENT OF MENTAL HEALTH IN THE STATE OF
MISSOURI, EMPLOYEES OF THE DEPT. OF MENTAL HEALTH
& EMPLOYEES OF THE METROPOLITAN ST. LOUIS
PSYCHIACTRIC CENTER; ANDREW SAUL ACTING
COMMISSIONER OF SOCIAL SECURITY & EMPLS. OF THE
SOCIAL SECURITY ADMIN.; THOMAS F. GEORGE OFFICE OF
THE CHANCELLOR & EMPLOYEES OF THE UNIVERSITY OF
MISSOURI ST. LOUIS; ANDREW SAUL CHANCELLOR
(CHAIR) WASH. UNIVERSITY’S VICE CHANCELLOR FOR
HUMAN RESOURCES & EMPLOYEES OF WASH. U.; WASH.
UNIVERSITY POLICE DEPARTMENT & ITS ATTORNEY;
WARNER L. BAXTER CHAIRMAN PRESIDENT & CHIEF
EXECUTIVE OFFICE OF AMEREN CO., EMPLOYEES OF
AMEREN ELECTRIC CO. & ITS INSURER; TYLER ASHER
PRESIDENT OF SAFECO INSURANCE, EMPLOYEES OF
SAFECO NATIONAL INSURANCE & SAFECO GROUP OF
INSURANCE COMPANIES; ADMINR. ANDREW WHEELER,
RONALD DOUGLAS
EMPLOYEES OF THE U. S. ENVIRONMENTAL PROTECTION
P.O. Box 300452
AGENCY & THE FEDERAL INTERAGENCY COMMITTEE ON
St. Louis Mo. 63130
AVIATION NOISE; ACTING REGIONAL 7 ADMINISTRATOR
Cell (314) 662-3161
EDWARD H. CHU, EMPLOYEES OF THE MO. EPA & THE MO. EMAIL ADD
AIR CONSERVATION COMMISSION; ELAINE LAN CHAO U.S. ronalddouglasl23456
SECRETARY OF TRANSPORTATION & EMPLOYEES OF THE
@out!ook.com
FEDERAL AVIATION ADMIN.; ADMINISTRATIVE AIDE TO
THE CHIEF OF POLICE (PRIVATE SECURITY); JANET L.
SCHANZLE SECURITY ARMORED CAR. & ITS INSURERS;
MO. BOARD OF REGISTRATION FOR THE HEALING ARTS
FILED
AUG 2 5 2020
MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS
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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): The District Court of St. Louis County, the United States District Court
Eastern District of Missouri and the United States Court of Appeals for the Eighth Circuit. I
am unable to pay the costs of these proceedings because of my poverty. Whereas, defendants
conspired and fraudulently concealed my medical malpractice lawsuit from me with lies.
deceit, trickery, misrepresentations, fraud, entrapment and attempted murder during the last
thirty-eight years. Hence, I am unable to pay a reasonable attorney fee. Because defendants
refuse to confess in that they have been receiving information about my personal and private
affairs through a sense other than the five major senses and/or through some other type of
communication of their agreements to conspire in such a fashion. Therefore, defendants
conspired and with pretextual arrest, falsely arrested and falsely imprisoned me and caused
me to lose two jobs (Security Armored Car and Pizza Hut). The City of Moline Acres took
my house from me through unlawful condemnation proceedings without just compensation
nor notice. Although I have made diligent efforts to obtain legal counsel. I have been unable
to secure same because of defendants’ conspiratorial and unlawful conduct as contested in
the petition. Where the circuit court and the United States District Court Eastern District of
Missouri erred in dismissing the petition (if dismissal is actually what occurred'). Because
the circuit court had jurisdiction to review the petition under Section 536.150 as a contested
case but refused.
1^1 Petitioner has not previously been granted leave to proceed in forma paupers in any
other court.
^Petitioner’s affidavit or declaration in support of this motion is attached hereto.
□ Petitioner’s affidavit or declaration is not attached because the court below appointed
counsel in the current proceeding and:
□ The appointment was made under the following provision of law:
or
□ a copy of order of appointment is appended.
4^—J
(Signature)
2 of 52
AFFIDAVIT OR DECLARATION
IN SUPPORT OF MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS
I. RONALD DOUGLAS ., am the petitioner in the above-entitled case. In support of my
motion to proceed in forma pauperis, I state that because of my poverty I am unable to pay 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 source
Average monthly amount during
the past 12 months
Amount expected
next month
You
Spouse
You
Employment
$14,600.04
$N/A
$JOB STORE CLOSING
Self-employment
$N/A
$N/A
$N/A
$N/A
Income from real property
(such as rental income)
$N/A
$N/A
$N/A
$NA
Interest and dividends
$N/A
$N/A
$N/A
$N/A
Gifts
$N/A
$N/A
$N/A
$N/A
Alimony
$N/A
$N/A
$N/A
$N/A
Child Support
$N/A
$N/A
$N/A
$N/A
Retirement (such as social
security, pensions,
annuities, insurance)
$N/A
$N/A
$N/A
$N/A
Disability (such as social
security, insurance payments)
$10,528.80
$N/A
$877.40
$N/A
Unemployment payments
$N/A
$N/A
$N/A
$N/A
Public-assistance
(such as welfare)
$N/A
$N/A
$N/A
$N/A
Other (specify):
$N/A
$N/A
$N/A
$N/A
$N/A
$N/A
$N/A
Total monthly income: $25,128.84
Spouse
3 of 52
2. List your employment history for the past two years, most recent first, (Gross monthly
pay is before taxes or other deductions.)
Employer
Address
Date of
Employment
Olivette 66 Service 9398 Olive
Jan. 1999-the present
Olivette 66 Service Center is closing soon____________
Gross monthly pay
$1,120
$.
$.
3. List year spouse’s employment history for the past two years, most recent employee
first. (Gross month Pay is before taxes or other deduction)
Employer
Address
Gross monthly pay
Date of
Employment
N/A
$.
$.
$.
4. How much cash do you and your spouse have? $-0-1 have no spouse__________
Below, state any money you or your spouse have in bank accounts or any in other
financial institution.
Type of account (e.g., checking
has or savings)
Amount you have
Amount your spouse
$4L
$4L
$z0z
$z0z
5. List the assets, and their values, which you own or your spouse owns. Do not list clothing
and ordinary household furnishings.
□ Home
Value see petition
□ Motor Vehicle #1
Year, make & model N/A
Value_________
□ Other real estate
Vale N/A
□ Motor Vehicle #2
Year, make & model N/A
Value_________
□ Other assets
Description N/A
Value________
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6. State every person, business, or organization owing you or your spouse money, and the
amount owed.
Person owing you or
your spouse money
see petition
Amount owed to your spouse
Amount you have
$.
$.
$.
$.
$.
7. State the persons who rely on you or your spouse for support. For minor children, list
initials instead of names (e.g. “J.S.” instead of “John Smith”).
Relationship
Name
Age
None
8. Estimate the average monthly expenses of you and your family. Show separately the
amounts paid by year spouse. Adjust any payments that are made weekly, biweekly,
quarterly, or annually to show the monthly rate.
You
Your spouse
$545
$1 have no spouse
Utilities (electricity, heating fuel,
water, sewer, and telephone)
$125
$N/A
Home maintenance (repairs and upkeep)
$N/A
$N/A
Food
$500
$N/A
Clothing
$25
$N/A
Laundry and-cleaning
$20
$N/A
Medical and dental expenses
$75,000
$N/A
Rent or home-mortgage payment
(include lot rented for mobile home)
Are real estate taxes included? □ Yes No
Is property insurance included? □ Yesl^No
5 of 52
You
Your spouse
$78
$N/A
Recreation, entertainment, newspapers, magazines, etc. $300
$N/A
Transportation (not including motor vehicle payments)
Insurance (not deducted from wages or included in mortgage payments)
Homeowner’s or renter’s
$N/A
$N/A
Life
$N/A
$N/A
Health
$N/A
$N/A
Motor Vehicle
$N/A
$N/A
Other: N/A
$N/A
$N/A
Taxes (not deducted from wages or included in mortgage payments)
(specify): N/A
$N/A
$N/A
Motor Vehicle
$N/A
$N/A
Credit card(s)
$N/A
$N/A
Department store(s)
$N/A
$N/A
Other: N/A
$N/A
$N/A
Alimony, maintenance, and support paid to others
$N/A
$N/A
Regular expenses for operation of business, profession,
or form (attach detail statement)
$N/A
$N/A
$76.593
$N/A
Installment payments
Other (special): N/A
Total monthly expenses:
6 of 52
9. Do you expect any major changes to your monthly income or in your assets or liabilities
During the next 12 months?
I^Yes □ No If yes, describe on an attached sheet.
Olivette 66 Service Center is closing and
see the petition for changes
10. Have you - or will you be paying - an attorney any money for services in connection
with this case, including the completion of this form?
□ Yes iJ^No
If yes, how much?
If yes, state the attorney’s name, address, and telephone number:
11. 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?
□ Yes
If yeas, how much?
If yeas, state the person’s name, address, and telephone number:
12. Provide any other information that will help explain why you cannot pay the costs of
this case.
READ THE PETITION
I, (Ronald Douglas), movant in this case, state that I have subscribed to the foregoing forma
pauperis; that I know the contents thereof; that the information mentioned in this document is,
to the best of my knowledge, true and correct. Therefore, I pray for Certiorari order and the
enjoining of the heretofore said conspiracy, the relators the defendants, their associates and
others;
SWORN
'S
Signature of Affiant SUBSCRIBED AND
to
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before
me
this
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Notary Public My commission
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Signature of Movant Ronald Douglas
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TAMMY RENE HYDE LEE
Notary Public - Notary Seal
St. Louis City - State of Missouri
Commission Number 11234440
My Commission Expires Aug 26, 2023
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