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

7 of 52

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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