Petition for Writ of Certiorari — R. Susan Woods, Petitioner v. Alina's Real Estate, LLC

DT _

ORIGINAL

W JL

Supreme Court, U.S.

FILED

OCT 1 8 2321

No.

OFFICE OF THE CLERK

IN THE

SUPREME COURT OF THE UNITED STATES

R. Susan Woods,

Petitioner

vs.

Alina's Real Estate, LLC and It's Managers Amaya and Branche,

Respondents (First Circuit No. 20-1991);

Joseph B. Collins, Chapter 7 Trustee,

Respondent (First Circuit No. 20-1992); and

Joseph B. Collins, Chapter 7 Trustee,

In his Official and Individual Capacity,

Respondent (First Circuit No. 20-1993).

On Petition for Writ of Certiorari to

The United States Court of Appeals for the First Circuit

PETITION FOR A WRIT OF CERTIORARI

R. Susan Woods, pro se

P. O. Box 160

Hadley, MA 01035-0160

mobile 413-883-1414

rsusanwoods@gmaiI.com

Questions Presented for Review

(generalized from lower court cases)

a. Under what circumstances is it appropriate for the courts to refuse

accommodation to the disabled?

b. Can a trustee in a bankruptcy matter use personal funds to purchase property

for an estate?

c. Must non judicial foreclosure follow the letter of the laws pertaining thereto?

d. Is court bias against the wrongfully foreclosed excusable, and if so, in what

circumstances?

e. Are bankruptcy exemptions subject to judicial discretion?

f. Is the inability to afford the costs of depositions a barrier to a fair trial?

g. Can a party who expressed interest in purchasing a property scheduled for

foreclosure, but who then declined to bid, be questioned about price rigging

within an adversary proceeding involving the buyer?

h. Can third party buyers be held liable for damages in matters of wrongful

foreclosure?

i. Is it ever appropriate for a bankruptcy trustee to demand escrowed rents from

tenants in cash?

j. Is having and maintaining safe, secure housing implicit relative to the right to

pursue happiness?

k. Does an officer of the Court have discretion to act outside of court authorized

orders? And if so, under what circumstances?

l. Can mortgagors be held liable for "forcing borrowers into bankruptcy"?

m. Are Registers of Deeds accountable to the courts? And if so, how?

n. Under what circumstances can tenants be threatened to vacate a foreclosed

property?

o. When, if ever, is it appropriate to displace a disabled person from their

lawfully occupied home?

p. When, exactly, does the sale of a property occur?

q. Is an officer of the courts personally liable for knowingly making false

representations, material omissions, or engaging in other illegal acts?

r. Are systemically important, too-big-to fail banks omnipotent?

s. Is the res judicata doctrine applicable against defendants?

II of XV

Questions for Review

(Specific to denial of request to proceed in forma pauperis)

1. Matters of due process are raised as to whether the appeal qualifies as

frivolous/not in good faith.

2. Constitutional matters are raised concerning

• property rights,

• indigent court costs law,

• Woods' state law right to the quiet enjoyment of her home, and

• "burdened rights".

3. Matters of jurisdiction are raised as to "voidness".

A. Did the judge err by applying the wrong standard to Woods’s forma pauperis by

requiring of her, because she is indigent, a litmus test on her right to appeal which is

not applied to those similarly situated who are not indigent (an apparent violation of

equal protection and due process, Amendments XIV and V)?

B. Did the judge err in apparently relying on opposing bankruptcy trustee’s

characterizations of Woods as litigious, when, beyond her control and against her best

judgment and, actually, physical capacity, bankruptcy rules require appeal of every

interlocutory decision, or you waive your appeal rights?

C. Did the judge err in declaring Woods’s appeals frivolous or vexatious, if such a

standard could even Constitutionally be applied, given the following:

III of XV

1. The jurisdictional issue of whether the bankruptcy judge can apply Federal equity

powers where a plain, adequate and complete remedy at law exists?

2. The jurisdictional issue of whether the bankruptcy judge can exercise her Federal

equity powers over a province of state law, where a state law provides a plain,

adequate and complete remedy?

3. Where issues as to the lower court’s jurisdiction had been raised, could the judge

foreclose on Woods’s right to appeal for the benefit of the court, where the only

question with a forma pauperis is the use of court resources going forward?

4. Where the question of the lower court’s jurisdiction was a central issue in the

appeal, is it not a removal of Woods’s due process rights to deny her an

opportunity to appeal and be fully heard, as guaranteed in such a situation?

5. Given that a review of the evidence is necessary to demonstrate the lower court’s

abdication of its obligation to review the veracity of a trustee’s report can only

be shown through the evidence?

6. Where the lower court judge’s avoidance of reviewing the relevant state statutory

requirements in an area that is the province of state law is only reviewable by

reviewing the evidence in the record, especially where Woods brought the

correct statutory interpretation to the attention of the lower court judge.

IV of XV

D. Did the Court err in not reviewing the evidence of Woods’s limitations, given her

disability in any deficiency in the record, where she brought her limitations on

disability to the attention of the Court?

E. Did the Court err in, even if the frivolous or vexatious standard had been applicable,

not reviewing de novo the violations of Massachusetts law in relationship to areas of

state province: real property law (mortgaging, transfer of mortgage and note and

foreclosure by sale requirements) and possession of property?

F. Did the judge err in not scheduling an evidentiary hearing as the only means of

reviewing de novo the evidentiary based determinations by the lower court judge,

where no discretion is to be given to a review of documentary evidence?

Public Interest Questions Raised bv These Cases

G. Given an unprecedented number of federal and state government lawsuits

against the mortgage servicers, lenders, and foreclosing entities, with

unprecedented size settlements, and vast evidence of illegal systemic practices,

and given that the very wealthy banks pauper their victims in predatory loans

and foreclosures, is it not especially in the public’s interest that a financial bar

not be used to stop the prosecution of what the jurisprudential record shows are

unusually likely to have been illegal actions by the huge predatory lending and

foreclosure industry?

V of XV

H. Given that Massachusetts foreclosure laws allow for (what a minority of states

still allow for) non-judicial foreclosure, where even the steps that are reviewed

by the courts as not reviewed as to the legal regulatory and jurisprudential

requirements for legal, not-void foreclosures, is it not especially in the public’s

interest that the claimed violations of those laws of the land be reviewed for

due process and equal protection violations as well?

I.

Given that those purportedly foreclosed are likely to be impoverished and

likely to be made homeless and to have their health harmed, is it not in the

public interest to make sure the Bankruptcy Trustees and Courts are required to

respect the laws of the state in this area, and the foreclosure related laws in the

state (given that real property and possession laws are provinces of state law),

the federal jurisdictional limits given the likelihood of the number of those

facing foreclosure or post foreclosure eviction are likely to have to file a

bankruptcy?

VI of XV

Additional Parties to the Proceedings

No. 20-1991: Wells Fargo Bank, National Association*

No. 20-1992: Martin Amaya Barazza (fraudulent claim)

No. 20-1993: Goldman Sachs Mortgage Company**; Andrea O'Connor;

Mickey Long and Cora Long

Related Cases

• Woods v. Alina's et al, No. 20-1991, U. S. Court of Appeals for the First Circuit.

Judgment entered April 27, 2021.

• Woods v. Alina's et al, No. 3:20-cv-30026, U. S. District Court for the Western

District of Massachusetts. Judgment entered October 22, 2020.

• Woods v. Alina’s etal, APNo. 18-03019, U. S. Bankruptcy Court for the

District of Massachusetts. Judgment entered February 4, 2020.

• Woods v. Collins, No. 20-1992, U. S. Court of Appeals for the First Circuit.

Judgment entered April 27, 2021.

• Woods v. Collins, No. 3:20-cv-30047, U. S. District Court for the Western

District of Massachusetts. Judgment entered October 22, 2020.

• Collins v. Woods, AP No. 19-03012, U. S. Bankruptcy Court for the District of

Massachusetts. Judgment entered February 28, 2020.

• Woods v. Collins, No. 20-1993, U. S. Court of Appeals for the First Circuit.

Judgment entered April 27, 2021.

• Woods v. Collins, No. 3:20-cv-30060, U. S. District Court for the Western

District of Massachusetts. Judgment entered October 22, 2020.

• In re: R. Susan Woods, No. 18-30549, U. S. Bankruptcy Court for the District of

Massachusetts. Judgment entered April 8, 2020.

* ** The banking entities are listed for liability purposes.

VII of XV

Associated Cases as of 10/15/21

(All Cases are in Massachusetts)

-Open Cases in Bold-Cases pending re-opening in italicsOpening Date

Date of Judgment

1. 9/05/17

W. Housing Ct, No. 17H79SP003929 (Alina’s v. Woods)

6/7/18

2. 2/12/18

W. Housing Ct, No. 18H79SP000663 (Goldman v. Woods)

withdrawn

3. 3/12/38

Mass. Land Ct., No. 18MISC000146 (Goldman v. Woods)

4/23/21

4. 4/10/18

5/1/18

5. 7/10/18

Mass. Appeals Ct., No. 2018-J-0158 (Woods v. Alina's)

Bankr. Ct., No. 18-30549 (C.7, sought stay)

ongoing

6. 7/12/18

Bankr. Ct.,A.P.No. 18-03019, (Woods v.Alina’s, illegal eviction)

42/4/20

7. 9/21/18

Mass. Supreme Judicial Ct., No. SJ-2018-0427 (appeal of bond)

7/22/20

8 2/15/19

US District Ct., No. l:19-cv-10321-DJC (appeal order to sell)

9. 2/19/19

US District Ct., No. 3:19-cv-30023-DJC (appeal contempt)

6/7/19

6/7/19

10: 2/27/19

Mass. Superior Ct., No. 1980CV00040 (remandpending)

transferred

11. 2/28/19

US District Ct., No. 3:19-cv-30028-DJC (appeal order vacate)

6/7/19

12. 2/28/19

US District Ct., No. 3:19-cv-30030-DJC (appeal 2nd contempt)

6/7/19

13. 3/04/19

US District Ct., No. 3:19-cv-30029-MGM (re-openingpending)

transferred

14. 3/08/19

Bankr. Ct., A.P. No. 19-03010, Woods v. Collins (illegal eviction)

6/6/19

15. 3/20/19

Bankr. Ct, A.P. No. 19-03012, Collins v. Woods (denial discharge)

2/28/20

16. 6/20/19

US District Ct, No. l:19-cv-11379-DJC (appt dismissal A.P. 03010)

74/1/20

17. 7/12/19

First Circuit, No. 19-1698 (from l:19-cv-10321)

2/11/20

18. 7/12/19

First Circuit, No. 19-1702 (from 3:19-cv-30023)

2/10/20

19. 7/12/19

2/10/20

20. 7/12/19

First Circuit, No. 19-1703 (from 3:19-cv-30028)

First Circuit No. 19-1704 (from 3:19-cv-30030)

21. 8/15/19

22. 8/27/19

Mass. Supreme Judicial Ct., No. SJC-12794 (recon. pending)

BAP, No. 19-038 (Woods v. Alina’s, Protective Order)

7/16/20

9/23/19

23. 11/04/19

BAP, No. 19-052 (Woods v. Alina’s, Claim #2)

11/12/19

24. 2/18/20

US District Ct, No. 3:20-cv-30026-LTS (from A.P. No. 18-03019)

10/22/20

25. 3/13/20

US District Ct, No. 3:20-cv-30047-LTS (from A.P. No. 19-03012)

26. 4/22/20

US District Ct, No. 3:20-cv-30060-LTS (appl. denial m. void sale)

10/22/20

10/22/20

27.11/04/20

First Circuit, No. 20-1991 (from 3:20-cv-30026)

4/27/21

28.11/04/20

First Circuit, No. 20-1992 (from 3:20-cv-30047)

4/27/21

29.11/04/20

First Circuit, No. 20-1993 (from 3:20-cv-30060)

4/27/21

30. 3/10/21

BAP, No. 21-006 (abandon claims, dismissed by Woods)

withdrawn

31. 4/23/21

BAP, No. MS 21-014 (transferred by Collins to US District Ct.)

transferred

32. 6/22/21

Mass. Appeals Ct., No. 2021-P-0561 (appeal dismissal)

9/7/21

33. 6/23/21

34. 5/07/21

Mass. Appeals Ct, No. 2021-J-0287 (L.C. denial of costs vacated)

6/30/21

US District Ct., No. l:21-cv-10754 (appl. vex., denial Notes)

ongoing

VIII of XV

2/10/20

Table of Contents

Questions Presented................................................

II

Parties & Related Cases..........................................

VII

Associated Cases......................................................

VIII

Table of Contents.....................................................

IX

Index of Appendices................................................

IX

Table of Authorities.................................................

X

Opinions Below........................................................

1

Jurisdiction.............................................................. .

1

Constitutional and Statutory Provisions Involved

3

Statement of the Case....................

7

Reasons for Granting the Petition

15

Conclusion........

17

Proof of Service

(separate document)

Index of Appendices

Appendix A: Decision of the U.S. Court of Appeals, No. 20-1991

Appendix B: Decision of the U. S. District Court, No. 3:20-cv-30026

Appendix C: Order of U. S. Court of Appeals Denying Rehearing

Appendix D: Decision of the U.S. Court of Appeals, No. 20-1992

Appendix E: Decision of the U. S. District Court, No. 3:20-cv-30047

Appendix F: Order of U. S. Court of Appeals Denying Rehearing

Appendix G: Decision of the U.S. Court of Appeals, No. 20-1993

Appendix H: Decision of the U. S. District Court, No. 3:20-cv-30060

Appendix I: Order of U. S. Court of Appeals Denying Rehearing

Appendix J: Statement by Attorney Sarah McKee

Appendix K: Doctor’s Note re: Covid during trial Woods v. Alina's

IX of XV

Table of Authorities

Acosta Abreu v. United States, 308 F.2d 248, 248 (1st Cir. 1962) (per curiam)

Adjartey v. Central Division of the Housing Court Department,

481 Mass. 830 (2019)

Allis v. Billings, 6 Mete. (Mass.) 415, 30 Am. Dec. 744

Andrew Robinson Int'l, Inc. v. Hartford Fire Ins. Co.,

547 F.3d 48,52 (1st Cir. 2008)

Attorney General v. Dime Savings Bank, 413 Mass. 284 (1992)

Ayala Serrano v. Gonzalez, 909 F.2d 8, 15 (1st Cir. 1991)

Bank ofAmerica, N.A v. Ceferino S. Rosa, 466 Mass. 613 (2013)

Barefoot v. Estelle, 463 U.S. 880, 893 (1983)

Baugh v. Taylor, 117 F.3d 197, 201 n.18 (5th Cir. 1997)

Benefits Ins. Agency v. Arkison, 134 S. Ct. 2165, 2172 (2014)

Berish v. Bornstein (2002) 437 Mass. 252, 270-271

Bonan v. Boston, 398 Mass. 315, 320 (1986)

Bongaards v. Millen, 440 Mass. 10, 15 (2003)

Boston v. Massachusetts PortAuth., 364 Mass. 639, 645 (1974)

Bui v. Ma, 62 Mass. App. Ct. 553,579 (2004)

Burlingham v. Crouse, 228 U.S. 459, 473 (1913)

Butner v. United States, 440 U. S. 48 (1979)

Chace v. Morse, 189 Mass. 559, 561 (1905)

Chipman v. Massachusetts Bay Transp. Authy., 366 Mass. 253, 256, 316 N.E.2d

725 (1974)

cert, denied, 449 U.S. 829, 101 S.Ct. 96, 66 L.Ed.2d 34 (1980)

Commonwealth v. Bernardo B. supra at 168

Commonwealth v. Fremont Investment & Loan, 452 Mass.

733,897 N.E. 2d 548 (2008)

X of XV

Commonwealth v. King, 374 Mass. 5, 20 (1977)

Commonwealth v. Lockley, 381 Mass. 156, 160 (1980)

Commonwealth v. McLeod, 437 Mass. 286,294 (2002)

Commonwealth vs. Reginald Souza, 397 Mass. 236, quoting Commonwealth v.

Lockley, 381 Mass. 156, 160 (1980)

Commonwealth v. Washington W., 457 Mass. (2010)

Commonwealth v. Welosky, 276 Mass. 398, 401, 177 N.E. 656 (1931)

Coppedge v. United States, 369 U.S. 438 (1962)

Crosby v. Bradstreet Co., 312 F.2d 483 (2nd Cir.) cert, denied,

373 U.S. 911 (1963)

Cuppettv. Duckworth, 8 F.3d 1132, 1148 (7th Cir. 1993) (en banc) (Ripple, J.)

Curtis v. Leavitt, 15 N. Y. 9, 90

Danca v. Taunton Savings Bank, 385 Mass.l, 8, 429 N.E.2d 1129, 1133 (1982)

Daniels v. Coleman, 253 S.C. 218 (1969)

DeLongv. Hennessey, 912 F.2d 1144, 1147 (9th Cir. 1990)

Deutsche BankNatl. Trust Co. v Gabriel, 81 Mass. App. Ct. 564, 565-566 (2012)

Douglas v. California, 372 U.S. 353

Draper, supra, 372 U.S. at 499, 83 S.Ct. at 781

Eaton v. Fed. Nat. Mortgage Ass rn, 462 Mass. 569, 584-85 (2012)

Eaton v. Federal National Mortgage Association, 93 Mass. 216 (2018)

Ellis v. United States, 356 U.S. 674, 674 (1958)

Exec. Benefits Ins. Agency v. Arkison, 134 S. Ct. 2165, 2172 (2014)

Fafardv. Lincoln Pharmacy ofMilford, Inc., 439 Mass. 512,515 (2003)

Fed. Nat. Mort. Ass’n. v. Gordon, 91 Mass. App. Ct. 527,

Frostv. Johnson, 256Ala. 383 (1951)

Green v. Pettingill, 47 N.H. 375 (1867)

Gupta v. Quincy Med. Ctr., 858 F.3d at 662-63, 664-65

XI of XV

Hanlon v. Rollins, 286 Mass. 444, 447, 190 N.E. 606 (1934)

Harper v. Virginia Bd. ofElections, 383 U.S. 663)

Herbert v. Sullivan, 123 F.2d 477, 478 (1st Cir. 1941)

Home Sav. Bank ofAmerica, FSB v. Camillo,

697 N.E.2d 134, 45 Mass.App.Ct 910 (1998)

HSBC Bank USA, N.A. v. Norris, 83 Mass. App. Ct. 1115; 983 N.E.2d 749 (2013)

HSBC Bank USA, N.A., Trustee v. Matt. 464 Mass. 193, 200 (2013)

Industrial Fin. Corp. v. State Tax Commn., 367 Mass. 360, 364,

326 N.E.2d 1 (1975)

In re: Felice, 480 B.R. 401, (Bankr. D. Mass. 2012)

In re Green, 669 F.2d 779, 781 (D.C.Cir. 1981)

In re Krebs, 527 F.3d 82,85 (3d Cir. 2008)

(quoting H.R. Rep. No. 95-595, at 126 (1977))

In re Mark Bell Furniture Warehouse, Inc., 992 F.2d 7, 8 (1st Cir. 1993)

In re Old Cold, LLC, 879 F.3d at 384

In re Powell, 851 F.2d 427, 431 (D.C.Cir. 1988)

InterFirst Bank Dallas, N.A. v. Risser (Tex.App. 1987) 739 S.W.2d 882, 905

Jaycox v. E.M. Harris Bldg. Co., 754 S.W.2d 931 (Mo. Ct. App. 1988)

Jinwala v. Bizzaro, 24 Mass. App. Ct. 1, 3-4 (1987)

J.R. Insulation Sales & Servs., Inc. v. P.R. Elec. Power Auth,

482 B.R. 47, 52 n.l (D.RR. 2012)

KHALSA vs. SOVEREIGN BANK, N.A., 88 Mass. App. Ct. 824 (2016)

Jarrett v. U.S. Nat. Bank of Oregon (1986)

Law v. Siegel, 571 U.S. 134 (2014)

Lee v. Clinton, 209 F.3d 1025, 1026 (7th Cir. 2000)

XII of XV

Lincoln Nat. Bank & Trust Co. v. Shriners Hospitalfor Crippled Children

(Ind. Ct. App. 1992) 588 N.E.2d 597, 600

Lindsey v. Normet, 405 U.S. 56 (1972)

Litton Business Sys., Inc. v. Commissioner ofRevenue, 420 N.E.2d 339,

383 Mass. 619, 622(1981)

Logan v. Zimmerman Brush Co., 455 U.S. 422 (1982)

Martin-Trigona, 737F.2dat 1270-74

Marrama v. Citizens Bank, 549 U.S. 365 (2007)

Massachusetts Comm'n Against Discrimination v. Liberty Mut. Ins. Co.,

371 Mass. 186, 190-191 (1976)

Matt, 464 Mass, at 200

Matter of Green Charitable Trust (1988) 172 Mich. App. 298, 330-31

McCausland v. York, 133 Me. 115 (1934)

McDonald v. Board ofElections, 394 U.S. 802,807

McDonough, 457 Mass, at 514, 528

McKaskle v. Wiggins, 465 U.S. 168 (1984)

Meunier's Case, 319 Mass. 421, 423, 66 N.E.2d 198 (1946)

Mexico Construction and Paving v. Thompson (In re Thompson), Case No.

11-32924, Adv. Pro. No. 12-03065 (Bankr. D. Conn May 22, 2014)

Moore v. Dick, 187 Mass. 207, 211 (1905)

More v. Urbano, 151 Conn. 381 (1964)

Moy, 906 F.2d at 470

Murphy v. Barnard (1894)

Nature Church v. Assessors ofBelchertown, 384 Mass. 811 (1981)

Newlin v. Helman, 123 F.3d 429, 433 (7th Cir. 1997)

O’Brien v. Director of the Div. ofEmployment Sec., 393 Mass. 482, 487,

488, 472 N.E.2d 253 (1984)

XIII of XV

Oliver, 682 F.2d at 445

Oliver v. NewburyportIns. Co., 3 Mass. 37, 1807 WL 721,3 Am.Dec. 77

Pariseau v. Brockton, 135 F. Supp. 2d 257, 263 (D. Mass. 2001)

Pate v. Stevens, 163 F.3d 437 (7th Cir. 12/24/1998)

Pavilonis v. King, 626 F.2d 1075, 1079 (1st Cir.)

Pelfresne v. Williams Bay, 85 F .2d 877, 883 (7th Cir. 1989)

People v. Shall, 9 Cow. (N. Y.) 778, 7S4

Pernell v. Southall Reality, 414 U.S. 363 (1974)

Reade v. Sec'y of Com., 472 Mass. 573, 578 (2015)

Rental Property Management Services v. Hatcher, 479 Mass. 542 (2018)

Rome v. Braunstein, 19 F.3d 54, 60 (1st Cir. 1994)

Pires at 829, 836

Rodriquez v. United States, supra, 395 U.S. at 330, 89 S.Ct. at 1717

Rutgers v. Waddington, 1784, New York City Mayor’s Court

Saxon Theatre Corporation ofBoston v. Sage, 347 Mass. 662, 666-667,

200 N.E.2d 241,244-245 (1964)

Scaplen v. Blanchard, 187 Mass. 73, 76 (1904)

Second Bank-State St. Trust Co. v. Linsley, 341 Mass. 113, 116(1960)

Seppala & Aho Constr. Co. v. Petersen, 373 Mass. 316, 320 (1977)

Serezze v. YWCA ofW. Mass., Inc., 30 Mass. App. Ct. 639, 644 (1991)

Shammas v. Merchants Natl Bank, C.A. No. 90-12217, 1990 WL 354452,

*6 (D. Mass. Nove. 9, 1990)

Sires v. Gabriel, 748 F.2d 49, 51 (1st Cir. 1984)

Slama v. Attorney Gen., 384 Mass. 620, 624 (1981)

Stern v. Marshall, 564 U.S. 462, 482 (2011)

Stern v. Marshall, 564 U.S. at 469

XIV of XV

Sullivan v. ChiefJustice for Admin. & Mgt. of the Trial Court,

448 Mass. 15,21(2006)

Tennessee v. Lane, 541 US. 509, 516, 524 (2004)

The Bank ofNew York Mellon v. Cairns, MISC 17-000037, Oct. 5, 2018,

Land Court, ss. Piper, J

The Woodward School For Girls, Inc. v. City Of Quincy (2014) 469 Mass.

151, 174-175

Travelers Cas. & Sur. Co. ofAm. v. Pac. Gas <£ Elec. Co., 549 U.S. 443,

450-51 (2007)

Tripati v. Beaman, 878 F.2d 351, 352 (10th Cir. 1989)

Turner v. Johnson & Johnson, 809 F.2d 90, 95 (1 Cir., 1986)

Tweedy v. United States, 276 F.2d 649, 651 (per curiam) (9th Cir. 1960)

United Church of the Medical Center v. Medical Center Com.,

689 F .2nd 693, 701 (7th Cir. 1982

U.S. Bank Nat. Ass'n v. Ibanez, 458 Mass. 637, 646, 647 n.16 (2011)

US. Bank Natl Ass ’n v. Schumacher, 5 N.E.3d 882, 891 (Mass. 2014)

U. S. Natl Ass'n, Tr. ofJ P Morgan Mort. Acq. Tr. v. Ayrton,

No.l6H85SPCV000757, Housing Court, Worcester, ss., 8/23/16, Horan, J

Warren v. James, 130 Mass. 540 (1881)

Waters v. Min Ltd., 412 Mass. 64, 66 (1992)

Whitehead v Shattuck, 11 S.Ct. 276 (1891)

Wilbur v. Maine, 421 F.2d 1327 (1st Cir. 1970)

Williams v. Resolution, 417 Mass, at 383

Williams v. Resolution GGF Oy, 417 Mass. 377, 382-383 (1994)

Wood, 705 F.2d 1515, 1523, 1526

XV of XV

Opinions Below

None found.

In re Woods (vs. Alina's) - United States Court of Appeals, First Circuit. April 27,

2021 Not Reported in Fed. Rptr. 2021 WL 1799849.

In re Woods (vs. Joseph Collins) -United States Court of Appeals, First Circuit.

April 27, 2021 Not Reported in Fed. Rptr. 2021 WL 1806568.

Jurisdiction

The date judgments sought to be reviewed were entered in each case is 4/27/21.

The date of order respecting requests for rehearing in each is 7/19/21.

Woods seeks review of denial of her in forma pauperis motions, which had

the predictable effect of terminating her appeals. This Court has jurisdiction for

appellate review under Article III, Section 1 of the U.S. Constitution. Woods'

petition is timely, wherein she timely filed for full panel rehearings in each matter,

each having been denied on 7/19/21.

Woods hereby notifies the Court that there may be further related and/or

associated cases coming before this Court, for which she may seek deferred

consideration.

Rule 12.4 Statement

There are three cases concurrently filed before this Court in which R. Susan

Woods, Petitioner, appealed dismissals from the U.S. District Court to the U.S.

Court of Appeals for the First Circuit, which affirmed the dismissals. The

1 of 19

judgments in each involve nearly identical or closely related questions. Thus, a

single petition seeks review of three judgments.

Note on Number of Related and Associated Cases

One might assume from a cursory review of the number of cases listed, and

from the Trustee's and other opponents of Woods complaints about her

vexatiousness and frivolousness, or lacking in good faith, that such

characterizations are accurate. Rather, those characterizations may be an elaborate

deception by design.

The Honorable Justices and Clerks are asked to consider the following:

• Woods occupies defensive postures throughout these proceedings.

• Woods is pro se, with no legal training, and as such the demands of having to

constantly respond to her opponents' assaults in the various courts, for which

each generally has specific rules and procedures that must be adhered to, is

enormously stressful and not of Woods' choosing.

• Woods suffers from several serious and complicating health diagnoses, which

further compromises her ability to respond timely and fully to the demands

configured by her opponents in the various tribunals.

• Woods has not ever intended to nor willfully engaged in actions to harass, delay,

or frustrate judicial economy and/or the swift administration ofjustice, of which

she may otherwise be a victim of her opponents' intentions thereto. Rather, she

prays for swift, just resolution to these and associated matters.

2 of 19

Constitutional and Statutory Provisions Involved.

Including Regulations

Bankruptcy Act of 1898

Declaration of Colonial Rights, First Continental Congress

Magna Carta, Establishment of Principles of Common Law

Massachusetts Constitution, Article I

Massachusetts Constitution, Article II

Massachusetts Constitution, Article X, Right to Protection of Property

Massachusetts Constitution, Article XI, Injuries to Property

Massachusetts Constitution, Article CXIV

Massachusetts Declaration of Rights, Article XI

United States Constitution, Article I

United States Constitution, Amendment V

United States Constitution, Amendment VI

United States Constitution, Amendment XIV

United States Declaration of Independence

"An Act preventing unlawful and unnecessary foreclosures," St. 2012

"An Act clearing titles to foreclosed properties"St. 2015, c. 141

Americans with Disabilities Act, Title II

Article 11 of the Massachusetts Declaration of Rights

11 U.S.C. § 101(14), Fiduciary to Certify Disinterestedness

11 U.S.C. § 305

11 U.S.C. §324, Removal of Trustee or Examiner

11 U.S.C. § 327, Professionals Employed by Trustee, Disinterestedness

11 U.S.C. § 328(c)

11 U.S.C. § 362(d)(1), Automatic Stay

11. U.S.C. §363(b), (f), (k), (n), (p)

3 of 19

11 U.S.C. § 522(k)

11 U.S.C. §523(a)(6), Exceptions to Discharge

11 U.S.C. §541

11 U.S.C. § 541(a)(3)

11 U.S.C. § 541(a)(5)

11 U.S.C. § 541(a)(6)

11 U.S.C. §704 (a) (2), (a)(3), and (a)(5)

11 U.S.C. §727 (a) (6) (A), Discharge

18 U.S.C. §154 Adverse Interest & Conduct

18 U.S.C. §241, Conspiracy Against Rights

18 U.S.C. § 242, Deprivation of Rights Under Color of Law

18 U.S.C. § 371: Conspiracy Against Rights

18 U.S.C. § 1001: False Statements

18 U.S.C. § 1341: Mail Fraud

18 U.S.C. § 1343: Wire Fraud

28 U.S.C. § 158(c)(1), Appeals

28 U.S.C. § 332(d)(1), Judicial Councils of Circuits, Necessary & Appropriate

Orders

28 U.S.C. § 586

28 U.S.C. § 1334(c)(1)

28 U.S.C. § 1334(e)(2)

Fed. R. Bankr. R 2014

Fed. R. Bankr. P. 6004(d)

Fed. R. Bankr. P. 9006(b)(1)

Federal Rule of Appellate Procedure 24(a)(3)

Rule 24(a)(4)(B)

Fed. R. App. P. 24(a)(5)

4 of 19

Fed. R. Civ. P. 12(b)(1)

F.R.C.R Rule 60 (b)(4)

F.R.C.P. Rule 60(d)(1)

F.R.C.R Rule 60(d)(3)

H.R. Rep. No. 95-595, at 126 (1977)

LR 83.6(5)(A), Rule 205, Disciplinary Referrals By Bankruptcy Judges

18 U.S.C. §§ 152, 157, and 3571 (fraudulent claims-Alina's, Collins)

28 U.S.C. §1915

28 U.S.C. § 1915(a)(3)

MBLR 2014-1

Mass. 209 CMR18.21A

Mass. 940 CMR 7.08: Validation of Debts

Mass. Chapter 513 of the Acts of 1983

Massachusetts Equal Rights Act (MERA)

93 A, M.G.L. c. 12 Unjust Enrichment

Massachusetts General Laws, Chapter 93, § 103 (a)

Massachusetts General Laws, Chapter 106 §§ 3 & 9

Massachusetts General Laws, Chapter 183.5(B)

Massachusetts General Laws, Chapter 183, §21

Massachusetts General Laws, Chapter 184, § 18,

amended by St. 1973, c. 778, § 1

Massachusetts General Laws, Chapter 186A

Massachusetts General Laws, Chapter 186 §14

Massachusetts General Laws, Chapter 235 §34

Massachusetts General Laws, Chapter 239, Sections 1 & 3

Massachusetts General Laws, Chapter 239, Sections 4

Massachusetts General Laws, Chapter 239, Sections 9 &10

5 of 19

Massachusetts General Laws, Chapter 244, Section 14

Massachusetts General Laws, Chapter 244, Section 15

Massachusetts General Laws, Chapter 244, § 35B

Massachusetts General Laws, Chapter 244, § 35C

Massachusetts General Laws, Chapter 260, § 120

Massachusetts General Laws, Chapter 266. § 30: Larceny by False Pretenses

Massachusetts General Laws, Chapter 261 §§27A-G

Mass. R. Civ. P. 12(h) (3)

Mass. R. Civ. P. Rule 60(b)(4)

Mass. Rules of Conduct Rule 3.1: Meritorious Claims and Contentions

Mass. Rules of Conduct Rule 3.3: Candor Toward the Tribunal

Mass. Rules of Conduct Rule 3.4: Fairness to Opposing Party and Counsel

Mass. Rules of Conduct Rule 3.5: Impartiality and Decorum of the Tribunal

Mass. Rules of Conduct Rule 4.1: Truthfulness in Statements to Others

Mass. Rules of Conduct Rule 4.4: Respect the Rights of Third Persons

PTFA, the federal Act Protecting Tenants in Foreclosure

/

Racketeer Influenced and Corrupt Organizations Act (RICO)

Restatement (Second) of Contracts § 208 (1981)

Restatement (Third) of Trusts §100 (2012)

Restatement (Third) of Trusts: Prudent Investor Rule § 208 (1992)

Restatement (Second) of Trusts § 208 (1959)

Rules of Judicial Misconduct Rule 3 (h)(3)(B)

Unif. Commercial Code, § 2-302. Unconscionable Contract or Clause

U.S. District Court L.R. 203.8013(c)

6 of 19

Statement of the Case

The instant three cases and each of the 31 current related and associated

cases, as well as the 3 cases from 2012 referenced in the district court's orders,

arise from predatory lending which resulted in wrongful foreclosure or attempts

thereto.

All (3) cases arise from matters appealed from the Bankruptcy Court, (i) an

appeal from an adversary proceeding in which Woods seeks claims against Alina's

R.E., LLC et al for admittedly illegal eviction in defiance of the automatic stay; (ii)

an appeal of denial of discharge against Woods; and (iii) an appeal of the denial of

the Woods' motion to void sale of her 70 Russell Street property due to numerous

violations of law thereto. Matters of voidness were raised but ignored in the second

and third evictions.

Woods sought and was refused evidentiary hearings thus far in the state

Housing Court, the state Land Court, the Bankruptcy Court, the state Superior

Court, and the U.S. District Court. The Land Court matter and the Bankruptcy

Court matter are currently under appeal. The Superior Court matter is subject to

remand for which motions for re-opening, remand, and sanctions have been filed,

although they have not been acted upon; intentional delay may be indicated.

The Housing Court matter has been appealed to the state Supreme Judicial

Court, wherein reinstatement of Appeals Court cases dismissed due inability to pay

onerous appeal bond orders and inapplicable use and occupancy fees are sought.

7 of 19

The SJC case awaits Woods' motion for reconsideration. Woods is joined by 24 co­

plaintiffs in the SJC matter.

Related previous matters before the First Circuit in 2019 were not decided

on the merits due to Woods' serious illness.

A related matter before the First Circuit in 2012 and 2013 can not and does

not apply to the instant matters because the named banking entity is different, thus

res judicata is inapplicable. The 2012 matter was also decided prior to recent case

law which renders the decision in Woods v. Wells Fargo no longer applicable.

Further, res judicata does not apply, as far as Woods can discern, to defendants.

Woods occupies defensive postures in each of the related and associated cases

since the 2012/13 First Circuit matter was heard and decided.

Each matter hereto was appealed by Woods and heard in the US District

Court by a single justice, who dismissed all three appeals summarily for "chronic

failure to comply with the scheduling deadlines governing litigation she has elected

to pursue"1 in the first matter and "lack of good faith"2 in the second and third

matters, affirming the decisions and orders of the Bankruptcy Court.

Woods timely appealed further to the First Circuit, which affirmed the

district court's determination that good faith was lacking, additionally denying the

1 This is in light of Woods' well documented serious, multiple health diagnoses, and in light of

limited access to courthouses due to the Covid-19 Pandemic restrictions.

2 This is in light of Woods' defensive posture in each and all associated matters.

8 of 19

IFP motions stating "Appellant has failed to identify any non-frivolous argument

on appeal".

The trustee appellee's motion to dismiss in the latter two matters was

allowed. "After careful review of the parties' filings and the record" the motion to

dismiss was granted because the court concluded that the appeal did not present a

"substantial question" and that for substantially the reasons set out by the district

court, affirmance was in order. The judgment of the district court was summarily

affirmed and any remaining pending motions were denied as moot. These rulings

are in contradiction to stare decisis of this Honorable Court. The rulings contradict

law and statute as well.

Woods now seeks review of denial of her IFP motions, which had the

predictable effect of terminating her appeals and rendering her remaining motions

moot, for which Woods also seeks redress. Without allowance to proceed in forma

pauperis Woods could not continue to prosecute her defenses of her properties.

Woods, a disabled, seriously ill woman made homeless by the courts three times

over was denied access to the First Circuit Court of Appeals, and thus was denied

access to justice due to poverty.

Woods has effectively been sidetracked from defending her properties to

defending her right to appeal. Meanwhile her health continues to deteriorate,

especially in light of being made homeless. This is a predictable outcome of the

illegal evictions.

9 of 19

It should be noted that jurisprudence after 1971 clarified two elements that

appear to have been lost in modem practice: (1) that the burden of showing that the

defenses are frivolous rests on the Plaintiff, not the Defendant, so that an extra

burden is not put on the person who has been deemed indigent.

“The Supreme Court in Draper, supra, 372 U.S. at 499, 83 S.Ct. at 781,

emphasized that its decision which invalidated rules of the State of

Washington governing the provision of transcripts to indigent

defendants does not prevent a State from applying “nondiscriminatory

rules to both indigents and nonindigents in order to guard against

frivolous appeals.” Pires at 829, 836.

And (2) that in all such appeal costs waiver jurisprudence, the nonfrivolousness of appeals must be determined evenhandedly. Either all appeals are

tested for their non-ffivolousness or if they are only tested for their nonfrivolousness in cases where an appeal costs waiver is sought it would then be a

discriminatory practice.

“The Court in Rodriquez also criticized the Ninth Circuit rule for

requiring the court to screen out purportedly unmeritorious appeals

contrary to the ruling of Coppedge v. United States, 369 U.S. 438, 82

S.Ct. 917, 8 L.Ed.2d 21 (1962); Id. Coppedge did not prohibit the

screening of appeals, but it did establish that the government, when

opposing an attempted criminal appeal in forma pauperis, bears the

burden of proving that the appeal is lacking in merit. Id. at 448, 82

S.Ct. 917. This rule prevents indigents from having “an

additional hurdle to clear just because their rights were violated

at some earlier stage in the proceedings.” Rodriquez v. United

States, supra, 395 U.S. at 330, 89 S.Ct. at 1717.

lOof 19

Case No. 20-1992 is a case of the Bankruptcy Court approving denial of

discharge relying on verbal and written misrepresentation of fact and law,

omissions of required documents that would demonstrate illegalities by the

Chapter 7 Trustee, Joseph B. Collins (“Collins”), and denial of Ms.

Woods’ (“Woods") legal rights.

Collins reversed course after qualifying the matter as a “no asset case” to

one where he used his own funds to purchase title to Woods’ second property, 70

Russell Street, Hadley (“70 Russell”), purportedly taking it into the bankruptcy

estate (“Estate”) via a release deed a full two months after the case commenced.

Collins then emptied 70 Russell by threatening Woods’ tenants who wished to

remain residing in it, misrepresenting the explicit Massachusetts’ statutory eviction

requirements to the Court, followed by constructively evicting Woods from it, and

liquidated it by a non-longer authorized Trustee sale. This used Bankruptcy

equitable powers to clean a title that Goldman Sachs Mortgage Company

(“Goldman”) had been sufficiently convinced was clouded by its own practices

that it had commenced a quiet title case against Woods; for $10, Goldman sold its

purported post foreclosure title to a property worth approximately $243,000.

For the estate to sell 70 Russell, Collins needed to increase the creditor

claims against the estate enough to require the 70 Russell equity to satisfy them.

Woods had filed this bankruptcy to stop an imminent eviction; she had little debt.

11 of 19

A denial of discharge prevents Woods from continuing to prosecute against

a.) Collins, b.) the purported third party buyers of 70 Russell, Attorney Mickey and

Cora Long (“the Longs”), c.) Goldman’s wrongful foreclosure of 70 Russell, d.)

the purported third party buyers of 43 West, Alina’s Real Estate, LLC, relative to

their bogus claim, e.) A purported Wells Fargo, N. A. REMIC Trust3 (“Wells

Fargo”), for wrongful foreclosure of 43 West, and f.) Korde & Associates, RC.,

who conducted both wrongful foreclosures.

Woods’ actions in occupying her own second property and relying on any

eviction having to comply with state law was under color of law. Woods further

had every right to rely on the limitations the lower Court put on its own orders.

However, the lower Court granted Collins contempt orders for Woods’ actions

under color of law and that provided a basis for denial of discharge.

Due to Woods having so little debt, the trustee fabricated and inflated claims

to justify his liquidation of the property, in which Amaya is an interested party to

conspiring with the Trustee, Joseph B. Collins, in seeking unjust enrichment by

making a false claim, that of Claim #2, in the amount of $15,638.53, which was

subsequently compromised to $10,083.04.

Woods has had to defend her properties in the Massachusetts Western

Housing Court (“WHC”), Land Court, Appeals Court, Supreme Judicial Court

3 Wells Fargo Bank, National Association, as Trustee for Securitized Asset Backed Receivables

LLC Trust 2005-FR2 Mortgage Pass-Through Certificates, Series 2005-FR2.

12 of 19

(“SJC”), the Bankruptcy Court, the B.A.P., the U.S. District Court, and the First

Circuit. This is her first certiorari petition.

The Court has held that no “reasonable person” would consider Woods’

arguments, however, Woods is unclear how the court reached that conclusion.

On January 7, 2011, the Mass. SJC, in the Ibanez decision (which impacted

courts across the United States), established that a purported mortgagee in order to

foreclose had to have a fully executed assignment prior to the foreclosure sale and

that it be recorded for best practice.

A supermajority of the Mass legislature and the Mass. Governor took it a

step farther and concurred. They codified that a complete chain of assignments

needed to be recorded and that those recorded assignments needed to be on notice

to the world, therefore included in any advertising.

Given that this was only passed into law in 2012 as an amendment to MGL

Chapter 244 section 14, not surprisingly there is not a top court decision upon it.

Still, the authority of the Mass, legislature and the Mass. Governor, and their intent

(which represents more than 100 people in agreement with Woods) agreed the

critical legal nature of the requirement to have those assignments, and to publish

all assignments. This hardly leaves Woods without reasonable persons in

agreement with her.

Voidness underlies and permeates all three cases, most especially no.

20-1993. The legal meaning of voidness likewise stands in a long tradition and a

13 of 19

court cannot affirm a void act. That has been true for well over 100 years of settled

jurisprudence.4 Therefore, the timelines of challenging a matter that was without

subject matter jurisdiction and therefore is void is also well settled law and

therefore represents widespread reasonableness. Again, many reasonable minds

have agreed with Woods over many decades.

The date of execution for conveyance of title is also a long settled matter by

reasonable minds in Mass.

The evidence in this case seems to lead to larger questions. Why are Woods'

opponents expending vast resources in their attempts to quash Woods? Why is

widespread and growing homelessness an accepted norm in our affluent society?

How many preventable deaths due to homelessness and its attendant despair are

acceptable? How many deaths due to wrongful foreclosure and the threat of

foreclosure due to stress are acceptable? Is Petitioner Woods expendable ?

4 See for instance, 1899 treatise, (Kleber, John C, VOID Judicial and Execution Sales and the

Rights, Remedies and Liabilities ofPurchasers Thereat with a BriefDiscussion of Curative

Statutes and Special Statutes Authorizing Involuntary Sales, Library of the University of

Michigan Law School), p. 70:

“VOID AND VOIDABLE SALES... There are sales void by reason of the want of authority

in the court to make or enter the judgment or decree upon which, or the order of sale under

which it’s had... are unconditionally void and of no effect for any purpose and not susceptible

of being validated at the instance of any one. ...

Void and Voidable Defined. In its strict legal signification, a void act is one devoid of legal

force or efficacy, and as a necessary result an absolute nullity, not binding on any one and

wholly incapable of ratification... A voidable act is not void in the sense of being incapable of

giving rise to rights or obligations and not susceptible of confirmation or ratification,

expressly or by implications,...

14 of 19

Reasons for Granting the Petition

The staggering number of foreclosures looming for Americans in the near

future due to the economic hardships for so many people resulting from the

Covid-19 Pandemic has dire implications for families, individuals, and the

economy in general. Chaos looms for the lower courts and the populace if the

banks are allowed to foreclose with impunity. It is critically important that all

foreclosures be scrutinized and minimized as applicable to stem the tide of

economic devastation that has and will surely continue to result if left unchecked.

The lower court decisions are erroneous because misapplied and

misconstrued quoted case law and statutes cited in Justice Sorokin's

memorandums and orders following Trustee Collins' mischaracterizations,

misrepresentations, and material omissions are therefore inapplicable, and were

made with zero regard for Woods' disabilities. These departures are so far from the

accepted and usual course of judicial proceedings as to call for an exercise of this

Court's supervisory power.

In addition to the previously made arguments, Constitutional matters are at

stake relative to Woods’ protected status as a member of a newly created “suspect

class,” that of the wrongfully foreclosed. See Commonwealth v. Washington, Mass,

case law holding that “the Equal Protection clause safeguards not merely against

invidious classification, such as race, but also against ‘an arbitrary classification of

persons for unfavorable government treatment”.

15 of 19

In the Bank ofNew York Mellon as Trustee v. Alton King decision of the

Massachusetts SJC the Court explicitly created a new class which under the 14th

Amendment is properly identified as a “suspect class” because the SJC reversed

even its most recent jurisprudence under Adjartey v. Central Housing Court; it

carved out from constitutional protections, as to indigency, the suspect class of

homeowners post the purported foreclosure.

Given the denial of constitutional rights to access to the court among others,

the Government (in this case the First Circuit Court of Appeals) will have to show

a compelling government interest for excluding such homeowners from their

constitutional rights accorded all other litigants in Massachusetts Courts and

further that excluding them from their ability to protect their interest in property

through the courts based on their inability to pay is the only and most narrow

resolution the First Circuit can find. At this point, post-purported foreclosure

homeowners such as Woods are now being treated disparately as a suspect class,

and as such this Court and all courts appear to be on notice to apply strictest

judicial scrutiny to any request for court action that will deny litigants such as

Woods the ability to equally exercise her rights to property both as to ownership

and as to possession.5

5 Mass. Constitution Article I, separately identifies both acquiring and possessing property as

guaranteed rights. The equal protection of these rights for all Massachusetts residents were

affirmed in 1783 in Commonwealth v. Jennison.

16 of 19

The Supreme Court is implored to exercise its discretionary jurisdiction and

decide the questions involved because the integrity of our judiciary is at stake.

These matters not only have dire consequences for Woods; the consequences for

these cases will ripple through these United States with implications for millions of

Americans. The time to act is upon us.

Conclusion

Woods has repeatedly requested accommodation for her disabilities, many of

which have been ignored by the bankruptcy Court6 and have been apparently

entirely overlooked by the District Court7. This is an affront to the integrity of our

democracy which is intended to guarantee every person equality under the law8.

Woods has suffered two unlawful evictions as a disabled person on behalf of

Alina’s and it’s managers Amaya and Branche, along with a third unlawful eviction

6 See Appendix K, which includes the time of the trial in which Woods stated in open court that

she wasn't well, and the judge failed to halt the proceeding.

7 See Appendix B referencing Woods' repeated missed deadlines rather than making

accommodation for her disabilities.

8 See Rutgers v. Waddington, 1784, New York City Mayors Court; argued by Founding Father

Alexander Hamilton, cross referenced from original sources by William M. Treanor, Georgetown

University Law Center, see William M. Treanor, The Genius of Hamilton and the Birth of the

Modem Theory of the Judiciary, in CAMBRIDGE COMPANION TO THE FEDERALIST (Jack

Rakove & Colleen Sheehan eds., Cambridge University Press, 2017).

17 of 19

on behalf of Trustee Collins and his associate Attorney Andrea M. O’Connor.9

Woods is entitled to redress because the judge’s order dismissing her appeal

in the District Court considers matters outside of the scope of the appeal, while

making erroneous findings and conclusions of fact and law in contravention of the

laws and context to pertaining to the issues on appeal.

Voidness has been raised pertaining to the mortgage documents, the

purported foreclosure, and therefore the Summary Process judgment which gave

rise to the evictions conducted within the jurisdiction of the Bankruptcy Court. The

Void contract, the Void purported foreclosure, and the therefore Void Execution for

possession are void by operation of law; it is simply a matter of a court of

appropriate jurisdiction affirming the void matters as void. Woods’ appeal concerns

matters of fact and law which must be thoroughly considered for due process to be

fulfilled.

Wherefore, this petition should be ALLOWED to proceed in the public

interest, the fair administration ofjustice, and equal access to government services.

9 See Statement by Sarah McKee at Appendix J and entered on the docket on 2/8/21 in case no.

20-1992, which applies equally to case no. 20-1991 given the very similar nexus of facts and

issues raised in each.

18 of 19

Respectfully submitte'

October 18, 2021

R. Susan Woods, Petitioner, pro se

P.O. Box 160, Hadley, MA 01035-0160

mobile 413-883-1414

rsusanwoods@gmail.com

19 of 19