Petition for Writ of Certiorari — In Re Gary Pfeffer, Jr., Petitioner

Supreme Court briefMar 18, 2023

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APPENDIX TABLE OF CONTENTS

Opinions and Orders

Order of the Supreme Court of the State of

Maryland Denying Petition for a Writ of

Certiorari (December 19, 2022)........................ la

Opinion of the Court of Special Appeals of the

State of Maryland (August 26, 2022)............... 3a

Mandate of the Court of Special Appeals of the

State of Maryland (October 18, 2022).............. 6a

Order of Dismissal of the Circuit Court for

Harford County (February 10, 2022)........... 7a

Rehearing Order

Order of the Harford County Circuit Court of

the State of Maryland Denying Motion for

Reconsideration of Dismissal of Action

(February 22, 2022).....................................

SEE ALSO MEMORANDUM OF POINTS AND

AUTHORITIES ATTACHED.

Background and Scope of Violations/Crimes

This Emergency Petition enumerates the viola

tions/crimes and resulting harms/injuries which

COTTER and CHIMES AGENTS are perpetrating

against all current employees of CHIMES DC, STATE

OF MARYLAND including petitioner using threat,

duress, and/or coercion in order to force said employ

ees into giving up/relinquishing certain unalienable

Rights which according to the Maryland Constitution

and the Constitution for the United States of America

and the Bill of Rights is prohibited by Law.

Black’s Law Dictionary, Fourth Edition, defines

DURESS: “Unlawful constraint exercised upon a man

whereby he is forced to do some act that he otherwise

would not have done . . . where the person is deprived

of his liberty in order to force him to compliance...

threats of bodily or other harm, or other means

amounting to Or tending to coerce the will of another,

and actually inducing him to do an act contrary to his

free will.” See Heider v. Unicume. 142 Or. 410.20 P.2d

384. 385: Shlenskv v. Shlenskv. 369 Ill. 179.15 N.E.2d

694. 698. And, defines COERCION: “Compulsion;

constraint; compelling by force... where one parry is

constrained by subjugation to other to do what his free

will would refuse.” See Metro-Goldwvn-Maver

Distributing Corporation v. Cocke. Tex.Civ.App.. 56

S.W.2d 489: Fluhartv v. Fluhartv. Del. Super.. 8

W.W.Harr. 487.193 A. 838. 840: Santer v. Santer, 115

Pa.Suner. 7, 174 A. 651. 652.

COTTER originally notified all employees of

CHIMES DC, STATE OF MARYLAND on or about

App.26a

October 12, 2021 and mandated all employees to “fully

vaccinate” by the date of December 8, 2021, and in the

interim employees who are not fully vaccinated, or

will not disclose, must comply with testing require

ments per site directions or be subjected to adverse

actions, up to and including dismissal. The “vaccination”

requirements deadline for petitioner, was October 11,

2021 to begin vaccination protocols with “Moderna,”

October 18, 2021 as last possible day to begin

vaccination protocols with “Pfizer”, and December 8,

2021 as last possible day to receive “final dose in a

two-dose vaccine regiment” or receive the “Johnson &

Johnson one-dose vaccine”. (See Exhibit 9, incorpo

rated by this reference as if fully restated herein).

Employees were informed a request for a reli

gious accommodation required clear statement of

sincerely held religious belief, name of the religion,

and identification of any religious practice guiding

objection to immunization including citation of reli

gious texts or supporting documentation from a reli

gious authority. Employees were ordered to “identify

if they have received vaccinations in the past and, if

so, why COVID 19 vaccination poses any particular

concerns.” CHIMES DC policy states “Individuals

granted an accommodation or exemption should be

prepared to submit proof on a recurring basis, of

negative test if required, to meet specific job site

requirements.” Petitioner was informed he would be

subject to mandatory COVID 19 weekly testing (2-3

times per week) at his own cost even if CHIMES DC

granted a request for a religious accommodation.

In response to these unlawful mandates, petitioner

served upon COTTER and CHIMES DC AGENTS

(Notice to Principal is Notice to Agent, Notice to Agent

App.27a

is Notice to Principal) a CONDITIONAL

ACCEPTANCE dated October 12, 2021 and COUR

TESY NOTICE dated October 29, 2021. COTTER and

CHIMES DC AGENTS were provided proper notice

and reasonable opportunity to respond. (See Exhibits

1 and 2, incorporated by this reference as if fully

restated herein).

Public servants in positions of trust (including

officers of public and private companies who were

given authority to uphold the constitution through

state and government officials and given that CHIMES

DC has accepted state and federal funds) have a duty

to timely respond. However, COTTER and CHIMES

DC AGENTS have chosen to remain silent on the

CONDITIONAL ACCEPTANCE and COURTESY

NOTICE and have suffered a default as a consequence,

as they had a legal and moral obligation to speak, to

wit: “Silence can only be equated with fraud when

there is a legal and moral duty to speak or when an

injury left unanswered would be intentionally

misleading.” U.S. v. Prudden. 424 F.2d 1021 (1970):

U.S. v. Tweel. 550 F.2d 297. 299 (1977). and further,

“A default is an omission of that which ought to be

done, and more specifically, the omission or failure to

perform a legal duty. The term also embraces the idea

of dishonesty; or an act or omission discreditable to

one’s profession.” Black’s Law Dictionary; Fourth

Edition. As a result of their silence, COTTER and

CHIMES DC AGENTS initiated the “Doctrine of

Estoppel by Acquiescence” which is now in full force

and effect upon them, to wit: “One’s ‘silence’ may

invoke doctrine of Estoppel by acquiescence.” Carmine

v. Bowen. 64 A. 932 (1906). (See NOTICE OF

DEFAULT dated November 3, 2021 and NOTICE OF

App.28a

ESTOPPEL dated December 8, 2021, Exhibit 3 and 4,

incorporated by this reference as if fully restated

herein).

Petitioner, and those similarly situated hereto,

provided COTTER and CHIMES DC AGENTS the

due process right of notice and opportunity to be heard

and to correct violations of Law and restrict their

actions to the limits placed upon-them by the State

and Federal Constitution. Due process requirements

have been fully satisfied in this matter, whereas, Black’s

Law Dictionary, Fourth Edition defines DUE

PROCESS OF LAW: “Law of the land,” “due course of

lawand “due process of law” are synonymous... The

essential elements of “due process of law” are notice

and opportunity to be heard and to defend...” See

Dimke v. Finke. 209 Minn. 29. 295 N.W. 75. 79: Pi

Maio v. Reid. 13 N.J.L. 17. 37 A.2d 829. 830: People v.

Skinner. Cal.. 110 P.2d 41. 45: State v. Rossi. 71 R.I.

284. 43 A.2d 323. 326: Stoner v, Higginson. 316 Pa.

481. 175 A. 527. 531.

The petitioner made a choice to risk his life and

fortune for the public, yet COTTER and CHIMES DC

AGENTS chose to stand mute and would not timely,

properly or honorably respond to the CONDITIONAL

ACCEPTANCE (see Exhibits 1 through 4, incorpo

rated by this reference as if fully restated herein).

Lack of timely response resulted in tacit agreement

with petitioner, and those similarly situated hereto,

including that COTTER and CHIMES DC AGENTS

do not have any proof of claim regarding their offer or

any Lawful authority in this matter concerning

“COVID-19” “policies,” “directives,” “orders” and

“mandates.” Whereas, “tacit” is defined by

Ballentine’s Law Dictionary, Third Edition: “Silent;

App.29a

not expressed; implied;” and by Bouvier’s Law

Dictionary, 14 Edition, Vol II: “That which although

not expressed, is understood from the nature of the

thing or from the provision of the law; impliedand

by Black’s Law Dictionary, Fourth Edition: “Existing,

inferred, or understood without being openly expressed

or stated, implied by silence or silent acquiescence,

understood, implied as tacit' agreement, a tacit

understanding.” See State v. Chadwick. 150 Or. 645.

47 P.2d 232. 234 (1935).

Although COTTER and CHIMES DC AGENTS

were noticed by petitioner of their Default and Estoppel,

served upon them on November 3, 2021 and December

8, 2021, they have ignored such and continue to

generate new “directives,” “orders,” “mandates,” and

enforcement deadlines concerning the requirement of

all employees of CHIMES DC for submitting “COVID19 Vaccination Status” and adhering to “vaccination”

requirements, or be subjected to disciplinary action

including being put on unpaid leave or termination of

employment. (See Exhibits 14, 15, 17, and 19, incor

porated by this reference as if fully stated herein). As

a result of their continued unlawful activity and

actions against petitioner, and those similarly situated

hereto, COTTER and CHIMES DC AGENTS violated

the Estoppel on or about December 8, 2021 as well as

petitioner’s repeated demands to cease and desist,

thereby accepting and activating the terms and obli

gations of petitioner’s fee schedule for damages on

December 13, 2021 ($200,000 US Dollars for the vio

lation of the estoppel and bill for damages at a mini

mum rate of $250,000 US dollars as well as $2,000 US

dollars per day per man or woman involved, plus any

interest and penalties, until the matter is settled in

App.30a

full), for which COTTER and CHIMES DC AGENTS

are personally liable and petitioner now has a Lawful

claim before this Honorable Court. (See Exhibits 4

through 6, incorporated by this reference as if fully

restated herein).

Consequently, COTTER and CHIMES DC

AGENTS did place petitioner on unpaid leave prior to

exhausting petitioner’s vacation pay without permis

sion. Petitioner is currently on unpaid leave, received

threats of termination effective January 24th 2022

and continues facing possible termination which

constitutes a clear, present, and impending danger to

the Rights and liberties of all CHIMES DC employees

who have not volunteered. Because COTTER and

CHIMES DC AGENTS have continued to violate the

Law and the Rights of their employees by imple

menting enforcement of their draconian “directives,”

“orders,” “mandates,” and “policies” without Lawful

authority or the opportunity for the employees to be

heard or for the matter to be debated, serious depri

vation of all employees’ Rights has taken place.

ENUMERATION OF VIOLATIONS/CRIMES

“COVID-19” “directives,” “orders,” “mandates,” and

“policies” (such as “guidelines” for “physical distancing,”

masking, testing, tracking, “status forms,” or

“vaccinations,” etc.) for employees of CHIMES DC

violate at minimum The Declaration of Rights of the

Maryland Constitution (1867) The Preamble, Articles

1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 13, 17, 19, 24, 36, 40, and 44

as well as the FIRST, FOURTH and FIFTH AMEND

MENTS to the Constitution for the United States of

America (Bill of Rights).

App.31a

Petitioner has suffered serious deprivation of

Rights and Liberties, and is sustaining on-going

irreparable harms and also faces imminent injury if

this Court does not intervene and provide EMER

GENCY INJUNCTIVE RELIEF and Lawful Remedy.

The violations/crimes and resulting harms/injuries

perpetrated by COTTER and CHIMES DC AGENTS

against the petitioner which are enumerated in the

employee’s sworn Declarations, include but are not

limited to the following:

Violation/Claim #1:

COTTER and CHIMES DC AGENTS have caused and

continue to cause harm, injury, and trespass upon

petitioner’s unalienable Constitutionally protected and

secured Rights on an ongoing basis using threat,

duress, and coercion, thereby elevating the nature and

seriousness of their violations against petitioner.

Clarification:

By COTTER and CHIMES DC AGENTS declaring

their intentions to injure and deprive petitioner of his

liberty in order to force him to compliance by compel

ling or coercing him to do some act contrary to his free

will, and in violation of his unalienable Rights,

constitutes a serious trespass upon petitioner and his

unalienable Rights. Their declarations show

forethought and malice indicating a conscious violation

of the Law fatally bent on mischief, admitting their

intentions to work injury to the person, property, and

Rights of petitioner, to inflict punishment, loss, and

pain upon him by seizing and detaining certain

unalienable Rights (which includes, but not limited to

petitioner’s freedom of religion; physical body; free

App.32a

will; mind; and soul), and then requiring some act as

a condition for the surrender of petitioner’s Rights,

which is tantamount to the crime of extortion.

Concerning COTTER and CHIMES DC AGENTS

requirement for petitioner to submit “COVID-19

Vaccination Status” divulging his personal and private

medical information, as well as fulfilling their require

ment for petitioner to take a “vaccination” by Decem

ber 8, 2021 or undergo mandatory recurring COVID

19 weekly testing, this has caused a menace or threat

of such a nature and extent as to unsettle the mind of

petitioner, in order to take away petitioner’s free and

voluntary action which alone constitutes petitioner’s

consent. COTTER and CHIMES DC AGENTS have

made it clear and admitted that they intend to inflict

punishment upon petitioner for non-compliance in the

form of disciplinary action including being put on

unpaid leave or termination of employment, which

constitutes a loss that would inflict pain upon

petitioner, which is a threat to work injury to

petitioner’s person, property, and Rights, with the

view of restraining petitioner’s freedom of action.

Further, COTTER and CHIMES DC AGENTS

are using duress for an unlawful purpose tending to

coerce the will of petitioner and actually inducing him

to do an act contrary to his will. Here, COTTER and

CHIMES DC AGENTS are committing a tortious

seizure and detention of petitioner’s liberty and

unalienable Rights consisting of, but not limited to

freedom of religion; physical body; free will; mind; and

soul of the petitioner who is entitled to these Rights,

and then inducing/forcing petitioner to do an act, such

as divulging personal and private medical information

and getting the so-called “vaccination,” contrary to his

App.33a

FIRST, FOURTH, and FIFTH AMENDMENT Rights,

the Law, his conscience, and better judgment. If

petitioner, relinquishes these Rights due to threat,

duress, and coercion, he no longer owns, nor remains

in control of his freedom of religious belief; physical

body; free will; mind; and soul as he would now be sub

ject to the style of religion or belief system, will, and

control of COTTER and CHIMES DC AGENTS. This

clearly constitutes Duress of Imprisonment by unlaw

fully restraining and depriving petitioner of his liberty

in order to force compliance upon him regarding

“COVID-19 Vaccination Status” and “vaccination”

requirements.

It is clear that COTTER and CHIMES DC

AGENTS, by use of coercion are forcing submission in

a vigorous or forceful manner to constrain petitioner

by subjugation to them in order to get petitioner to do

what his free will would naturally otherwise refuse to

do. The use of threat, duress, and coercion being per

petrated against petitioner, in order to force him to

surrender his unalienable Rights and dignity,

elevates the nature and seriousness of these wicked

and wanton acts on the part of COTTER and CHIMES

DC AGENTS. Again, the threat of punishment, the loss

of emplovment/livelihood. decrease in future earning

potential, and the pain associated with these, as well

as the pain already inflicted bv such threats, duress.

and coercion causing the unsettling of petitioner’s

mind and body verifies the on-going harm, injury, and

trespass committed against petitioner.

Violation/Claim #2:

COTTER and CHIMES DC AGENTS are creating an

unsafe and hostile work environment for petitioner.

App.34a

Clarification:

COTTER and CHIMES DC AGENTS have created

an unsafe and hostile work environment for petitioner

including ongoing incidents of harassment, religious

discrimination, and disrespect of privacy, harm to rep

utation, etc. as well as repeated threats of demotion, loss

of pay and termination of employment (“get vaccinated

or be fired”) for noncompliance with unlawful “COVID19” “directives,” “orders,” “mandates” and “policies”

(such as “guidelines” for “physical distancing,” masking,

testing, tracking, “status forms” or “vaccinations”).

There seems to be a deliberate and persistent

campaign on the part of COTTER and CHIMES DC

AGENTS to use threats, duress, and coercion in an

attempt to force petitioner to relinquish certain

unalienable, Constitutionally protected and secured

Rights and bend to the will of CHIMES DC regarding

“vaccination” requirements. This hostile work

environment and infringements upon individual

liberties is an actual ongoing harm and employees

also face additional imminent injury of pay/job loss for

noncompliance. CHIMES DC AGENTS placed

Petitioner on unpaid leave as of December 31st 2021

after first involuntarily exhausting his accrued paid

time off and notified him he will be terminated as of

January 24th 2022 if he does not submit to their

unlawful demands. Petitioner is at risk of being able

to provide food and shelter for him and his family due

to loss of income and employment.

Violation/Claim #3:

COTTER and CHIMES DC AGENTS are violating

petitioner’s Right respecting the establishment of reli

gion.

App.35a

“Congress shall make no law respecting an

establishment of religion, or prohibiting the free

exercise thereof...”

—Constitution for the United States of America,

FIRST AMENDMENT

Clarification:

It is petitioner’s religious belief that he has been

made free by his Creator, thus he is not a servant of

the government or of men, to wit, “. . . be not ve the

servants of men.” I Corinthians 7:23. To be true to his

Creator and religion, petitioner must reject being

brought under subjugation of others, to wit: “Stand

fast therefore in the liberty wherewith [Creator] hath

made us free, and be not entangled again with the yoke

of bondage” Galatians 5:1. Any attempt to alter

petitioner’s relationship with his Creator by mandating/

requiring something contrary to his own established

religion, is in reality COTTER and CHIMES DC

AGENTS imposing the establishment of their own

style of religion or belief system, that of man-made

control and domination, contrary to the FIRST

AMENDMENT prohibition to do so upon petitioner,

which is unlawful.

Here COTTER and CHIMES DC AGENTS are

attempting to seize control over petitioner’s free will

and freedom of choice of religion and belief system and

impose their own will and belief system upon him, by

using threats, duress, and or coercion to force compli

ance with unlawful “directives,” “orders,” “mandates”

and “policies,” which is an actual and immediate

harm. Petitioner objects to being forced by COTTER

and CHIMES DC AGENTS to convert his longstand

ing and proper role as master of his own religion, body,

App.36a

mind, will, and soul to that of a servant of government

and of men, and submit his will to COTTER and

CHIMES DC AGENTS rather than follow his own

conscience as guided by his Creator, and accept the

belief system of COTTER and CHIMES DC AGENTS

against his will and better judgment, thereby causing

him to turn his back on his Creator, and comprise the

eternal impact of his choices and his relationship with

his Creator whom he relies upon for his life, protection

and sustenance beyond all matters of men, to wit;

“The laws of nature are the laws of God; whose

authority can be superseded by no power on earth. A

legislature must not obstruct our obedience to him

from whose punishments they cannot protect us. All

human constitutions which contradict his laws, we are

in conscience bound to disobey. Such have been the

adjudications of our courts of justice.” Robin v.

Hardaway Cite as: Jeff. 109. 1772 WL 11 (Va.Gen.Ct.)>

page 6. 1772. In the General Court of Virginia.

Petitioner’s freedom of religion is at stake here if he is

being forced to subscribe to another belief system that

conflicts with his own and participate in ways that are

unconscionable and against his religion.

And further, as per petitioner’s sincerely held

religious belief: private, personal, and medical infor

mation, as protected by law, is not the business of

COTTER and CHIMES DC AGENTS, nor does this

information have any bearing on petitioner’s ability to

perform his duties as an employee of CHIMES DC. It

is petitioner’s sincerely held religious belief that he

keep said information private and not share it with

those who do not have his best interests at heart,

which is his right.

App.37a

Violation/Claim #4:

COTTER and CHIMES DC AGENTS are violating

petitioner’s Right to freedom of choice and free exer

cise of religion.

“Congress shall make no law respecting an

establishment of religion, or prohibiting the free

exercise thereof...”

— Constitution for the United States of America,

FIRST AMENDMENT and Maryland Constitution

(1867), Declaration of Rights, Article 36.

Clarification:

COTTER and CHIMES DC AGENTS are

attempting to prohibit petitioner from the free exer

cise of his own religion through use of threat, duress,

and/or coercion, to require him to comply with unlawful

“COVID-19” “directives,” “orders,” “mandates” or

“policies’ which are contrary to his own religious

beliefs and an infringement and violation of his reli

gion body, mind, will, and soul. “Religious beliefs need

not be acceptable, logical, consistent, or compre

hensible to others in order to merit First Amendment

protection.” Thomas v. Rev. Bd. Of Ind. Emn. Sec. Div..

450 U.S. 707. 714 (1981). See also Church of the

Lukumi Babalu Ave. Inc, v. City of Hialeah. 508 U.S.

520. 531 (19931.

Secondly, it is petitioner’s strong religious belief

and stance that injecting a foreign potentially harmful

and deadly substance into his body is not what his

Creator desires for him, to wit: 16 “Know ye not that

ye are the temple of God, and [that] the Spirit of God

dwelleth in you?” I Corinthians 3:16. It is petitioner’s

religious Right and belief to put his trust in his

App.38a

Creator to help him decide for himself what he will

and will not put or allow to be put into his body. Gov

ernment or corporations do not have the Lawful right

to make medical or product consumption decisions for

the People.

It is petitioner’s strong religious belief that where

a human being’s “vaccination status” does not have

any bearing on that individual’s ability or inability to

transmit a virus, that it is immoral and unethical to

declare one group unclean and discriminate against

them by coercing them to wear masks and/or submit

to mandatory testing and tracking and sharing of

their private medical information while another group

is declared “clean” and afforded the privilege of their

God-given and unalienable rights and freedoms going

unchallenged, and it is against petitioner’s belief to

participate or facilitate in this discrimination, to wit:

15 “ . . . Do not call anything impure that God has

made clean.” Acts 10:15 NIV.

The mere notion that a public servant or corpo

rate entity with a financial interest has any claim of

“authority’ to decide what is right for others and then

force their will on these others by holding their Rights

and liberties ransom through the use of threat, duress,

and or coercion is not only reprehensible but flies in

the face of the founding principles upon which this

great nation was founded — LIBERTY, FREEDOM,

and FREE WILL and CHOICE! The purpose of the

FIRST AMENDMENT of the Bill of Rights is to pro

tect petitioner against any unlawful intrusion into his

life and religion, and it also serves as a PROHIBITION

against government intrusion into religious affairs.

App.39a

Violation #5:

COTTER and CHIMES DC AGENTS are violating

petitioner’s, Right to petition the government for a

redress of grievances.

“Congress shall make no law respecting an

establishment of religion, or prohibiting the free

exercise thereof; or abridging the freedom of speech,

or of the press; or the right of the people peaceably

to assemble, and to petition the Government for a

redress of grievances.”

—Constitution for the United States of America,

FIRST AMENDMENT

“That every man hath a right to petition the

Legislature for the redress of grievances in a

peaceable and orderly manner”

—Maryland Constitution (1867), Declaration of Rights,

Article 13.

Clarification:

Although as public servants COTTER and

CHIMES DC AGENTS were given proper notice and

reasonable opportunity to respond where they had a

legal and moral duty to speak, they have chosen to

remain silent on petitioner’s CONDITIONAL

ACCEPTANCE (see Exhibit 1, incorporated by this

reference as if fully restated herein); consequently,

COTTER and CHIMES DC AGENTS now stand in

DISHONOR. As this CONDITIONAL ACCEPTANCE

enumerates petitioner’s concerns and grievances, he

feels that his FIRST AMENDMENT Right to petition

the government for redress of grievances is being

violated by COTTER’S and CHIMES DC AGENTS’

App.40a

silence as well as a fraud being perpetrated upon him,

to wit, “Silence can only be equated with fraud when

there is a legal and moral duty to speak or when an

injury left unanswered would be intentionally

misleading” U.S. v. Prudden, 424 F.2d 1021 (1970):

U.S. v. Tweel. 550 F.2d 297. 299 (1977). Further,

COTTER and CHIMES DC AGENTS continue to

issue “directives,” “orders” and “mandates” concerning

“COVID-19 Vaccination Status” and “vaccination”

requirements OR mandatory weekly testing under

threat, duress, and/or coercion, even after COTTER’S

and CHIMES DC AGENTS’ acquiescence and tacit

agreement to petitioner’s position due to COTTER’S

and CHIMES DC AGENTS’ silence and being served

with petitioner’s NOTICE OF DEFAULT (Exhibit 3,

incorporated by this reference as if fully restated

herein) and NOTICE OF ESTOPPEL (Exhibit 4,

incorporated by this reference as if fully restated

herein).

Violation/Claim #6:

COTTER and CHIMES DC AGENTS are violating

petitioner’s Right to be secure in his persons, houses,

papers, and effects against unreasonable searches and

seizures, with regards to “COVID-19 Vaccination

Status” and giving up personal and private medical

information contrary to Law.

“The right of the people to be secure in their

persons, houses, papers, and effects, against

unreasonable searches and seizures, shall not be

violated...”

—Constitution for the United States of America,

FOURTH AMENDMENT and The Declaration of

Rights of the Maryland Constitution (1867), Article 24.

App.41a

Clarification:

COTTER and CHIMES DC AGENTS are seizing

petitioner’s “persons,” “papers,” and “effects” (belong

ings, property, Rights, information in one’s head,

what one knows, etc.) against his will through use of

threat, duress, and/or coercion and then unreasonably

and unlawfully searching his “persons,” “papers,” and

“effects,” and then unlawfully seizing his personal and

private information, and then using said information

against him. This is a clear violation of petitioner’s

FOURTH AMENDMENT Rights. Further, private,

personal, and medical information, as protected by

Law, is not the property of COTTER and CHIMES DC

AGENTS, nor does this information have any bearing

on petitioner’s ability to perform duties as an employ

ee of CHIMES DC.

Violation/Claim #7:

COTTER and CHIMES DC AGENTS are violating

petitioner’s Right to be secure in his person, houses,

papers, and effects against unreasonable searches and

seizures, with regards to “vaccination” requirements.

“The right of the people to be secure in their

persons, houses, papers, and effects, against

unreasonable searches and seizures, shall not be

violated...”

—Constitution for the United States of America,

FOURTH AMENDMENT and The Declaration of

Rights of the Maryland Constitution (1867), Article 24.

Clarification:

Petitioner has a Right to be secure in his

“persons,” “papers,” and “effects” (belongings, property,

App.42a

Rights, information in one’s head, what one knows,

etc.). COTTER and CHIMES DC AGENTS are

attempting to seize control of, not only petitioner’s

physical body, but his will as well. If COTTER and

CHIMES DC AGENTS can force petitioner to take the

so-called “COVID 19” “vaccination” (OR submit to

mandatory COVID 19 tests 2-3 times per week) then

this is prima facie evidence of the actual seizure and

control of his body and will by COTTER and CHIMES

DC AGENTS, which means he has lost control and

ownership of his own body through COTTER’S and

CHIMES DC AGENTS’ use of threat, duress, and or

coercion against petitioner, meaning he no longer

would be permitted to make personal lifestyle choices

for himself. This is a clear violation of petitioner’s

FOURTH AMENDMENT Rights. Clearly, COTTER

and CHIMES DC AGENTS are refusing to recognize

and honor petitioner’s, and those similarly situated

hereto, unalienable Rights that he is entitled to and is

systematically denying and destroying his ability to

remain secure in his Rights, even in off-duty

capacities. Again, this is tantamount to the seizure

and control of petitioner’s physical body, mind, will,

and soul, all of which are his private property.

Violation/Claim #8:

COTTER and CHIMES DC AGENTS are violating

petitioner’s Right to not be compelled to testify

against himself.

“No person... shall be compelled.. .to be a witness

against himself, nor be deprived of life, liberty, or

property, without due process of law; nor shall

private property be taken for public use, without

just compensation.”

App.43a

—Constitution for the United States of America,

FIFTH AMENDMENT

Clarification:

COTTER and CHIMES DC AGENTS are unlaw

fully demanding/requiring, by use of threat, duress,

and or coercion that petitioner submit “COVID-19

Vaccination Status” revealing personal and private

medical information which would be the same as

being compelled to testify against himself, which has

direct and immediate consequences such as breach of

privacy, segregation, hostility and/or harassment from

supervisors and co-workers, etc. This is a clear violation

of his FIFTH AMENDMENT Right.

Violation/Claim #9:

COTTER and CHIMES DC AGENTS are violating

petitioner’s, and those similarly situated hereto, Right

not to be deprived of life, liberty or property, without

due process of Law.

“No person... shall be compelled... to be a witness

against himself nor be deprived of life, liberty, or

property, without due process of law; nor shall

private property be taken for public use, without

just compensation”

— Constitution for the United States of America,

FIFTH AMENDMENT and The Declaration of Rights

of the Maryland Constitution (1867), Article 24.

Clarification:

COTTER and CHIMES DC AGENTS are denying

petitioner’s Right to due process of law by using threat,

duress, and or coercion to get him to turn over to

App.44a

COTTER and CHIMES DC AGENTS his life, liberty,

and property. The fact that COTTER and CHIMES

DC AGENTS are attempting to get petitioner to turn

over control of his life, liberty, and property against

his consent, in the form or in the nature of petitioner’s

will, what is in his head, his decision making, and his

physical body, even in off-duty capacity, under threat

of disciplinary action including being put on unpaid

leave and/or termination of employment is not due

process of Law as guaranteed by FIFTH AMEND

MENT Rights. Loss of petitioner’s livelihood, income

and/or employment constitutes a material harm and

deprivation of property in the sense that petitioner

would be forced to forfeit the investment he has made

in his career as well as future earnings and promotions

he might obtain during the remainder of his tenure

with CHIMES DC.

EMERGENCY RELIEF SOUGHT

Therefore, petitioner seeks relief for failure of

COTTER’S and CHIMES DC AGENTS to safeguard

his natural, unalienable, Constitutionally protected

and secured Rights, and any other Rights, Privileges,

and Immunities he might have; thus, moves with

extreme urgency in this matter, and seeks EMER

GENCY INJUNCTIVE RELIEF or any other Lawful

Remedy available by this Court against COTTER,

EXECUTIVE VICE PRESIDENT for CHIMES DC, and

DORSETT, DIRECTOR OF HUMAN RESOURCES

for CHIMES DC, as well as any agents of CHIMES

DC following unlawful directives, ordering them to:

1. Cease and Desist in sending/delivering any

and all further communications such as, notices,

“directives,” “orders,” “mandates,” requirements, and

App.45a

threats concerning COTTER’S and CHIMES DC

AGENTS’ unlawful requirement to divulge personal

and private medical information by way of

“COVID-19 Vaccination Status” or by any other means.

2. Cease and Desist in informing, noticing, order

ing, directing, mandating, requiring or mentioning any

requirement for petitioner to be “vaccinated” as a

requirement for employment, or face disciplinary

action, unpaid leave, or termination.

3. Cease and Desist in informing, noticing, order

ing, directing, mandating, requiring or mentioning any

requirement for petitioner, and those similarly situated

hereto, to be masked in any way as a requirement for

employment, or face disciplinary action or termination

(with the understanding that petitioner reserves his

right to utilize a mask at his own discretion under

certain conditions which may arise from time-to-time

in the performance of his professional duties).

4. Cease and Desist in informing, noticing, order

ing, directing, mandating, requiring or mentioning any

requirement for petitioner to be tested for “COVID19” in any way as a requirement for employment, or

face disciplinary action or termination (unless peti

tioner, and those similarly situated hereto, volunteers

for said testing).

5. Cease and Desist in any further action against

petitioner, and those similarly situated hereto, whether

disciplinary, retaliatory or in the nature of demotion

or unpaid leave or termination of employment for fail

ure to comply with unconstitutional/unlawful

“directives,” “orders,” “mandates” or “policy” concern

ing the gathering of personal/private medical informa

tion through “COVID-19 Vaccination Status” or by

App.46a

any other means, as well as any and all requirements

for “COVID-19” and “variants” including, but not

limited to, “vaccinations,” testing and masking.

6. Be held personally liable for any fees and

fines for damages pursuant to petitioner’s, and those

similarly situated hereto, fee schedule ($200,000 US

Dollars for violation of estoppel and bill for damages

at a minimum rate of $250,000 US dollars as well as

$2,000 US dollars per day per man or woman involved,

plus any interest and penalties, which will continue to

accrue until this matter is settled in fun), as a result of

activating and accepting the terms and obligations of

said fee schedule (on December 13, 2021) due to

continued unlawful activity and actions against

petitioner including the above-mentioned violations of

his natural, unalienable, Constitutionally protected

and secured Rights. (See Exhibits 4 through 6, incor

porated by this reference as if fully restated herein).

prejudice.

Respectfully Submitted,

/s/ Gary Pfeffer Jr.

Gary Pfeffer Jr., In Sui Juris

Date: 2/9/2022

App.47a

LETTER TO CIRCUIT COURT JUDGE

(JANUARY 21, 2022)

Petitioner:

Gary Pfeffer Jr.

1122 Frenchtown Rd.

Perryville, Maryland

Attention: Administrative Judge Angela M. Eaves

and All Participating Judges of Harford County

Circuit Court of Maryland

20 West Courtland Street,

Bel Air, Maryland - Circuit Court

Bel Air, MD 21014

REGARDING: Ex Parte at Common Law Seeking Lawful

Remedy and Injunctive Relief

READ THIS CAREFULLY

Dear Honorable Judge ANGELA EAVES,

I am writing in order to provide you notice of my

intention to file an Ex Parte petition at Common Law

(not within the statutory or policy jurisdiction),

coming in Pro Per (“in one’s own proper person”), in Sui

Juris (“of his own right”), by way of Special Appearance

(not generally), and seeking lawful remedy and

injunctive relief. I trust that you will facilitate the

filing and hearing of my petition pursuant to Common

Law and in accordance with due process protections of

the Federal and State Constitutions.

I expect that the Ex Parte hearing will be sched

uled for a date and time to accommodate petitioner by

Zoom video (rather than by phone) and that there will

be no fee for petitioner to appear at the hearing.

App.48a

NOTICE TO AGENTS IS TO NOTICE

PRINCIPALS, NOTICE TO PRINCIPALS IS

NOTICE TO AGENTS!

I also expect that I will appear before a proper

court of record with a court reporter. If necessary, I

would be happy to provide a court reporter to ensure

accuracy of the court record.

Additionally, I expect that no notice of hearing or

summons will be served upon the Defendant for the

Ex Parte at Common Law. Please understand that the

Defendant was already provided proper notice and

reasonable opportunity to respond and yet chose to

remain silent which resulted in the Defendant being

found in default and estopped in this matter.

Black’s Law Dictionary. Fourth Edition: EX

PARTE. On one side only: by or for one party;

done for, in behalf of, or on the application of,

one party only. 661 EX PARTE A judicial

proceeding order, injunction, etc., is said to

be ex parte when it is taken or granted at the

instance and for the benefit of one party only,

and without notice to, or contestation by, any

person adversely interested. Janin v. Logan,

209 Ky. 811, 273 S.W. 531, 532: Van Alen v.

Superior Court in and for Los Angeles

County, 37 Cal.App. 696, 174 P. 672; Stella v.

Mosele, 299 53, 19 N.E. 2d 433, 435. Ex parte

means that an application is made by one

party to a proceeding in the absence of the

other. Thus, an ex parte injunction is one

granted without the opposite party having had

notice of the application. It would not be

called “ex parte” if he had proper notice of it,

App.49a

and chose not to appear to oppose it.

Thank you for your consideration and prompt

attention. Upon receipt, please respond to me directly

as soon as possible due to the urgency of this matter.

I can be reached at (202) 894-0760 or by email at

chemmyl981@gmail.com.

Very truly,

Gary Pfeffer Jr.

In Sui Juris Without Prejudice

/s/ Gary Pfeffer Jr.

Supreme court

PRESS

Supreme Court of Maryland

Case Summary

Case NO. COA-PET-0269-2022

In the Matter of Gary' Pfeffer, Jr.

Location: Supreme Court of Maryland

Filed on: 11/01/2022

Appellate Court of Maryland 7-2022 Term

Case Number:

C-12-CV-22-000087 (Harford

Circuit Court Case Number:

Co)

Case Information

Case Type: Petition on Civil Case

Related Cases

C-12-CV-22-000087 (Petition Filed)

CSA-REG-0007-2022 (Petition Filed)

Case Flags: Judicial Conflict

Case Assignment

Date

Current Case Assignment

Case Number

Court

Date Assigned

COA-PET-0269-2022

Supreme Court of Maryland

11/01/2022

Party Information

Petitioner

Pfeffer, Jr„ Gary

Pro Se

Date

Events & Orders of the Court

11/01/2022

Index

Petition for Writ of Certiorari

Petition for Writ of Certiorari filed. F.F. pd.

11/01/2022

Comment .

CSA No. 7 - 2022 Term, Opinion: 8/26/22 - Unreported, Mandate: 10/18/22

11/01/2022

Comment

CC Harford County, Eaves, J., C-l2-CV-22-000087

11/02/2022

1>l Petition Receipt

Petition docket receipt e-filed and mailed to petitioner.

11/09/2022

Q Appendix

Appendix to Petition for Writ of Certiorari filed; CC docket entries

11/17/2022

Conference (10:00 AM)

*Judge Eaves Recused

12/14/2022

Court of Appeals Renamed Supreme Court of MD eff. 12/14/22

12/19/2022

Petition denied. (Order mailed to petitioner)

12/19/2022

Denied

Comment (Petition denied. *Judge Eaves Recused.)

Date

Financial Information

PAGE 1 OF 2

Printed on 04/25/2023 at 11:37 AM

Supreme Court of Maryland

Case Summary

case No. COA-PET-0269-2022

Petitioner Pfeffer, Jr„ Gary

Total Charges

Total Payments and Credits

Balance Due as of 04/2S/2023

61.00

0.00

PAGE 2 OF 2

Printed on 04/25/2023 at 11:37 AM

Supreme Court of Maryland

Case Summary

CASE NO. COA-PET-0269-2022

In the Matter of Gary Pfeffer, Jr.

Location: Supreme Court of Maryland

Filed on: 11/01/2022

Appellate Court of Maryland 7-2022 Term

Case Number:

C-l2-CV-22-000087 (Harford

Circuit Court Case Number:

Co)

Case Information

Case Type: Petition on Civil Case

Related Cases

C-12-CV-22-000087 (Petition Filed)

CSA-REG-0007-2022 (Petition Filed)

Case Flags: Judicial Conflict

Case Assignment

Date

Current Case Assignment

Case Number

Court

Date Assigned

COA-PET-0269-2022

Supreme Court of Maryland

11/01/2022

Party Information

Petitioner

Pfeffer, Jr„ Gary

Pro Se

Date

Index

Events & Orders of the Court

11/01/2022

1>1 Petition for Writ of Certiorari

Petition for Writ of Certiorari filed. F.F. pd.

11/01/2022

Comment

CSA No. 7 - 2022 Term, Opinion: 8/26/22 - Unreported, Mandate: 10/18/22

11/01/2022

Comment

CC Harford County, Eaves, J., C-l2-CV-22-000087

11/02/2022

1^-1 Petition Receipt

Petition docket receipt e-filed and mailed to petitioner.

11/09/2022

^•*1 Appendix

Appendix to Petition for Writ of Certiorari filed; CC docket entries

11/17/2022

Conference (10:00 AM)

*Judge Eaves Recused

12/14/2022

Court of Appeals Renamed Supreme Court of MD eff. 12/14/22

12/19/2022

@1 Petition Denied

Petition denied. (Order mailed to petitioner)

12/19/2022

Denied

Comment (Petition denied. *Judge Eaves Recused.)

Date

Financial Information

PAGE 1 OF 2

Printed on 04/25/2023 at 11:37 AM

Supreme Court of Maryland

Case Summary

Case NO. COA-PET-0269-2022

Petitioner Pfeffer, Jr„ Gary

Total Charges

Total Payments and Credits

Balance Due as of 04/2S/2023

61.00

0.00

PAGE 2 OF 2

Printed on 04/25/2023 at 11:37 AM

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.