Supplemental Brief — Dora L. Adkins, Petitioner v. Merrifield Hotel Associates, LP

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IN THE

Supreme Court of the United States

DORA L. ADKINS,

Petitioner,

v.

MERRIFIELD HOTEL ASSOCIATES, L.P.

Respondent.

ON PETITION FOR WRIT OF CERTIORARI

TO THE UNITED STATES COURT OF APPEALS

FOR THE FOURTH CIRCUIT

SUPPLEMENTAL BRIEF

Dora L. Adkins, Pro Se

P.O. Box 3825

Merrifield, VA 2116

DoraAdkins7@aol.com

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TABLE OF CONTENTS

TABLE OF CONTENTS

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TABLE OF AUTHORITIES

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SUPPLEMENTAL BRIEF

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28-PETITIONS THAT ALLEGED FOOD AND/OR CHEMICAL POISIONING

OF THE PETITIONER................................................................................................. 5

15-CHEMICAL AND/OR FOOD POISIONING EMERGENCY COMPLAINTS

THAT HAVE NOT BEEN FILED BECAUSE PETITIONER IS ENJOINED IN

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THE DISTRICT COURT AND/OR THE STATE OF VIRGINIA

PETITIONER’S DEVASTATING IMPACT OF BEING ENJOINED

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CONCLUSION

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CERTIFICATE OF SERVICE

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TABLE OF AUTHORITIES

Cases:

Dora L. Adkins v. Merrifield Hotel Associates, L.P., No.: l:22-cv-399-AJT-IDD

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Dora L. Adkins v. Hilton Worldwide Holding, LLC

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Dora L. Adkins v. Hyatt Corp., 1:20-CV-1410

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Dora L. Adkins v. SP Hotel, LLC

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Dora L. Adkins v. The Ritz-Carlton Hotel Company, LLC, Case No., l:22-cv00934...............................................................................................................................

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SUPPLEMENTAL BRIEF

NEW MATERIAL:

Petitioner at the time of filing a Writ of Certiorari on September 1, 2022, in

the case of Dora L. Adkins v. Merrifield Hotel Associates, L.P., No.: l:22-cv-399-AJTIDD, did not know that the U. S. District Court for the Eastern District of Virginia

and U.S. Court of Appeals for the Fourth Circuit Abused its Discretion when it did

not properly apply a Pre-Filing Injunction Order to deny Petitioner Dora L. Adkins’

motions for leave to file a complaint against respondent Merrifield Hotel Associates,

L.P., and that the Judgment and Order needs to be VACATED by this Honorable

Court. (Dkt. No. 11, Dkt. No. 12)). Pet. Appendix A, pg. 12; Pet. Appendix B, pg.

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Petitioner had no way to know how the District Court ruling in the case of

Adkins v. Hyatt Corp., 1:20-CV-1410 issued to the Petitioner regarding previous

filings (listed below) related to chemical and/or food poisoning; would in fact STALL

all Complaints whether or not the Complaint was labeled by the Petitioner as an

Emergency Complaint as in the case Dora L. Adkins v. Merrifield Hotel Associates,

L.P., No.: l:22-cv-399-AJT-IDD, and would prove to have a devastating effect on the

Petitioner when poisoned by Chemicals by the Respondent, Merrifield Hotel

Associates, L.P.. Petitioner had no way of knowing that NO chemical poisoning

and/or food poisoning filed by the Petitioner would ever be GRANTED.

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It is not that that the Petitioner is a vexatious pro se litigant; filing groundless

and vexatious litigation, but it is GOD who provided EVERY detail in EVERY

COMPLANT and/or EMERGENCY COMPLAINT who caught ALL of the Defendants

in over correction (90-Complaints) filed by the Petitioner. “Legal proceedings

starting with malice and without good case,” has NEVER been the objective of the

Petitioner. Vexatious litigation is meant to bother, embarrass, or cause legal

expenses to the defendant. A plaintiff who starts such litigation either knows or

should reasonably know that no legal basis for the lawsuit exists. To obtain a remedy

for vexatious litigation, the injured party often files a claim for malicious

prosecution.” Petitioner did not file any of the 90-Complaints and/or Emergency

Complaints combined without good cause and in the approximately 90-Complaints

and/or Emergency Complaints filed by the Pro Se Petitioner, no Defendant filed a

Claim for Malicious Prosecution, which mean Petitioner should not have been

ENJOINED by the District Court and certainly not ALL of the Courts in the State of

Virginia that Petitioner just became aware of.

Legal proceedings were not started by the Petitioner with malice and without

good case in the approximate 28-Complaints filed by the Petitioner that were later

Petitioned in the Supreme Court of Virginia; with the U.S. Court of Appeals for the

Fourth Circuit; and the United Stated Supreme Court:

I.

ALL OF THE FOLLOWING PETITIONS ALLEGED FOOD AND/OR

CHEMICAL POISIONING OF THE PETITIONER:

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These petitions related to food poisoning and chemical poisoning were

filed with the Supreme Court of Virginia:

1) Dora L. Adkins v. HEI Tyson’s Corner, LLC, Record No. 111454;

2) Dora L. Adkins u. Davidson Hotel Company, LLC, Record No. 131897;

3) Dora L. Adkins v. High Velocity Hospitality, LLC, Record No. 140431;

4) Dora L. Adkins v. Fair Oaks Inn, LLC, 140690;

5) Dora L. Adkins v. King Street Station and Hotel Associates, LLC, Record No.

140872;

6) Dora L. Adkins v. Hilton Worldwide, Inc., Record No. 140875;

7) Dora L. Adkins v. Alexandria Hotel Associates, LLC, Record No. 141334;

8) Dora L. Adkins v. The Ritz-Carlton Hotel Company, LLC, Record No. 150574;

9) Dora L. Adkins v. Renaissance Hotel Operating Company, Record No. 150623;

10) Dora L. Adkins v. HEI Tyson’s Corner, LLC, Record No. 151510;

11) Dora L. Adkins v. W-LCP Alexandria VII, LLC, Record No. 160570;

12) Dora L. Adkins v. CP/IPERS Arlington Hotel, LLC, Record No. 160685;

13) Dora L. Adkins v. JBG/Tysons Hotel, LLC, Record No. 161145;

14) Dora L. Adkins v. Noodles & Company, Record No. 161238;

15) Dora L. Adkins v. CH Realty Vi-Grey-Star MF Tysons Elan, LLC, Law Case

No. Case No.: 2017-17657;

16) Dora L. Adkins v. Park Hotels & Resorts, Inc 2016;

17) Dora L. Adkins v. Hyatt Corporation 2017;

18) Dora L. Adkins v. B. F. Saul Company;

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19) Dora L. Adkins v. Park Hotels & Resorts, Inc 2018;

20) Dora L. Adkins v. Chipotle Mexican Grill, LLC.

These petitions related to food poisoning and chemical poisoning were

filed with the U.S. Court of Appeals for the Fourth Circuit:

1) Dora L. Adkins v. Whole Foods Market Group, Inc.; Docket Number 1:16 -CV00031-CMH-JFA, (Dismissed)

2) Dora L. Adkins v. Public Storage; Docket Number l:16-cv-01556-JCC-IDD,

(Dismissed)

3) Dora L. Adkins v. Whole Foods Market Group, Inc.; Docket Number l:17-cv01023-AJT-JFA, (Dismissed)

4) Dora L. Adkins u. Alexandria Towers, LLC; Docket Number l:16-cv-0049

JCC-TCB, (Dismissed)

5) Dora L. Adkins u. Dulles Hotel Corporation, Docket Number l:20-cv-00361RDA-IDD, (Dismissed)

6) Dora L. Adkins u. Driftwood Special Servicing, LLC, Docket Number l:22-cv00109-AJT-IDD, (Affirmed)

7) Dora L. Adkins v. Merrifield Hotel Associates, L.P., Docket Number 1:221414-AJT-IDD, (Affirmed)

8) Dora L. Adkins v. Tysons Lodging LLC., Docket Number l:22-cv-00553,

(Affirmed)

II.

THE FOLLOWING CHEMICAL AND/OR FOOD POISIONING

EMERGENCY COMPLAINTS HAVE NOT BEEN FILED BECAUSE

PETITIONER IS ENJOINED IN THE DISTRICT COURT AND EVERY

COURT IN THE STATE OF VIRGINIA:

1) Dora L. Adkins v. Ashford TRS Alexandria, LLC;

2) Dora L. Adkins v. Ashford TRS Alexandria, LLC;

3) Dora L. Adkins v. Fitness International, LLC;

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4) Dora L. Adkins v. SP Hotel, LLC;

5) Dora L. Adkins v. Hilton Worldwide Holding, LLC;

6) Dora L. Adkins v. The Ritz-Carlton Hotel Company, LLC;

7) Dora L. Adkins v. THC Arlington, LLC; (FILED IN ALINGTON COUNTY

CIRCUIT COURT)

8) Dora L. Adkins v. HEI Tyson’s Corner, LLC.

III.

OTHER EMERGENCY COMPLAINTS ALLEDGING FOOD AND/OR

CHEMICAL POSIONING AFTER BEING ENJOINED IN EVERY

COURT IN THE STATE OF VIRGINIA:

1)

Dora L. Adkins v. Hilton Worldwide Holdings, Inc.;

(FILED IN FAIRFAX COUNTY CIRCUIT COURT)

2) Dora L. Adkins v. 12777Fair Lakes Circle Owner, LLC.;

(FILED IN FAIRFAX COUNTY CIRCUIT COURT)

3) Dora L. Adkins u. Davidson Hotel Company, LLC, Record No. M021001647;

(FILED IN THE CITY OF ALEXANDRIA, CIVIL DIVISION)

4) Dora L. Adkins v. Starbucks Corporation;

(FILED IN U.S. DISTRICT COURT)

5) Dora L. Adkins v. HEI Tyson’s Corner, LLC.

(FILED IN FAIRFAX COUNTY DISTRICT COURT)

PETITIONER NEVER FILED A LAWSUIT IN NO. 6 THAT CAUSED DEATH

IN THE PETITIONER (RE-LIVED THROUGH AND BY GOD’s DEVINE

INTRVENTIONV:

6) Dora L. Adkins v. Hilton Garden Inn, Woodbridge, VA; (NEVER FILED A

LAWSUIT)

7) Dora L. Adkins v. Red Lobster. (NEVER FILED A LAWSUIT)

IV.

PETITIONER’S DEVASTATING IMPACT OF BEING ENJOINED

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With GOD’s help of providing Petitioner with EVERY detail in EVERY

Complaint and/or Emergency Complaint, Petitioner was able to allege cognizable

claims with supporting Facts, Proof, and Evidence that is ACCURATE and TRUE.

EVERY Complaint and/or Emergency Complaint involved GOD directly. Petitioner

analyzed Five of the Emergency Complaints presently before the District Court and

found the physical and emotional injuries are the same for the same Defendant

Years later. Petitioner in 17-years have not had to file Emergency Complaints while

already in Court for chemical poisoning and/or food poisoning but the physical and

emotional injuries occurred at EVERY hotel.

Chemical poisoning of the Petitioner in Petitioner’s Condominium Unit #304

located at Hallmark Condominium, Alexandria, VA in the Year 2005 that caused

Petitioner five-DEATHS and Petitioner re-lived through and by GOD’s Devine

Interventions was copied on September 3, 2022, in the Conference Room located at

the Hampton Inn & Suites located in Richmond, VA and/or 17-years ago is PROOF

and EVIDENCE that the facts Petitioner alleged and/or plead in ALL of the

Complaints and Emergency Complaints related to chemical poisoning and/or food

poisoning were TRUE and ACCURATE. Petitioner filed the following Emergency

Complaint in the case of Dora L. Adkins v. SP Hotel, LLC that is stalled because

Petitioner is ENJOINED. Petitioner was seen at the Emergency Room located in

Reston, VA for an unrelated matter and Petitioner’s Blood Pressure read 175/125

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from inhaling chemical poisoning from inside the Conference Room at the Hampton

Inn & Suites, located in Richmond, VA that was meant to kill the Petitioner.

A second example is found in the same District Court on August 25, 2022,

which granted Petitioner’s Motion for Leave to Proceed in forma pauperis in the

case of Dora L. Adkins v. The Ritz-Carlton Hotel Company, LLC, Case No., l:22-cv00934 that claims chemical poisoning which caused Petitioner Death from inhaling

septic poisoning amongst other claims in the Emergency Complaint. The exact way

of chemical poisoning the Petitioner in a prior case against The Ritz Carlton Tysons

was by septic poisoning in its parking area all the way to the entrance to the

elevator to the Guest Rooms. Dora L Adkins u. The Ritz-Carlton Hotel Company,

LLC, Case No., l:22-cv-00934 would not have been approved to proceed in forma

pauperis if the CLAIMS alleged were not substantiated.

A third example is Petitioner allegedly being both food poisoned and

chemically poisoned at the Embassy Suites Tysons since the Year 2010 and/or 12Years later that caused the Petitioner two-Deaths and is one of the 10-Emergency

Complaints presently filed but is stalled because Petitioner is ENJOINED in the

District Court is against the Embassy Suites Hotel Tysons and/or Dora L. Adkins v.

Hilton Worldwide Holding, LLC that is stalled because Petitioner is ENJOINED.

There were five-Complaints filed by the Petitioner against the Embassy Suites

Tysons who was allegedly dishonest about who the Registered Agent is and has an

out-of-date'license in its office; the same problem exists with the Hilton Garden Inn,

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located in Woodbridge, VA; whereby Petitioner was unable to locate the Registered

Agent for the Hilton Garden Inn.

In a Summary, it was good for Petitioner to show this Court how the New

Material fit together and sadly for the Petitioner it would not have been possible

had any one of the Petitions been GRANTED to the Petitioner.

CONCLUSION

For the foregoing reasons, the court should grant the petition.

Respectfully submitted,

Dated: September 24, 2022

Dora L. Adkins, Pro Se

P.O. Box 3825

Merrifield, Virginia 22116

DoraAdkins7@aol.com

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