Petition for Writ of Certiorari — Joann Artis Stevens, Petitioner v. Town of Snow Hill, North Carolina, et al.

Supreme Court briefMay 27, 2023

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IN THE

SUPREME COURT OF THE UNITED STATES

Pro Se

JoAnn Artis Stevens

— PETITIONER

(Your Name)

vs.

Town of Snow Hill, et al

— RESPONDENT(S)

ON PETITION FOR A WRIT OF CERTIORARI

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

(NAME OF COURT THAT LAST RULED ON MERITS OF YOUR CASE)

PETITION FOR WRIT OF CERTIORARI

JoAnn Stevens

712 West Harper St.

Snow Hill, NC, 28580

252-933-9490

QUESTION (S) PRESENTED

1. This Claim is of exceptional importance, and is a vehicle to

remedy the issues and conflict in our Judicial Systems by use

of Pretrial Motion 12(b)(6) which are recurring and warrants

review. This is of significant importance to the administration

of Justice as Pretrial Motions thwart remedy for meritorious

and civil cascases that are deemed by the Courts non frivo

lous. There is a divide amongst Judges and Legal Scholars on

use thereof to include contemporaneous Affirmed and Per Cu

riam Affirmed Judgements.

2. Will our Honorable Courts, remedy the longstanding conflict and

issues within the Judicial, Legal Field of questionable and conflict

ing Pre-trial motions? In light of past measures, attempts, and re

views of the inefficiencies of Civil Litigation, the high and rising

costs, undue delays and abusive practices associated and caused

thereby? In that countless attempts to address the central issues,

by amendment of the Federal Rule of Civil Procedure (the Federal

Rules or Rule), by congressional statute, and by judicial doctrine

have failed i.e. Cardoza Law Review?

LIST OF PARTIES

[ ] All parties appear in the caption of the case on the cover page.

[V] All parties do not appear in the caption of the case on the

cover page.A list of all parties to the proceeding in the court

whose judgment is the subject of this petition is as follows:

TOWN OF SNOW HILL

Defendant - Appellee

GREENE COUNTY

Defendant - Appellee

Katherine Marie Barber Jones Direct: 919-670-0338

Email: kbarber-jones@hartzoglawgroup.com

HARTZOG LAW GROUP LLP

Suite 305

2626 Glenwood Avenue

Raleigh, NO 27608

Dan M. Hartzog,

Jr. Direct: 919670-0338

Email: dhartzogjr@hartzoglawgroup.com

HARTZOG LAW GROUP LLP

Suite 305

2626 Glenwood Avenue

Raleigh, NC 27608

James R. Morgan,

Jr. Direct: 336721-3710

Email: Jim.Morgan@wbdus.com

WOMBLE BOND DICKINSON (US)

LLP

1 West 4th Street

Winston-Salem, NC 27101

LENOIR COMMUNITY COLLEGE &

FOUNDATION, NC

Defendant. - Appellee

William John Cathcart, Jr.

Direct: 919-890-4469

Email:

ica.thcart@bcvtlaw.m

BROWN, CRUMP, VANORE & TIER

NEY, PLLC

Suite 330, 801 Oberlin Road

Raleigh, NC 27605

RELATED CASES

Brown v. Board of Education of Topeka (1954)

Conley v. Gibson u.s.. 355 44 (1957)

Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007)

The Civil Rights Cases, 1S. (1883)

TABLE OF CONTENTS

OPINIONS BELOW.

II.

JURISDICTION

III.

TABLE OF AUTHORITIES

IV.

CONSTITUTIONAL AND STATUTORY PROVISIONS IN

VOLVED

STATEMENT OF THE CASE..........................

1. INTRODUCTION.........................................

2. IRREPARABLE HARM

VI.

REASONS FOR GRANTING THE WRIT........................

VII.

CONCLUSION....................................................................

VIII.

INDEX TO APPENDICES BELOW

INDEX TO APPENDICES

APPENDIX A - UNITED STATES DISTRICT COURT

APPENDIX B - UNITED STATES COURT OF APPEALS

APPENDIX C - TIMELY PETITION FOR REHEARING DENIED

APPENDIX D - EXTENSION OF TIME TO FILE WRIT FOR CERTIORARI

APPENDIX E - REASON FOR REQUEST FOR EXTENSION OF TIME TO FILE

WRIT OF CERTIORARI

APPENDIX D - EXTENSION FOR TIME TO FILE

TABLE OF AUTHORITIES CITED

Cardoza Law Review

Thomas Reuters.

The New Rule 12(b)(6) Twombly, Iqbal, and the Paradox of Pleading

Rakesh N. Kilaru, Stanford Law Review, Stanford University.....

Campbell Law Review, Vol. 15, Iss. 2 [1993], Art.1 http://scholarship.law.campbell.edu/clr/vol15/iss2/1........

TABLE OF CASES

Twombly, 55Q U,S. at 570

5,6

Iqbal. 556 U.S. at 878-79

Conley v. Gibson, U.S. 355 4 (1957)

NextWave Personal Commc’ns v, FCC, No. 00-1402, 2001

U.S. App. LEXIS 19617. at *4 (D.C. Cir. Aug. 23, 20011

Books v. City of Elkhart. 239 F.3d 826 (7th Cir. 2001)

Barefoot v. Estelle, 463 U.S. 880, 893 n.4 (1983)

Gomez v Toledo, 446 US 635, 638 (1980)

Marburvv. Madison. 1803

Bell Atlantic v. Twombly

5,6

Statutes and Rules

28 U. S. C. § 1254(1)

2,3

Fed. R. Civ. Pro. 12(b) (6)

2,3,4,5

Per Curiam Affirmation

IN THE

SUPREME COURT OF THE UNITED STATES

PETITION FOR WRIT OF CERTIORARI

Petitioner respectfully prays that a writ of certiorari issue to review the judgment below.

OPINIONS BELOW

The opinion of the United States Court of Appeals appears at Appendix A to the Petition

The opinion of the United States District Court appears at Appendix B to the Petition

A petition for rehearing was timely filed in my case on Nov. 17,2022.

A timely petition for rehearing was denied by the United States Court of Appeals

on the following date on December 28, 2022. and a copy of the order denying

rehearing appears at Appendix C.

An extension to file the petition for a writ of certiorari is filed on March 28 2023.

appears at Appendix D.

Extension to file petition for Writ of Certiorari Granted until May 27, 2023

JURISDICTIONAL STATEMENT

The date on which the United States Court of Appeals decided my case was on

November 4, 2022.

The jurisdiction of this Court is invoked under 28 U. S. C. § 1254(1).

INTRODUCTION

Appellant JoAnn Stevens respectfully petitions this court for a

writ of certiorari to review the judgment of Lower Court Decisions

and for remand. The certiorari petition will present substantial

question (s) and is of Great Importance and will serve as a vehicle

for review to remedy issues of use of Motion 12(b)(6). There is good

cause for a stay. The standard of a “‘reasonable probability”’ of the

Supreme Court granting certiorari and reversing has been met.

NextWave Personal Commc’ns v. FCC, No. 00-1402, 2001 U.S. App.

LEXIS 19617, at *4 (D.C. Cir. Aug. 23, 2001)(quoting Books v. City

of Elkhart, 239 F.3d 826 (7th Cir. 2001)). In applying a similar

standard, the petitioner “must demonstrate that the issues are de

batable among jurists of reason.” Barefoot v. Estelle, 463 U.S. 880,

893 n.4 (1983). U.S. Courts on behalf of the Federal Judiciary,

sites that: an individual who believes that his or her constitutional

rights have been violated can bring a civil action against the govern

ment to recover the damages sustained as a result of that violation.

Specifically; 42 USC §1983 “provides a cause of action for the depri

vation of any rights, privileges, or immunities secured by the Constitu

tion and laws by any person acting under color of any statute,

ordinance, regulation, custom, or usage, of any State or Terri

tory ” Gomez v Toledo, 446 US 635, 638 (1980) (internal quotations

omitted). Appellant has exercised this right and pray our Honorable

Court will Stay the Mandate.

Appellant properly asserted the two causes of action under 42

USC §1983 in her Civil Rights Case filed. In Gomez, the United

States Supreme Court determined that only two elements must be

pled to properly assert a cause of action under 42 USC §1983. First,

the Plaintiff must specifically identify the constitutional right of

which she was deprived. Id. at 640. Second, the Plaintiff must as

sert that “the person who deprived her of that federal right acted un

der color of state or territorial law.” Id. All Defendants are State Ac

tors, Plaintiffs site Constitutional Violations. This is arguable and

debatable in the Court of Law and by Jurors. (D) Plaintiff Pray

the Courts for Judicial Review “Marbury v. Madison, 1803” and its

precedence over controversial rulings and pretrial motions that fail

to recognize the merits and constitutional violations of a Color of

Law Cases; i.e. 12 (b)(6) motions, Per Curiam Affirmation,

laws. The United States Supreme Court has the final say in all

matters concerning Constitutional Issues.

Cardoza Law Review, Standford University, Thomas Reuters

and other Reviews, Judges, Attorneys and Law School Profes

sionals reviewed 12(b)(6) Motions as controversial and site they are

utilized before a case is developed. Law Professionals, and Reviews

have sited that 12(b)(6) motions are rarely successful, and when

they are it is due to the Judge.

Plaintiff alleged Judicial Bias. Constitutional Claims warrant

strict scrutiny for governmental review. Per curium Judgement

opinions are issued in the name of the Court rather than specific

judges and denoted Plaintiffs claim as non-controversial, which

was stated in the Courts opinion. Civil cases always stem from con

troversy and denote review. Rule 12(b)(6) motion serves quite differ

ent functions by allowing, elimination of cases at the pleading stage

and even before discovery. In order to streamline civil procedure

and make it consistent with justice, the operation of Rule 12(b)(6)

must become clearer. RULE MUST BECOME CLEARER i.e.Camp

bell Law Review, Vol. 15, Iss. 2 [1993], Art.l http://scholar

ship. law, campell.edu / clr / vol 15 / iss2 /1.

Judges and Civil Procedure Scholars Divided Over New Rule

The New Rule 12(b)(6) Twombly, Iqbal, and the Paradox of Pleading

Rakesh N. Kilaru: States; In the aftermath of the Supreme Court’s 2007

opinion in Bell Atlantic v. Twombly, judges and civil procedure scholars

throughout the country divided on the opinion’s significance. In just

twenty-four pages, Twombly uprooted the Conley v. Gibson standard for

evaluating motions to dismiss a lawsuit under Rule 12(b)(6) of the Fed

eral Rules of Civil Procedure. Under Conley, a court could dismiss a

complaint only if it “appeared] beyond doubt that the plaintiff could

prove no set of facts in support of his claim which would entitle him to

relief.” That standard had governed motions to dismiss for fifty years

and embodied the liberal notice-pleading regime envisioned by the

framers of the Federal Rules of Civil Procedure.But no more. Faced

with a suit alleging that almost every major telephone company had en

gaged in anticompetitive conduct amounting to an antitrust conspiracy,

the Court introduced a new system of “plausibility” pleading designed to

curb discovery abuse and weed out frivolous lawsuits. Now, plaintiffs

had to include in their complaints “enough factual matter” to “nudge[]

their claims across the line from conceivable to plausible . ...” In

responding to the opinion, some judges agreed with Justice Stevens’s

view in dissent that Twombly “rewr[o]te the Nation’s civil procedure

textbooks and callfed] into doubt the pleading rules of most of its

States,” whereas others viewed Twombly fundamentally as an antitrust

case and assumed that the case’s effects would begin and end there. At

the same time, scholars fractured over the opinion’s normative desira

bility; some viewed the opinion as a necessary bulwark against abusive

practices by plaintiffs’ attorneys, whereas others saw it as going too far

in assisting defendants. Almost immediately, Twombly became one of

the most frequently cited cases in pleadings, even as judges split on how

to apply its m any strands.il In the midst of all this confusion, perhaps

only one thing was settled: Twombly’s reach was still unclear.

STATEMENT OF CASE

Plaintiff is an African American (a class) Woman (a woman), Defend

ants acted under the Color of Law, clothed in said authority.

(1) Discrimination: Plaintiff discriminated against because of my

race, gender and the class of the resource “Snow Hill Colored School” of

which we sought to preserve, restore and utilize as a catalyst for

economic development within a Low to Moderate Income Minority Com

munity of West Harper St. in Greene County, N'C, to the benefit of all.

With perfunctory support from State Actors to their inurement of Bond

Funds exceeding 5 million dollars, to the demolition of neglect of Snow

Hill Colored School.

(2) Due Process Violation; Plaintiff was locked out of the school

which served as her Office and focal point for economic development ac

tivities. By State Actors, without Due Process of Law, publicly, bla

tantly with disregard and malicious intent to harm and Plaintiff, her ef

forts and hamper the benefits to be realized by the school’s preservation

and the community at large.

(3) Interference with Prospective Economic Advantage; Defend

ants amended a government contract between the Town of Snow Hill,

N.C. Department of Commerce and Rosenwald Center, to build Plaintiff

and the organization’s capacity to build a housing development, sending

back funds from the Grant and locking Plaintiff out of Office which now

houses Defendant Lenoir Community College programs, adjacent to the

Snow Hill Colored School. Renaming the ballfield, defacing a contrib

uted scoreboard to Plaintiff and organization, honoring a white male,

Coach Fulghum who never attended the segregated school, nor con

tributed its preservation efforts. This was a public event. Halting a

relationship between Minges Bottling Group and Plaintiff because

Defendants usurped the Ballfield and removed Minges Bottling

Group’s name from Scoreboard donated to Plaintiff for organization

and community use, without Due Process of Law. Defendants conspired together to obtain grant funding from the Lowes Fund

through the National Trust denoting Plaintiff perfunctorily as a

partner in. their perfunctory preservation efforts, upon obtaining the

Grant discarded Plaintiffs office equipment, pertinent documents,

locking Plaintiffs Summer Camp participants and Plaintiff out of

the Office and facility.

(4) First Amendment Violation

Plaintiff was invited by former Town Administrator John Bauer to

speak on past work done and view for path forward for preservation

of the Snow Hill Colored School. Plaintiffs protected speech was violated by Town Official Defendant, representing Defendant Lenoir

Community College and Foundation. Plaintiffs protected speech

was shut down in the meeting violating her First Amendment Right.

Plaintiff was stereo-typed in pleadings of Defendant Attorneys,

saying it was necessary to keep decorum of the meeting. Plaintiff

did not shout, clap her hands, stomp, prolong the time allotted to

her nor speak on any subject matter but spoke regarding the path

forward for preservation of the Snow Hill Colored School. Plaintiffs

protected speech was stopped because of her viewpoint.

THERE IS LIKELYHOOD OF IRREPARABLE HARM IF A STAY IS

NOT GRANTED:

Plaintiff has been the center of discriminate actions, ridicule, debili

tation, and undue disregard since being locked out of Snow Hill

Colored School in 2004. There exists no oversight for State Authori

ties and Municipalities in our Rural Area. This leaves the Honorable

Courts as a last reprieve for Plaintiff and other who seek redress.

Plaintiff has received letters from Defendants and their Attorneys.

On June 10, 2010 Plaintiff received letter after being locked out of

the office at former Alternative School Site in which Defendant Le

noir Community College occupied a portion of the building and is

now in possession of this facility; requesting Plaintiffs property be

removed. Defendants blatantly removed Plaintiffs property and per

tinent belongings piling most of them at the back door of the col

lege. One in particular from former President of Lenoir Community

College and Foundation, that the Rosenwald School was not a prior

ity for them and could not become one, while garnering over 5 mil

lion dollars in Bond funding. Followed by a Letter from Defendant

Attorney Thomas H. Morris on December 19, 2015 to threaten and

intimidate Plaintiff, the allowance to date May, 2023 allow the

Snow Hill Colored School to sit in disrepair from demolition by ne

glect. Afterwards Dr. Briley having their attorney send Plaintiff an

intimidating letter. On August 22, 2022, Plaintiff received a letter

from Defendant Lenoir Community College and Foundation’s Attor

ney White and Allen, P.A., Matthew S. Sullivan, referencing that

District Court dismissed my claim and confirmed Lenoir Commu

nity College as owner of the School and not to enter upon the "Pub

lic Facility”, nor try to access it. Plaintiffs had no intentions of try

ing to take possession. But to participate with Community partners

for a back-to-school event to be held on the Snow Hill Colored

School and Rosenwald Memorial Ballfield Site. Plaintiff has not

sought to provoke any Defendants and no longer attend Public Fo

rums or meetings held by them due to fear of retaliation and ad

verse actions and response. Plaintiff has suffered undue stress,

mental anguish, interference with prospective economic advantage.

REASONS FOR GRANTING THE PETITION

An important function of the Supreme Court is to resolve disa

greements among lower courts about specific legal questions. There

are numerous questions, reviews and studies, surrounding the

procedural use and standards of Motion 12(b)(6). Under Brown vs

Board, the Fourteenth Amendment, with its guarantee of equal

protection, became the nation’s most important source of anti-dis

crimination law. It provided a constitutional mandate that states

and their subdivisions and agents refrain from treating persons

and groups of persons differently without good cause. Many of our

protections are currently subject to rejection by the Court, which is

our last resort to be heard and for redress and the Administration

of Justice. Although it has been said that a Rule 12(b)(6) motion, is

rarely granted the District Court has granted a Rule (12) (b)(6) mo

tion and the court of appeals has reversed or vacated that grant in

a considerable number of cases: 4. Thomas E. Willging, Use of Rule

(12) (b)(6) in Two Federal District Courts (Federal Judicial Center

1989). There are conflicting views on Rule (12)(b)(6): Id. At 18: i.e.

credits: Campbell Law Review. Absent a stay irreparable harm will

ensue, thie administration of Justice in the Color of Law claim will

not be realized and it will give State Actors more authority to vio

late Constitutional Rights of Citizens without reprieve and redress.

The Lower Court used its methodology of Frivolity Review to rule

out meritless and frivolous cases. Lower Court sited facts plausi

ble on their face and in Order and Memorandum, sited Plaintiffs

1983 claim to proceed and that at dismissal Plaintiff need only

prove she was treated differently than non-minority males. Plaintiff

has stated and provided exhibits to substantiate her claim which

were not excluded by the Court. And will be of great significance to

the Courts and the Public at large. Plaintiff has succinctly stated

cause for remedy and Pray the Honorable Court Grant Review.

Motion 12(b)(6) is an enemy of Pro Se Litigants, Civil Rights

Cases and can often be the friend of Defendants and overbur

dened Courts.

CONCLUSION

The Honorable Court is our last resort for remedy, I pray the Court consider the long history of discrimination, terror, systemic oppression of

People of Color and the actions being ensued to further advance those.

The acknowledgement that People of Color are indeed and fact and have

been violated and are a class in need of these protections due to mind

sets and yes slavery/master ideology. Without the Courts, the Constitu

tion and laws to protection for People of Color who are marginalized, the

era of Jim Crow, Black Laws and Codes will again dominate and sup

press our lives. There exists no local governmental oversight and to deny

Plaintiff is to allow the furtherance of retaliatory actions and irreparable

harm and miscarriage of justice by use of controversial pretrial motions.

I Pray Our Honorable Court Grant the petition for a writ of certiorari.

Respectfully subrnitted,

Date:

<r -r'YV

—

------------------------------------------------ JL

No.

IN THE

SUPREME COURT OF THE UNITED STATES

JbAnn Artis Stevens

— PETITIONER

(Your Name)

VS.

Town of Snow Hill, et al

RESPONDENT©)

MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS

The petitioner asks leave to file the attached petition for a writ of certiorari

without prepayment of costs and to proceed in forma, pauperis.

Please check the appropriate boxes:

V Petitioner has previously been granted leave to proceed in forma pauperis in

the following court(s):

United States District Court for the Eastern District of North Carolina at Greenville

United States Court of Appeals for the Fourth Circuit

The appointment was made under the following provision of law: 3 of

Federal Rule of Appellate Procedure___________________________

a copy of the order of appointment is appended,

(Signature)

AFFIDAVIT OR DECLARATION

IN SUPPORT OF MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS

JoAnn Artis Stevens

, am the petitioner in the above-entitled case. In support of

I..

my motion to proceed in forma pauperis, I state that because of my poverty I am unable to pay

the costs of this case or to give security therefor! and I believe I am entitled to redress.

1. For both you and your spouse estimate the average amount of money received from each of

the following sources during the past 12 months. Adjust any amount that was received

weekly, biweekly, quarterly, semiannually, or annually to show the monthly rate. Use gross

amounts, that is, amounts before any deductions for taxes or otherwise.

income source

Average monthly amount during

the past 12 months

Amount expected

next month

You

Spouse

You

Spouse

Employment

Self-employment

Income from real property

(such as rental income)

Interest and dividends

Gifts

Alimony

Child Support

$0.

Retirement (such as social

security, pensions, annui

ties, insurance)

$4500

$Deceased

Disability (such as social secu $1684

rity, insurance payments)

$3500

$Deceased

Unemployment payments

$Deceased

Public-assistance

(such as welfare)

$Deceased

Other (specify):

$Deceased

$1684

$3500

$4500

$Deceased

Total monthly income:

2. List your employment history for the past two years, most recent first.

is before taxes or other deductions.) Not applicable

Employer

Address

Dates of

Employment

(Gross monthly pay

Gross monthly pay

3. List your spouse’s employment history for the past two years, most recent employer first.

(Gross monthly pay is before taxes or other deductions.) Not applicable

Employer

Address

Dates of

Employment

Gross monthly pay

4. How much cash do you and your spouse have? $

_____ _________________

Below, state any money you or your spouse have in bank accounts or in any other financial in

stitution.

Type of account (e.g., checking or savings)

checking

savings

Amount you have

$ 367_

$235.71

Amount your spouse has

$22.54

$25.15

5. List the assets, and their values, which you own or your spouse owns.

and ordinary household furnishings.

Home $48,000

Value _____

Motor Vehicle #1

Year, make & model- 2013 BMW

Value $8000.00_______

Other assets

Description

Value____

Other real estate

Value________

Motor Vehicle #2

Year, make & model___

Value_______

Do not list clothing

6. State every person, business, or organization owing you or your spouse money, and the

amount owed. N/A

Person owing you or

your spouse money

Amount owed to you

Amount owed to your spouse

$Deceased

SDeceased

$Deceased

7. State the persons who rely on you or your spouse for support. For minor children, list initials

instead of names (e.g. “J.S.” instead of “John Smith”). Not Applicable

Name

Age

Relationship

8. Estimate the average monthly expenses of you and your family. Show separately the amounts

paid by your spouse. Adjust any payments that are made weekly, biweekly, quarterly, or

annually to show the monthly rate.

You

Rent or home-mortgage payment (in

clude lot rented for mobile home)

Are real estate taxes included? Yes

Is property insurance included? Yes

Your spouse

480

Deceased

X No

430

Deceased

Utilities (electricity, heating fuel, wa

ter, sewer, and telephone)

Home maintenance (repairs and upkeep)

$350

$ Deceased

Food

$575

$ Deceased.

Clothing

$325

$ Deceased

Laundry and dry-cleaning

$100

$ Deceased

Medical and dental expenses

$80.

$ Deceased.

You

Your spouse

Transportation (not including motor vehicle payments)

$0.

$Deceased.

Recreation, entertainment, newspapers, magazines, etc.

$375

$Deceased

Insurance (not deducted from wages or included in mortgage payments)

Homeowner’s or renter’s

$145

$Deceased

Life

$125

$Deceased

Health

$0.

$Deceased

Motor Vehicle

$380.

$Deceased.

Other:

$Deceased

Taxes (not deducted from wages or included in mortgage payments)

House Taxes per .year

680

(specify):

$Deceased

Installment payments

Motor Vehicle

$251

$Deceased

Credit card(s)

$350.

$Deceased

Department store(s)

$150.

$Deceased_

OthehPersonal Loans.

$796.

$Deceased_

Alimony, maintenance, and support paid to others

$0.

$Deceased.

Regular expenses for operation of business, profession,

or farm (attach detailed statement)

$Deceased_

Other (specify):

$Deceased

Total monthly expenses:

$4,912.00.

$Deceased

9. Do you expect any major changes to your monthly income or expenses or in your assets or

liabilities during the next 12 months?

X-Yes

If yes. describe on an attached sheet.

10. Have you paid - or will you be paying - an attorney any money for services in connection

X No

with this case, including the completion of this form? Yes

If yes, how much?______________________

If yes, state the attorney’s name, address, and telephone number:

11. Have you paid—or will you be paying—anyone other than an attorney (such as a paralegal or

a typist) any money for services in connection with this case, including the completion of this

form?

Yes

X -No

If yes, how much?

If yes, state the person’s name, address, and telephone number:

12. Provide any other information that will help explain why you cannot pay the costs of this case.

My husband was the primary breadwinner of our home. He passed on March 15, 2023 from

an accidental fire. He died at the UNC Burn Center leaving me to pay all the bills we both

acquired over the years including assisting our children who have student loans and high

rents. We were planning to install a heating unit in our home as ours went out and to also

repair the roof on our home this year which needs to be done, with costs estimates of

15,000.00. My husband was a spinal cord injury Veteran and purchased some of the items

he needed to prevent total immobility. I travelled to Richmond VA Hospital, Durham Va

and Greenville VA, extensively, staying sometimes weeks at the time, which was a cost to

me. To acquire a Civil Rights Attorney for my such case is next to impossible and very un

affordable. This case has been pending since 2019 it will be prolonged further in seeking

representation as I sought that prior and could not obtain any.

I declare under penalty of perjury that the foregoing is true and correct

Executed on; June 29.

, 2023

(Signature)

ATTACHMENT - CHANGE IN INCOME

XI. Do you expect any major changes to your monthly income or ex

penses or in your assets or liabilities during the next 12 months?

X-Yes No

If yes. describ e on an attached sheet

My home was a two-income household and we managed utilizing credit over the years. My

husband passed on March 15, 2023 after an extensive bout with spinal cord injury.

He was the sole supporter of our home. Although my income has increased from widow’s

pension and his retirement, it is not sufficient enough for me to take on any more financial

responsibilities.

We have done repairs over the past few years on our home and it still need some major up

grades and repairs. We were making plans to get a new heating and air unit as ours no

longer works. Our roof which has been repaired over the years, now need to be replaced.

There are other repairs needed as well.

Medically, I do not have dental insurance and recently had to acquire dentures and need

other dental work done. I do not have insurance that covers vision and recently had to get

new glasses. I remain under doctors care as wall.

Thanks, Respectfully, JoAnn Artis Stevens (

(/)Ol

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.