Petition for Writ of Certiorari — In Re L. E. Pauli Coffey, Petitioner

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Original Case No.20-7568

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Supreme Court of the United States of America

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MAY 2 i» 2023

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In RE: Coffey v. South Carolina

OFFICE OF THE CLERK

SUPREME COUfffj 11st

On Petition for a Writ of Mandamus

To The United States 7th Circuit Court of Appeals

Petition for Writ of Mandamus

-■a'

L.E. Pauli Coffey

3493 Birchwood Ave

Indianapolis, IN

46205

i

AUG 1 1 2023

SUPRlME'couf^f,1^ J

RECEIVED

AUG - 7 2023

OFFICE OF THE CLERK

SUPREME COURT, U.S.

Original Case No.20-7568

Case no.

In the

Supreme Court of the United States of America

In RE: Coffey v. South Carolina

On Petition for a Writ of Mandamus

To The United States 7th Circuit Court of Appeals

Petition for Writ of Mandamus

L.E. Pauli Coffey

3493 Birchwood Ave

Indianapolis, IN

46205

QUESTIONS PRESENTED

Question 1.) Do the Federal Laws of Civil Procedure (Fed R. Civ. P 12) and the Federal

Laws of Appellate Procedure (31) set a time limit for a respondent to respond to notice of

litigation?

Question 2.) In Timbs v. State of Indiana did the US Supreme Court Rule:

Held- The Eighth Amendment’s Excessive Fines Clause is an incorporated protection

apphcable to the States under the Fourteenth Amendment’s Due Process Clause. Pp. 29.(a) The Fourteenth Amendment’s Due Process Clause incorporates and renders applicable

to the States Bill of Rights protections “fundamental to our scheme of ordered liberty,” or

“deeply rooted in this Nation’s history and tradition.” McDonald v. Chicago, 561 U. S. 742,

767 (alterations omitted). If a Bill of Rights protection is incorporated, there is no daylight

between the federal and state conduct it prohibits or requires. Pp. 2-3.

(b) The prohibition embodied in the Excessive Fines Clause carries forward protections

found in sources from Magna Carta to the English Bill of Rights to state constitutions from

the colonial era to the present day. Protection against excessive fines has been a constant

shield throughout Anglo-American history for good reason^ Such fines undermine other

liberties. They can be used, e.g., to retaliate against or chill the speech of political enemies.

They can also be employed, not in service of penal purposes, but as a source of revenue. The

historical and logical case for concluding that the Fourteenth Amendment incorporates the

Excessive Fines Clause is indeed overwhelming. Pp. 3-7.

Question 3 ; Should a writ of Mandamus be issued directing ALL Courts to acknowledge the

lack of response by, and refusal of, the state of South Carolina to timely respond to any of

Petitioner’s efforts, as required by Fed r. Civ. P. 12 et sec, beginning with US District Court

Southern District Indiana L20-CV-0006 and leading to case no. SCOTUS 20-7568, in the

Supreme Court of the United States of America, thereby awarding Petitioner “the win” and

the Right to be made whole for her losses, immediately and without further process.

Petitioner is a person who was turned into an American slave when her Constitutional

Rights and Constitutional Protections were maliciously taken from her so that her assets,

her future and her wealth could be taken from her through the wrongful ascent of Judge

James R. Sweeney and the 7th Circuit Court of Appeals when it upheld Judge Sweeney’s

wrongful decision that ANY state has the Sovereign Right to Deny and Violate Petitioner’s

Right to Due Process.

Question 4 ; Was OUR Constitution written for the purpose of making all people in America

safe through the creation, iteration, application and preservation of OUR equal Rights

(14A), or was OUR Constitution written for the betterment of only those who can afford to

pave the road to the Courts with greenbacks and gold? Are we all equal in the eyes of the

law in America?

PARTIES TO THE CASE

L.E.Pauli Coffey

Vs.

State of South Carolina

(South Carolina NEVER responded)

TABLE OF CONTENTS

Pg. 1. Title page

Pg. 2.-3 Questions presented

Pg. 4. Parties to the Case

Pg. 5. Table of Contents

Pg. 6. Appendix List

Pg. 7. Statement of related Proceedings

Pg. 8. Table of Authorities

Pg. 9. Petition for Writ and Jurisdiction

Pgs. 10-15 Statement of case

Pg. 16-17 Petitioner’s Right to a Writ of Mandamus

Pg. 18. Statement of warrant of a Writ and Conclusion

Pg. 19 Notice of Distribution

Word Count

6276 words

APPENDIX LIST

1.

Docket Record for SCOTUS case no. 20-7568

2.

7th Circuit Court of Appeals Dismissal of Petitioner’s Appeal, citing lack of

jurisdiction and citing Fed R. App. P. Clearly some parts of Fed. R. App. P. are recognized if

they are convenient to the court.

3.

1-20-CV-00006-JRS-MJD dated 03/24/2020 with no citation other than 42 USC 1983.

It’s the original Entry.

4.

Impact iteration from Petitioner dated 06/28/20.

5.

South Carolina Court of Appeals Order demanding two (2) sureties in an amount

equal to twice the value of Petitioners home, an amount nearly seven times great than the

value of the “mortgage” in the fraudulent foreclosure.

6.

14th Judicial Circuit FORM 4 citing foreclosure action against a deceased person but

levied against a hving person who was not party to any mortgage.

7.

7th Circuit Court of Appeals Order regarding the courts’ suspension of paper copies

as of March 31, 2020, due to the world wide Covid-19 emergency. This order vacates the

March 31 2020, Order and returns to allowing and possibly mandating paper copies to be

filed with the court.

STATEMENT OF RELATED PROCEEDINGS

Gateway v. Coffey

2016-CP-07-02261 14TH Judicial Circuit of South Carolina

Gateway v. Coffey

2016-LP-07-00637 14th Judicial Circuit of South Carolina

Coffey v. Gateway

9:17-CV-03021-DCN-MGB US District Court District of Charleston SC

4TH Circuit US Court of Appeals

Gateway v. Coffey

2018-001743 South Carolina Court of Appeals

Coffey v. South Carolina

D19-CV-03064 US District Court Southern District of Indiana

Coffey v. South Carolina

D20-CV-00006 US District Court Southern District of Indiana

Coffey v. South Carolina

20-7568 Supreme Court of the United States of America

***

Amy Coney Barrett should recuse herself from this matter***

TABLE OF AUTHORITIES

Timbs v. Indiana 17-1091(SCOTUS 2019)

Ex Parte Young 209 US 123 (1908)

[The federal court granted the request for an injunction, since it was unpersuaded by Young

that the Eleventh Amendment removed its jurisdiction over a case in which a state was

sued by a citizen of another state (in this case, the shareholders).]

Article I, II, III

8TH Amendment to the US Constitution

4TH Amendment to the US Constitution

14th Amendment to the US Constitution

13th Amendment to the US Constitution

Supremacy Clause

U.S. Constitution

Constitution of the State of South Carolina

Williams v. Illinois 399 US 235-236 37 (1970)

PETITION FOR A WRIT OF MANDAMUS

Petitioner respectfully petitions for a writ of mandamus to the United States District Court,

Southern District of Indiana and the 7th Circuit Court of Appeals requesting that the 7th

Circuit Court of Appeals remand this case to the district court.

JURISDICTION

28 USC 1651(a) The Supreme Court and all courts estabhshed by Act of Congress may

issue all writs necessary or appropriate in aid of their respective jurisdictions and agreeable

to the usages and principles of law.” 28 U.S.C. § 1651

STATEMENT OF CASE

On or about October 21, 2016, Petitioner was served in the state of Indiana with a

malicious Notice of a fraudulent Foreclosure on her home in the state of South Carolina,

County of Beaufort, City of Beaufort, by Gateway Mortgage Group LLC, when she had

never entered into a mortgage with anyone.

Ultimately, Petitioner lost her South Carolina home to a fake, malicious foreclosure

ONLY AFTER Gateway Mortgage Group LLC appointed its’ own attorney as the presiding

judge in the matter of Gateway v. Coffey when the actual Equity judge for the 14th Judicial

circuit vacated the malicious Lis Pendens action and case AND vacated all Equity courts in

the state of South Carolina so that the matter could not simply jurisdiction hop into a more

friendly locale. The Equity Master knew the history of the 14th judicial circuit and did his

best to spare Petitioner the agony and abuse he knew it had become famous under the reign

of the Murdaughs and likeminded fellows. His attempts were in vain, as Gateway

Mortgage Group LLC was allowed to appoint its’ own attorney as the presiding judge in the

matter of Gateway v. Coffey and used its’ attorney to engineer an illegal win.

Damn, its’ easy to win a case when your own attorney is the presiding judge!

Obviously, despite her lack of understanding of exactly how corrupt the courts of

the 14th Judicial Circuit of the state of South Carolina had been for more than a century,

Petitioner did everything allowed by law, as the records show in graphic detail, but still lost

her home, her assets, her wealth, her possessions and years of her life to a false, malicious,

and wanton foreclosure/lis pendens action when Gateway’s Judge issued Orders for his

client to write a mortgage in Petitioner’s dead husband’s name and apply it to Petitioner’s

home, her exclusive property as a matter of law, so that it could be sold on the steps of the

Beaufort County court house for five bucks to the very entity responsible for petitioner’s

husband’s death,

IF you’ve never had the great misfortune of having encountered the 14th judicial

circuit of the state of South Carolina, and its’ level of lunacy, larceny and corruption, please

consider yourself blessed as NOTHING could prepare a rational person for these on-goings.

Petitioner can attest to the fact that the Constitution of the United States of America, as

the record shows, has no place in the 14th judicial circuit of the state of South Carolina

Heck, not even the Constitution of the state of South Carolina, as the record shows, has any

meaning beyond setting a templet for fiscal billing. The Constitution for the state of South

Carolina isn t even a general rule of thumb for the courts or staff of the 14th judicial circuit

in South Carolina.

Petitioner was educated on what “Biblical license” in a Court Record/Docket means,

in the state of South Carolina. Wow!

Gateway Mortgage Group LLC and the state of South Carolina, through the 14th

judicial circuit, trafficked Petitioner from the state of South Carolina to the state of Indiana

against her will and her wishes using a fraudulent financial instrument, a fake mortgage

that did not exist until October 2018, years after the Lis Pendens/foreclosure was filed, to

the financial benefit of Gateway Mortgage Group, the state of South Carolina, the first

buyer and the second buyer. Petitioner’s other choice rather than returning to Indiana, to

the home her son had used to complete his college education, was to sleep on the road in

front of what used to be her South Carolina, water view home.

The state of South Carolina, through many mechanisms of its’ courts, stripped

Petitioner of her 8th Amendment Right to be free from excessive fines. The State of South

Carolina stripped Petitioner of her 14th Amendment Due Process rights. The state of South

Carolina stripped Petitioner of her equality. By stripping Petitioner of her Rights, her

wealth and her future, South Carolina enslaved Petitioner to serve the will and whimsy of

the state of South Carolina, at great harm to Petitioner, a common practice in Beaufort

County, South Carolina, as the world has now witnessed.

The Court of Appeals of the state of South Carolina, oddly enough, was appointed in part by

the presiding judge in the matter of Gateway v. Coffey, Gateway’s own attorney. The Court

of Appeals of the state of South Carolina demanded that Petitioner produce two (2) surety

bonds equaling the amount of $700,000.00, nearly seven times the value of the fake

mortgage, to prevent the sale of her home during the appellate process. This demand was

clearly a violation of Petitioner’s 8th Amendment Right to be free of unreasonable fines.

And, in light of the many times the appellate court DID NOT require homeowners to

produce such an asinine bond, Petitioner should never have been required to produce a

surety bond in any amount to save a home that was in her name but plagued by a 2018

mortgage in her dead husband’s name, a man who died years earlier.

The state of South Carolina allowed Gateway Mortgage Group LLC to appoint its’

own attorney as the presiding judge! What more needs to be said, beyond that?

The state of South Carolina also allowed the Courts to refuse to acknowledge its’ own

caselaw in matters of lending, as evidenced by Petitioner, for years," i.e. Federal Land Bank

v. Ledford 9 SE 2d 804 (SC 1940). The state ignored its’ own, state issued, Real Estate

Essentials (2014-2018) manual, as cited by Petitioner.

That state of South Carolina stripped Petitioner of her 4th amendment Right to be

free from illegal search and seizure. Petitioner’s person, papers, things and home were

illegally searched and her home and possessions were illegally seized.

The state of South Carolina’s 14th judicial circuit did horrible things to Petitioner,

effects of which can surely still be felt, today. Petitioner lost years of her life, her assets,

her cash, future income, a fact that was surely by design as a poor person cannot afford

counsel and fight for her Rights and Protections, and please let’s not forget that OUR

Constitution does provide exactly that. It provides not only Rights by which we are

guaranteed to enjoy life, it also provides Protections by which we can be assure that our

Rights and our way of life are dictated by our lawful choices and not by the crimes of those

who financially benefit by hurting others. Petitioner was born a free person but she has

been denied freedom and equality by the state of South Carolina and Gateway Mortgage

Group LLC and the lower courts. Petitioner has been denied the Rights and Protections

guaranteed to her by OUR Constitution that would enjoin her with the freedom necessary

for her to live her lawful life as she sees fit.

On January 2, 2020, Petitioner brought her claim to the US District Court, Southern

District Indiana for the second time, case no 1;20'CV_00006, and was assigned to Judge

James R. Sweeney s court. At the time of her filing, Covid 19 was just around the corner

and no one knew that an entire planet was going to be shut down in the middle of March of

that same year. Petitioner DID timely notify the state of South Carolina of suit AND did

contemporaneously provide evidence of that USPS Notice to the court. Alan Wilson Atty

General for the state of South Carolina did timely receive Notice of suit and never

responded. By January 29, 2020, after hearing nothing from the state of South Carolina,

Petitioner moved for default judgement for refusing to comply with Fed. R. Civ. P 12 et sec.

Despite the missive of Judge Sweeney, that Petitioner did not have cause to file her suit

with the Court because states have the Sovereign Immunity to ignore our laws and destroy

whoever they please, Judge Sweeney WAS wrong and simply whining! Judge Sweeney

cannot gift any state Sovereign Immunity. No Court, though it happens all the time, can

pick and choose who has Rights and who does not. At least they’re not supposed to do that.

As it stands now, the precedence has been set that ANY state merely ignore Notice of Suit

and it’ll go away.

The state of South Carolina had myriad excuses to use to deflect Petitioner’s suit, as

provided by Fed R. Civ. P. 12 et sec, if only for the purpose of dragging Petitioner through

Hell, sideways, for a little longer. As a matter of law, no excuse in Fed. R. Civ. P. 12 had

any standing and Petitioner should have been immediately awarded the ’’win” and justly

compensation for the crimes committed against her by the state of South Carolina and for

her suffering and losses. Petitioner did successfully show injury at the hands of the state of

South Carolina, But Judge James R. Sweeney, a marine who served at some point in South

Carolina, wasn’t having any part of that! Instead of responding to Petitioner’s Motion for

Default judgment, as required by law, Judge Sweeney ignored it for two months and, under

cover of the closing of the courts for Covid" 19, Judge Sweeney defied our Constitution and

our laws and illegally ruled that the state of South Carolina had the Sovereign Immunity to

violate Petitioner s Due Process Rights. South Carolina never said a word as it was obvious

Judge James R. Sweeney was speaking for South Carolina. Petitioner, after living in

coastal South Carolina, can only assume that one act bought an awesome vacation home off

Edisto beach or Pauley’s Island! Using Sovereign Immunity to deflect a pro se litigant with

the law on her side was obviously a gift to someone, somewhere, AND in direct violation of

Timbs v. Indiana 17-1901 (US Supreme Ct Feb 20, 2019).

Petitioner wants to set the record straight, as she understands it. Even Pro Se

litigants are supposed to have EQUAL Constitutional Rights and Protections. Without

them, our country, no matter how lawless it seems right now, would have no laws if not for

our Constitutional Rights and Protections. Criminals have glass encased, limestone and

concrete monuments erected in their honor to insure and protect their Rights and

Protections if, and when, they are arrested for their crimes. Those structures are called

Courts.

Professional courtesy is NOT an excuse to ignore/deny Petitioner’s Rights. The ONLY

business of the Court is to serve the people who give it purpose and those people are

citizens, without regard for their ability to afford representation. It would appear that the

US District Court, Southern District of Indiana, has taken it upon itself to pick up a really

broad paint brush, dip it in some lead based paint and start lashing out with it against

anyone, not a criminal, who can’t afford an attorney. Murderers get free attorneys.

Innocent people are called victims and we have rights, also. Fed R. Civ. P. is very clear that

unrepresented people DO NOT have to use super-secret legalese to state a claim.

Petitioner had no difficulty stating a claim in Judge Sweeney’s court. Fed R. Civ. P 12. say

a defendant has to respond. South Carolina did not respond and Judge Sweeney took it

upon himself to NOT serve the state of South Carolina. It’s a good thing Petitioner did

timely serve the state of South Carolina and evidence it in Judge Sweeney’s court.

Judge Sweeney DID take it upon himself to wait until more than eighty (80) days had

passed before he took cover under the closing of the Federal and Appellate court(s), due to

Covid-19, to respond to Petitioner’s Motion for default judgement stemming from the state

of South Carolina refusing to respond. Judge Sweeney believes only some people have

Rights and Protections in America and in Indiana.

Upon Notice of Judge Sweeney’s March 23, 2020 ruling, in violation of our Constitution and

contemporaneous case law, petitioner found a way to respond DESPITE having no way to

print documents or file electronically, and asked that Judge Sweeney and the Court revisit

his decision. Judge Sweeney, again, ignored Petitioner’s request to revisit until August of

2020, nearly two months AFTER the 7th Circuit Court of Appeals resumed its’ acceptance

of paper filing. It is well documented that Petitioner was denied access to Pacer/ECF and

was not allowed to electronically file anything reference her case in the court.

It s like having both hands tied behind your back and then being thrown in a deep

body of water to sink or swim.

On June 23, 2020, the 7th Circuit Court of Appeals resumed acceptance of paper

filings and on July 7th, 2020, having heard nothing from Judge James R. Sweeney,

Petitioner filed her initial appeal of Judge Sweeney’s unlawful decision with the 7th Circuit

Court of Appeals, fewer than thirty days (30) after the court became available, due to

Covid-19. The 7th Circuit, Amy Coney Barrett included, inexplicably upheld the unlawful

ruling of Judge James R. Sweeney, initially and through review, despite it having no basis

in law and also refused to require the state of South Carolina to respond to Notice of

Appeal. The only business of the Court is supposed to be OUR laws and OUR laws say no

one has the Sovereign Immunity to Violate my 8th Amendment Right to Due Process and

no one has the Sovereign Immunity to Violate my Due Process(es).

In January 7, 2021, Petitioner filed her appeal of the unlawful decision of the 7th Circuit

Court of Appeals with the Supreme Court of United States of America, Coffey v, State of

South Carolina, 20-7568. Shortly after Petitioner’s initial filing, Judge James R. Sweeney,

who was, now, apparently paying attention to Petitioner, took it upon himself to file an

extraneous Notice with the Court that Petitioner had untimely filed her appeal with the 7th

Circuit. This is untrue! Judge Sweeney did not even file a response to Petitioner’s demand

that he revisit his decision of March 23, 2020, until August 2020, AFTER Petitioner filed

her appeal within thirty (30) days of Notice of the renewed availability of the 7th Circuit

Court of Appeals.

PETITIONER’S RIGHT TO ISSUANCE OF A WRIT IS CLEAR

Petitioner’s Right to the Issuance of a writ is very clear. The Court may “issue all

writs necessary or appropriate in the aid of their respective jurisdictions and agreeable to

the usages and principles of law.” 28 U.S.C. § 1651(a). A writ of mandamus is warranted

where “(l) no other adequate means exist to attain the relief [the party] desires, (2) the

party s right to issuance of the writ is clear and indisputable, and (3) the writ is appropriate

under the circumstances.” Hollingsworth v. Perry, 558 U.S. 183, 190 (2010) (quoting

Cheney v. United States Dist. Ct., 542 U.S. 367, 380—81 (2004)) (internal quotation marks

and alterations omitted). Mandamus is reserved for “exceptional circumstances amounting

to a judicial ‘usurpation of power.’” Cheney, 542 U.S. at 380 (citation omitted). Where a

lower court “mistakes or misconstrues the decree of this Court” and fails to “give full effect

to the mandate, its action may be controlled k k k by a writ of mandamus to execute the

mandate of this Court.” Gen. Atomic Co. v. Felter, 436 U.S. 493, 497 (1978) (per curiam)

(quoting In re Sanford Fork & Tool Co., 160 U.S. 247, 255 (1895)); see also United States v.

Fossatt,62 U.S. 445, 446 (1858) (“[W]hen a case is sent to the court below by a mandate

from this court, k k k if the court does not proceed to execute the mandate, or disobeys and

mistakes its meaning, the party aggrieved may, by motion for a mandamus, at any time,

bring the errors or omissions of the inferior court before this court for correction.”). Citing

Justice Alito, Borden, Jr v. US, US 19-5410, (2021)(oral arguments)

[ Well, you know, I was" I was on a court of appeals at the time, and

I acknowledged that I had to follow Supreme Court opinions...]

Exceptional circumstances are present in the matter of Coffey v. South Carolina.

OUR Constitution guarantees Petitioner a fair trial no matter where she is in

America. This isn’t even something we should be discussing. The Amendments to OUR

Constitution were created for the purpose of guaranteeing that all people enjoy the same

Rights and Protections described in our Constitution and its’ Amendments. It isn’t our laws

that are the problem. It is the application of, and practice of, our laws that have led us

down this rabbit hole, together.

Judge James Sweeney had one job: Rule for the law. The law is very clear. States do NOT

have the Sovereign Immunity to deny anyone their Right to Due Process. Timbs v. State of

Indiana, US Supreme Ct case no. 17_1091 (Feb 2019). The 14th Amendment does not refer

to a single Due Process Right. It does not refer to a handful of Due Process Rights. The

14th Amendment was not created as a party favor to be handed out to only those with

most favored status” in America. But it would appear that as Judge James R. Sweeney

ignored our Constitution, ignored the 14th Amendment to the Constitution and ignored

contemporaneous case law, i.e. Timbs v. State of Indiana, to the benefit of the state of South

Carolina, the defendant that Judge James R. Sweeney refused to require to comply with

Fed. R. Civ. P 12. Judge Sweeney simply ignored Fed R. Civ P 12.

If the rules of the court and the rule of law had been applied, Petitioner would have been

spared additional years of suffering. Petitioner would have been spared the pain of

delivering pizza for a living, during a pandemic, because it was the only way she could pay

her bills. Bills that would have been paid by the proceeds from the sale of her South

Carolina home or the proceeds from her husband’s wrongful death suit, a suit called off

because South Carolina went after Petitioner’s home for the purpose of removing her fr om

the venue of her husband’s death.

Petitioner’s appeal to the US Supreme Court was initially picked up and then

dropped like a bomb after Judge James R. Sweeney filed his untimely and blatantly

incorrect Notice in April 2021. Petitioner did timely and correctly file her Appeal as allowed

by the Orders of availability set by the 7th Circuit Court of Appeals.

Petitioner is not an attorney and could never been an attorney until a few vital

issues are settled in America. One of those issues may be standing front and center of this

request for writ of mandamus. At issue is whether a female pro se litigant has equal rights

in the eyes of the court. Any court. OUR Constitution says that all people have equal rights

in America (14A). Our country was founded by persons wishing to escape the rule of ascent

in England and yet, here we are, staring straight into the face of the rule of ascent, in

violation of Fed. R. Civ. P., by Judge James R. Sweeney.

Judge Sweeney had no legal standing to deny Petitioner the benefit of the application of

the federal rules of civil procedure in the matter of Coffey v. South Carolina. i:20-CV00006. Petitioner showed jurisdiction, venue, cause and harm/injury suffered. Article III

was absolutely satisfied. Requiring the state of South Carolina to comply with Fed R. Civ.

P. 12 and simply respond, at the very least, would have, in no way, harmed Judge James R.

Sweeney or the state of South Carolina or the US District Court, Southern District of

Indiana. However, sparing the state of South Carolina from having to respond to

Petitioner s suit saved the state of South Carolina from having to answer for why it allowed

a plaintiff to appoint its own attorney as adjudicator in a fraudulent foreclosure which

provided financial benefit to South Carolina, the 14th Judicial Circuit of South Carolina

and a mortgage company that has been banned from ever operating in the state of Georgia

due to its’ fraud, while simultaneously turning a service connected DAV widow into an

American slave with no rights.

Petitioner believes that any person who would read this Petition would do so with the belief

that, individually (standing alone in America), they have been bestowed with Rights and

Protections to ensure equal opportunity to pursue their lawful dreams and life styles

without hinderance or burden or the need to keep an attorney in their pocket and on

retainer. The Haves and the Have nots...

Additionally, Petitioner would like to believe that no court would deny an individual equal

rights just out of its’ own objective to maintain job security for attorneys. The Haves and

Have nots... The Federal Rules of Civil Procedure have been intentionally written to be

our most recent representation America’s commitment to “all-inclusiveness”. But those

rules are useless when they are only subjectively observed. Failure to equally apply those

rules to all persons is where slavery begins and grows in America.

The state of South Carolina, despite its’ means, refused to respond to any Notice of suit or

appeal or Notice of changing venue to the US Supreme court for appeal and its’ silence

forfeited its’ Rights to respond or complain. The record shows that in U.S. District Court,

Southern District Indiana, that pro se, male litigants who also happen to be terrorists, i.e.,

John Walker Lindh, the American Taliban, have their pro se 1983 cases met with the

court s assistance in getting an ACLU attorney appointed to ensure that his Constitutional

Bights are not violated. Tyson Timbs, a drug dealer, enjoyed an entire cadre of attorneys,

to include current staff at the US District Court Southern District of Indiana, to ensure

that his 14th Amendment Right to Due Process and all his Due Processes were upheld and

enforced.

In the matter of Coffey v. South Carolina (20-7568), petitioner is not a male. Petitioner is

not a drug dealer. Petitioner is not a Terrorist. Petitioner is a genetically born female who

has been stripped of her Due Process Rights, her Due Process Protections, her Due

Processes, her wealth, her property, and her peace of mind because, by all outward

appearance, her sole defect is being a female. Petitioner has pointed it out several times

but the ONLY business of the Court is to provide for the citizens of this country, even the

female citizens of this country.

A WRIT OF MANDAMUS IS WARRANTED

America has become painfully aware in recent days of how devastating and how

destructive double standards in law can truly be. Especially in the state of South Carolina.

As the whole world has watched in amazement and horror, the ugly truth about the real

14th Judicial Circuit of the state of South Carolina has not only reared its’ ugly head in the

matter of the state of South Carolina v. Richard Alex Murdaugh, it has cast a shadow

across the entire judiciary of the whole state of South Carolina. In the 14th Judicial Circuit

of South Carolina, it is standard operating procedure to hire a politician as counsel if you

have the money and can afford to pay for a nearly guaranteed win in court. Laws have

never before mattered in the 14th Judicial Circuit of South Carolina.

Gateway Mortgage Group LLC took such a path in 2017 and hired South Carolina

state representative R. Thayer Rivers Jr. as counsel after the actual Equity Judge in the

14th Judicial Circuit vacated the fraudulent foreclosure against Petitioner.

But R. Thayer Rivers Jr. provided a second protection for his client, Gateway Mortgage

Group LLC. In his capacity as a state of South Carolina representative, R. Thayer Rivers

Jr. also enjoyed swishing his hand through the appointment process for the bench of the

Appellate Court of the state of South Carolina, thereby eliminating Petitioner’s chance at a

fair trial in the Appellate Court. It was the Appellate Court of the state of South Carolina

that, at its discretion, enforced a requirement for an illegal bond which violated Petitioners’

8th Amendment Right to reasonable fees, a bond Petitioner could not afford and one which

eclipsed the “value” of the fraudulent mortgage by seven (7) times, to spare Petitioner’s

home from sale during an appeal that she later discovered she could never win because

Gateway Mortgage Groups’ attorney appointed the bench of the South Carolina Court of

Appeals. The South Carolina Court of Appeals had many times waived the illegal bond

requirement for other litigants, similarly situated and fighting to save their homes. But no

such mercy came from that court for Petitioner. Rights are like party favors in South

Carolina.

Petitioner spent literally years screaming about the corruption of the Courts of the 14th

Judicial Circuit and, until a young girl’s fife was ended in Beaufort, South Carolina, no one

listened. The South Carolina Court of Appeals showed that it subjectively takes mercy on

some people but not others, most likely determined by whom may be facing off against a

state politician in a court of law. Alice had it better in Wonderland. All she had to do was

survive psychedelic mushrooms and disappearing cats.

Petitioner even went so far as to file a FCRA case against Gateway Mortgage Group

LLC, US District Court Charleston, South Carolina, Beaufort Division, Coffey v. Gateway

Mortgage Group LLC 9-17'CV‘03021'DCN"MGB, for publicly and falsely accusing

Petitioner of having entered into a mortgage to which petitioner was never a party.

Petitioner’s name and likeness were put in harm’s way with Gateway’s reckless and illegal

behavior. Behavior which was condoned and facilitated by the state of South Carolina and

which financially benefited the state of South Carolina. But, once again, a single woman

was denied her Rights in a Court of law, (Coffey v. Gateway LLC earlier cited; please read

the documents. The docket was written with a bit of South Carolinian biblical license.)

Heck, Petitioner even went so far as to file bankruptcy to avoid the fraudulent judicial hen

ordered by Thayer Rivers Jr, after his Orders, instructing his client to finally write a

mortgage, were issued in October of 2018. Petitioner was notified by the bankruptcy court

that she could not file bankruptcy because she did not have creditors, at which point

Petitioner was not going to waste any more time on bankruptcy and, once again, the docket

in that matter does not reflect the documents provided. The state of South Carolina wanted

Petitioner as far away from those who killed Petitioner’s husband as they could push

Petitioner, and wanted her as busy as they could make her by wrongfully and wantonly

taking her home from her so she could not file suit for her husband’s wrongful death,

Williams v. Illinois 399 US 235-236-37 (1970) (citation omitted). South Carolina had very

little resistance because Petitioner is a woman. Being a genetic woman means you are a

possession in American Courts and not a person.

The matter of Coffey v. South Carolina has spanned several states and possibly nine

courts in total and is so brutally removed from what our Constitution is supposed to protect

and provide to anyone standing in America and our rights, that it has rewritten what is

right and what is wrong in our Courts. Men have rights but genetic women do not have

rights. Drug dealers have rights, including the right to free counsel, but genetic women

who are not criminals do not have rights. Male terrorists who killed Americans on behalf of

ISIS have rights and free attorneys and they spend less time in jail than this Petitioner has

spent fighting to get her Constitutional Rights and Protections recognized and reinstated.

Cold hard facts, America’s greatest fear on planet Earth is not Iran with nuclear weapons.

Its’ greatest fear is not North Korea armed with nuclear weapons. America’s greatest fear

is not Dylan Mulvaney with a cold brew in a bathtub, somewhere. America’s greatest fear

is a woman, standing alone in a court of law, with equal rights and equal protections.

Women are less than equal in the eyes of every court if women stand before a court

alone. And that needs to change immediately! Our Constitution was written by five (5) men

in 1776. Since its ratification, it has evolved to show the growth and change in America.

Each Amendment to OUR Constitution represents the growth of the aspirations of our

great country to be even better. Unfortunately, our courts, independently and collectively,

have refused to evolve and grow with our country and its’ collective aspirations, that all

people in our country are not only equal but that each person is treated equally in the eyes,

blindfolded or not, of the Court. As evidenced by James R. Sweeney, the court is more than

willing to outright lie for the purpose of protecting a court from a genetic woman who

mistakenly believes she not only has equal rights but equal protections bestowed upon her

by virtue of simply standing in America. If America wants to quote Bible and verse to the

rest of the planet about the rights and protections it expects for women, then maybe it

needs to lead by example. Mistakes have been made. Amy Coney Barrett needed to recuse

herself from this matter at the Supreme Court level and she did not. James R. Sweeney

needed to rule for case law and Constitutional law and he did not. Rights and Protections

are not supposed to be the exclusive property of the rich and the criminals. America needs

to own this and fix it.

A Writ of Mandamus ordering the appellate court to remand the matter to the district court

so that the district court may correctly rule for law and Petitioner, rather than for

professional courtesy, is the only way to begin to fix what is broken in our courts and in

OUR country. Our laws are not meant for the privileged few. Our protections are not

meant for the privileged few. Petitioner is not so naive as to believe she can save America,

but she hopes she can work towards ending this kind of slavery in America.

CONCLUSION

For the foregoing reasons, and if this Court chooses not to revisit this matter of its’

own volition and spare Petitioner an even longer fight, the Court should issue a writ of

mandamus directing the appellate court to remand this matter to the lower court so that

the lower court may rule for Petitioner and Order the state of South Carolina to make

Petitioner whole for her losses and suffering so that Petitioner may resume her life. Had

Judge Sweeney obeyed the law and the rules of the Court in 2020, as Petitioner’s filing was

not deficient, this matter would never have made it to the Supreme Court of the United

States of America and there would be no appearance of this type of slavery in America.

Respectfully Submitted,

L/EirPaiili Coffey

A

3493 Birchwood Ave

Indianapolis, IN 46205

In RE: 20-7568 Coffey v. South Carolina

Petition for Writ of Mandamus

WORD COUNT 4465

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