Petition for Rehearing — Meghan Kelly, Petitioner v. United States District Court for the Eastern District of Pennsylvania

Supreme Court briefOct 29, 2024

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IN THE SUPREME COURT OF THE STATE OF DELAWARE

Meghan Kelly,

)

Plaintiff Below,

)

Appellant,

)

Donald Trump, a.k.a. Donald J.

)

Trump, a.k.a. President Trump

)

a.k.a. President Donald Trump,

)

in his official capacity as President of )

the United States

)

Defendant Below,

)

Appellant,

)

No. 119, 2021

APPELLANT’S MOTION FOR THE DELAWARE SUPREME COURT TO

REQUIRE THE RECUSAL OF THE HONORABLE CHIEF JUSTICE COLLINS

J. SEITZ, JUNIOR IN THIS MATTER

I, Meghan Kelly, pro se appellant, unopposed, having been granted in

forma pauperis relief, move this honorable Delaware Supreme Court, unopposed,

move to recuse the Honorable Chief Justice Collins J. Seitz, Junior (“Chief Justice

Seitz”) from participating in review of my case, requiring delegation to the other

honorable Justices.

On about May 25, 2021, I sent the honorable Court Appellant’s

(unopposed) Motion to guide or reign in the arms of the Delaware Supreme Court,

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or for other relief this Court deems just, (the “motion”), incorporated herein as if

included in the first instance. I suggested private guidance. Motion at 1, 37, 38.

One of the allegations in the motion was concerning De-Lapp’s

response to a request for a suspension of bar fees to serve De-Lapp’s purpose not

to help to pay any fee since I paid such fees. Motion at 24 -30. Attached please

find my receipt of payment of the Bar registration fee, incorporated as an exhibit,

as if expressly stated herein.

I attached the May 24, 2021 attack letter as an exhibit to the motion,

and incorporate it herein as if included as part of the motion.

In the May 24, 2021 attack letter, Carol Waldauser and Eleanor Kiesel

state, “We understand that you may be experiencing some financial difficulties

with regard to license fees.”

The only person who knew I made a request for suspension of

Attorney Registration of license fees is Chief Justice Seitz, since I made the

request to him, and Mark Vavala.

I reached out to Mark Vavala (“Mark”) per the emails, attached herein

and included and incorporated herewith as if alleged as part of this motion

(“Emails”), admitted under the state of mind exceptions, belief and admissions.

See Exhibit, the Emails.

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I turned to Mark for guidance, as he has always treated me as a judge

should, with respect regardless of poverty, religious belief or association, as to

requesting relief for attorney registration fees.

In the past I turned to Mark when he was a commissioner when Cathy

Marshall, the former Supreme Court Clerk treated me with great cruelty and

disregard for humanity for cost and convenience, reflecting the image of Satan

with regard to unbending rules and penalties regarding the rather unsafe

requirement of registration online and by required use of emails during a

heightened time of increased threats to electronic hacks.1

I am trying to persuade US Attorney General Garland to close the back doors on

electronic devices President Bush Junior opened up under the guise of safety from

terrorism. Bush opened the door to economic, speech and privacy attacks, making

the entire globe less safe, especially with regards to health data, health insurance

hacks and systems in recent years. Our information is more easily manipulated

making us believe we are safe when the pandemic may not be waning as much as

suspected. Please note, worldometer has not been reporting all states in its data but

has excluded about ten states every day for the past two weeks. I suspect it is

being manipulated, hacked, to market the vaccine as working better than it is. I

have checked worldometer every day for over a year. They included most states

every other day. This is strikingly concerning to me. See, Dckt 71, Exhibit E,

Exhibit 26, copy of the web site worldometer, to show healthcare is the biggest

global money maker and expense.

Bush sold our freedoms for money by opening the door to those who will kill, steal

and destroy or diminish freedoms and lives to gain more material gain. Freedom is

not for sale. People are not for sale, to those who require they pay for freedom.

People are priceless not price tags, worthy of protection by this Court. Throwing

money at a problem or grants is never the solution. Neither is money given to

government agencies without strings attached. The spend it as you see fit or lose it

provisions reward waste. Strings attached to laws must be tied with all

government money offering guidance for good not evil greed, the mark of the

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damned. The desire for more government money for government partnered

entities under the guise of charity or otherwise, including churches, is the problem.

Business greed, to use for the study of things, science to manipulate to gain grants

or business profit for something different or for a different fix instead of removing

the problem should end. Entities are rewarded with more money by not resolving

the problem. Government must fund itself, not pay bribes to entities which per se

try to get as much as they can for as little as they can. Then, such entities may

supplement with fundraising and charity which I believe damns people to hell.

Schools, sports and the post offices would be fully funded if the government paid

bills instead of bribes. Children learn to go the way to hell by learning early to rely

on associations and organizations, artificial entities without hearts, that run on the

mark of the beast to represent their interests, instead of choosing to use their own

brains to think, to care, to know, to love, individually and specially, as the treasure

they are. We lose treasures to hell. Children are forced to fundraise for sports and

schools which will damn them to hell should they not unharden their heads and

learn such evil is bad, all to pay bribes of government agents to serve their interest.

Property taxes should not be increased to fund government bribes, thereby creating

disparate treatment by zip code, based on home values in violation of the Equal

Protections Clause applicable to the states via the Fourteenth Amendment, with no

rationally related purpose. The government would decrease waste, create a more

fair, equal and just union if government employees, including Presidents and law

makers, did their jobs instead of exploiting tasks to serve government agents

personal interest including but not limited to getting out of work or liability, while

arguably creating artificial debt in violation of the 13th amendment to serve greed

not need, by paying entities to profit off of its government duties at a greater bill to

its people in terms of not merely monetary loss but loss of constitutional freedoms.

It is an abomination. The government itself is a heartless beast should the agents

not use their power to individually use their free will, their brains, to think, to care,

to know, to love people, instead of acting as heartless robots going through

mechanical motions of a system. Then brainlessly blaming the system, instead of

themselves, for problems they cared naught to address.

I digress, government funding for science is bad and a black hole, that should be

closed from sucking the life blood and souls out of humanity by indentured

servitude to feed unsatiable greed by entities without hearts. Just laws, just

policies and justice in the courts is the solution to close the black hole. The

government rewards businesses for made to break, made to repair and replace

products, polluting in the production and polluting with replaced parts and

products in the landfills. The US through its unjust decrees, including but not

limited to the UCC, tax code wrote offs and insurance laws is the reason why the

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world is so polluted. China would not make made to break, service and replace

products if our courts and laws did not reward such, instead of made to last goods,

decreasing polluting in production and in parts. Money is never the solution, since

it rewards misbehavior, to create the endless lust for greed to make something

different, or use of a product for a different function, not made to last, not made to

work. Science is the study of things. When the pupils, doctors and scientists

declare themselves to be the masters of the universe on a subject, the experts, or

knowing the answers, they are per se stupid, and defeat science. Science, after all,

is the mere study of things, not the master of things as defined by the scientific

method with built in recognized uncertainties called variables, unknown and

known. Meaning possible error, not knowing everything, is declared as part of the

scientific method. Learning is good, but manipulating data while using good

science, retrieved from tests for self-gain, not knowledge, is deceptive and wicked.

Our government appears to be partnered with private industries, not for profits,

businesses, and churches, by bought or bartered for bribes, in exchange for loyalty

or backing of elections, paid with money taken from being used for the people’s

need, government infrastructure, not Biden’s bad plan either, to be used to pay

entities to perform the government’s job because the government employees evade

responsibility of working and blame for expenditures and plans not working, grants

and bailouts to exploit the problem to waste money and cause harm to the world

for self-gain, by creating industries to profit off of the problems instead of

correcting the problem by making the world more safe by closing the back doors in

electronics, including but not limited to making lawyers money by adding an

unnecessary additional field, insurance companies, fields for miners who sell our

data, anti-virus software companies. I am still brainstorming constitutional and

criminal theories to persuade the US AG Garland to save us regarding foreseeable

looming threats not by people but by entities without hearts, businesses, LLCs and

such, by protecting our freedom of speech without government sponsored or

encouraged threats against privacy or speech, and a potential 13th amendment

argument regarding artificial debt which is a sin against God in the old testament

especially, called inequity and will damn the perpetrators to hell despite their

stupidity and ignorance. See, Matthew 13, Hosea 4:6. It is no small matter. It is a

matter of heaven and hell. The Bible teaches people go to hell for

misunderstanding evil for good and good for evil. Not knowing can kill you

eternally. You have to care to think, care to know, care to love to escape the fire of

the second death at the resurrection of the dead the last day. You must use you

free will, your brain, not your belly, meaning your desires. Philippians 3:19,

“Their end is destruction, their god is their belly (meaning their appetites, their

desires), and they glory in their shame, with minds set on earthly things.” I argued

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that Trump does not use his brain, but is reigned by his desires, the mark of the

beast, the whore, the damned, the mark sadly most of humanity has should they not

erase that mark before it is too late and they are dead. See Dckt 60 at 21,94,123,

124, 413. Trump is reigned by desires, emotions, instead of laying down his

desires, to care to think to love others, by sacrificing to self. I am pointing this out

to confirm believe not using your brain to think, to care, to love, is sin.

As a licensed teacher, previously substituting in the schools, I tried to teach kids

they were loved and respected no matter whether they failed or succeeded, and to

love and respect one another regardless as to whether others succeed or fail. I

taught them to think for themselves, instead of writing what they thought I wanted

to hear. I taught them their diverse unique view made us all smarter, by shedding

light on a different perspective. I tried to teach kids the way to heaven young by

Jesus’s new command in John, to love one another, without violating the

separation of church and state, without using God’s name or bible verses in vain. I

am pointing this out as I try to live my faith, live my religious beliefs by doing the

will of God, through understanding Jesus’s words. I believe Jesus is not kidding.

I also have ideas on how Attorney General Merrick Garland can safeguard the right

to vote, and eliminate the temptations for law makers to create unjust decrees and

policies by removing three temptations to do so, eliminating money in politics,

ending entity and private backing with money, by allowing the people to more

equally and freely, not by purchase of support or opposing a candidate by the only

equal, fair, free form, the vote.

Our laws fund grants for science that serve greed, the bottom line, not learning or

truth to improve societal conditions. Our tax laws, grant policies and other laws

increase temptations to make made to break, made to replace, polluting in the

production, and polluting by throwing away replaced parts and products in landfills

into infinity, to gain more money by selling replacement parts or products. More

grants are given out for some different research. Greed for money is rewarded,

driving out love for humanity leading to exploitation of the people and the

environment, and I believe damnation in hell.

Additionally, our health care harms health to make people feel better, by feeling

nothing, or by masking the ailment, often inhibiting people's faculties, their ability

to use their free will, their brain, their mind, I believe guaranteeing their damnation

in hell. I believe eternity is determined at the last day of your life. (See, Docket

77, Exhibit F, Exhibit 43, Article I drafted and factors relating to my passion to

improve healthcare, to care for the sick and elderly's health, not destroy health by

comfort care, eliminating the pain by causing patients to feel nothing, like

vegetables, often inhibiting their free will which I believe they need to use to go to

heaven, likely misleading the sick and elderly to hell, which breaks my heart, 1.

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Mark is not hard headed, hard hearted or hard handed. He

understands the rules are there to serve humanity, not exploit humanity for the cost

Coastal Point, Guest Column, Representative candidate says health is wealth, By

Meghan Kelly, Esq., Candidate Delaware House of Representatives, 38th District,

2. Document, “Your Health is your Wealth You are Priceless. Not a price tag!

Kelly seeks Federal Consideration of Health Care Proposal, 3. Meghan Kelly’s

teaching certificate, which goes to credibility. I learned psychology and behavior

theories like BF Skinner’s. I also am licensed to teach health so I know something

about health. 4. Meghan Kelly’s redacted law school transcript to show she took a

course Health Care Finance and the course Law and Medicine while attending

Duquesne School of Law. 5. Meghan Kelly’s redacted undergraduate college

transcript to show she took relevant courses related to

History of Western Medicine

Economics

Medieval Philosophy

Psychology courses

Evidence of surgery that requires I drink water, rest and eat so I do not faint

or die due to dehydration when I have my period. I lose five pounds every month.

This is still a challenge. I must assert my right to live because many people serve

Satan by not wanting to be inconvenienced to care to adapt to safeguard my life, or

the lives and health of others.)

Drugging the elderly and sick people up so they cannot use their free will to choose

to think, to care, to know, to love removes their freedom of conscience to choose

the way to eternal life.

It is healthcare, not comfort care, deceiving people to believe you are healing them

only to be killing them in this life and the next by concealing pain. At this time, I

may not have standing with these unrelated issues, but the Attorney General may

have standing down the line. It is noteable, about 33 billion has been misused for

years via NIH for bad healthcare that cares less about patients’ health and more

about entities’ wealth.

Without protecting freedom of conscience, none are free, none have liberty, all are

controlled by the forced will of heartless beasts, organizations and entities, even

government, to serve what I argue is the mark of the beast, business greed. We

must allow our judges to use their brain, their free will too, to think, to care, to

love, instead of robotically adhering as troops in a war, where they no longer lead

but are misled by heartless beasts that rule over them.

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and convenience by those who wield government power. See Matthew 23:11,

regarding Jesus’s claim leaders are servants. I believe servants of self are

misleaders and deceivers, who exploit those they are charged to serve to serve

those who serve them thereby serving themselves, reflecting the image of Satan,

aka children of the devil not choosing to be saved from the fire the last day by

laying down their desires to care to love those outside their own, specifically those

who inconvenience them, and their greed by need. See, John 8:47, 1 John 3:10-11,

Acts 13:10, Matthew 13:38, regarding children of devil.

11.

I thought I sinned against God by forgetting to look after Mark’s

daughter, an attorney within the arms of the ODC. I thought Mark’s kid may have

lost her job at the ODC, with the news of a new hiring at the ODC, because her

father helped me in the form of guidance with regard to requesting a suspension or

waiver of attorney fees from the Honorable Supreme Court by official request to

Chief Justice Seitz. See Emails.

12.

I realized the only two people on the planet aware of my request for

the waiver are Chief Justice Seitz and Mark Vavala per that revelation in the Email. See Emails

13.

In my horror and great sadness, I confronted Mark to determine

whether he “threw me under the bus.” Citing Emails. I quickly confronted him to

determine the worst possible scenario to eliminate any doubt that may tarnish a

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professional relationship based on mutual respect for the dignity of all, even one

another.

14.

I tested him. Mark did not instigate the ODC and DE-Lapp attacks.

See Emails.

15.

Besides passing the test, I trust Mark Vavala as a former judge, a

commissioner, without partiality based on self-interest. I sought Mark’s help for

years to gain his wisdom and kind guidance. He is smart and wise, and unafraid

of tough questions, because he answers honestly with integrity, even with the

honest response, I don’t know.

16.

The conclusion Mark Vavala was not the perpetrator of potential

abuse me, led me to determine that Chief Justice Seitz may have instigated the

abuse by De-Lapp and the ODC.

17.

The interest for fees for an arm may have tarnished Chief Justice’s

vision as I noted in my motion, the Supreme Court itself may have instigated the

abuse. Motion at 25.

18.

Far worse, the Chief Justice may have instigated attacks by the ODC

and De-Lapp discussed in my motion because my second request relating to

waiving attorney registration fees is based on and intertwined with religious

arguments in violation of my free exercise and the RFRA which applies to state

agents too, including judges and judges’ agents, its arms, ODC, De-Lapp, and their

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agents, foreseeably impeding and obstructing my access to the Courts in this

proceeding.

19.

I must correct my allegation at Motion at 25. I was blinded by my

desire to persuade this court to save the world by saving me in my case, and

possibly other matters, even if the court does not want to. Jesus says if we believe

we can move mountains, we will move them. Citing Jesus, Mark 11:23. I believe I

have an opportunity, not a guarantee, that I may move a mountain by moving this

Court’s justices’ hearts to be our heroes. Mountains after all means impediments

on our hearts, temptations to sin by comfort, costs and convenience instead of

doing what is right. Id., (See, Luke 8:10. Jesus speaks in parables so only those

who seek his will instead of their own or the mere will of man understand what

Jesus says by mountains and in general. Others do not choose to use their brains,

their free will, to understand God’s will, God’s plan which is love. They, instead,

willfully are blinded by worldly temptations and do not use their brains to think, to

care to know, to care to love in truth, not lust, not covetousness based on lies.)

20.

I forgot, this court did answer my first request for a suspension of fees

relating to attorney registration based on unemployment or financial impediment. I

am including the response attached to and incorporated therewith as an exhibit.

See, the Court’s response attached hereto.

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In a letter dated February 2, 2021 the Court responded, “The Court

acknowledges receipt of (my) letter dated January 7, 2021, wherein (I) request that

the attorney registration fees for lawyers out of work due to the pandemic be

waived.

22.

I responded per the attached February 5, 2021 letter, attached hereto

and incorporated herewith in toto, as an Exhibit. I provide in part:

“Thank you for the February 2, 2021 letter in which the Court indicated it

would consider requests for waivers of attorney fees on a case by case basis,

by formal request.

My concern, is accepting applications for waivers on a case by case basis

violates the Equal Protections Clause applicable to the State's agencies, even

the courts via the 14th Amendment, by disparate treatment within a class. I

am likely not the only one out of work due to the pandemic. Others are

struggling too. A case by case determination would likely be per se

unconstitutional.

I will likely never have standing to stand up for those similarly situated with

myself. Yet, if I made such a request, I would be asking the Court to treat

me with preference instead of impartiality as required by law.

My conscience may not allow me to make such a request, tempting this

Honorable Court to misbehave to serve my own gain.

I can, however, request that all fees for attorney registrations be the same

regardless of years barred. So, I am making such a request for future

consideration for 2022 and beyond. Please treat all lawyers the same by

requiring the same lawyer registration fee for every lawyer, without

persecution towards attorneys with more years of experience by an increased

fee. There is no rational basis for an increase in lawyer’s fees based on

number of years, except the desire for more money.

It is wrong to assume the longer you have been barred, the more money you

have or must pay.

I am saddened when I see unjust decrees and policies based on the love of

money, desire for money, at the cost of driving out the love for humanity,

the people the state serves.

On an aside, the reason why I became a lawyer is my faith in Jesus Christ.

Justice in the Courts is a command by God. See Amos 5:15. Jesus Christ

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taught that “justice, mercy, and faithfulness” are more important commands.

Matthew 23:23.

23.

In my second request relating to attorney fees, dated February 5, 2021,

I go on to discuss more religious concerns therein.

24.

I note, Mark Vavala in the Email exhibits noted 5 other attorneys

reached out to him regarding attorney fee cost issues.

25.

Imagine how many other lawyers may be struggling due to the

pandemic, possibly catching the sickness or caring for a loved one or merely life’s

struggles unforeseeably hampering lawyer’s capability to pay the Registration fee.

26.

Such case by case application creates disparate treatment by the

hidden reign of lusts or likes as it suits the judges interests, not the impartial rule of

law, without selective application.

27.

The Court should create a form that permits lawyers without the

ability to pay to waive such fees, to automatically apply for waiver based on debt

or financial burden, and such waivers should be freely given, instead of enslaving

already financially desperate people with additional pressure.

28.

No one is above the law. No one is below the law, not even judges

who administer the laws. Judges must maintain their independence from self

interest, and their appearance of independence.

27.

“The Founders rejected the medieval myth that sovereign (rulers, even

judges and Presidents) are anointed by God to rule over them. The Founders laid a

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new foundation for our country, based not on the lie of divine right, (but by free

choice, the free will of the people based on the universal belief that) all people are

created equal and all just powers are derived from the consent of the governed.

They changed the very source and nature of Law. Law does not emerge from the

mouth of a king but rather the votes of the freely chosen representations of the

people,” with limited, not absolute power, limited by the Constitution by the

Courts. Citing, Duquesne Lawyer, The Rule of Law, the Constitution and

Democracy, by Wilson Huhn, Professor of Law, Spring 2021 Edition.

28.

Partiality and the appearance of impartiality must be maintained in my

case to protect the integrity of the courts.

29.

I seek to protect the judiciary.

30.

To maintain the integrity of the three branches of government.

31.

In this United States, the Founders created checks and balances to

prevent and fix branch overreach. The fact a check is made, means the system is

focused on maintaining a more equal, fair, just union. Humans with hearts are in

control and in charge of choosing to maintain, and service the checks on the

executive, judicial and legislative branches, like a car in need of oil to run better.

People must choose to use their brain to care to think, to care to know, to care to

love humanity, instead of comfort, convenience and cost by avoiding tune ups in

our system of government.

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32.

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The fact I seek correction will not prevent me from seeking protection

of the same system I am seeking to tune up through law suits, to prevent the engine

of our nation from failing us, the impartial rule of law.

33.

The Courts can uphold the integrity, encourage faith in the system by

having the humility to understand it is run by imperfect people in need of guidance

through checks and balances, the executive branch, the legislative branch and even

the judiciary.

34.

In addition, my little cousin, Ikey Adams, a family member, is a

partner in Sidley Austin, in DC, where Chief Justice Seitz’s daughter appears to

work too.

34.

These two issues, as to who instigating the government threats via the

ODC and De-Lapp, and the familial relations, create the appearance of partiality,

or bias that may blemish a rather historical case, should this Court allow me to go

forward with arguments.

35.

The President(s) need the court’s heavy hand of loving guidance to

reign in the Presidents’ abuse and misuse of power and government funding by

dissolving the establishment of government-religion. President Bush Junior,

President Obama, President Trump, and President Biden all misbehaved, and

misbehavior will continue well past their fleeting lives, should this court fail to

declare the Presidents are not above the Constitution. Sovereign immunity seems

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to be waived for RFRA claims per the Supreme Court against officials, including

the President. Tanzin v. Tanvir, 141 S. Ct. 486, 208 L. Ed. 2d 295 (2020)

36.

I respectfully request that the Honorable Chief Justice be recused from

deciding this case.

May 28, 2021

Respectfully Submitted,

/s/ Meghan Kelly

Meghan Kelly

34012 Shawnee Drive

Dagsboro, DE 19939

pro se, as a party, not an

attorney advocate

meghankellyesq@yahoo.com

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Kelly v. Trump

No. 119, 2021

SUPREME COURT OF DELAWARE

May 28, 2021

Reporter

2021 DE S. CT. BRIEFS LEXIS 423 *

Meghan Kelly, Plaintiff Below, Appellant, v. Donald Trump, a.k.a. Donald J. Trump, a.k.a. President Trump a.k.a.

President Donald Trump, in his official capacity as President of the United States Defendant Below, Appellant,

Type: Motion--Other

Counsel

Meghan Kelly, Dagsboro, DE, Pro se.

Title

Appellant's Motion for Recusal of Chief Justice Seitz

Text

[*1] 1. I, Meghan Kelly, pro se appellant, unopposed, having been granted in forma pauperis relief, move this

honorable Delaware Supreme Court, unopposed, move to recuse the Honorable Chief Justice Collins J. Seitz,

Junior ("Chief Justice Seitz") from participating in review of my case, requiring delegation to the other honorable

Justices.

2. On about May 25, 2021, I sent the honorable Court Appellant's (unopposed) Motion to guide or reign in the

arms of the Delaware Supreme Court, or for other relief this Court deems just, (the "motion"), incorporated herein

as if included in the first instance. I suggested private guidance. Motion at 1, 37, 38.

3. One of the allegations in the motion was concerning De-Lapp's response to a request for a suspension of bar

fees to serve De-Lapp's purpose not to help to pay any fee since I paid such fees. Motion at 24 -30. Attached

please find my receipt of payment of the Bar registration fee, incorporated as an exhibit, as if expressly stated

herein.

4. I attached the May 24, 2021 attack letter as an exhibit to the motion, and incorporate it herein as if included as

part of the motion.

5. In the May 24, 2021 attack letter, Carol Waldauser [*2] and Eleanor Kiesel state, "We understand that you may

be experiencing some financial difficulties with regard to license fees."

6. The only person who knew I made a request for suspension of Attorney Registration of license fees is Chief

Justice Seitz, since I made the request to him, and Mark Vavala.

7. I reached out to Mark Vavala ("Mark") per the emails, attached herein and included and incorporated herewith

as if alleged as part of this motion ("Emails"), admitted under the state of mind exceptions, belief and admissions.

See Exhibit, the Emails.

8. I turned to Mark for guidance, as he has always treated me as a judge should, with respect regardless of

poverty, religious belief or association, as to requesting relief for attorney registration fees.

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9. In the past I turned to Mark when he was a commissioner when Cathy Marshall, the former Supreme Court

Clerk treated me with great cruelty and disregard for humanity for cost and convenience, reflecting the image of

Satan with regard to unbending rules and penalties regarding the rather unsafe requirement of registration online

and by required use of emails during a heightened time of increased threats to electronic hacks. [*3] 1

1 I am trying to persuade US Attorney General Garland to close the back doors on electronic devices President Bush Junior

opened up under the guise of safety from terrorism. Bush opened the door to economic, speech and privacy attacks, making the

entire globe less safe, especially with regards to health data, health insurance hacks and systems in recent years. Our

information is more easily manipulated making us believe we are safe when the pandemic may not be waning as much as

suspected. Please note, worldometer has not been reporting all states in its data but has excluded about ten states every day for

the past two weeks. I suspect it is being manipulated, hacked, to market the vaccine as working better than it is. I have checked

worldometer every day for over a year. They included most states every other day. This is strikingly concerning to me. See, Dckt

71, Exhibit E, Exhibit 26, copy of the web site worldometer, to show healthcare is the biggest global money maker and expense.

Bush sold our freedoms for money by opening the door to those who will kill, steal and destroy or diminish freedoms and lives

to gain more material gain. Freedom is not for sale. People are not for sale, [*4] to those who require they pay for freedom.

People are priceless not price tags, worthy of protection by this Court. Throwing money at a problem or grants is never the

solution. Neither is money given to government agencies without strings attached. The spend it as you see fit or lose it

provisions reward waste. Strings attached to laws must be tied with all government money offering guidance for good not evil

greed, the mark of the damned. The desire for more government money for government partnered entities under the guise of

charity or otherwise, including churches, is the problem. Business greed, to use for the study of things, science to manipulate to

gain grants or business profit for something different or for a different fix instead of removing the problem should end. Entities

are rewarded with more money by not resolving the problem. Government must fund itself, not pay bribes to entities which per

se try to get as much as they can for as little as they can. Then, such entities may supplement with fundraising and charity which

I believe damns people to hell. Schools, sports and the post offices would be fully funded if the government paid bills instead of

bribes. Children [*5] learn to go the way to hell by learning early to rely on associations and organizations, artificial entities

without hearts, that run on the mark of the beast to represent their interests, instead of choosing to use their own brains to think,

to care, to know, to love, individually and specially, as the treasure they are. We lose treasures to hell. Children are forced to

fundraise for sports and schools which will damn them to hell should they not unharden their heads and learn such evil is bad, all

to pay bribes of government agents to serve their interest. Property taxes should not be increased to fund government bribes,

thereby creating disparate treatment by zip code, based on home values in violation of the Equal Protections Clause applicable

to the states via the Fourteenth Amendment, with no rationally related purpose. The government would decrease waste, create a

more fair, equal and just union if government employees, including Presidents and law makers, did their jobs instead of

exploiting tasks to serve government agents personal interest including but not limited to getting out of work or liability, while

arguably creating artificial debt in violation of the 13th amendment [*6] to serve greed not need, by paying entities to profit off of

its government duties at a greater bill to its people in terms of not merely monetary loss but loss of constitutional freedoms. It is

an abomination. The government itself is a heartless beast should the agents not use their power to individually use their free

will, their brains, to think, to care, to know, to love people, instead of acting as heartless robots going through mechanical

motions of a system. Then brainlessly blaming the system, instead of themselves, for problems they cared naught to address.

I digress, government funding for science is bad and a black hole, that should be closed from sucking the life blood and souls

out of humanity by indentured servitude to feed unsatiable greed by entities without hearts. Just laws, just policies and justice in

the courts is the solution to close the black hole. The government rewards businesses for made to break, made to repair and

replace products, polluting in the production and polluting with replaced parts and products in the landfills. The US through its

unjust decrees, including but not limited to the UCC, tax code wrote offs and insurance laws is the reason why [*7] the world is

so polluted. China would not make made to break, service and replace products if our courts and laws did not reward such,

instead of made to last goods, decreasing polluting in production and in parts. Money is never the solution, since it rewards

misbehavior, to create the endless lust for greed to make something different, or use of a product for a different function, not

made to last, not made to work. Science is the study of things. When the pupils, doctors and scientists declare themselves to be

the masters of the universe on a subject, the experts, or knowing the answers, they are per se stupid, and defeat science.

Science, after all, is the mere study of things, not the master of things as defined by the scientific method with built in recognized

uncertainties called variables, unknown and known. Meaning possible error, not knowing everything, is declared as part of the

scientific method. Learning is good, but manipulating data while using good science, retrieved from tests for self-gain, not

knowledge, is deceptive and wicked. Our government appears to be partnered with private industries, not for profits, businesses,

and churches, by bought or bartered for bribes, [*8] in exchange for loyalty or backing of elections, paid with money taken from

being used for the people's need, government infrastructure, not Biden's bad plan either, to be used to pay entities to perform

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the government's job because the government employees evade responsibility of working and blame for expenditures and plans

not working, grants and bailouts to exploit the problem to waste money and cause harm to the world for self-gain, by creating

industries to profit off of the problems instead of correcting the problem by making the world more safe by closing the back doors

in electronics, including but not limited to making lawyers money by adding an unnecessary additional field, insurance

companies, fields for miners who sell our data, anti-virus software companies. I am still brainstorming constitutional and criminal

theories to persuade the US AG Garland to save us regarding foreseeable looming threats not by people but by entities without

hearts, businesses, LLCs and such, by protecting our freedom of speech without government sponsored or encouraged threats

against privacy or speech, and a potential 13th amendment argument regarding artificial debt which is a sin against God [*9] in

the old testament especially, called inequity and will damn the perpetrators to hell despite their stupidity and ignorance. See,

Matthew 13, Hosea 4:6. It is no small matter. It is a matter of heaven and hell. The Bible teaches people go to hell for

misunderstanding evil for good and good for evil. Not knowing can kill you eternally. You have to care to think, care to know,

care to love to escape the fire of the second death at the resurrection of the dead the last day. You must use you free will, your

brain, not your belly, meaning your desires. Philippians 3:19, "Their end is destruction, their god is their belly (meaning their

appetites, their desires), and they glory in their shame, with minds set on earthly things." I argued that Trump does not use his

brain, but is reigned by his desires, the mark of the beast, the whore, the damned, the mark sadly most of humanity has should

they not erase that mark before it is too late and they are dead. See Dckt 60 at 21,94,123, 124, 413. Trump is reigned by

desires, emotions, instead of laying down his desires, to care to think to love others, by sacrificing to self. I am pointing this out

to confirm believe not using your brain to [*10] think, to care, to love, is sin. As a licensed teacher, previously substituting in the

schools, I tried to teach kids they were loved and respected no matter whether they failed or succeeded, and to love and respect

one another regardless as to whether others succeed or fail. I taught them to think for themselves, instead of writing what they

thought I wanted to hear. I taught them their diverse unique view made us all smarter, by shedding light on a different

perspective. I tried to teach kids the way to heaven young by Jesus's new command in John, to love one another, without

violating the separation of church and state, without using God's name or bible verses in vain. I am pointing this out as I try to

live my faith, live my religious beliefs by doing the will of God, through understanding Jesus's words. I believe Jesus is not

kidding. I also have ideas on how Attorney General Merrick Garland can safeguard the right to vote, and eliminate the

temptations for law makers to create unjust decrees and policies by removing three temptations to do so, eliminating money in

politics, ending entity and private backing with money, by allowing the people to more equally and freely, not by [*11] purchase

of support or opposing a candidate by the only equal, fair, free form, the vote.

Our laws fund grants for science that serve greed, the bottom line, not learning or truth to improve societal conditions. Our tax

laws, grant policies and other laws increase temptations to make made to break, made to replace, polluting in the production,

and polluting by throwing away replaced parts and products in landfills into infinity, to gain more money by selling replacement

parts or products. More grants are given out for some different research. Greed for money is rewarded, driving out love for

humanity leading to exploitation of the people and the environment, and I believe damnation in hell.

Additionally, our health care harms health to make people feel better, by feeling nothing, or by masking the ailment, often

inhibiting people's faculties, their ability to use their free will, their brain, their mind, I believe guaranteeing their damnation in hell.

I believe eternity is determined at the last day of your life. (See, Docket 77, Exhibit F, Exhibit 43, Article I drafted and factors

relating to my passion to improve healthcare, to care for the sick and elderly's health, not destroy [*12] health by comfort care,

eliminating the pain by causing patients to feel nothing, like vegetables, often inhibiting their free will which I believe they need to

use to go to heaven, likely misleading the sick and elderly to hell, which breaks my heart, 1. Coastal Point, Guest Column,

Representative candidate says health is wealth, By Meghan Kelly, Esq., Candidate Delaware House of Representatives, 38th

District, 2. Document, " Your Health is your Wealth You are Priceless. Not a price tag! Kelly seeks Federal Consideration of

Health Care Proposal, 3. Meghan Kelly's teaching certificate, which goes to credibility. I learned psychology and behavior

theories like BF Skinner's. I also am licensed to teach health so I know something about health. 4. Meghan Kelly's redacted law

school transcript to show she took a course Health Care Finance and the course Law and Medicine while attending Duquesne

School of Law. 5. Meghan Kelly's redacted undergraduate college transcript to show she took relevant courses related to

a. History of Western Medicine

b. Economics

c. Medieval Philosophy

d. Psychology courses

6. Evidence of surgery that requires I drink water, rest and eat so I [*13] do not faint or die due to dehydration when I have my

period. I lose five pounds every month. This is still a challenge. I must assert my right to live because many people serve Satan

by not wanting to be inconvenienced to care to adapt to safeguard my life, or the lives and health of others.)

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10. Mark is not hard headed, hard hearted or hard handed. He understands the rules are there to serve humanity,

not exploit humanity for the cost and convenience by those who wield government power. See Matthew 23:11,

regarding Jesus's claim leaders are servants. I believe servants of self are misleaders and deceivers, who exploit

those they are charged to serve to serve those who serve them thereby serving themselves, reflecting the image of

Satan, aka children of the devil not choosing to be saved from the fire the last day by laying down their desires to

care to love those outside their own, specifically those who inconvenience them, and their greed by need. See,

John 8:47, 1 John 3:10-11, Acts 13:10, Matthew 13:38, regarding children of devil.

11. I thought I sinned against God by forgetting to look after Mark's daughter, an attorney within the arms of the

ODC. I thought Mark's kid may have lost her job at the ODC, with the news of a new hiring at the ODC,

because [*15] her father helped me in the form of guidance with regard to requesting a suspension or waiver of

attorney fees from the Honorable Supreme Court by official request to Chief Justice Seitz. See Emails.

12. I realized the only two people on the planet aware of my request for the waiver are Chief Justice Seitz and

Mark Vavala per that revelation in the Email. See Emails

13. In my horror and great sadness, I confronted Mark to determine whether he "threw me under the bus." Citing

Emails. I quickly confronted him to determine the worst possible scenario to eliminate any doubt that may tarnish a

professional relationship based on mutual respect for the dignity of all, even one another.

14. I tested him. Mark did not instigate the ODC and DE-Lapp attacks. See Emails.

15. Besides passing the test, I trust Mark Vavala as a former judge, a commissioner, without partiality based on

self-interest. I sought Mark's help for years to gain his wisdom and kind guidance. He is smart and wise, and

unafraid of tough questions, because he answers honestly with integrity, even with the honest response, I don't

know.

16. The conclusion Mark Vavala was not the perpetrator of potential abuse [*16] me, led me to determine that

Chief Justice Seitz may have instigated the abuse by De-Lapp and the ODC.

17. The interest for fees for an arm may have tarnished Chief Justice's vision as I noted in my motion, the

Supreme Court itself may have instigated the abuse. Motion at 25.

18. Far worse, the Chief Justice may have instigated attacks by the ODC and De-Lapp discussed in my motion

because my second request relating to waiving attorney registration fees is based on and intertwined with religious

arguments in violation of my free exercise and the RFRA which applies to state agents too, including judges and

judges' agents, its arms, ODC, De-Lapp, and their agents, foreseeably impeding and obstructing my access to the

Courts in this proceeding.

19. I must correct my allegation at Motion at 25. I was blinded by my desire to persuade this court to save the

world by saving me in my case, and possibly other matters, even if the court does not want to. Jesus says if we

believe we can move mountains, we will move them. Citing Jesus, Mark 11:23. I believe I have an opportunity, not a

guarantee, that I may move a mountain by moving this Court's justices' hearts to be our heroes. Mountains [*17]

Drugging the elderly and sick people up so they cannot use their free will to choose to think, to care, to know, to love removes

their freedom of conscience to choose the way to eternal life.

It is healthcare, not comfort care, deceiving people to believe you are healing them only to be killing them in this life and the

next by concealing pain. At this time, I may not have standing with these unrelated issues, but the Attorney General may have

standing down the line. It is noteable, about 33 billion has been misused for years via NIH for bad healthcare that cares less

about patients' health and more about entities' wealth.

Without protecting freedom of conscience, none are free, none have liberty, all are controlled by the forced will of heartless

beasts, organizations and entities, even government, to serve what I argue is the mark of the beast, business greed. We must

allow our judges [*14] to use their brain, their free will too, to think, to care, to love, instead of robotically adhering as troops in a

war, where they no longer lead but are misled by heartless beasts that rule over them.

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after all means impediments on our hearts, temptations to sin by comfort, costs and convenience instead of doing

what is right. Id., (See, Luke 8:10. Jesus speaks in parables so only those who seek his will instead of their own or

the mere will of man understand what Jesus says by mountains and in general. Others do not choose to use their

brains, their free will, to understand God's will, God's plan which is love. They, instead, willfully are blinded by

worldly temptations and do not use their brains to think, to care to know, to care to love in truth, not lust, not

covetousness based on lies.)

20. I forgot, this court did answer my first request for a suspension of fees relating to attorney registration based

on unemployment or financial impediment. I am including the response attached to and incorporated therewith as

an exhibit. See, the Court's response attached hereto.

21. In a letter dated February 2, 2021 the Court responded, "The Court acknowledges receipt of (my) letter dated

January 7, 2021, wherein (I) request that the attorney registration fees for lawyers out of work due to the pandemic

be waived.

22. I responded per the attached February 5, 2021 letter, attached [*18] hereto and incorporated herewith in toto,

as an Exhibit. I provide in part:

"Thank you for the February 2, 2021 letter in which the Court indicated it would consider requests for waivers

of attorney fees on a case by case basis, by formal request.

My concern, is accepting applications for waivers on a case by case basis violates the Equal Protections

Clause applicable to the State's agencies, even the courts via the 14th Amendment, by disparate treatment

within a class. I am likely not the only one out of work due to the pandemic. Others are struggling too. A case

by case determination would likely be per se unconstitutional.

I will likely never have standing to stand up for those similarly situated with myself. Yet, if I made such a

request, I would be asking the Court to treat me with preference instead of impartiality as required by law. My

conscience may not allow me to make such a request, tempting this Honorable Court to misbehave to serve

my own gain.

I can, however, request that all fees for attorney registrations be the same regardless of years barred. So, I

am making such a request for future consideration for 2022 and beyond. Please treat all lawyers the

same [*19] by requiring the same lawyer registration fee for every lawyer, without persecution towards

attorneys with more years of experience by an increased fee. There is no rational basis for an increase in

lawyer's fees based on number of years, except the desire for more money.

It is wrong to assume the longer you have been barred, the more money you have or must pay.

I am saddened when I see unjust decrees and policies based on the love of money, desire for money, at the

cost of driving out the love for humanity, the people the state serves.

On an aside, the reason why I became a lawyer is my faith in Jesus Christ. Justice in the Courts is a

command by God. See Amos 5:15. Jesus Christ taught that "justice, mercy, and faithfulness" are more

important commands. Matthew 23:23.

23. In my second request relating to attorney fees, dated February 5, 2021, I go on to discuss more religious

concerns therein.

24. I note, Mark Vavala in the Email exhibits noted 5 other attorneys reached out to him regarding attorney fee

cost issues.

25. Imagine how many other lawyers may be struggling due to the pandemic, possibly catching the sickness or

caring for a loved one or merely life's [*20] struggles unforeseeably hampering lawyer's capability to pay the

Registration fee.

26. Such case by case application creates disparate treatment by the hidden reign of lusts or likes as it suits the

judges interests, not the impartial rule of law, without selective application.

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27. The Court should create a form that permits lawyers without the ability to pay to waive such fees, to

automatically apply for waiver based on debt or financial burden, and such waivers should be freely given, instead

of enslaving already financially desperate people with additional pressure.

28. No one is above the law. No one is below the law, not even judges who administer the laws. Judges must

maintain their independence from self interest, and their appearance of independence.

27. "The Founders rejected the medieval myth that sovereign (rulers, even judges and Presidents) are anointed by

God to rule over them. The Founders laid a new foundation for our country, based not on the lie of divine right, (but

by free choice, the free will of the people based on the universal belief that) all people are created equal and all just

powers are derived from the consent of the governed. They changed [*21] the very source and nature of Law. Law

does not emerge from the mouth of a king but rather the votes of the freely chosen representations of the people,"

with limited, not absolute power, limited by the Constitution by the Courts. Citing, Duquesne Lawyer, The Rule of

Law, the Constitution and Democracy, by Wilson Huhn, Professor of Law, Spring 2021 Edition.

28. Partiality and the appearance of impartiality must be maintained in my case to protect the integrity of the

courts.

29. I seek to protect the judiciary.

30. To maintain the integrity of the three branches of government.

31. In this United States, the Founders created checks and balances to prevent and fix branch overreach. The fact

a check is made, means the system is focused on maintaining a more equal, fair, just union. Humans with hearts

are in control and in charge of choosing to maintain, and service the checks on the executive, judicial and legislative

branches, like a car in need of oil to run better. People must choose to use their brain to care to think, to care to

know, to care to love humanity, instead of comfort, convenience and cost by avoiding tune ups in our system of

government.

32. The fact [*22] I seek correction will not prevent me from seeking protection of the same system I am seeking

to tune up through law suits, to prevent the engine of our nation from failing us, the impartial rule of law.

33. The Courts can uphold the integrity, encourage faith in the system by having the humility to understand it is run

by imperfect people in need of guidance through checks and balances, the executive branch, the legislative branch

and even the judiciary.

34. In addition, my little cousin, Ikey Adams, a family member, is a partner in Sidley Austin, in DC, where Chief

Justice Seitz's daughter appears to work too.

34. These two issues, as to who instigating the government threats via the ODC and De-Lapp, and the familial

relations, create the appearance of partiality, or bias that may blemish a rather historical case, should this Court

allow me to go forward with arguments.

35. The President(s) need the court's heavy hand of loving guidance to reign in the Presidents' abuse and misuse

of power and government funding by dissolving the establishment of government-religion. President Bush Junior,

President Obama, President Trump, and President Biden all misbehaved, and misbehavior [*23] will continue well

past their fleeting lives, should this court fail to declare the Presidents are not above the Constitution. Sovereign

immunity seems to be waived for RFRA claims per the Supreme Court against officials, including the President.

Tanzin v. Tanvir, 141 S. Ct. 486, 208 L. Ed. 2d 295 (2020)

36. I respectfully request that the Honorable Chief Justice be recused from deciding this case.

May 28, 2021

Respectfully Submitted,

Case 1:21-cv-01490-CFC

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/s/ Meghan Kelly

Meghan Kelly

34012 Shawnee Drive

Dagsboro, DE 19939

pro se, as a party, not an

attorney advocate

meghankellyesq@yahoo.com

End of Document

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50860

EFiled: Jun 02 2021 11:29AM EDT

Filing ID 66649842

Case Number 119,2021

IN THE SUPREME COURT OF THE STATE OF DELAWARE

Meghan Kelly,

)

Plaintiff Below,

)

Appellant,

)

Donald Trump, a.k.a. Donald J.

)

Trump, a.k.a. President Trump

)

a.k.a. President Donald Trump,

)

in his official capacity as President of )

the United States

)

Defendant Below,

)

Appellant,

)

No. 119, 2021

APPELLANT’S MOTION FOR THE DELAWARE SUPREME COURT TO

REQUIRE THE RECUSAL OF THE HONORABLE CHIEF JUSTICE COLLINS

J. SEITZ, JUNIOR IN THIS MATTER

I, Meghan Kelly, pro se appellant, unopposed, having been granted in

forma pauperis relief, move this honorable Delaware Supreme Court, unopposed,

move to recuse the Honorable Chief Justice Collins J. Seitz, Junior (“Chief Justice

Seitz”) from participating in review of my case, requiring delegation to the other

honorable Justices.

On about May 25, 2021, I sent the honorable Court Appellant’s

(unopposed) Motion to guide or reign in the arms of the Delaware Supreme Court,

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or for other relief this Court deems just, (the “motion”), incorporated herein as if

included in the first instance. I suggested private guidance. Motion at 1, 37, 38.

One of the allegations in the motion was concerning De-Lapp’s

response to a request for a suspension of bar fees to serve De-Lapp’s purpose not

to help to pay any fee since I paid such fees. Motion at 24 -30. Attached please

find my receipt of payment of the Bar registration fee, incorporated as an exhibit,

as if expressly stated herein.

I attached the May 24, 2021 attack letter as an exhibit to the motion,

and incorporate it herein as if included as part of the motion.

In the May 24, 2021 attack letter, Carol Waldauser and Eleanor Kiesel

state, “We understand that you may be experiencing some financial difficulties

with regard to license fees.”

The only person who knew I made a request for suspension of

Attorney Registration of license fees is Chief Justice Seitz, since I made the

request to him, and Mark Vavala.

I reached out to Mark Vavala (“Mark”) per the emails, attached herein

and included and incorporated herewith as if alleged as part of this motion

(“Emails”), admitted under the state of mind exceptions, belief and admissions.

See Exhibit, the Emails.

Case 1:21-cv-01490-CFC

Document 448-10 Filed 08/07/24

50862

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